INTEL s GENERAL POSITION AND COMMENTS

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1 INTEL s GENERAL POSITION AND COMMENTS Intel fully supports the NTRA studies related with WiMAX and Intel believes there is a big opportunity for offering true personal broadband wireless technology in a similar manner to the most developed countries. It will accelerate the transformation process of society to information society. Therefore, Intel believes the WiMAX licencing should be complemented as soon as possible. Intel recommends Administrations consider providing access to spectrum in the 2.5 GHz (mobile broadband), and GHz (fixed/nomadic). It is Intel s preference that access to the 2.5 GHz be prioritized for fixed/nomadic and mobile under a technology neutrality and service neutrality regulatory framework. Intel also supports access to the 5.8 GHz band for some applications but it is not of a high priority for Intel due to poorer in-building penetration and less favourable propagation characteristics when compared to the 2.5 GHz (mobile) and 3.5 / 3.7 GHz bands (fixed/nomadic). Intel firmly believes that 2.5 GHz and 3.5 /3.7 GHz bands identified by the WiMAX Forum under their initial profiles should be considered by Administrations as bands suitable for Wireless Access. We also would like Administrations to consider bands for Wireless Access rather than label the bands fixed as this has a particular meaning as defined in ITU-R Recommendation F as shown below Fixed wireless access (FWA) Wireless access application in which the location of the end-user termination and the network access point to be connected to the end-user are fixed Mobile wireless access (MWA) Wireless access application in which the location of the end-user termination is mobile Nomadic wireless access (NWA) Wireless access application in which the location of the end-user termination may be in different places but it must be stationary while in use. The diagram below represents the WiMAX Forum s perspective on suitable bands for personal broadband. Initial certification has completed for the GHz band with the other bands immediately following.

2 WiMAX and Spectrum WiMAX (2.3 / 2.5 GHz, 3.5 / 3.7 GHz, 5.8 GHz) Future profiles include below 1 GHz Current WiMAX Forum Profiles Copyright 2004 WiMAX Forum WiMAX Forum and "WiMAX Forum CERTIFIED are registered trademarks of the WiMAX Forum. * All trademarks are the properties of their respective owners GHz band: Intel is pursuing access to the GHz band where we are supporting opening this band for more than just IMT-2000 and have provided significant input to the European Commission s objective to open the band for IMT-2000 and technically compatible technologies. Globally Intel is encouraging Administrations to consider providing access to this band under a technology neutral regulatory framework to allow innovative services the opportunity to access this band. From a Mobile WiMAX perspective in order to deliver a truly impressive personal broadband experience, Intel believes that Nationally Operators should be provided as a minimum with 30 MHz (either 30 MHz TDD, or 2 X 15 MHz). Ideally, if more spectrum is available then this would provide a greater opportunity to successfully deploy at a National level. Intel is of the opinion that providing small amount of spectrum per operator in a given area would present serious challenges to development of a viable business case and would disadvantage the wireless access Operators compared to other wireless operators in other bands; especially disadvantaging new entrants. The amount of spectrum per operator should be large enough to enable them to deploy a true broadband system that can compete with other wired broadband services. The amount of spectrum should be such that would allow an operator to choose wide channels, e.g. 10 MHz, and be able to choose a low risk frequency reuse plan, e.g. 3:1. Therefore as mentioned previously, a minimum allocation of 30 MHz per operator would allow a positive business case to be developed. As an example, arguably one of the reasons for the failure of UMTS TDD operations in Europe to materialise is because the allocations per operator in most countries are very small (typically 5 MHz).

