1. Introduction

TelstraClear welcomes the opportunity to make a submission on the Ministry of Economic Development Discussion Paper Renewal of Management Rights for Cellular Services.
As outlined in our previous submission,¹ TelstraClear’s primary interest in relation to the 800 MHz and 900 MHz Management rights is obtaining Management Rights to spectrum in one and/or the other of these bands. As a result, the focus of this cross submission is those aspects of other parties’ submissions that seek to raise technical reasons as to why it is inappropriate to reallocate some of the 800 MHz and/or 900 MHz spectrum to new entrants. In summary, the submissions from other parties’ have provided no information to change TelstraClear’s view that sufficient spectrum is available for spectrum to be allocated to new entrants in both the 800 and 900 MHz bands.
While this submission does not focus on other aspects of the Discussion Paper, notably the basis for setting the renewal price and the terms of the renewal, TelstraClear does not consider that the submissions made by other parties on these matters in any way invalidates TelstraClear’s previous submissions. TelstraClear therefore considers that its original submissions on these matters stand.

¹TelstraClear, Submission on Ministry of Economic Development Discussion Paper Renewal of Management Rights for Cellular Services, 11 September 2006.

Last updated 3 April 2008