Call for comments concerning the modification of Dolphin Telecomís authorisation to establish and operate a public professional mobile radio (PMR) network / 22 October 2002

To download the call for comments (doc)

1. Purpose

In the decree dated 30 March 2000, published in the Journal Officiel of 10 May 2000, the company Dolphin Telecom was authorised to establish and operate a public digital professional mobile radio (PMR) network and to provide public telephone service. This authorisation was issued in accordance with articles L. 33-1 and L. 34-1 of the Post and Telecommunications Code.
Section I of the specifications appended to the authorisation decree stipulates that "the operator establishes across the entire country (Ö) a network conforming with the TETRA standardisation".

Dolphin Telecom has requested that Autorité de régulation des télécommunications (ART) changes the operating conditions of its authorisation.

Dolphin Telecom explains that demand on the PMR market is leaning more and more towards medium- and high-speed data transmission needs. It feels that these needs will not be met by the future upgrade of the TETRA standard (TETRA release 2: TAPS and TEDS), although it does wish to see the upgrade included in the specifications.
Because of this, Dolphin Telecom asks that another standard be added to the reference mentioned in the specifications appended to the authorisation. It asks to be permitted to use CDMA-PAMR technology, on the frequency bands allocated to it, given that this technology is able to meet data transmission needs at medium and high speeds.

Modification of the operating conditions of the authorisation must meet the requirements for transparency, objectivity and non discrimination stipulated by the Post and Telecommunications Code. Therefore, in order to better understand the consequences this modification might have, ART has decided to launch a public consultation in order to give interested parties the opportunity to share their comments regarding such a change. This consultation is being conducted by the regulator, and will be used when it will prepare its proposals to the Minister of Telecommunications, who alone has the authority to modify an L. 33-1 and L. 34-1 authorisation.

2. Review of the introduction of professional mobile radio in France

ART first launched a call for comments for the introduction of digital professional mobile radio in France in April 1997. Response to this public consultation showed the need to introduce digital mobile professional networks in France. Therefore, an application procedure was launched in July 1997, giving candidates the choice between systems based on the TETRA and TETRAPOL standards. Following this procedure, in ART decision no. 98-377 dated 3 June 1998, published in the Journal officiel of 2 August 1998, the company Régiocom, which was subsequently named Dolphin Telecom in February 1999, was granted permission to establish and operate a digital professional mobile radio (PMR) national network using the European TETRA standard, as chosen by this operator.

Event before its network was launched commercially, Dolphin Telecom requested permission to transform its L. 33-2 network (independent network) into an L. 33-1 network (public network) for the following reasons:

  • to gain access to France Telecomís interconnection catalogue prices, which is not permitted for L. 33-2 networks
  • to attribute to its clients mobile numbers beginning with 06 right from the start
  • This transformation request, which is permitted under the Post and Telecommunications Code, was the subject of a call for comments, following which ART proposed that the network be requalified in a Ministry decree dated 30 March 2000.

    3. Evolution of the network

    Following the difficulties of its parent company, Dolphin Telecom was placed in administration on 6 September 2001. On 27 June 2002, the commercial court of Nanterre accepted the continuation plan presented by the company Inquam, although this plan depends on the ability to use other technologies than that based on the TETRA standard. According to Dolphin Telecom, the upgrade of the TETRA standard may not allow the long-term existence of its project. In its opinion, this standard is no longer necessarily suited to its clienteleís needs and cannot offer specific services for data transmission at medium and high speeds, such as sending images or video (e.g.: transmitting medical files, maps, mugging photos or photos triggered upon the sounding of alarms, etc.).
    Therefore, Dolphin Telecom asks that its authorisation be modified in order to allow it to use the CDMA-PAMR technology in the frequency bands assigned to it. This technology is based on the CDMA 2000 standard which is part of the IMT 2000 family of interfaces.

    4. The frequencies allocated

    In its decision no. 00-517 dated 7 June 2000, ART allocated to Dolphin Telecom frequencies in the 410-430 MHz band to operate its network, taking into account that this band is shared with the Ministry of Defence, and previously authorised networks. The 410-430 MHz band is one of the four bands identified by the CEPT to be used for digital professional mobile networks.

