Tele2 (UK) UK - Response to the Consultation Document: 3.4 and 10 GHz: Scenarios For Spectrum Packaging and Delivery

Tele2 is pleased to submit this response to the Radiocommunications Agency on the consultative document issued in December 2000 concerning its inquiry into the various scenarios presented for 3.4 & 10 GHz Spectrum Packaging and Delivery. This response follows the structure of the consultation document.

Spectrum Options

Allocation of the available 3.4 & 10 GHz spectrum should be considered separately as we believe there is little synergistic benefit as the markets to be served and equipment required by the respective allocations are significantly different.

Tele2 believes that the RA should allocate the limited spectrum available based on the Scenario 3 'Hot Spot' option presented in the Consultation document. This method has the advantage of ensuring the spectrum is allocated in geographic areas where it is most needed, deriving maximum benefit from the limited spectrum available.

Within any geographic area we believe that the available spectrum can only support a single operator in each of the available bands. Moreover, Tele2 do not believe that the 2 x 17MHz of spectrum available at 3.4GHz is sufficient to permit the cost-effective delivery of profitable services in this band unless combined with additional adjacent spectrum.

We do not consider delay in the allocation of the available spectrum to be a realistic alternative as we are strongly of the opinion that there is a limited time-window available for the delivery of competitive wideband and broadband wireless services in relatively developed markets, such as the United Kingdom.

Our experience from the UK and in other markets, means that we are convinced of the potential and of the significant consumer and national advantages that wireless competition provides in this area.

Award Process

We strongly hold the view that the most appropriate award mechanism for licences to use this spectrum is a comparative selection process.

Tele2 would support the imposition of realistic 'use it or loose it' conditions incorporated within the licence conditions.

Tele2 believes payment for spectrum should be on the basis of realistic annual fees, phased in to allow an operator to become established. We also believe that the fee mechanism should contain a ratchet rebate to compensate the operator for the provision of services to less attractive geographic areas.