Introduction
1. The SACF is an industry association that represents a broad group of members
in the ICT ecosystem and our primary purpose is contributing to creating an
inclusive, competitive sector that can attract and sustain investment.
1. The SACF welcomes the opportunity to comment on the draft implementation
of the radio frequency migration plan and the International Mobile
Telecommunications (IMT) roadmap and express our interest to participate in
any further processes, including a public hearing.
2. The SACF expresses its concerns over specific issues related to the Authority’s
draft implementation of the radio frequency migration plan and the IMT
roadmap. Our submission is limited to matters which our members have
reached consensus. Any point on which our members have varying opinions is
not part of this submission and will be included in their respective submissions.
General Comments
3. Communications infrastructure has become one of the most critical national
infrastructures that underpin and support all other sectors of the economy. The
current COVID-19 pandemic has demonstrated how ICT infrastructure and
services are critical to economies across the globe. Countries almost came to
a standstill, a situation that was salvaged by access to communications
infrastructure where work, learning, social interaction, commerce, medical
access, and most other aspects of life switched to a virtual environment.
4. SACF submits its comments in an environment that has fast-forwarded the
reality into a space that WRC-19 had only envisaged in the distant future. It is,
therefore, imperative that South Africa adopts a forward-looking and bold
approach to enable access to communications in ways that will stimulate
economic activity and spur economic recovery.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 2
5. Access to the critical frequency spectrum is key as technologies evolve and
the applications and use cases grow. Several frequency bands were identified
for IMT at WRC-19. This contributes to the growing number of use cases.
6. The global identification of frequencies for IMT will help unlock economies of
scale needed to accelerate the delivery of innovative and affordable 5G
services worldwide. This is set to benefit many industries, including
manufacturing, transport, healthcare, and education.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 3
7. Over time, countries have opened up ground-breaking possibilities for 5G
services while still protecting the existing radio services. WRC-19 delivered on
this goal and secured a pathway to 5G’s future success in the agenda for WRC23.” (https://www.gsma.com/newsroom/press-release/gsma-wrc-19-opensdoor-to-exciting-new-5g-services/). Spectrum demand for IMT continues to
grow as mobile communication evolves, and WRC-19 recognised this by
setting an agenda for the next WRC in 2023 that will consider the identification
of additional mid and high frequency bands for varied used including IMT.
8. Globally, commercial 5G services are already operating in the mid-frequency
spectrum in the 3 GHz range (from 3.3-4 GHz), providing a good balance of
coverage and capacity. Increasing the globally harmonised spectrum in this
frequency range at WRC-23 would boost 5G network performance, decrease
deployment costs and realise significant economic benefits.
9. Spectrum can contribute significantly to a nation’s GDP. Some studies have
found that in countries with advanced information and communication
technologies, the use of spectrum enabled an increase in GDP of about 3.4%.
This contribution is attributed to spectrum enabling advances in several areas,
including employment, technology, and investment in a wide variety of
spectrum initiatives. If the pace of innovation around spectrum remains steady,
it will provide more opportunities for countries to grow GDP and develop new
sources of revenue1.
10. Spectrum’s revenue potential is just part of its importance, however. Spectrum
is also the communications backbone for a country’s crucial social and public
services, and it offers a means of providing broadband services to underserved
rural areas. Embracing the new era of the Fourth Industrial Revolution, spectrum
will help to bridge the digital divide and streamline a digital economy and
lifestyle for the future.
1 Reference
The Coming Battle for Spectrum https://www.bcg.com/publications/2020/coming-battle-for-spectrum
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 4
Issues of concern to SACF
There are several issues on which SACF would like to express concerns over and which
directly touch on its members.
Current Regulatory Framework not sufficiently forward-looking
11. Spectrum is one of the most critical resources for the ICT sector, and the general
post-Covid-19 economic recovery. SACF thinks that it is crucial for the Authority
to adopt a forward-looking approach in licensing of the spectrum. WRC-15 and
WRC-19 identified several bands for IMT (including 5G). They include 24.25-27.5
GHz (Res. 242), 37-43.5 GHz (Res. 243), 45.5-47 GHz (Res. 244), 47.2-48.2 GHz (Res.
