Submission No. 02: Econet Wireless New Zealand

Econet Wireless Newzealand LTD response to Ministry of Economic Development:

Renewal of management rightd for cellular services discussion paper

To Discuss Spectrum valuation and renewal without simultaneously discussing the allocation of that spectrum to achieve competitive outcomes, along with the interplay between spectrum and co location, roaming, and market behaviour, is dangerously narrow-focused, and extremely damaging to new entrants. The whole process illustrates government agencies playing into the hands of the incumbents

How can any new entrant in New Zealand in 2006 sensibly discuss spectrum valuation and renewal procedures, if they are not discussing allocation, co location, roaming, and market behaviour simultaneously?

Incumbents like Telecom and Vodafone want fragmented, diluted, convoluted rules, with weak, self regulatory structures with general confusion amongst government agencies

Its time to learn from shameful NZ policy disasters of the 1990s

"It’s time to understand the interplay between spectrum management, competition"