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Response to "Proposals For The Licensing Of Radio Spectrum At 28 GHz" - MLL Telecom |
We have requested and request again that serious consideration is given to allocating one licence in each of the areas to be licensed solely to be used on a carrier’s carrier basis. This will mean that the recipient of the licence concerned will sell capacity on the network to any operator who wishes to provide services to the end user, therefore ensuring that the market is provided with a wide range of services from a wide range of suppliers, instead of the spectrum being dominated by three operators, possibly on a totally self interest basis.
As we have stated in the past, we would prefer comparative selection as opposed to an auction. It is vital to the economy that the cost of providing circuits over BFWA is kept to a minimum in order to provide competitive services to end users. The auction process, whereas theoretically driven by market forces, may well be dominated by strategic players who wish, in turn, to create a PAN European network and also to pay more for licences in order to restrict competition as much as possible. In addition, the competing technologies to BFWA for access do not have licence fees to pay, nor are they faced with the risk of building a network based on new technology.
We agree that the amount of spectrum allocated to each licence should be 2 x 112MHz, although the recent discovery that there is an additional 2 x 56MHz we suggest should enable the Agency to allocate four licences per area with one licence of 2 x 112MHz reserved for a carrier’s carrier network.
Whereas as a carrier’s carrier we would prefer a national licence, should the eventual outcome be a number of regional licences, we suggest the number of regions is kept to a minimum.
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