We would also like to use this platform to urge the Authority to finalise the award process for spectrum in the 2.5- 2.6 GHz band given that these draft regulations integrate the procedure and criteria for granting radio frequency spectrum licences for competing applications or instances where there is insufficient spectrum available to accommodate demand. We provide below our detailed comments in response to the draft spectrum regulations. Detailed Comments in response to the draft spectrum regulations Regulations 12 and 14 Transfer and Lease of Radio – Frequency Spectrum Licence Smile broadly supports the provisions of regulation 12 and 14 of the draft spectrum regulations which allows for the transfer and lease of spectrum licences. As stated above, we believe that putting in place different options other than a fresh acquisition of spectrum from the regulator is a means to facilitate competition in the market and allow for more efficient use of the scarce natural resource. The transfer and lease of spectrum licences will also help to address the issue of spectrum hoarding by encouraging licensees in possession of available spectrum to allow access to other licensees. We respect and agree for any transfer and lease of frequency spectrum to be subject to regulatory approval, but we are of the view that the amounts paid in respect of any transfer or lease will constitute a commercial transaction between the parties and the Authority ought not to set the values in respect of the transaction. Regulating the
We would also like to use this platform to urge the Authority to finalise the award process for spectrum in the 2.5- 2.6 GHz band given that these draft regulations integrate the procedure and criteria for granting radio frequency spectrum licences for competing applications or instances where there is insufficient spectrum available to accommodate demand. We provide below our detailed comments in response to the draft spectrum regulations. Detailed Comments in response to the draft spectrum regulations Regulations 12 and 14 – Transfer and Lease of Radio Frequency Spectrum Licence Smile broadly supports the provisions of regulation 12 and 14 of the draft spectrum regulations which allows for the transfer and lease of spectrum licences. As stated above, we believe that putting in place different options other than a fresh acquisition of spectrum from the regulator is a means to facilitate competition in the market and allow for more efficient use of the scarce natural resource. The transfer and lease of spectrum licences will also help to address the issue of spectrum hoarding by encouraging licensees in possession of available spectrum to allow access to other licensees. We respect and agree for any transfer and lease of frequency spectrum to be subject to regulatory approval, but we are of the view that the amounts paid in respect of any transfer or lease will constitute a commercial transaction between the parties and the Authority ought not to set the values in respect of the transaction. Regulating the