Radio spectrum is the key raw material for our mobile business. The rapid take-up mobile broadband means that mobile network capacity needs to be expanded constantly. Spectrum awards are also a key factor in the mobile market, affecting the level of investment and competition.
We believe that:
Given the importance of spectrum to the mobile industry and the wider economy, spectrum policy should be designed and implemented through thorough, transparent and consultative processes where policymakers set out their evidence-based proposals and stakeholders are allowed to review, comment and provide alternative evidence.
Well designed and run spectrum auctions are the most efficient way to allocate new spectrum, and are most effective when multiple bands are auctioned at the same time.
In setting auction reserve prices, authorities should seek to recover only administration costs and allow for price discovery through the auction. They should not allow prices to be influenced by national fiscal ambitions.
Early, fair and cost-effective spectrum allocation will give companies and their shareholders the confidence to invest in new mobile internet services, which will underpin future economic growth in the countries in which we operate.
Spectrum licences should be perpetual, or easily renewed well in advance of expiry at moderate cost. Spectrum trading can also help to ensure spectrum can be acquired by those who attach the most value to it.
Licence exempt or shared spectrum (e.g. wifi) can be a useful supplement to licensed spectrum bands, but is not a substitute. Where a regulator has the choice, licensing spectrum on a dedicated basis will be more efficient than shared access.
To ensure a fair market, equality between spectrum users is crucial - in terms of pricing and access, and between existing licensees and potential entrants. Ring-fencing, or reserving, spectrum for a new entrant puts existing licensees at a competitive disadvantage and results in a distorted and inefficient market.
Consumers are best served by multiple network operators competing freely in a market. This can be enhanced through voluntary tower or network sharing, which improve the economics of the sector, especially when it comes to deploying in more economically-challenging areas. A balance should be struck between the improvement of the economics of the sector and maintaining competition. As recent Vodafone sharing agreements have shown, it is possible to strike such a balance. Extending coverage and digital inclusion are important social objectives, which can be partly achieved by including appropriate coverage obligations in licences, while ensuring that spectrum fees are set accordingly, and that coverage in uneconomic areas is specifically supported through collaborative schemes where MNOs and State together provide adequate funding.
Additionally, when examining merger proposals, competition authorities should consider the risk of spectrum consolidation adversely impacting competition.