The draft Frequency Migration Plan (FMP) contains a number of anachronisms and contradictions that are difficult to resolve, Vodacom said in a written response to ICASA.
Vodacom, which is owned by British mobile phone giant Vodafone, has previously proposed that the Frequency Migration Plan should ideally be incorporated in the National Radio Frequency Plan.
“Vodacom stands by this position,” Vodacom wrote in the submission.
The plan provides for, among others, the background and basis of the Radio Frequency Migration Plan, identification of the radio frequency bands where migration may be required and make proposals regarding such frequency migration as may be required; and identify the radio frequency bands which are subject to a feasibility study.
Vodacom said it appreciates that the drafting of a NRFP (National Radio Frequency Plan of 2018) and FMP are large complicated undertakings.
In 2013, ICASA finalised the Frequency Migration Plan before finalising the National Radio Frequency Spectrum Plan of 2013.
“In the current consultation we are confronted with a situation where the Final 2018 National Radio Frequency Plan was published in May 2018, while the consultation on the 2018 Frequency Migration Plan was initiated in August 2018,” Vodacom wrote in its submission.
“As a result, the draft Frequency Migration Plan contains a number of anachronisms and contradictions that are difficult to resolve.”
Vodacom proposed that ICASA amend the NRFP of 2018 to resolve any inconsistencies that arise between the final FMP and the current NRFP.
As in 2012, Vodacom in its written response proposed that Radio Frequency Re-farming be removed from the scope of the Frequency Migration Plan.
Furthemore, Vodacom noted that ICASA contemplates “re-farming” between IMT standards (eg. 2G, 3G, and LTE) as a means to assign IMT spectrum to new entrants.
The GSM 900 MHz and 1800 MHz frequencies are currently occupied by the incumbent mobile operators who have nationwide assignments. If there is a case to inject competition in this market, a re-farming exercise would also need to consider ways and means to re-allocate spectrum between the incumbents and new entrant(s) so as to facilitate free and fair competition.
Such an exercise could be carried out for both 900 and 1800 bands at the same time in conjunction with assignments in other bands allocated to IMT to allow existing operators to maintain their existing level of service.
In this regard Vodacom cautioned that migration must not infringe on the rights of incumbent licensees.
“Vodacom does not agree with the Authority’s interpretation of spectrum re-farming and Vodacom opposes the erosion of the principle of technology neutrality,” the company wrote in its submission to ICASA.
“Nevertheless, Vodacom supports the principle of spectrum redeployment or in-band migration of spectrum assignments when it is warranted to improve the efficiency with which IMT spectrum can be used.”
Notwithstanding ICASA’s conclusion that 3 to 5 years is a reasonable timeframe to conclude spectrum migrations, Vodacom said that experience has shown that even seemingly simple spectrum migration plans can be difficult to execute.
Vodacom proposes that ICASA should be capacitated to proactively drive the execution of Radio Frequency Spectrum Assignment Plans.
It said this could include:
a) A framework for prioritizing migration plans; b) Proactive identification of stakeholders and communication with stakeholders; c) Regular monitoring and progress reports on migration projects.
Furthermore, Vodacom said ICASA should guard against new spectrum assignments that could jeopardize strategic spectrum migration projects.