3 Intel recommends Administrations consider providing a minimum of 30 MHz of spectrum per Operator. WHAT SHOULD BE THE BANDWIDTH FOR EACH OPERATOR? GHz band: Intel believes that access to the GHz band is highly desirable for the provision of wireless services. We encourage Administrations to consider releasing additional spectrum in this band to enable greater deployment of broadband wireless services and to promote competition. We initially support access to the band for fixed and nomadic type services (as defined in ITU-R Recommendation F.1399) and once additional sharing studies have been undertaken we would support access to this band for mobile broadband wireless services. Intel is also encouraging Administrations to consider allowing greater access to this band for TDD-based technologies and not to consider this band as only a FDD band. Bandwidth should be at least 56 MHz of contiguous spectrum for TDD or 2x28 MHz for FDD each operator. WiMAX STANDARDS AND PRODUCTS WiMAX is a reality. Standards and certified products are ready for application. NATIONAL OR REGIONAL LICENCES Intel supports National licenses where ever possible but if there justifiable reasons where regional licenses are more appropriate we would support this approach but we would encourage Operators to self-co-ordinate to maximize spectrum efficiency. LICENCE FEE Intel believes that the greatest economic benefit from broadband wireless / personal broadband is from the continues and long-term usage of the spectrum and not from the assignment process alone. We encourage Administrations to partner potential Operators to ensure mutual benefit from a successful commercial deployment. LICENCE DURATION Intel believes that a license between years would be appropriate but with an appropriate review period to ensure that the spectrum is being utilized for the intended purpose. Intel is opposed to spectrum hoarding. WiMAX: WORLWIDE STANDARDIZATION INTEROPERABILITY BENEFITS Developed and supported by the WiMAX forum (more than 350 members), WiMAX is worldwide technology based standard for broadband and will guaranty interoperability (i.e.multivendor CPEs), reliability and evolving technology, but also, thanks to high

4 volumes and integration, will ensure equipments with very low cost. With CPEs under 100 $ as one of the first objective, business model can easily be profitable even in developing countries. Before WiMAX there was not any globally accepted Wireless Broadband standard, this is the one of the most important disadvantage of previous Wireless Broadband systems. CRITERIAS FOR THE DETERMINATION OF WiMAX LICENCE FEE Ideally Intel prefers licenses to be issued to those with the best business case and the best utilization of the spectrum for broadband wireless. In the instance where there is more than one Operator then the Administration may consider an auction process but the auction should not be structured to extract the maximum value for revenue generating purposes. WHAT CAN BE THE RIGHTS OF WiMAX OPERATORS? 1) There shouldn t be any restriction for nomadic application. 2) There shouldn t be any restriction on TDD 3) There shouldn t be any restriction for mobile application 4) There shouldn t be any restriction for voice, VoIP, or any other telecommunication services. 5) They should have the interconnection and roaming rights (national and international) with other operators 6) An operator should have the rights to obtain licences at all regions. WHAT CAN BE THE OBLIGATIONS OF WiMAX OPERATORS: 1) Coverage 2) Customer support 3) Service quality 4) Should use certified interoperable products, e.g. WiMAX, otherwise compatibility between different manufacturer products can not be satisfied, and user terminal at different operators area will not work. 5) Compliance to ETSI, ITU, IEEE related standards is necessary SHOULD THERE BE THERE A COVERAGE OBLIGATION FOR WiMAX OPERATORS? Each operator should cover their licencing area in a specific time with required service quality. WiMAX NOMADIC APPLICATION The WiMAX networks will be able to support fixed and nomadic wireless broadband connectivity on the same network. Nomadic application is very important standard property of WiMAX and there shouldn t be any restriction for Nomadic applications. Not

