Value chain · CLM-0876
In plain terms
A common way to measure how long spectrum takes to reach users is to count the years from an international conference to the national licences. For the UK's 2018 3.4 GHz award that count may start from the wrong conference: the 2015 conference added no new footnote identifying that band for the UK's region; it amended an existing footnote that, as amended, identifies it, and the 2015 text does not show whether the identification itself was older. What these conferences do is identify bands for use, not for study.
The claim as recorded
The United Kingdom's 2018 award of 3410-3480 MHz and 3500-3580 MHz is NOT shown by the WRC-15 Final Acts to be an instance of a WRC-15 IMT identification leading to national licensing, because those Final Acts give no sign that WRC-15 identified that band in Region 1. In the WRC-15 Final Acts the footnote covering 3 400-3 600 MHz in Region 1, 5.430A, carries the revision marker MOD, so the FOOTNOTE pre-dates that conference. WRC-15's own ADD footnotes are 5.429B, 5.429D and 5.429F, covering 3 300-3 400 MHz, and 5.431B, which does cover 3 400-3 600 MHz but only IN REGION 2, while the United Kingdom is in Region 1. That pairing is the argument, and it is stronger than the marker alone: where WRC-15 created a new identification in this band it gave it a new ADD footnote, so a Region 1 identification created at the same conference would be expected to carry one too, and none does. Separately, the Final Acts identify bands for International Mobile Telecommunications and contain the phrase "for IMT study" zero times, so a WRC identification is not a study step - though that null is corroboration rather than the ground, which is 5.430A's own positive text. Ofcom's publication of the auction results under regulation 111 of the Wireless Telegraphy (Licence Award) Regulations 2018, dated 13 April 2018, states that the licences for that band were granted, so they were granted on or before that date; by our arithmetic that is at most about 2.4 years after WRC-15 closed on 27 November 2015 - but measured from a conference that the Final Acts do not show identified the band.
Evidence behind this: T1 as normative instruments: both documents are cited FOR THEIR OWN REQUIREMENT and for the revision markers the conference itself applied, not for any assertion about the world. Neither measures nor models anything.
Scope and limits
THIS RECORD FALSIFIES A PAIRING. IT DOES NOT SUPPLY A REPLACEMENT INTERVAL, and nothing here should be read as one. Three things it does NOT establish. First, which conference originally added 5.430A: the held document shows only that it pre-dates WRC-15, and no earlier conference's Final Acts are cited, so no earlier conference is asserted. Nor, and this is finer, does MOD establish that the IMT IDENTIFICATION inside 5.430A pre-dates WRC-15 - only that the FOOTNOTE does. A MOD is equally consistent with a conference amending an existing footnote so as to insert an identification, and the Final Acts print modified provisions in full with no change bars, so the held document cannot separate the two readings. The Region 2 comparison above is an argument from the instrument's own drafting practice, and it is an inference rather than a reading. Second, the zero count of "for IMT study" is NOT load-bearing and must not be read as the Final Acts never associating IMT with study: the instrument has 19 places where IMT falls within sixty characters of "stud", including "that ITU-R studies" and "will need further study". What carries the point is 5.430A's own text, which identifies the band for IMT outright. Third, whether the lag from identification to licensing is long or short in general - a single falsified example is not a measurement of the population.
What it assumes
That the ADD, MOD and SUP markers in the Final Acts carry their standard ITU meaning of a provision added, amended or suppressed by the conference that published them.
Where it comes from
: the marker line immediately preceding each footnote reads ADD for 5.429B, 5.429D, 5.429F and 5.431B, and MOD for 5.430A, 5.432B and 5.433A. The allocation table entry at 3 300-3 400 MHz lists 5.429B; 5.430A opens "The allocation of the frequency band 3 400-3 600 MHz to the mobile, except aeronautical mobile, service is subject to agreement obtained under No. 9.21. This frequency band is identified for International Mobile Telecommunications (IMT)." A whole-document count of the string "for IMT study" returns zero. SRC-433 was made 24 January 2018 and its Schedule tables the 3.4 GHz lots from 3410 MHz in 5 MHz steps. SRC-436 opens "The names of the winning bidders to whom licences were granted are" and lists four companies, tabling 3410-3460 MHz, 3460-3480 MHz, 3500-3540 MHz, 2350-2390 MHz and 3540-3580 MHz against them; it is signed "Ofcom" and dated "13 April 2018" on its face and says the licences "were granted", so it evidences a grant on or before that date and is not itself a licence. SRC-437 gives the principal stage, CreationDate 2018-04-04, published 05/04/18.
Related records
- Answers question
- QST-001 not published in this release
- Contradicts
- CLM-0553 not published in this release
- Supersedes
- CLM-0553 not published in this release
Cite this
energyaperture.com/c/clm-0876
CLM-0876, Energy Aperture, as of 2026-09.