243) and 66-71 GHz (Res 241) for the deployment of IMT (5G) networks.
12. SACF acknowledges that not all the bands can be licensed simultaneously and
urges the Authority to licence them on a priority basis. The priority can be
determined by the maturity of the ecosystem (such as network infrastructure
and devices), the channelling plans, the availability of investment, and others
as the Authority would deem applicable. The SACF believes that much of the
underlying work, such as the frequency migration plan, among others, ought
to begin. SACF further expresses its interest to participate in this process.
Regulatory Certainty
13. The SACF is concerned that some bands that were earmarked for IMT were
historically licensed through opaque processes, favouring some licensees over
others. SACF urges that all licensing must be fair and transparent, allowing all
eligible and interested parties to fairly compete for access to available
spectrum.
14. Regulatory certainty is always important but more so in capital intensive sectors
where very significant levels of investment are required. Therefore, it is
imperative that processes are consistent, clear, fair, and transparent.
15. The SACF has highlighted several bands identified for IMT use that are yet to be
licensed. We anticipate that demand will exceed supply in most bands
although it is unlikely that this will be the case in all instances. We, therefore,
urge ICASA to assess the demand for each band and then apply the most
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 5
appropriate licensing process. The processes must be consistent, clear, fair, and
transparent. In the bands where demand exceeds supply, ICASA must apply a
competitive process.
16. In addition to processes being clear, fair, transparent, and consistent, it is
important that ICASA has a standard approach to issues so that no licensee is
prejudiced over another. This especially clear in respect of licensee migration
where a licensee for example was granted an incentive to migrate, while
others were not despite having been in a similar position.
17. The SACF does not support the approach of incentivizing or granting
concessions to licensees to migrate, as it may have the unintended
consequence of encouraging squatting in bands in anticipation for a large
payday.
18. Instead, we acknowledge that there the circumstances in respect of migration
may differ therefore, the SACF would urge ICASA to create a framework for
migration to clearly set out the rules which will enhance fairness, transparency,
and consistency.
19. The necessity to expedite digital migration is clear, as is the speed and
therefore, ICASA should publish regular updates with at least quarterly targets
to be met.
Ineffective public consultation
20. Public consultation is a key element of any regulatory process and is explicitly
enshrined in the constitution and founding legislation. It is a critical element of
any regulatory, policy or legislative process to enable all affected stakeholders
an opportunity to present its challenges, concerns and make proposals on
envisaged solutions to address the identified challenges and concerns.
21. It is equally important that stakeholders have a clear understanding of the
problem being cured as this would assist stakeholders proffer solutions.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 6
22. The public consultation improves transparency and the quality of the
regulations because of the diversity of ideas, solutions, and perspectives. Public
consultations ought to be viewed on the same basis as the principle of network
externalities, where every additional comment adds value to the collective
and the process. Conversely, everyone input denied prejudices the process
and collective by depriving the collective of the ability to consider the
additional perspective that will shape the outcome.
23. It is imperative to draw the distinction between competitive and noncompetitive processes as the approach to each would be different. The
approach to a non-competitive public consultation would be more
acquiescent because of the objective of the process.
24. A competitive process would of course be less flexible due to the potential
prejudice to be suffered by participants in the process.
25. The integrity, fairness, transparency, and consistency of a competitive process
must be sacrosanct to mitigate legal challenges. Legal challenges can never
be eliminated but can be mitigated when the prospect of success is limited.
26. Notification and awareness of the process is essential for stakeholders to
participate. Therefore, it is essential that the process and the timeframes are
clear. Stakeholders cannot participate in a process that they unaware of or the
timeframes are particularly short.
27. Meaningful consultation is premised on the ability of stakeholders to consider
regulatory proposals and do the necessary scenario planning assessing the
impact. This is a critical element of providing meaningful commentary.
Therefore, the timing of the publications and processes is important.
28. While ICASA publishes an annual plan, the SACF urges ICASA to ensure a better
spread of overlapping and similar categories of projects due to the limited
resources of stakeholders. The most severely prejudiced stakeholders would be
those with more limited resources.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 7
29. The Authority should consider that some stakeholders do not have the capacity
to respond to multiple public consultations at the same time. If there are
multiple consultations at the same time, then the response times should be
staggered over time while taking the public interest into account.