    The spectrum assigned to Dolphin Telecom:

  • In the Paris region (Ile de France), the 415-420 MHz band paired with the 425-430 MHz band, taking into account the frequencies assigned to RATP and SERTA until 31 December 2010.
    In this band, forty-four 12.5-kHz channels in the 418.7500 to 419.2000 MHz and 419.3625 to 419.4375 MHz sub-bands were assigned to RATP (decree no. 1024 dated 18 December 1996), or the equivalent of twenty-two 25-kHz channels.
  • Twenty-eight 12.5-kHz channels in the 418.0375 to 428.6375 MHz sub-band were assigned to SERTA (ART decision no. 98-228 of 30 April 1998), making fifteen 25-kHz channels unavailable.
    In all, Dolphin Telecom was assigned 4.075 MHz of band (163 channels), including 3 MHz continuous (415-418 MHz).

  • Outside Ile de France, the 416-420 MHz band paired with the 426-430 Mhz band, taking into account the frequencies assigned in Lyon to Société Lyonnaise des Transports en Commun, for ten 12.5-kHz channels in the 418-418.450 MHz sub-band (ART decision no. 00-507 dated 30 May 2000 and footnote F040a of the National Frequency Band Distribution Table (TNRBF).
  • It is important to note that a change of standard would have to take into account the constraint inherent to the frequencies coordination at borders, which might prevent the operator from deploying a new network in border regions in the long run. Since the CDMA-PAMR standard requires a continuous frequency band, this question may be of particular relevance.

    Footnote no. F033d of the TNRBF stipulates: "In the 414.5-420 MHz and 424.5-430 MHz bands, ART use is reserved to digital systems. Moreover, the introduction of shared-resource pan-European radio systems using the TETRA standard is permitted in this band in accordance with decision ERC/DEC(96)04 dated 7 March 1996 of the European Radiocommunications Committee".

    Dolphin Telecom has stated that it does not wish any change to the frequency band assigned it. Moreover, the company has not made any requests for additional bands in the short or medium term.

    5. The technologies

  • The TETRA standard
  • The European Telecommunications Standardisation Institute (ETSI) has established a standard called TETRA (TErrestrial Trunked RAdio) for digital professional networks. TETRA networks are used for high-density networks using TDMA technology and 25 kHz channelling. Work is currently underway at ETSI and CEPT to upgrade this standard to high speed (TETRA release 2: TAPS and TEDS).

  • Technology planned for the authorisation change
  • In requesting a change to its authorisation, Dolphin Telecom plans to use the CDMA-PAMR technology[1]1.
    CDMA-PAMR is a system which uses voice-over-IP (VoIP) technology running over a CDMA-1X radio access network.

    This involves:

    1) a CDMA radio access network with the associated IP data network s and components,
    2) and a PAMR application (PMR network), consisting of the mobile client part running on the mobile terminal and the network server part running on servers connected to the network. The PAMR application should offer various PAMR services.

    CEPT has formed a number of subgroups of the radio committee to study this technology, and in particular, spectral efficiency aspects in a PAMR environment.

    The CDMA-1X radio interface, of the CDMA 2000 series which is part of the IMT 2000 radio interface family defined by ITU for third-generation mobile systems, is described in documents [2] to [6] of the TIA standard (Telecommunications Industry Association) which can be downloaded from:

    The carrier is 1.25 MHz wide, and a guard band is needed on either side of the spectrum used.

    According to one of the equipment manufacturers developing this technology, CDMA-PAMR should be available in late 2002 or early 2003.

    6. Deployment timetable for the technology

    Dolphin Telecom wishes to deploy the CDMA-PAMR technology on the areas which are not yet open commercially, as soon as its authorisation has been modified.
    Dolphin Telecom plans to continue to deploy the TETRA technology in the four areas already covered (Nord-Pas-de-Calais, Paris-Ile-de-France, Rhône-Alpes, Marseille-Nice) and the highways linking these areas, increasing the number of base stations to improve coverage and quality of service. It aims to switch these areas to the CDMA-PAMR technology by 2007, in order to cover the entire country with a single technology.

