New Zealand carriers mobile spectrum holdings

An email from Janet Bache, a communications advisor at the Ministry of Business, Innovation and Employment says:

Just wanted to let you know that the information in this article (now removed) about how much radio spectrum is currently held by Vodafone, Telecom and 2Degrees isn’t accurate.

My story is an indirect quote from Paul Brislen from Tuanz, the telecommunications users group:

As Brislen writes in his blog post — and has told me often — the problem is that Vodafone holds about 300 MHz of wireless spectrum, Telecom NZ has roughly 200 MHz and 2degrees has about 100 MHz. This makes for an uneven market. There’s a danger 2degrees will be effectively shut out leaving New Zealand with two powerful mobile giants and one minnow.

The ministry’s view is:

Here are the correct figures on the total spectrum held by the three companies across all spectrum used for cellular phones: Vodafone: 130.4 MHz; Telecom: 110 MHz; 2degrees: 99.6 MHz (some of which is owned by 2degrees’ shareholders Trilogy Ltd and Hautaki Ltd) .

This information is publicly available through the online Register of Radio Frequencies at http://www.rsm.govt.nz/smart-web/smart/page/-smart/WelcomePage.wdk  .

Now that’s interesting because Brislen says he didn’t pluck his numbers out of the air. He says he has used them before and says until now no-one has challenged him.

Where do the mobile spectrum numbers come from?

Well there’s this from Vector’s Submission on the Commerce Commission’s Statement of Preliminary Issues – 700 MHz Spectrum Applications:

It is clear that should the Commission allow Vodafone or Telecom to acquire  a fourth block in the 700 MHz band, this would further intensify the  concentration of spectrum in their hands, substantially lessening competition in the national market for spectrum management rights.

Along with this graph:

Which certainly looks close to the numbers I quoted in the original story.

So who is right? Are Vector's numbers wrong? The caption to the chart says the information comes from the same MBIE source as it’s possible there’s wiggle room in the term “across all spectrum used for cellular phones” and that some of the mobile spectrum in the Vector chart isn’t used for that purpose. Vodafone owns some Local Multipoint Distribution Service (LMDS) frequencies.

However, there’s nothing to say it couldn’t be used for cellular. Indeed New Zealand’s licensing regime effectively allows carriers to repurpose spectrum. So my understanding is the numbers quoted by the ministry are for cellular holdings as they are used, while the numbers from Brislen and Vector account for the spectrum as it could be used, maybe when 5G rolls into town.