30. ICASA has recently adopted an unnecessarily harsh approach to receipt of
submissions, requests for extensions despite the detailed reasoning and
commentary periods which in our view significantly undermines the public
consultation appearing to reduce it to a superficial consultation.
31. A standardisation of the processes and submission times would be more helpful
and inclusive and as a result can only enhance the process and outcome.
Consistency in compensation for migration
32. The SACF understands that the Authority’s position is that there will be no
compensation for licensees affected by migration. RAIN (WBS) was however
given an extra 5 MHz in the 2.6 GHz band for their in-band migration. However,
a dissimilar approach is envisioned for the 900 MHz in-band migration where
spectrum will be reclaimed from the migrating licensees without any
compensation.
Use of Spectrum Sharing techniques
33. The SACF understands that spectrum is a scarce resource that requires efficient
utilisation. This can be achieved using modern technologies that seek to
optimise the use of the resource. Spectrum sharing, trading, and pooling can
be useful tools to ensure the most effective and efficient use of assigned
spectrum. However, it is important that this is done on a commercially agreed
basis to prevent the undue prejudice to licensees.
34. A clear framework will protect all interested stakeholders and provide much
needed regulatory certainty.
35. Spectrum sharing has been embraced across the world, including here in South
Africa. SACF urges the Authority to fully embrace spectrum sharing on all
applicable frequency bands to achieve the most efficient utilisation of the
available spectrum.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 8
Migration of Frequency Bands from FDD to TDD
36. Most of the IMT frequency bands are operating under FDD, which needs
separate frequency bands/channels for uplink and downlink to allow fullduplex communication. This offers less efficient spectrum utilisation than TDD,
which allows both uplink and downlink communication to occur within one
frequency channel, by dividing it into time slots. Uplink and downlink
communications are allocated different time slots within the same channel. This
is most preferred for the bands above 2.1 GHz. SACF, respectively, urges that
all frequency bands above 2.1 GHz operating under FDD technique be
migrated to TDD technique.
Use of Active Antenna System (AAS)
37. Active Antenna Systems (AAS) use new technologies, e.g., Beamforming. The
spectrum utilisation is much more efficient with this technology, as compared
to other types of antennas. Additionally, 3GPP Technical Specification 38.104
proposes that the transmission counters of the new AAS base station are
represented by OTA (Over-the-Air). The measurement conditions are defined
as Total Radiated Power (TRP), not Effective Isotropic Radiated Power (EIRP).
TRP is more accurate in assessing interference between 5G and other mobile
systems.
The Current Spectrum Sharing Provisions are Unclear
38. The SACF has noted that the current spectrum sharing provisions are unclear in
that they do not state who, what/which, when and where spectrum can be
shared. This could be one reason why spectrum sharing has not been actively
embraced in South Africa.
39. Section18(2) of the Authority Radio Frequency Spectrum Regulations 2015
states that “The Authority may require a licensee to share an assigned
frequency with other licensees”, thus allowing the Authority to use arbitrary
criteria.
40. The Authority does not seem to have fixed rules and criteria for approving
spectrum sharing agreements. It asks interested parties to submit applications
when these entities approach it for clarity.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 9
41. The SACF notes that in the UK an operator-initiated spectrum sharing
arrangement has been implemented and is supported by Ofcom. It appears
to address some of typical challenges in extending networks to rural areas
including strengthening the business case which may be increasingly
weakened by the growing migratory behaviour of South Africans. Nevertheless,
the need for equitable connectivity to rural areas remains a national
imperative. While the spectrum sharing project is still at its infancy and it is
important to watch and see how it evolves and the lessons from this project
could provide valuable insights in addressing rural connectivity in South Africa.
42. The obligations imposed during Telkom’s exclusivity may provide valuable
insights on the need to comprehensively study approaches adopted in other
jurisdictions before implementation. We, therefore, urge ICASA to study this
project.
