Please find attached the Institution of Engineering and Technology s written submission in the form requested.

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1 The Institution of Engineering and Technology Michael Faraday House Six Hills Way, Stevenage Hertfordshire, SG1 2AY United Kingdom T +44 (0) F +44 (0) Ref: S1015/ab Rail Digital Services 4th Floor, Zone Great Minster House 33 Horseferry Road London SW1P 4DR E: RailDigitalServices@railexecutive.gsi.gov.uk 10 July 2015 Re: Improving mobile communications to UK rail passengers Please find attached the Institution of Engineering and Technology s written submission in the form requested. About the IET The IET is one of the world s leading professional societies for the engineering and technology community, with more than 160,000 members in 127 countries and offices in Europe, North America and Asia-Pacific. The IET provides a global knowledge network to facilitate the exchange of ideas and promote the positive role of science, engineering and technology in the world. This submission has been approved on behalf of the IET s Board of Trustees, and takes into account the views of IET Members under the guidance of the IET s Communications Policy Panel and should not be taken as representing in any way the individual views of the organisations for which the panel members work. The IET is happy to discuss these points with the Ministers or Officials. Yours sincerely, Paul Davies Head of Policy Tel: pdavies@theiet.org Enc. Page 1 of 7

2 DfT, DCMS Consultation Improving mobile communications to UK rail passengers Consultation questions Government intervention A.1 Why is there not already good mobile coverage on rail? The UK mobile network is commercially driven and hence has focussed heavily on serving areas of high potential use (the urban areas) this means that rural areas and areas through which many railway lines run are under served. The UK Government's recent focus on ending the digital divide and promoting access to better digital services in rural areas has again, focussed on settlements in rural areas and so missed out the unpopulated areas that many railway lines pass through. A.2 Is Government intervention necessary and, if so, how is it best targeted? The UK rail network is well served with private fibre and wireless communications along rail routes, used for private communications. This need for communications, either though fibre or private radio systems, (also being rolled out across the network by Network Rail), will grow as the UK moves to implementing ERTMS. A UK wide study of available spare capacity within these networks and the practicality of using this for public mobile voice and data should be undertaken. This would allow NR's network to extend mobile coverage along the corridors that the railway routes follow. This could take the form of agreements to lease capacity to the mobile network providers (inefficient), or a means by which NR provides connectivity for users through itself, with gateways provided into the mobile networks systems. Technical Solutions. A.3 What would be the most effective strategy for meeting the mobile connectivity needs of rail passengers? On-train technical options (with reference to numbered sections in consultation document) 1. On -train WiFi this is a good solution because it supports aggregation of different bearers, i.e. aggregating multiple MNOs, local infill. Most operators are now offering native dialling/voice by WiFi and this may even render Femtocell requirements obsolete. WiFi uses Ethernet backbone, most trains now being fitted with this backbone. 2. D-OBR already fitted Class 220, 221, 222 Voyager & Meridian and Class 390. This is because these trains are fitted with K glass windows or have small effective apertures. Whilst D-OBR does improve communications, the benefit is small on trains with large clear windows. 3. Femtocells It is currently technically complex getting multi-mno configurations. A large space is required and equipment is currently not well suited to rolling stock. WiFi voice calls (native dialler) are now an alternative and may be easier for users than Skype and other similar services (which also use WiFi) as the handset will automatically switch to WiFi. As yet not all MNO s Page 2 of 7

3 are supporting the service but it is anticipated that most will as new handsets are released. 4. Passive repeaters - Not sure how this would work. Off-train technical options (with reference to numbered sections in consultation document) 5. The IET supports the concept but implementation would require railway infrastructure access. Perhaps site sharing of mast/reb etc. could be coordinated with Network Rail. Note: government announced sell off of NRT, perhaps an MNO will acquire railway assets?? 6. Yes, as above. Need to manage GSM-R co-existence, do not use 800MHz LTE. 7. The IET supports the concept although the Quicksilver initiative was flawed due to there being only a single MNO. Ofcom intervention is required to encourage MNOs to do more for the rail sector. 8. It is not clear by who or how the costs would be met. Currently passengers expect Mobile voice / data for free as part of their existing plans. 9. Currently it is not clear what costs would be incurred in addition to the issue of low data rates and latency. Complexity Challenge Essentially the introduction of an additional technology - be it Femto or WiFi - which will be expected to interface seamlessly with current 3G/4G mobile networks (standard customer expectation) will prove a challenge. There is currently a major debate in the industry on this area, particularly between WiFi and LTE. By definition the train scenario centers around the more complex dynamic environment, which differs from the classic WiFi/Femto-to-Macro hotspot handoff which is from a static location hence much simpler use cases. Many of these issues plus other requirements specific to rail will require new feature development, a likely architecture rework and new interworking between 3 rd parties, etc. Any consideration must be subject to scaling as there are hundreds of passengers in an average train, and therefore additional allowances must be made. Femto/WiFi services to date can handle fewer concurrent sessions than mobile so would only be a complement until this is resolved. A.4 What would be the costs of delivering each of the technical solutions and what would the passenger experience be in each case? A.5 Are there technical solutions which have not been considered? If so, what are the benefits over other options, and what would be the associated costs? A.6 What technologies and solutions have been successfully used in other countries or industries to address similar problems? Page 3 of 7

