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1. Introduction

  1. TelstraClear welcomes the opportunity to make a submission on the Ministry of Economic Development Discussion Paper Renewal of Management Rights for Cellular Services.
  2. As TelstraClear submitted in relation to the discussion paper Spectrum Allocations for Broadband Wireless Access, TelstraClear has an interest in obtaining Management Rights for 800 MHz and/or 900 MHz spectrum. This spectrum is very desirable for deployment of new networks because its non-line-of-site performance and reach means a given level of coverage can be achieved at much lower cost than higher frequencies. TelstraClear considers that the current holdings of Vodafone and Telecom far exceed their actual needs given New Zealand’s characteristics. This means that there is scope for reconfiguring these rights for use by new entrants as well as the incumbents.
  3. TelstraClear therefore recommends that when these rights expire they are not offered back to Telecom and Vodafone unchanged, as currently proposed. Instead, the Ministry should reconfigure these bands to enable national services to be offered by new entrants at these frequencies, as well as by the existing providers. Access to rights for new entrants should be allocated by auction.
  4. TelstraClear’s preliminary view1 is that 10 MHz paired is sufficient for a single cellular network operator in these bands. Sufficient spectrum in the 800 MHz and 900 MHz bands should be set aside for viable entry by at least two new entrants, ie at least one block of 10 MHz paired in both the 800 and 900 MHz bands. This spectrum should be Management Rights with a length of 20 years.

 

1TelstraClear wishes to undertake further analysis before committing to a “final” view of a recommended amount.
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Last updated 3 April 2008