43. There should be a standalone spectrum sharing regulation, or an amendment
of the current provisions, that sets out the requirements for approval of
spectrum sharing, the terms and conditions and applicable fees if any.
44. The SACF urges the Authority to consult from other regulators who have wellestablished frameworks on spectrum sharing.
Insufficient information publicly available about spectrum assignments
45. The SACF is concerned that there is limited information about spectrum
assignments that is publicly available. This information is critical to stakeholders
and is part of ICASA’s mandate.
46. The SACF therefore urges ICASA to publish regular updates on the spectrum
assignments. As there is limited public value in indicating the licensees to whom
the spectrum has been assigned, we would therefore urge ICASA to publish
updated assignments only. Linking them to licensees may present competition
challenges.
47. Similarly, there is insufficient information publicly available about Digital
Restacking Plans.
48. There was a recent news article (accessible via the link below) indicating that
Sentech is restacking the digital dividend spectrum. However, there is no
published plan to show what will be done and by when. SACF urges the
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 10
Authority to publish this digital restacking plan.
(https://mybroadband.co.za/forum/threads/sentech-begins-digital-dividendrestacking-in-northern-cape-and-north-west.1171986/
Maximum Radiated Power Limit
49. The current Radio Frequency Spectrum Assignment Plans (RFSAPs) contain a
maximum radiated power limit of 61dBm/5MHz EIRP. SACF notes that in the
CEPT ECC Decision (11)06 in-block power limit is not obligatory, and if it is
desired by an administration, a value not exceeding 68dBm/5MHz EIRP per
antenna for non-AAS and 47dBm/5MHz TRP for AAS may be applied. Such
more recent moves suggest that it may be prudent for the Authority to
reconsider its position on EIRP and conduct further research into recent global
developments, and then update the definitions of “maximum radiated power
limits” in the related RFSAPs in the implementation of the migration process,
which applies to the TDD bands 2300-2400 MHz, 2500-2690 MHz, 3300-3800 MHz,
etc.
Service neutrality Vs Technology neutrality
50. The Electronic Communications Act (ECA) encourages the Authority to be
technology neutral. In relation to radio frequency spectrum (RFS), the SACF
understands this to mean that the Authority should grant licences that specify
the type of service that can be provided e.g., Fixed or Mobile, without dictating
the specific technology to be used by the licensee.
51. As we have pointed out in previous submissions there is a fundamental
difference between service and technology neutrality. The ECA provides for
technology neutrality.
52. Technology neutrality means that technical standards designed to limit negative
externalities (e.g., radio interference, pollution, safety) should describe the result to
be achieved, but should leave companies free to adopt whatever technology is
most appropriate to achieve the result.
53. We understand refarming to mean that the technology for a specific band may
change, for example from 4G to 5G but IMT, nevertheless.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 11
Reclaim, migrate and re-license
54. However, once the allocation of a band changes, the spectrum must be
reclaimed by ICASA, licensees in the band must be migrated out of the band and
the spectrum must be licensed in a fair and transparent manner and within the
prescribed framework.
55. Failure to do so has the potential of encouraging to licensees to prospect and
hoard the spectrum until it becomes more valuable. This can never be ICASA’s
intention.
56. The SACF recommends that the Authority should consult on the principles of
service and technology neutrality and develop clear guidelines to ensure
transparency and fairness.
Frequency bands of interest to SACF members
450-470 MHz
57. SACF urges the Authority to expedite clearing of this band to allow licensing for
IMT use.
606-694 MHz
58. SACF appeals to the Authority to consider licensing this band on a noninterference, non-protection basis, including for IMT.
3600-3800 MHz
59. It was widely anticipated that WRC-19 would have allocated this band to the
Mobile Service on a primary basis. However, this decision was deferred to WRC23 and the band was allocated to Mobile on a secondary basis in Region 1.
60. As a result, Satellite remains the primary use in this band.
61. Europe and the Middle East have been able to fast forward and use this band
for IMT due to the relatively low number of satellite users and consumers in these
bands. At the same time, SACF does appreciate that Africa, in general, has a
considerably higher usage of satellite services. Despite this, South Africa does
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 12
not have a similarly high use of satellite services in this band compared to other
African states.
