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Response to "Proposals For The Licensing Of Radio Spectrum At 28 GHz" - Broadnet Europe |
Cliff Mason
Broadband Fixed Wireless
Section
Radiocommunications Agency
11B/21D Wyndham House
189 Marsh
Wall
London E14 9SX
19 May 2000
Dear Mr Mason
Broadband Fixed Wireless Access – Proposals for the Licensing of Radio Spectrum in the 28GHz Range
On behalf of Broadnet Europe sprl ("Broadnet"), I set out below their response to the above proposals as requested.
The Radiocommunications Agency are aware of the views of Broadnet on the question of an auction as opposed to comparative selection process. There is little if any evidence that consideration has been given to a comparative selection process which is favoured by Broadnet (and a significant majority of the operators as well as representatives of telecommunications users, most notably the Telecommunications Managers Association). The statement by the Chairman of the Broadband Fixed Wireless Access Consultative Group at its most recent meeting to the effect that the RA did not know how they would evaluate a beauty contest bears this out. Limited research amongst the RA’s fellow regulators would know doubt provide useful guidance.
Accordingly, we will be addressing our concerns on this point separately.
Broadnet approve the proposal for three licences (i.e. each of the licences having approximately 2 x 112 GHz of spectrum). We understand that some additional spectrum appears to have been made available and we would support a proposal either to make this available by way of a fourth licence or to expand the available spectrum in each of the three licences.
Broadnet would support the division of the UK into either the 9 or 12 regions referred to in the recent proposals made by KPMG. Scope of Services Whilst Broadnet consider that the spectrum should largely be made available for BFWA, most operators will need to attract early stage revenue by providing backhaul to mobile operators. This is the evidence from elsewhere in Europe. Accordingly, we do not consider that this should be prohibited. Therefore we would support an obligation on the successful licensee to utilise a significant percentage of the available spectrum for BFWA within a particular timescale to avoid provided the operator had flexibility in relation to the balance of their spectrum. This should ensure that the objectives of the Minster is met and prevent the mobile operators bidding for the spectrum with the sole or principal purpose of using it for backhaul.
We consider that the primary factor preventing the licence process satisfying the stated competition objectives is the use of an auction. Proposals made by the RA to date, which suggest a UMTS style auction, indicate that the process envisaged will favour the deepest pockets (i.e. BT and the cable operators) and ignore the development of competition and innovative services.
We consider a "Use it or Lose" condition more appropriate in the context of a comparative selection process. In this case any such condition needs to be realistic in the context of a new entrant. However, there is very little evidence that this type of retributory device has been effective in the past (e.g. the cable operators).
Yours sincerely
Rosemary Jackson
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