    7. ART requests comments on the following points

  • Technological Aspect
  • Q 1. To your knowledge, what are the data transfer services provided by the TETRA standard release 2 and/or the CDMA-PAMR system?

    Q 2. What is the expected availability date for medium- and high-speed TETRA solutions?

    Q 3. The TETRA standard includes a number of PMR services and functions. Which ones should be available regardless of the standard used?

    Q 4. Which of the services listed in Dolphin Telecomís L 33-1 authorisation must be available?

    Q 5. The CDMA-PAMR offers PMR services by way of a software application. Can this system be considered as a PAMR system like TETRA is?

    PMR and/or PAMR market

    Q 6. Are the PMR and/or PAMR needs for voice and data currently being fully met? If not, why not?

    Q 7. Do you believe there is a need for medium- and high-speed PMR and/or PAMR services? If yes, how soon?


  • Issues regarding allowing Dolphin Telecom to use IMT 2000 systems, such as CDMA 2000, in the 410-430 MHz band
  • Q 8. Players are invited to express any concerns they may have regarding an authorisation for Dolphin Telecom to use an IMT 2000 system such as CDMA 2000 in the 410-430 MHz band.

  • Issues regarding the introduction process for IMT 2000 third-generation mobile systems in France
  • Third-generation mobile systems have been introduced across Europe in the 1900-1980 MHz / 2110-2170 MHz bands. These bands have been chosen at the global level for the IMT 2000 family of systems, which includes CDMA 2000.

    In France, two application procedures have been held to grant four authorisations. These authorisations cover the establishment and operation of a public network conforming with IMT 2000 standards and the provision of public telephone service, under articles L.33-1 and L.34-1 of the Post and Telecommunications Code.

    These procedures gave all players wishing to deploy CDMA 2000 the opportunity to apply. There were only a total of three applications for both these procedures. As a result, one authorisation to deploy an IMT 2000 system, such as UMTS and CDMA 2000, has not been granted.

    The authorisation which Dolphin currently holds, is also subject to articles L.33-1 and L.34-1 of the Post and Telecommunications Code, but is based on the TETRA standard. Dolphin Telecomís activity targets professional clients exclusively.

    In this context, Dolphin Telecomís request to extend its authorisation to include the CDMA 2000 radio interface in the frequency bands it has been assigned, requires that a number of questions be answered regarding the global coherence of the system used to introduce IMT 2000.

  • Competition and the specificity of Dolphin Telecomís activities and those activities authorised under the 3G application procedures
  • Q 9. ART requests comments on the difference between:
    - The activities of a public network operator and public telephone service provider for professionals currently practiced by Dolphin Telecom and which the operator wishes to extend to include CDMA 2000
    - The activities covered by the authorisation granted by the application procedures for third-generation mobile systems belonging to the IMT 2000 family of standards.

    Q 10. To what degree do these activities compete? Do either of them have any unique characteristics with respect to the other?

  • Technical aspects regarding the optimisation of spectrum use
  • Dolphin Telecomís request would require the extension in France of the frequency spectrum assigned to IMT 2000 systems to a new band. The 410-430 MHz bands have not been set aside globally for IMT 2000 systems. On the contrary, frequencies in the 1900-1980 MHz/2110-2170 MHz bands, assigned to IMT 2000 systems worldwide, are still available in France.

    ART seeks technical information on this issue which affects the proper management of the frequency spectrum.

    Q 11. What technical reasons would justify opening in France the 410-430 MHz frequencies to IMT 2000 systems, in addition to the bands identified at a global level, and which are still available in France?

    Q 12. Are there any specific technical characteristics inherent to the activity of an IMT 2000 network operator for professionals which would make the bands set aside globally for IMT 2000 mobile networks unsuitable for this type of activity?

    Q 13. If the 410-430 MHz frequencies were made available in France to IMT 2000 systems, are there technical reasons which make this band better suited to a mobile network operator targeting professionals rather than to a mobile network operator targeting the general public?

