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Te Weraiti (Bay of Plenty) TOPO50: BD36 558.87 097.54 WGS84: 175.9072617E 37.8237783S
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2. Introduction

  1. Vodafone welcomes the opportunity to provide further input in relation to the Ministry’s latest discussion paper on the cellular spectrum renewal process. Thank you also for the extension of time to make this submission.
  2. There is some commercially sensitive and confidential information in this submission relating to our future plans. As usual, we have enclosed this information in square brackets, and we request that this version of our submission be held on a "Commercial-in-confidence" basis by the Ministry.
  3. Disclosure of this information would prejudice Vodafone’s commercial interests. We trust that the Ministry will consider this issue carefully and withhold disclosure if there is an OIA request that covers this submission in the future. We also expect that, as usual, the Ministry will give us the opportunity to comment on any OIA request that covers this material, and provide sufficient time for Vodafone to take action to protect its position should that prove necessary.
  4. We cover a number of issues in this submission:
  • Section IV of this submission addresses the Ministry’s questions about future demand for 900 MHz spectrum.
  • In section V we discuss how we think the Ministry can maximise the value of spectrum to society and the important question of who is likely to be the highest value user.
  • Section VI looks at the arguments of TelstraClear and Econet for reallocation of 900 MHz spectrum, and points out the risks involved in the Ministry directly influencing the allocation, as opposed to leaving it to the normal process.
  • Section VII responds more specifically to some of the claims made by others, including rejecting the criticism that this process is really about short-term revenue raising.
  1. We refer generally to “900 MHz spectrum” in this submission because that is where our interest lies. But this phrase could easily be taken to include 800 MHz spectrum in most cases as well.
  2. Should you wish to further discuss any issues raised in this submission please contact Aarasaratnam Sathyendran (Sathy) or by phone 021 605 993, or Hayden Glass or by phone 021 689 176.
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Last updated 3 April 2008