Contents

Table of contents

1. Summary.
   1. Demand for 900 MHz spectrum is very uncertain 
   2. The Ministry is rightly focussing on how to maximise the value of this spectrum to society 
   3.   There are dangers in the Ministry trying to influence the allocation of spectrum directly
2. Introduction
3. Future demand for 900 MHz spectrum

   1. This is not really a question of "requirements"

   2. Future demand for 900 MHz spectrum is highly uncertain
4. The focus should be on how to maximise the value of this spectrum to New Zealand
   1. Vodafone is likely to be the highest value user of this spectrum
5. There are dangers in the MED directly influencing spectrum allocation
   1. A market management approach is legally questionable
   2. 900 MHz spectrum is not required for a metro mobile build
   3. We question whether Econet and TelstraClear would actually use this spectrum if they had it
6. Responses to claims made by others
   1. The Ministry’s work is not about short-term revenue raising
   2. Vodafone’s GSM spectrum ownership is not a "policy failure"
   3. Our roaming and co-location pricing is reasonable
   4. Vodafone should not be forbidden to bid at any auction
   5. 20 years is an appropriate renewal timeframe
7. Conclusions