RE: SPANISH CONSULTATION Re:  Decision 1538 (SRD Decision) and release of spectrum in the bands 874MHz and 915MHz

The Spanish authorities have recently issued a consultation on updates to the national Frequency Allocation Table. A part of this consultation is the proposed implementation of EC Decision 1538 (SRD Decision) and release of spectrum in the bands 874MHz and 915MHz. This spectrum is becoming ever more important in the delivery of IoT and smart city applications allowing our members to deliver significant socioeconomic value.

The LPRA, therefore, welcomes the implementation of 1538 but we note that significant additional spectrum is available for SRDs from 870-874MHz, as shown in Recommendation 70-03. Given this spectrum is available in Spain (and not used by military services) and has been released by the majority of EU countries, we believe that the Spanish authorities should release it.

We would urge members to respond to the consultation* and would like you to know that, in addition,  the LPRA Council will be responding on behalf of the entire industry.

The consultation closed on the 27th December 2019.

The LPRA's response was made on the 23rd December 2019 :

Dear Sir/Madam

The Low Power Radio Association (LPRA) exists to represent the interests of the Short Range Devices (SRD) industry. SRD’s are used in a wide range of professional and consumer applications as diverse as remote controls for home automation and car key fobs, wireless smoke alarms, RFID tags, medical telemetry and remote environmental monitoring/control systems.

The LPRA applauds the release of additional UHF spectrum in Spain which will enable our members to add significant socioeconomic value in the country through the delivery of hitherto unavailable applications and services such as high scan rate RFID deployments, networked SRDs and support for the Internet of Things.

We are disappointed to read, however, that only the minimal amount of spectrum in the 870MHz band is proposed to be released. We are aware that the spectrum from 870-874MHz is currently unusded in Spain and so could and should be released in line with the technical parameters set out in ERC Rec 70-03. The spectrum has been given out in many European Union countries and is becoming a de facto region wide band.

We would be happy to elaborate these ideas if it were useful.

Regards