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3. Full listing of TelstraClear’s recommendations

  1. The following recommendations are made in this Submission, and repeated here in full for the convenience of the reader.
  2. TelstraClear recommends that:
    1. The Ministry note that because of the deployment cost advantages of 800 and 900 MHz spectrum, the lack of access to this spectrum by new entrants constitutes a barrier to entry.
    2. When the Management rights to the 800 and 900 MHz spectrum 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;
    3. The Ministry note that TelstraClear’s preliminary view9 is that 10 MHz paired is sufficient for a single operator;
    4. Sufficient spectrum in the 800 MHz and 900 MHz bands is 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;
    5. If some of this spectrum is reallocated to new entrants that it be Management Rights with a length of 20 years;
    6. In the event that no reallocation is made to new entrants, TelstraClear recommends a renewal period of significantly less than 20 years, say 8 years;
    7. The Ministry:
      1. take steps to ensure that it does not seek advice for a matter such as the renewal of a price from advisors of parties directly affected by the advice in future; and
      2. commission a further review of the advice on renewal pricing from an independent advisor that has no professional relationship with either Vodafone or Telecom;
    8. The renewal price for the existing rightholders should be no less than the price obtained for any 800 or 900 MHz spectrum reallocated to new entrants by auction; and
    9. The increment used for calculating the renewal price should be the quantity of spectrum subject to the renewal offer.

 

9TelstraClear wishes to undertake further analysis before committing to a “final” view of a recommended amount. 

 

 

 

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Last updated 3 April 2008