The structure of the Radio Frequency Migration Plan will have to be reworked completely, Telkom, South Africa’s telecommunications group, has recommended.
The plan provides for, among others, the background and basis of the Radio Frequency Migration Plan, identification of the radio frequency bands where migration may be required and make proposals regarding such frequency migration as may be required; and identify the radio frequency bands which are subject to a feasibility study.
The company said in its written submission to ICASA that the plan Radio Frequency Migration Regulations contained in Part 1 of the draft plan be moved to the Radio Frequency Spectrum Regulations, which contains all spectrum related regulations.
The Radio Frequency Migration Plan can then be published separately.
In addition to moving the Frequency Migration Regulations, Telkom also recommends that the structure of the Radio Frequency Migration Plan be reworked completely.
Telkom said ICASA should create two sections; first section should deal with all the background and general information pertaining to migration whereas the second section should contain the proposed migration plan.
In addition, topics and frequency bands must preferably be grouped to ensure a logical flow of information and ensuring that all information pertaining to a frequency band or topic is contained in one section/sub-section.
“Telkom requests the Authority to rework the Frequency Migration Plan, 2018 and then publish a second version for public consultation, considering the substantial changes we believe is necessary before the Radio Frequency Migration Plan can be finalised,” Siyabonga Mahlangu, group executive: Regulatory Affairs and Government Relations at Telkom, said in a written submission.
ICASA published the draft Radio Frequency Migration Plan, 2018 on 24 August 2018 in Government Gazette and invited written representations from interested parties on their views by no later than 16h00 on Friday, 12 October 2018.
The Authority will conduct public hearings from 25 to 26 October 2018.
Mahlangu added that Telkom is of the view that ICASA is mixing the concepts of migration and refarming.
In its written submission, the company recommended that the ICASA remove the concept of re-farming from the Radio Frequency Migration Plan or, as a minimum, amend the proposed definition to capture the reality that licensees are already re-farming existing spectrum assignments (example replacing 2G with 3G and 4G).
“Telkom recommends that the Authority performs a revision of the existing IMT450 Radio Frequency Spectrum Assignment Plan based on the outcome of the WP5D revision of ITU-R Recommendation M.1036,” said Mahlangu.
“Further, the Authority must conduct a feasibility study as proposed in the 2013 Radio Frequency Migration Regulations and Plan before concluding on the migration of current users from this band.”
The telecoms firm also said it was concerned that the proposals pertaining to the 850 MHz frequency band” is unclear and will lead to confusion”. It recommended a total re-work of the proposed migration plan for the band 862 – 890 MHz.