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Peter Hayward
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Dear Sir:
I would like to comment on the points raised in your consultation document, "3.4 Fixed Wireless Access Spectrum".
"Proposal to change the original basis ... the provisioning of voice services."
I am of the opinion that advancements in compression techniques and emerging technologies lend themselves to voice services as well as the higher data rate speeds than the residential or SOHO markets have witnessed to-date. I would recommend that emerging yet verifiable technology and the operators' business plan dictate the suite of services (not just voice) to be offered in this spectrum band.
"The Government would welcome ... national, regional or sub-regional basis."
I would agree with the assessment that a single license is likely to provide maximum benefit, however I would suggest that regardless of the governments ultimate decision that it give serious consideration to an alternative licensing fee structure. In most if not all global regulatory jurisdictions licenses are awarded either by auction or a competitive review process.
I would suggest that there is a third option, that licensing fees be based on a scalable revenue sharing formula with a successful applicant over the term of the license. This has the effect of expanding the 'beauty contest' terms of reference, ensuring effective business plan modeling, the provisioning of proven technologies, lower cost of entry for a larger number of potential applicant as well as to ensure the governments commitment to 'high quality modern communications' with maximum financial benefit to the tax payer.
Sincerely,
Peter Hayward
| 7 December 1999 |
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