62. SACF believes that the Authority has already started licensing broadband
services in this band, albeit on a secondary basis. However, these licences were
issued for fixed wireless access (FWA) services, as SACF understands it. This raises
several questions for the SACF and our members, which include:
▪ Are these licences temporary, in that they will be reconsider post WRC 23?
▪ Following WRC-23, if the band is allocated to the Mobile service on a
primary basis, will these FWA licensees be migrated out of the band?
▪ Will the Authority then allow the transition from fixed use to Mobile for
licensees currently licensed in these bands?
▪ Will the Authority recover the spectrum and follow an adequately
constituted competitive process, as SACF is aware that some of our
members applied for spectrum in these bands and were not granted
licences, nor were they refused licences either?
63. As this band is likely to be allocated to the Mobile service on a primary basis in
the future, SACF urges the Authority to at least align with ITU Region 1 to
allocate the band to the Mobile service on a secondary basis at this time and
not wait for a primary allocation to mobile after WRC-23. This could be done to
prevent interference, where licensees are required to coordinate access.
64. This becomes especially important to prevent undue prejudice to small
licensees, should they invest. It would seem more prudent to instead pursue a
sound, fair, transparent licensing process to mitigate undue prejudice and legal
challenges.
65. Furthermore, the standards established for equipment in these bands are
evidenced in Europe and the Middle East. The SACF understands that
channelling arrangements are being developed.
66. Finally, SACF believes this will contribute to economic activity, particularly as it
supports 5G services essential for 4th Industrial Revolution (4IR) economies.
Recommendation
67. The Authority should urgently provide clarity on the approach to licensing and
whether it will be retaining or reclaiming the currently licensed spectrum.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 13
1427-1518 MHz (L-band)
68. The L Band is a good coverage band with better propagation properties than
the 1800 MHz band. For example, while it is a good coverage band, it is a
complementary band used with other coverage bands.
69. SACF notes that the power limits assigned to this band should apply to outdoor
applications and should be reduced for indoor applications as the probability
of interference is limited.
70. SACF believes that a TDD configuration allows for more innovative, adaptive,
and efficient spectrum use, allowing for adjustments and corrections based on
current use case patterns.
71. “The requirement for standalone operation in the band (both UL and DL
transmissions) has emerged in some other regions. (https://fundarccomm.xgnlab.com/2019/02/the-need-for-globally-harmonised-5g.html) In the
case of standalone 5G systems, a TDD access scheme is a potentially
appropriate option, accommodating traffic asymmetry in the UL/DL directions
with good potential for economies of scale.
72. SACF supports the release of the 1452-1492 MHz band for IMT. Additionally, we
also encourage the Authority to release the 1427-1452 MHz and 1492-1518 MHz
bands as soon as feasible to enable a significant block of spectrum in this band
(91 MHz vs. 40 MHz).
73. While some regulators have already assigned this band for supplemental
downlink (SDL – Band n75), the SACF expects that there may be a future
migration to the more flexible Band n50+n51 arrangement. As such, the SACF
recommends that the Authority should immediately assign the range 1432-1518
MHz in a Band n75 configuration, with a migration plan to the n50+n51 (1427-
1518 MHz) TDD band plan. This would allow for use of 5G for downlink only,
uplink only or uplink/downlink transmissions depending on the needs of the
operators.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 14
Recommendation
74. Harmonise the band for B75/N75 and get it ready for licensing while still
gathering data and conducting research.
2500-2690 MHz (IMT2600)
75. In May 2020, the SACF participated in the Authority’s consultative process on
the IMT 2600 band FDD conversion to TDD. SACF welcomes the Authority’s
decision to amend the draft plan accordingly, and SACF believes that this will
improve the spectrum efficiency in the band.
3300-3400 MHz
76. As SACF understands, the 3300 – 3400 MHz band was identified for IMT at WRC15 but is yet to be implemented in the South African market. The network
ecosystem for this band is still small but growing, supported by recent
allocations in South America and South Asia. SACF believes that no barriers are
prohibiting the licensing of this band.