5 only commercial users will benefit from WiMAX nomadic applications also government Entities will need it ( security, health etc ). Today users can benefit from the wireless broadband service at restricted area of Wi-Fi hotspots. And with nomadic application users will be able to get wireless broadband at any place inside large WiMAX network The Nomadic operation supports wireless broadband communication within a given area while the end user or device is stationary through the area. This means a user can connect to a WiMAX network at home, take their WiMAX-enabled device (PDA, laptop modem, handset) to work or play and connect to a WiMAX network at those locations as well. From a service provider perspective, this means they can "own" the end user throughout this large network coverage area, providing increased revenue opportunity. Support for nomadic services and the ability to provide ubiquitous coverage in a metropolitan area provides a tool for law enforcement, fire protection and other public safety organizations enabling them to maintain critical communications under a variety of adverse conditions. Private networks for industrial complexes, universities and other campus type environments also represent a potential business opportunity for WiMAX. For example Gomedia, the Italian broadband wireless solution provider, used WiMAX nomadic application to deliver security video applications during Winter Olympic Games. WiMAX SERVICES WiMAX is not a simple last mile (WLL) system. WiMAX supports Fixed, Nomadic, Mobile, VoIP and other standard carrier class applications and there shouldn t be any limitation for any type of services. Users should be able to benefit all of the properties of WiMAX. If there may be limitations this can be similar to someone have a latest model automobile but don t have the rights to use all the functions. WiMAX PCMCIA cards and WiMAX chips will be ready in laptops at soon and WiMAX networks should be ready for the usage, without any restriction. HOW THE WiMAX WILL INFLUENCE EGYPT TELECOM MARKET? WiMAX will enable competition and choice for the broadband access and therefore reduce associated costs to the consumer. POSSIBLE EFFECT OF WiMAX SERVICES (like Mobile WiMAX) OVER 3G SERVICES? Intel believes that there is big demand for beyond 3G wireless broadband services. As a beyond 3G wireless broadband technology, Mobile WiMAX offers much higher data rates and advanced applications than 3G services. Currently in South Korea operators

6 offer 3G services. In spite of 3G services existence operators start to offer WiMAX technology services since there is a demand for higher data speeds. This can be a good example where the technology is going and what will be the demand. In fact, Wi-Fi, WiMAX, 3G technologies will be complementary technologies. Users will able to have always best connection over existing networks according to their place. From an Operators perspective Intel believes that utilizing a mobile WiMAX deployment as a data overlay in a 3G network can provide significant benefits, i.e. of loading data traffic which still maximizing voice capacity. Intel has a very strong interest in the GHz band due to our interests in Mobile WiMAX and realising the personal broadband experience. Intel is aware that there is a perception that the 2.5 GHz band is exclusively for use by IMT-2000 Extension but it is important to recall that the ITU-R Radio Regulations actually states the following regarding the identification of this band for IMT-2000, as well as noting that 3G technologies already have core allocations A The bands, or portions of the bands, MHz and MHz, are identified for use by those administrations wishing to implement International Mobile Telecommunications-2000 (IMT-2000) in accordance with Resolution 223 (WRC-2000). This identification does not preclude the use of these bands by any other applications of the services to which they are allocated and does not establish priority in the Radio Regulations. Intel encourages Administrations to enable access to the GHz band for IMT and technically compatible technologies. Intel continues to commit significant resources in pursuit of access to the GHz band. We support the opening of this band for more than just IMT-2000 and have provided significant input to the European Commission in pursuit of opening the band for IMT-2000 and technically compatible technologies. Globally we are encouraging Administrations to consider providing access to this band under a technology neutral regulatory framework to allow innovative services the opportunity to access this band. Intel believes access to the 2.5 GHz band should be available as early as possible for new innovative 3G beyond broadband wireless systems. WiMAX COMMERCIAL APPLICATIONS There are more than below commercial applications!"# $%&'( )*+!&'( # ##,!*** -"-.!!#!"+,* &'( )*""$ /#&'( #

7 !" ** #** )!""!*"! 0&'(#!" *#!, )# 0 ##+$ /*&10& #!&'(,,#,!, **,,*** 0 +* + #2!*+3456&778 ** ) *!"*" #9 :;<= (.:;'%= /. :;1!*= 1:;>#"= -*6+:;4!!= +**;!= +/*: ;+=.:;4= '))45"?:45":;<= #:;-= &'(:; )=!"!!# *#,! +!" *"!!#< %!9 A+4;A+4=*#*"/.*## 1# 1!*!#" &'( #A+4/# * #,!+ (.'" '%1' >#"-*6+ 4!!+**! # *, #,! #1* + # +/* 4 #&'(!*" # +!!"#&'( )%! *!#*"" #94:;4= 4:; B= # :; = 1/11/* 1#:;**=.:;=.:;#= +#!":;*= %'*:;4!!= <% ):; =A:;#= &'( ) ** *!* #+,*!2!!: : ::!"*!# #!&'(*" #!#*"# CDE*F>C77*G * #&'( +$/*!# + )# # # #!*#!&'(! + H#!) #! )#!*+* 66!

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