4 A.7 Do you foresee any particular safety risks to the railway associated with a particular type of technical solution or strategy? Benefits A.8 Are you supportive of initiatives to improve mobile coverage on rail, and do you believe there is an appetite for this from the public? Persistent and stable connectivity for rail users is essential, both in offering service to business users, and one that can differentiate rail from other modes such as road and air, for private users. It is important to recognise that in future private users will not only want connectivity for leisure uses such as web surfing and social media, but also to manage their journey, plan and book onward travel, use 'ApplePay' type systems, etc.. In order that rail travel can continue to be seen as relevant and attractive, it needs to address these needs for 'always on' connections. A.9 Are there any other parties or services, both Government or otherwise, that could benefit from the improvements to mobile communications on the rail network? The availability of 'always on' connectivity on rail will aid the development of door-todoor journey planning, which in turn will be a major factor in promoting public transport use versus car use. As systems that allow users to get accurate real-time information are developed, and as it becomes possible for users to plan and book onward travel (taxi, bus, cycle hire, etc. ) on-line, so the ability to do this reliably whilst travelling by rail will become increasingly important. A.10 Are there other quantifiable benefits of introducing improved mobile coverage on trains, for instance by facilitating work for business travellers? Better ability to work for business travellers is an obvious example, although the drive for ever shorter journey times actually works against this, but as above, there are benefits around wider use of connected devices for purchases, travel planning and real time information that might actually be more relevant in the future. It is highly likely that within a short number years, the idea of 'black spots' with no mobile data coverage will increasingly appear an anathema to large parts of the population and the expectation of always on data coverage will grow. In order for rail to continue to appear an attractive option, this issue has to be addressed. A.11 To what extent will improved mobile communications make rail a more attractive travel option? See above... A.12 Are there any other benefits associated with this work? Page 4 of 7

5 Delivery Strategy A.13 Are the requirements of passengers consistent throughout the UK? If not, where should investment be targeted? Are there areas which would benefit more from voice rather than data services, and vice versa? Public investment should be concentrated at the more remote areas. As the appetite for mobile data grows, and the effects of the Governments work on digital divide comes to fruition, it is likely that gaps in coverage in the more populous areas of the country will be filled in as a commercial activity by the mobile networks. The more remote and sparsely populated areas that many rail routes operate through will continue to be less attractive in commercial terms and so should be the focus on any specific 'rail connectivity' investment. A.14 How do the requirements of passengers vary by journey type e.g. commuter, business, leisure, etc.? It is probably not worth trying to draw distinctions here. As data usage evolves from specific needs (reading s, web surfing, etc.) to a more general expectation of always on coverage, so the distinctions between uses will become less clear. It is probably safer to assume that in the future an expectation of permanent, reliable mobile data will become viewed as a necessity for all manner of aspects of daily life we currently cannot predict. It is important to bear in mind that any project to provide widespread connectivity on the rail network would not be doing so to address the needs of today, but to ensure rail is well placed to serve the needs to tomorrow. We cannot say what these uses may be, but it is clear from the direction of travel of technology that reliable, pervasive and fast data connections will be central. A.15 Who are the key stakeholders who should be directly involved in this work and how can these organisations work together to aid delivery? A.16 What risks are there in pursuing this initiative? There are risks around ensuring appropriate technologies are used and suitable business models employed and to ensure any solution is suitably future proofed. There is also a need to ensure public investment is not used in areas where commercial development could reasonably be expected to invest, or that public investment duplicates private sector investment. Behavioural insights A.17 What does a good passenger experience look like? Page 5 of 7

6 A.18 What devices can we expect the majority of rail passengers to use to communicate while on the train in the next 2, 5 or 10 years? As long as the connectivity is present to allow users to use their devices to a standard at least as good as in the major urban areas, why try to predict what end user's devices will be? A.19 What capabilities of mobile devices will passengers seek to use while travelling? What will be the most important and frequently used functions by passengers? As above, it is probably not the case that the uses we see people engaged in today will be the ones we see tomorrow. Although there will always be a need for mobile working, access to , social media etc., there will be increasing dependence on mobile devices for a wide range of aspects of daily life and a move away from using devices for individual 'tasks' to using them seamlessly and generally as part of our daily lives. A.20 Is the ability to make and receive phone calls or being able to access the Internet with high-speed data more important to passengers? Data,in the broad sense, as with all handset use should not be different for rail travellers compared with fixed communications. A.21 Will consumers prefer to access the Internet using Wi-Fi or 4G/LTE in future? If both are available, what is the preferred method of connection? There is an argument that 4G will render public Wi-Fi provision obsolete. Assuming the networks are able to provide 4G in an affordable manner, why would users want to search out and connect to location specific Wi-Fi networks when their standard data package provides similar performance automatically? 4G access everywhere would be a better way of delivering seamless connection, unless future technologies allow for seamless roaming between Wi-Fi networks. However, as a matter of fact, present systems increasingly assume Wi-Fi for high-demand applications such as video or system/app updates. This issue will need addressing but is really a handset OS matter. A.22 How do passengers' preference towards using Wi-Fi change with the requirement of needing to register and log-in? As above, this is a major impediment, but it is increasingly unacceptable to charge for WiFi anywhere as many rail operators do not anyway. The requirement to register (or repeatedly accept T&Cs) may also become impractical unless this can be userunaware on handset OS s. A.23 In 5 years, what would the data throughput to a train need to be to ensure that all passengers of that train are satisfied with performance? Page 6 of 7

7 Commercial arrangements A.24 How can we ensure that all relevant parties have the right commercial incentives to support successful delivery of a solution? A.25 What sources of private funding could be used in this initiative? A.26 What existing infrastructure could be shared or used to improve coverage, and what commercial arrangements could be established to encourage this? A.27 What arrangements could be made for the integration of an alternative service provider or aggregation network with mobile network operators? A.28 Do you have suggestions for any innovative commercial options to support this initiative? End of response Page 7 of 7