77. The licensing of these bands sooner rather than later will create certainty and
allow operators to roll out more efficiently and have less cause for replacing
the equipment over the short to medium term. This will contribute to the
national priorities reducing the cost to communicate and extending
infrastructure ubiquitously.
78. In this regard, SACF urges the Authority to share its plans on preparing the band
for licensing. The South African Communications Forum believes that such plans
should include any migration plans, including the applicable timeframes. In
instances where there will be coordinated usage, SACF urges the Authority to
develop a database of the extent of radar/radiolocation use within the bands.
Recommendation
79. SACF recommends that the Authority license the 3300–3400 MHz band sooner
rather than later and create or publish a database of current users together
with its plans and associated timeframes for licensing.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 15
4800-4990 MHz
80. This band was first identified for IMT use at WRC-15.
81. While the ecosystem is still in its developmental stages, SACF has noted that the
period for developing the ecosystem is continually getting shorter. SACF
anticipates this trend to continue as countries with large markets are beginning
to licence this band.
82. SACF believes that the Authority should expedite the licensing of this band,
particularly as this is considered an essential band going forward.
83. The South African Communications Forum urges the Authority to identify
possible migration in the band. The migration plans, together with timelines,
should be published.
Recommendation
84. Provide information and transparency on incumbents and begin to prepare
the band for licensing as soon as possible.
24250-27500 MHz (26 GHz) & 37000-43500MHz (38 GHz & 42 GHz) bands
85. SACF notes the allocation of the 26.5-27.5 GHz band for mobile communication
and that WRC-19 Resolution 242 and footnote 5.532AB identified this band for
IMT.
86. The SACF believes it is essential to begin preparing this band for access.
However, while it is important to start preparing the band for licensing, SACF
recognises that the preparation of this band is likely to be a complex task due
to the number of legacy users in the band. As a result, SACF believes that the
band would need harmonisation. SACF, thus, urges the Authority to begin the
licensing process as soon as possible.
87. Notwithstanding the challenges in the band, SACF believes that there are parts
of the band that could be licensed sooner rather than later.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 16
Recommendation
88. SACF urges the Authority to begin preparing the band for licensing with
applicable timelines and the processes to be followed as information for the
industry.
5925-7125 MHz (6 GHz)
89. According to the ITU, the data traffic consumption of 5G users is growing at a
considerable speed, with the average monthly traffic per mobile user
worldwide anticipated to reach 250 GB by 2030. In addition, 5G will be widely
used in various vertical industry applications.
90. Given the above business requirements, the GSMA forecasts that each country
will still need an additional 1-2 GHz mid-band spectrum by 2030 in addition to
the refarming of the existing spectrum.
91. The upper 6 GHz band is potential golden capacity spectrum for 5G/6G and
should follow the WRC-23 agenda item 1.2 process to study the possibility for
IMT identification.
92. Beyond the 3 GHz & 4 GHz bands (which still suffer from legacy incumbent use),
the next available capacity band for IMT is in the 6 GHz range.
93. When compared to the limited user connectivity of Wi-Fi (typically being
constrained to users with alternative fixed access), the prospect of providing
high capacity IMT services to large numbers of users is a more compelling
proposition in a country such as South Africa that has very limited fixed access.
94. In regard to local Wi-Fi networks, there are other short-range alternatives for
personal area networks such as such as WiGig in the 60 GHz band.
95. If the spectrum is to be used as a Mobile hotspot, the data traffic will be
backhauled over the Mobile network’s spectrum. Therefore, it would mean that
there is duplicate use of spectrum in that traffic would be carried over the
operator’s spectrum while the Wi-Fi spectrum will merely act as a relay to the
local network. This will be inefficient use of the spectrum resource.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 17
96. For all these reasons, SACF urges the Authority to avoid a rushed decision on
the allocation of the lower part of the 6 GHz band (5925-6425 MHz) to
unlicensed use. With regards to the upper part of the band (6425-7125 MHz),
SACF supports the consideration for mobile use.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 18
Table 1: Frequency Bands of Interest to SACF members
Frequency
Band
Prioritisation
Location in the Spectrum Framework
Motivation for the Prioritisation
Band Plan Migration Plan Assignment Plan
IMT 700
Immediate Completed Completed Completed
Completed
March 2022 national Switch off
Publication of monthly status updates.
