3. Process and terms of renewal

Issue 3.1

Do you have any comments on the proposed timing of the renewal offers?
What would be a reasonable period for incumbent right holders to consider whether to accept or reject the renewal offers? Why?

Econet only provides an answer to this question on the understanding that it maintains the whole process under which these questions are asked is flawed and inadequate to achieve Government objectives.
 

Issue 3.2

Do you have any comments on the terms of offer?

Econet does not provide an answer to this question on the understanding that it maintains the whole process under which these questions are asked is flawed and inadequate to achieve Government objectives.
 

Issue 3.3

Do you have any comments on the terms of settlement?
Would you prefer an early on-off payment or annualised payments – why?
What should be the latest date for settlement? Why?
What should be the penalty for failure to settle on time – why?

Econet only provides an answer to this question on the understanding that it maintains the whole process under which these questions are asked is flawed and inadequate to achieve Government objectives.

Econet believes that part payment should be acceptable with rollout requirements matched to payment dates with appropriate penalties (this is for new entrants).
For incumbents there should be upfront one off payments, as they have no network to build.

The Ministry of Economic Development desperately need to work with the Commerce Commission to align policy and align the 900 spectrum with that of WCDMA spectrum holders.

THE MED is repeating the mistakes of the 2000 spectrum auctions they are making spectrum decisions with no realistic impact of the other Commerce Commission decisions re co location, behaviour, or other such matters.
 

Issue 3.4

Do you have any comments on allowing purchasers to assign and transfer contractual rights and obligations prior to settlement?

Econet only provides an answer to this question on the understanding that it maintains the whole process under which these questions are asked is flawed and inadequate to achieve Government objectives.
 

Issue 3.5

Do you have any other comments on the process and terms of renewal?

Econet only provides an answer to this question on the understanding that it maintains the whole process under which these questions are asked is flawed and inadequate to achieve Government objectives.

The Ministry of Economic Development has failed on the following issues:

1. to administer spectrum in a competitive manner
2. to conduct a sensible auction which was not gamed by Vodafone and Telecom
3. to prevent a bottleneck in 900MHz spectrum
4. to prevent hoarding of spectrum that prevents new entry
5. to interface with other regulatory bodies and understand interplay with other services
6. to ask third party consultants such as Price Waterhouse Coopers to consult with new entrants
7. to review similar countries to New Zealand, specifically Ireland, Denmark, and the Congo