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1. Summary

  1. Vodafone is pleased to have the opportunity to comment on the Ministry of Economic Development’s (MED) discussion paper titled “Renewal of Management Rights for Cellular Services”.
  2. In this submission we make three main points:
  • We support the use of the ODV method for valuation the Ministry is proposing. But it is important that the Ministry is aware that this is not a simple process. It is a matter of some complexity to build an optimal network model.
  • The parameters that are critical to the ODV methodology are technology, network traffic, network configuration, spectrum holding, discount rate and network costs.
  • Vodafone has already spent over $NZ2 Billion in capital expenditure to date. It has high level plans to roll out broadband network to most of Regional New Zealand. Access to 900MHz spectrum is critical to this network roll out.
  1. We also comment on other issues raised by the Ministry’s paper, including benchmarking, the future uses of the spectrum, and the renewal process.
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Last updated 3 April 2008