 |
BT
|
BT notes the publication of this document and that its intention is predominantly to outline how the matter of spectrum pricing is to be progressed. BT broadly supports the line being proposed. Particular points worth making at this stage are as follows:
The RA is rightly considering the phasing in of spectrum pricing to cover products previously excluded; e.g., Satellite and Broadcasting, and this has been noted in previous consultations. Nevertheless, the RA needs to be aware that clear and specific rules and, where appropriate, the agreed methodology for arriving at a ball park spectrum fee, need to made available in good time to allow those being required to pay such fees to plan and budget accordingly. The RA should take into account the fact that most organisations, of necessity, budget annually in advance, and while this is perhaps particularly important for small companies and new entrants, it is true for all. In an increasingly competitive market it is vital that the RA and indeed Government pay proper attention to the part they will be playing in these matters.
In respect of spectrum pricing for satellite earth stations, BT would advocate a process which encouraged teleport style stations for satellite antennae. Such stations allow for better environmental planning, while it is also easier for other operators to plan around such stations. In turn, this leads to greater potential spectral efficiency, both from the perspective of interference and better re-use of a scarce resource.
Finally, I would like to re-iterate a point which has been made both by BT and others in the past; that the introduction of spectrum pricing, or, in other cases, neglecting to introduce appropriate spectrum pricing, should not itself create new distortions in a converging marketplace. It is increasingly the case that, from a customer perspective, similar services will be taken using differing technologies. While it is appropriate for technologies utilising spectrum to bare relevant costs, spectrum pricing should be used as a tool to aid the market and not as a way of artificially determining "winning" technologies or favouring specific sectors of the market.
At this stage BT has nothing further to add but looks forward to participating fully in all future consultations. In particular consultations relating to satellite but also discussions relating to broadcasting spectrum originally scheduled for the end of 1999 but apparently delayed.
Yours Faithfully
Lorraine Flawn
Senior UK Licensing and Radio Policy Adviser
|
