21 January 2025
Ref: DOIA-REQ-0007106
Jonathan Brewer
Email:
[FYI request #29426 email]
Tēnā koe Jonathan
Thank you for your request of 3 December 2024 to the Ministry of Business, Innovation and Employment
(MBIE), under the Official Information Act 1982 (the Act), for the following information:
Please supply the complete text of all complaints made to MBIE on the topic of Radio Spectrum
Management (the general concept and the organisation) between the dates of 1 January 2022
and 1 December 2024. Please supply all responses to these complaints.
Please supply the complete text of all OIA requests made to MBIE on the topic of Radio Spectrum
Management (the general concept and the organisation) between the dates of 1 January 2022
and 1 December 2024. Please supply all responses to these complaints.
MBIE has identified 30 complaints received from 1 January 2022 to 1 December 2024. The way this
information is stored, however, means we are unable to confirm we have identified all complaints. Please
note that this number does also not include all complaints about the Register of Radio Frequencies (RRF).
A summary of the complaints received can be found in appendix one to this request.
MBIE has identified 49 Official Information Act requests (OIA requests) received from 1 January 2022 to 1
December 2024 relating to Radio Spectrum Management. Our previous and current system do not record
which team or subject matter an OIA request relates to, so this data has been col ated on the basis of the
manager who signed the response, and cross-matched against manual searches through records held by
individuals and a text search for “radio spectrum” in the request text. A summary of these requests can
be found in appendix two.
Both summaries include complaints and OIA requests which you have made.
Your request for al responses made by MBIE to complaints and OIA requests would require substantive
collation and research to identify and provide to you. Complaints and their responses are not held in a
central database, and therefore these would require a manual search through email correspondence to
identify. A search run by the records management team for correspondence in inboxes likely to contain
radio spectrum management complaints identified 2918 potential emails containing the keyword
“complaint”.
OIA requests, while recorded centrally, consist of a large quantity of information which would require
substantive collation and research to provide. A sample of five requests was considered (DOIA 2122-2119,
DOIA 2223-2664, DOIA 2223-2327, DOIA 2324-1983 and DOIA-REQ-0006181), and it was identified these
files contained 561 pages of information, which if extrapolated would constitute approximately 5,500
pages of information.
Given the large amounts of information which would need to be sorted through and released, MBIE is
refusing your request under section 18(f) of the Act, as the information requested cannot be made
available without substantial collation or research.
In line with our obligations under section 18B of the Act, we have considered whether consulting with
you, extending or fixing a charge would remove the reason for this refusal, however we believe that this
would not be the case. Should you wish to file a request for a subset of the received correspondence or
responses to complaints and OIA requests identified in the appendices, you are welcome to do so. Any
information you wil request will be subject to our normal OIA process, including redactions of private and
commercial information where necessary.
If you wish to discuss any aspect of your request or this response, or if you require any further assistance,
please contact
[email address].
You have the right to seek an investigation and review by the Ombudsman of this decision. Information
about how to make a complaint is available
at www.ombudsman.parliament.nz or freephone 0800 802
602.
Nāku noa, nā
Claire Smollett
National Manager Radio Spectrum Management Compliance
Market Integrity
Appendix One – Complaints made to the Ministry of Business, Innovation & Employment regarding Radio
Spectrum Management
Complaint Date Subject of Complaint
22/11/2024
Updating RRF Details Complicated
17/6/24
No Response to Email
11/6/24
Unable to Contact RSM
15/5/24
No Response to Licence Cancel ation Request
4/12/23
No Response to Issue
30/11/23
RRF Functionality Issues
1/11/23
Duplicate Charges in License Invoice
30/10/23
Invoice Creation Issues
6/10/23
Delays to Resolving Duplicate Invoice Charges
7/8/23
RRF Web Form Issues
24/7/23
RRF Direct Debit Set-Up Issues
21/7/23
RRF API and Complaint Ticketing Issues
17/7/23
Duplicate Invoice Issues
13/7/23
Late Response to Queries
