Telstra has confirmed its is taking a fine-toothed comb to the ACMA’s new 400MHz spectrum regulations to determine whether its previous concerns have been heeded.
A Telstra spokesperson told Computerworld Australia the company was analysing the large amount of information in today’s paper and it was premature to make any comment until this analysis is complete.
"We are assessing how our concerns previously set out in our submission have been dealt with both in the ACMA decisions and their proposed implementation arrangements," the spokesperson said. "While it is premature for Telstra to make any definitive comments at this stage, it is observed that the decisions paper has recognised concerns from a range of stakeholders."
However, in its submission to the ACMA on its review of the 400MHz band, Telstra (ASX: TLS) argued the ACMA had failed to fully consider the impact of its changes on the 403-520 MHz band.
“If implemented, ACMA’s proposal to clear the 403-430MHz band exclusively for Government use would place Telstra in an impossible position as the primary universal service provider in Australia,” the submission reads.
“The proposal would directly threaten Telstra’s existing fixed wireless services operating in the band, which are used to deliver services Telstra is required to supply under regulation or by contract, including more than 100 standard telephone services…”
Telstra utilises the 403-420 MHz band to deliver a wireless standard telephone service in rural and remote regions where it is not feasible to install or maintain fixed line services.
The company added that the cost to migrate these services to another band is not currently reflected in any universal service obligation funding arrangement.
Telstra also argues that it would be forced to migrate its Fleetcoms service, a commercial trunked land mobile service operating in the 403-420 MHz band, to another band.
“Further, the proposal would see 27 MHz of highly valuable spectrum warehoused, Australia-wide, for exclusive Government use,” the submission reads. “An allocation of this size is not justified, would be spectrally inefficient, and would fail to maximise the overall public benefit serviced from that spectrum.”
As an alternative the telco suggested the smaller 418 – 430 MHz band be utilised exclusively for government use.
Telstra had argued that, rather than use the band for government services, the 450-470 MHz band could have been used to accommodate a trunking user if they were displaced from the 403-430 MHz band, or to support high-capacity rural wireless access services.
Further, implementing improved coordination process around the band could have obviated the need for some existing upper 400 MHz band spectrum licences.
The company also put forward an argument for the appointment of a commercial manager to manage government only spectrum to ensure any allocated spectrum was utilised efficiently.
For its part, the ACMA touted the changes to the 400MHz spectrum as a means to dramatically increase essential and emergency service interoperability within state and federal government agencies.