DOC

COVER SHEET FOR RESPONSE TO NCA PUBLIC CONSULTATION ON THE

By Calvin Perry,2014-06-16 23:58
9 views 0
COVER SHEET FOR RESPONSE TO NCA PUBLIC CONSULTATION ON THE ...

    COVER SHEET FOR RESPONSE TO NCA PUBLIC CONSULTATION ON

    THE SELECTION AND AWARD PROCEDURE FOR LICENSES IN

    THE 2.500GHz 2.690GHz BAND BASIC DETAILS

    Name of respondent:

    Eben Albertyn (Chief Technical Officer)

    Representing (self or organisation/s):

    Scancom Limited

    Address:

    Head Office:

    Scancom Limited,

    Plot # 17&19

    Ridge Towers

    10th - 12th Floor

    6th Avenue, Ridge

    P.O. Box 281 Intl. Trade Fair La,

    Accra - Ghana

E-Mail: info@mtn.com.gh

    Tel: 00 233 24 4300 000

    Fax: 00 233 21 231974

Registered Office Address:

    41 A Graphic Road,

    Auto Parts Building

    South Industrial Area

    (Note: All correspondents to be sent to Head Office)

DECLARATION

    I confirm that the correspondence supplied with this cover sheet is a formal consultation response. It

    can be published in full on NCA’s website, and I authorise NCA to make use of the information in this response to meet its legal requirements. If I have sent my response by email, NCA can disregard

    any standard e-mail text about not disclosing email contents and attachments.

Name : Eben Albertyn Signed (if hard copy)

    Scancom Limited (MTN Ghana)

    Comments and Views on NCA’s Selection & Award Procedure

    January 2010

    Page 2 of 11

MTN Ghana wishes to thank the National Communications Authority (NCA) for the opportunity given to

    express our opinion on the Public consultation document for the licensing of spectrum in the 2.5GHz band.

    MTN strongly believes that with the economy of scale associated with this band, MTN would definitely be

    in a position to cater the Ghanaian population with low cost and efficient Broad Band wireless services in

    future.

    Also, we will like to congratulate NCA for a very good quality and detailed document on the selection and

    award procedure for awarding the licenses.

    Please refer to the paragraphs below for our views on the selection and award procedure outlined in the

    public consultation document.

A. Summary Of Consultations 7: The AUTHORITY intends to issue a total of up to five (5) Spectrum

    Licenses for BWA Services as per the Selection and Award Procedure for Licenses in the 2500MHz

    2690MHz Band.

    MTN Ghana Comment: We would like to appreciate the technology neutral approach adopted but at

    the same point in time would like to express our concern about the limited Bandwidth available for the

    FDD applications which is also not in alignment with major auctions that happened across the world.

    Go-to-market and cost-to-company significantly increases on technology adopted in the TDD

    spectrum as opposed to the FDD spectrum which has got a direct relation to the Broad Band

    Wireless service in terms of coverage and quality that both NCA and MTN would like to bring to the

    Ghanaian mass in a stipulated timeframe as per NCA’s guideline.

B. Selection Process (3.2) The Authority shall employ a multi-stage selection and award process (a

    combination of “beauty contest” and auction) to select prospective applicants for the award of a BWA

    License. This procedure requires that successful applicants meet and satisfy a Three Stage process:

    Stage One: Pre-Qualification (Administrative) Stage Two: Evaluation of Technical-Operational-

    Management Competence; Evaluation of Strategic, Operational & Technical Submissions; Evaluation

    of Business Presentations. Stage Three: Financial (Auction).

    Timetable 3.7: The Process shall take place in accordance with the following timetable (Table as

    presented in the NCA Public Consultation Document):

    MTN Ghana Comment:

    MTN would like to reiterate that due to the current structure of the bidding process (time specified in

    the NCA document), it is practically impossible for interested organisations to meet up with all the

    Scancom Limited (MTN Ghana)

    Comments and Views on NCA’s Selection & Award Procedure

    January 2010

    Page 3 of 11

requirements by the due time specified (which from our understanding, the deadline is early

    February). The major challenges that pose the threat are:

    ? Time needed to prepare a comprehensive business plan;

    ? Board and management approvals;

    ? Preliminary financing for the project;

    ? Time and processes required for setting up a Joint Venture having 30% Ghanaian ownership; and

    ? Adherence to all NCA legal conditions with regards to all the pre-qualification requirements.

    Therefore we request that the proposal submission process should commence on 1 May 2010, and

    the dates for each activity and submission of each required document should be stated clearly and

    explicitly.

    Clarification is also required whether each activity in the 3 stages is expected to run simultaneously or

    non-concurrent.

    For example, (1) do the “Prequalification documents” and the “Submission of Application & Proposal”

    run concurrently? (2) will the “Review of Public Comment” which has 15 days, run in parallel with “Submission of Application & Proposals to NCA” which has 40 days? We advice that NCA matches the activity dates with each of the 3 stages in the selection process.

    Also, the dates for each activity and submission of each required document should be stated clearly

    and explicitly.

    C. Spectrum Blocks (7). The Authority intends to issue a total of up to five (5) Spectrum Licenses for

    BWA Services as per the Selection and Award Procedure for Licenses in the 2500MHz 2690MHz Band; to be awarded as follows

    a. Three (3) slots of 30MHz blocks nationwide for operators using technologies that require unpaired

    spectrum for a 10-year period.

    b. Two (2) slots of 2x15 MHz blocks nationwide for operators using technologies that require paired

    spectrum for a 10-year period.

    c. There shall be an extra paired 2x5MHz and an extra contiguous unpaired 15 MHz available to

    winners of the spectrum blocks in i. and ii. above through negotiations with the Authority.

    Scancom Limited (MTN Ghana)

    Comments and Views on NCA’s Selection & Award Procedure

    January 2010

    Page 4 of 11

MTN Ghana Comment: MTN wishes to state that with the proposed Band Plan, it is unfair on the

    industry taking the FDD evolution path technologically having only 2 slots of the 2x15 MHz (60 MHz in

    total) as opposed to the 105 MHz on the TDD block. With a global approach to the spectrum

    harmonization of the 2600 MHz band and for economies of scale MTN firmly believes that the 2x70

    MHz FDD block should be maintained.

    It has been observed that majority of the auctions around the world has followed the CEPT strategy of

    having the 2x70 MHz block in the 2600 MHz band for FDD.

    An example of a country with a commercial LTE network launched in a large scale is Sweden with the

    following allocations:

    Bidder BW awarded Telia Sonera Mobile Networks AB 2x20 MHz (FDD) Tele2 Sverige AB 2x20 MHz (FDD) HI3G Access AB 2x10 MHz (FDD) Telenor Sverige AB 2x20 MHz (FDD) Intel Capital corporation 50 MHz (TDD)

    Similar observation was made with spectrum allocations in Asia in the same band.

    Also MTN would like to re-iterate the fact that since the 2300 MHz band is a TDD exclusive band, this

    should be included in the Auction for the industry more inclined towards TDD applications and at the

    same time will help the additional spectrum allocation to the FDD block on the proposed band Plan.

    This will not only help achieve harmonization across the band but will also be a very future proof plan

    for the industry as a whole.

    D. Spectrum Band Plan (2.5)

MTN Ghana Comment: MTN wishes to state that taking into account the extremely aggressive

    rollout plan laid down by the NCA, it would be more cost-effective for FDD deployment rather that

    TDD deployment by virtue of the technology itself which will then also be aligned with our mission