Intel

Before the Ministry of Economic Development, Radio Spectrum Policy and Planning, Energy and Communication Branch

COMMENTS OF INTEL CORPORATION In response to the discussion paper: Radio Frequency Auction: 2.3 and 2.5 GHz Bands

September 14th, 2007

Intel Corporation commends the Ministry of Economic Development, Radio Spectrum Policy and Planning, Energy and Communications Branch for continuing the initiative to create a spectrum policy and planning framework which will foster the adoption and growth of new wireless technologies such as WiMAX, to the benefits of New Zealand and global citizens. Intel Corporation is the world’s largest semiconductor manufacturer and a leader in technical innovation. Intel is also a leading manufacturer of communications and networking chips and equipment.

As stated previously¹ , Intel agrees with the policy to assign the spectrum in a technology neutral manner and to enable spectrum trading to ensure “flexible and efficient use”. This approach will enable consumers to reap the benefits of the rapid technological innovations that are occurring in the communications industry and will promote the economic and social benefits that broadband can deliver. In the bands most promising for global harmonization, Intel recommends that regulators allocate sufficient spectrum for Broadband Wireless Access (BWA) and allot flexible large bandwidth licenses. Then licensees, in response to market forces, will be free to achieve the benefits of innovation and economies of scale and interoperability through the adoption of international standards. They will have an incentive to converge on one technology where the benefits of convergence are greater or adopt a new technology where those benefits are greater. We also agree that an auction format is preferred when demand exceeds supply, and that it is appropriate to assign both the 2.3GHz and 2.5 GHz bands sooner rather than later.

Intel agrees with the recent cabinet decisions to assign the two spectrum bands and supports many of the ideas discussed in this consultation and welcomes the opportunity to respond. Please find enclosed our answers to select questions in this consultation.

Respectfully Submitted,
John Roman
Intel Corporation
2111 N.E. 25th Ave
Hillsboro, Oregon 97124
503-712-9289

^{1.Comments of Intel Corporation in response to the consultations “Spectrum Allocations for Broadband Wireless Access”, July 2006, and “The Radio Frequency Auction No. 9: Overview”, 2007.}

ANSWERS TO ISSUES FOR COMMENT

Question 1: Considerations Relating to Lot Design

Do you agree with the considerations discussed in this chapter concerning lot design?
Please provide any comments under the following headings:
a. Expected technical developments and likely demand.
b. Size and location of the managed spectrum park or parks, including:

Whether two MSPs should be provided for in the 2.5 GHz band in order to allow for FDD (including CMAR) uses.

c. Acquisition limits.
d. Technical issues such as:

• accommodating TDD and FDD technologies;
• Guard-bands;
• Other.
  

e. Preferences regarding auction type.
f. Other.

Answer:

Intel generally agrees with the considerations for lot design; however we have some specific comments. We agree that the band should be made flexible, barring technical constraints (for example too little spectrum to assign paired bands), to allow for FDD as well as TDD assignments. We would like to note that TDD operation should be also allowed in paired bands.

Regarding guard bands, we agree with the Ministry preference, that while provisions for extra spectrum are planned for a potential guard band, the spectrum rights holders should take responsibility for managing interference issues, and acquire sufficient spectrum to be able to do so. Additionally we believe that operators also should be encouraged to coordinate in the construction of their networks to minimize interference, and that ultimately the extra spectrum be allowed to be used for transmission purposed provided it is not needed to address interference. This should be reflected in the acquisition limits. In terms of the current proposed limits, we believe that while 5 MHz is likely sufficient as a maximum for a guard channel if needed, 30 MHz of spectrum for BWA services is considered a minimum needed to provide broadband services. We encourage the Ministry to consider allowing operators to obtain more than 30 (35 with provisional guard channel) MHz of spectrum if required for their service model.

Question 2: Proposed Lot Design

Do you prefer Option A, B or C for the lot design? Please explain why. If you prefer Option C is your preference for C(i) or C(ii)? Why? If there is an alternative option you prefer please specify it and explain why it would be preferable.

Answer:

Intel prefers Option A for the 2.3 GHz band. For the 2.5 GHz band, we support an approach similar to what is being proposed by OFCOM in the United Kingdom. Ofcom has proposed a two-tier auction to determine the ratio of paired versus contiguous bands in the 2.5 GHz band. We believe this approach will optimize the banding based on the market demand. We also note that any paired bands determined through the process be separated by a 120 MHz duplex gap to minimize product variants. In addition, as previously stated, we believe that irrespective of the final banding, TDD should also be allowed to be used in any paired bands.

Question 3: Māori Interests

What provision should be made regarding allocation of spectrum in the 2.3 GHz and 2.5 GHz bands for use by Māori (i.e. Māori service providers)?

What provision should be made regarding allocation of spectrum in the 2.3 GHz and 2.5 GHz bands for use for Māori (i.e. Māori as service consumers, or in the interests of Māori language and culture)?

What terms and conditions should apply to this spectrum?

Answer:

Intel has no comment.

Question 4: Eligibility to Bid

Do you agree that no restrictions should be placed on the eligibility of parties to bid for lots?

Answer:

Yes

Question 5: Duration of Acquisition Limits

Do you consider the expiry of acquisition limits 1 year before the (December) use or lose date to be satisfactory? Do you prefer a different acquisition limit date? Please explain reasons for your view? Do you have any other comments on the time for acquisition limits
to expire?

Answer:

Generally we agree that there beneficial and detrimental considerations and that a balance must be struck in order to optimize the approach. While it is difficult to comment specifically if a 1 year duration prior to the use or lose date is reached would be sufficient, we would like to point out that a 30 MHz spectrum assignment is considered a minimum amount today and due to future projected broadband demands, we encourage a regimen that facilitates the ability for licensees to acquire additional spectrum as demand permits, in a timely fashion.

Question 6: Use or Lose Provisions

Do you prefer a date of December 2012, 2014, or 2106, for applying the use or lose test? If not what alternative date would you prefer to implement the Cabinet decisions on use or lose? Please explain. Do you prefer Option A or Option B or some other option regarding the test for ‘use’? If you do not agree with the proposals, what ‘use or lose’ provisions do you propose? Should financial consequences result from not using rights, either in addition or as an alternative to loss? How should the amount of any financial consequence be calculated?

Answer:

Intel has no comment.

Question 7: Settlement

Do you agree with the proposed settlement terms (30 days following completion of the auction)? If not, what other factors do you see as relevant?

Answer

Intel has no comment.

Question 8: Managed Spectrum Parks: Proposed Allocation Procedures and Usage Rules

a. Do you agree with the suggested eligibility criteria for access to a MSP?
b. Do you agree with the suggested core technical and usage requirement?
c. Of the three options outlined above, which is your preferred method for implementing a MSP? Why?
d. Are there better alternatives or variations on these implementation options?
e. What incentives for gaming arise under the various options, and what measures, if any, could be taken to minimize such incentives?
f. What fees or resource charges should be levied (particularly for your preferred option)?

Answer:

Intel has no comment.

Question 9: Transition Plan for the 2.5 GHz Band

Do you have any comments on the proposed transition plan for existing licences in the 2.5 GHz band?

Answer:

In general we agree that the transition process should be designed to encourage a timely transition to new services, as well as ensure protection to current and future users during the transition period.