The SACF written submission requested quarterly
plans, however the lack of readiness by
broadcasters at the hearings demonstrated the
need for more frequent updates.
IMT 800
Immediate Completed Completed Completed
IMT 2600
Immediate Completed Completed Completed Incorrectly reflected in the draft Band Plan.
Needs to be reflected correctly.
3300 – 3400
MHz
Immediate Completed Completed
Begin as soon as is
practicably
possible.
Already licensed for non IMT applications.
Identified for IMT usage at WRC 15.
Equipment already deployed supports the use of
these bands and there is a mature user terminal
ecosystem that supports this band.
Publish a database of current users for coordinated usage.
Publish licensing timeframes.
3500 MHz Immediate Completed Completed Completed
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 19
Frequency
Band
Prioritisation
Location in the Spectrum Framework
Motivation for the Prioritisation
Band Plan Migration Plan Assignment Plan
3600-3800
MHz
Medium-term
– Post WRC-23
On the Agenda for
WRC-23
Will follow
WRC-23
processes
Will follow WRC-23
processes
Authority should urgently provide clarity on
approach to licensing and whether it will be
retaining or reclaiming currently licensed
spectrum. Clear articulation of licensing
process to be followed.
The SACF’s proposal is to reclaim, migrate and
assign.
Reallocation of the band planned for WRC-23.
Identification of all prospective high demand IMT
bands.
4800 – 4900
MHz
Medium-term
Update Band
Plan – decided at
WRC-19
Identify legacy
users
Begin
consultation on
migration plans
Begin as soon as is
practicably possible.
Financial year: 2022-
23
Already identified for IMT at WRC-19.
L Band 1427-
1518 MHz Immediate
Update the
Band Plan
Identify legacy
users
Begin
consultation on
migration plans
Begin as soon as is
practicably possible.
SACF recommends that the Authority begins
preparation for access to the band, while still
gathering data and conducting research.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 20
Frequency
Band
Prioritisation
Location in the Spectrum Framework
Motivation for the Prioritisation
Band Plan Migration Plan Assignment Plan
26, 38 & 42
GHz
Mediumterm
Update the
Band Plan as per
WRC- 19 decision
Publish a
database of
legacy users to
begin migration
of the band.
Grandfathering
to be
considered.
Begin as soon as is
practicably possible.
Identified for IMT at WRC-19
Favours 5G (High bandwidth and low latency)
6425-7125
MHz (upper
6 GHz)
Long-term Part of Agenda Item
1.2 of WRC- 23
Will follow
WRC-23
processes
Will follow WRC-23
processes
The SACF notes with appreciation the Authority’s
support at ITU WP5D for identification of this band
for IMT and its input contribution of a sharing study
between IMT and incumbent services in the band.
The Authority should collaborate with industry
partners to cultivate the E2E IMT ecosystem of the
6 GHz band
SACF also recommends adding a note to all subbands between 6425 MHz and 7125 MHz to
indicate that this band is under consideration at
WRC-23 for future IMT use.
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 21
SACF Response To ICASA Consultation On Draft Migration Plan And IMT Roadmap 22
General comments
Licensing Process
97. SACF holds the position that:
▪ The licensing processes must be clear, fair, transparent, and consistent;
▪ The Authority should be explicit on its position concerning the status of
spectrum licences when the use of the band changes from one service to
another e.g., fixed to mobile. There is need for clarity on whether users retain
the assigned spectrum or does the Authority reclaim the spectrum.
▪ SACF’s recommendation is to reclaim, migrate and assign through the
appropriate process, following an assessment of demand.
Additional Comments
98. The Minister of Communications and Digital Technologies announced an
analogue switch-off date of March 2022.
99. Broadcasters have indicated a lack of readiness to migrate from the IMT700
and IMT 800 bands. SACF appeals that this deadline should not be extended
any further.
100. The Authority should develop and publish a strategy to fast-track
migration as it is tied to the licensing of the critical high demand spectrum.
WRC 23 Agenda Items
▪ ICASA should include a note that highlights bands on the WRC-23 agenda.