Spectrum

Award of available spectrum: 2500-2690MHz, 2010-2025MHz

Consultation on auction rules, procedures and draft regulations

Issued 1 February, 2008

Executive summary

BT is pleased to respond to this third consultation on the proposed award of the 2010 – 2025 and 2500 – 2690 MHz bands. We appreciate the opportunity to comment on the few remaining issues that Ofcom has identified and we are pleased to note that Ofcom anticipates issuing a Policy Statement early in 2008.

Our response to the key issues raised by Ofcom is provided in detail in Section 2 and are summarized in the following points.

1. On the question of Auction Information Policy BT notes Ofcom’s movement on this issue since the last Discussion Document. In addition, there are areas where BT believes further clarification would be helpful.

2. On the matter of Changes to eligibility for unpaired lots, BT is content with Ofcom’s proposals.

3. The minor changes to the Pricing algorithms and winner determination are acceptable to BT.

4. With regards to Deposits and bidder default, BT notes Ofcom’s revised proposals for deposits, recognising the concerns of stakeholders as well as Ofcom itself. BT believes some minor refinements as further detailed below would be simple to implement and improve the robustness of the process and the outcome for all parties.

5. The proposed changes to the bidder association rules are noted. As they currently exist in outline form only, it is not possible to provide a definitive response to a partially described proposal. BT acknowledges the rationale for the proposal but also recognises the possible risks this introduces.

6. With regard to the version of the draft regulations included in the consultation, excluding those areas where BT has raised issues, they currently appear to provide a suitable and pragmatic balance. It is however noted that there are areas which are not yet resolved (which Ofcom acknowledges) and therefore not included in the current version of the draft regulations.

You can download the full response as a PDF document

BT would welcome any comments on the contents of this document. Comments should be emailed to Chris Cheeseman.