  • Need for other systems in these bands
  • In that an authorisation to establish a CDMA 2000 network belonging to the IMT 2000 family would substantially change the organisation of this band, ART wishes to know if other systems are needed in these bands.

    Q 14. Players are invited to express any needs for other systems in these bands.

  • Appropriateness of opening the 410-430 MHz band to IMT 2000 systems and plans for deploying such networks in this band
  • Q 15. Players are invited to express their opinions on the appropriateness of opening the 410-430 MHz band to IMT 2000 systems.

    Q 16. Players are invited to state whether they would be interested in deploying IMT 2000 systems in the 410-430 MHz band, if it were made available to such systems. If yes, for what types of uses?

  • Rights and responsibilities related to the deployment of an IMT 2000 network in the 410-430 MHz band
  • The application procedures for the 1900-1980 MHz / 2110-2170 MHz bands to introduce IMT 2000 systems defined the rights and responsibilities of authorised operators. In particular, the Finance law set fees, which take into account the "quantifiable advantage" of obtaining the right to occupy frequencies.

    Q 17. What would the functional and financial rights and responsibilities be for an authorisation to establish and operate a public IMT 2000 network in the 410-430 MHz band?

    Q 18. If the occupation right to frequencies is modified to permit an IMT 2000 standard, would the amount of the fee, which has been defined for an authorisation under the TETRA standard, have to be revised?

  • Means of granting an authorisation to operate an IMT 2000 network in the 410-430 MHz band
  • Dolphin Telecom has stated that it wishes to replace its network under the TETRA standard with a network using the CDMA 2000 standard.

    ART reiterates that Dolphin Telecomís authorisation was granted following an application procedure based on the TETRA and Tetrapol standards, in which Dolphin Telecom chose the TETRA standard.

    Permission to Dolphin Telecom to establish an IMT 2000 network in the 410-430 MHz band would be a major change to the conditions of this authorisation.

    The following questions deal with the hypothesis that the 410-430 MHz band were opened to the establishment of a mobile network conforming with one of the standards of the IMT 2000 family, such as CDMA 2000.

    Q 19. Do you think it would be possible to automatically modify Dolphin Telecomís authorisation? If yes, would certain rights or responsibilities in Dolphin Telecomís authorisation have to be modified to guarantee competitive equity?

    Q 20. Would the fact that Dolphin Telecom is limited to 4 MHz (not other frequencies are available in the band) prevent competition with "general" 3G operators?

    8. General conditions for the consultation

    Responses from interested parties must be sent to Autorité de régulation des télécommunications (ART) before Tuesday 19 November at noon, at the following address:

    Autorité de régulation des télécommunications
    Service Operateurs et Ressources (Unité Réseaux professionnels, pièce 1319)
    7 square Max Hymans
    75730 Paris Cedex 15

    ART reserves the right to publish all or part of the comments it receives, unless the contributor explicitly identifies them as confidential. In this case, the contributor is invited to place confidential elements in a separate appendix.

    The following persons may be contacted for additional information on this consultation document:

    Christian Gastou, Manager, Professional Networks Unit
    (tel.: +33 (0)1 40 47 70 94; fax: +33 (0)1 40 47 72 05;

    Jean-François Santé, Assistant Manager, Professional Networks Unit
    (tel.: +33 (0)1 40 47 72 35; fax: +33 (0)1 40 47 72 05;

    Jean-Paul Magne, Manager, Professional Mobile Networks
    (tel.: +33 (0)1 40 47 71 00; fax: +33 (0)1 40 47 72 05;

    Daniel Quintin, Manager, Professional Consultation
    (tel.: +33 (0)1 40 47 71 08; fax: +33 (0)1 40 47 72 05;

    Jérôme Rousseau, Manager, Mobile Operators Unit
    (tel.: +33 (0)1 40 47 70 85; fax: +33 (0)1 40 47 72 06;

    Secretariat - tel.: +33 (0)1 40 47 70 83

    ©Autorité de régulation des télécommunications - October 2002
    7, Square Max Hymans - 75730 PARIS Cedex 15
    Téléphone : +33 1 40 47 70 00 - Télécopie : +33 1 40 47 71 98