Cross submission No. 01: Telecom New Zealand Limited

Executive summary

The Ministry has invited cross-submissions on use of the 850/900 MHz spectrum, specifically:

•  The optimal quantity of spectrum required by current management right holders between 2011-2031; and
• The optimal quantity of 800 MHz or 900 MHz spectrum that a new entrant would require in these bands to operate a nationwide cellular network over the period 2011-2031.

This paper is Telecom’s cross submission. In summary, in this paper we:

1. Provide background on the evolution of mobile technologies, concluding that 20MHz is likely to be the
carrier bandwidth for future mobile technologies e.g. IMT Advanced.

2. Outline the issues Telecom would face if unable to renew all of its current 850MHz spectrum holdings:

• Impact on CDMA

1. We discuss spectrum holding in the US and Europe and the fact that Telecom does not have access to the 1900 MHz band, which restricts the evolution path for its CDMA network;
2. We highlight the fact any reduction in bandwidth would limit Telecom’s ability to offer high speed value added services for our customers, which has a flow on effect on our customers;
3. By contrast GSM/UMTS operators in NZ and internationally have companion bands (900MHz, 1800MHz and 2.1GHz) which they can use to offer high bandwidth services. These bands also allow alternative means for managing bandwidth/capacity constraints that may occur if GSM operators’ holdings are reduced;
4. We identify two potential band plans for the 850MHz spectrum to show our planned utilisation of all 20MHz of our existing spectrum holding.

• Technical: Issues relating to guardbands and inter-operability issues – in particular the fact that dividing the 850MHz band may necessitate additional guard bands, further reducing the amount of usable spectrum.

3. We also comment on the options available to a new entrant. We consider there is not sufficient spare bandwidth available in the 850MHz spectrum band, but that there are other options available to a new entrant, including the ability to negotiate roaming or wholesale re-sale arrangements.