Lisbon, 3 May 2011 Vodafone Portugal considers ANACOMs decision to hold an auction to allocate frequencies for 4th Generation Mobile Communications (4G/LTE) appropriate since it is the model that best promotes access by interested parties by allowing flexibility of strategies for the rapid development of mobile communications networks and better use of the spectrum.
Vodafone Portugal is of the view, however, that the choice of this mechanism for allocating spectrum does not by itself ensure some of the key requirements for guaranteeing protection of the public interest. In fact, the draft auction document presented by ANACOM is unclear about several measures that are crucial to enabling an informed and considered investment decision by potential bidders, such as guaranteeing transparency about candidates and bidders which is essential for ensuring a competitive environment, and the proper balance between the amount payable for the spectrum and the subsequent investment needed to develop the network and quickly introduce an innovative offer of 4G services.
Additionally, the architecture of the model to be adopted should permit the implementation of strategies aimed at exploiting the relations of complementarity and substitutability between the different frequency bands, thus boosting the market in the demand for efficient solutions for the provision of 4G mobile telecommunications services. Vodafone believes that the sequential auction is not the best option for this and has suggested other, more appropriate and proven auction models. Such measures, of which transparency, complementarity and substitutability are the foremost examples, are not new and, on the contrary, are to be found in most auction procedures already conducted or being implemented in Europe, especially in Germany, Denmark, Spain, the Netherlands, Italy and the United Kingdom.
Vodafone Portugal therefore believes that ICP-ANACOM and the Government, the bodies legally responsible for assigning spectrum usage rights, will, in view of the huge investment that is required of bidders, recognise the need for a model that ensures the appropriate use of frequencies while allowing the speedy implementation of network development plans to ensure more efficient use of the 4G/LTE spectrum by operators.