13/7/23
Delay in Ship License Callsign Correction
3/7/23
RRF Client Amendment Issues
8/6/22
LCFM License Ownership Issues
30/1/23
Use of Lyttleton FM frequency
28/8/24,
3.3GHz Resource Charges for Cancelled Licenses
1/10/24
6/4/24
Overlap of Protection Areas Causing Potential Impingement or Interference
5/9/24
Al ocations of Spectrum to be Freed by Management Right 514 (MR514)
Licence Revocations
28/8/24
Wrongful Process in Assessing 3.3GHz Licence Applications
10/5/24
Planned Opening of CRM 258 and CRM 514
10/6/24
Engineering and Certification of Licences by Approved Radio Engineer 159
16/7/23
Errors in PIB39 calculations
15/7/24
RRF License Search Issues
26/9/23
Issues with Currently Certified MR514 Licenses
20/7/23
PIB39 Publication and Versioning, Rejection of Licence Applications, Progress of
Additional Licence Applications
13/7/23
Reasons for Licence Application Declinatures
21/7/23
Defining Locations to Meet RRF Requirements in Licence Applications
Appendix Two – Official Information Act requests made to the Ministry of Business, Innovation &
Employment regarding Radio Spectrum Management
Request ID Date
Requested Information
Received
2122-1941 7/04/2022
Radio New Zealand briefings and advice regarding FM and AM
transmission since 2018, and radio spectrum frequency changes since
2017
2122-2119 9/05/2022
Information provided to cabinet, and information on consultations, in
relation to the Technical Working Group on 3.3-3.8GHz presentation on
15 December 2021
2122-2275 31/05/2022 Information, analysis and communications regarding a November 2021
briefing on future access rights
2223-0599 22/09/2022 Information regarding licence audits, including those in Camborne,
Porirua, since 2000
2223-1773 13/02/2023 A copy of the Radio Al ocation Act and a list of radio repeater locations
registered over the last five years, as well as a full site map.
2223-2664 16/05/2023 Information relating to the auctioning of MR514 radio spectrum
allocations via TradeMe in May 2023
2324-0349 17/08/2023 Information regarding a cell tower erected in Paeroa
2324-0970 31/10/2023 Joint Report on funding for Māori interests in radio spectrum
(T2023/1550)
2324-1011 6/11/2023
Joint Report on funding for Māori interests in radio spectrum
(T2023/1550)
2122-1383 11/01/2022 Information regarding radio interference with key fobs in a Hamilton mal
2122-1445 19/01/2022 Information regarding 5G cell tower output capacity
2122-1712 2/03/2022
Information regarding MBIE policies on 5G output restrictions and
reference material updates
2122-2120 6/05/2022
Use of EMF in New Zealand
2223-0284 11/08/2022 Information regarding licensing of, and output limits on, cell towers in
Porirua
2223-0421 30/08/2022 Communications with 2degrees in 2016
2223-0523 14/09/2022 Application of s133A of the Radiocommunications Act 1989 to aircraft and
ship transmissions, and to satellite receivers.
2223-0864, 26/10/2022 Communications with Spark in 2016
2223-0865
2223-0859 26/10/2022 Information regarding decision between allocation or auction of 5G
spectrum
2223-1325 16/12/2022 Information regarding implementation of 5G by NPDC, frequencies and
radiation levels emitted in Invercargill, use of cameras in street lights, and
a drone network in Southland
2223-2151 22/03/2023 Number of active amateur radio operators in New Zealand
2223-2327 12/04/2023 Correspondence and consultations relating to the decision to auction 3.3-
3.34GHz spectrum, and any financial estimates of revenue from allocation
of the 3.5GHz spectrum and auction of the 3.3-3.34GHz spectrum
2223-2567 16/04/2023 Updates, surveys and requests for information on 3.3-3.4 GHz assignment
process, including discussions with WISPA and equipment manufacturers
2223-2650 21/04/2023 Al 5G and 4G frequencies in use, use and health impacts of mmWave
frequencies and EMFs created by satellite coverage
2223-2940 16/06/2023 Cel phone tower locations, names and postal details of owners, and
related compliance orders and regulations for the last 5 years.
2223-3020 27/06/2023 Phased array antenna usage and protection measures in relation to 5G
towers in Invercargill
2223-3048 30/06/2023 Details regarding communication of PIB 39 update in May 2023
2324-0026 4/07/2023
Briefings from Treasury and MBIE regarding 3.5GHz allocations to Spark,
2degrees, Vodafone/One NZ and the Rural Connectivity Group, and any
related cost/benefit analyses
2324-0067 10/07/2023 Evidence supporting RSM decision to preserve spectrum for future users.
Correspondence with and advice received from ACMA regarding 169MHz
spectrum applications.
2324-0098 16/07/2023 Information regarding PIB 39 version 8.3 publication post-May 2023
2324-0220 27/07/2023 Follow-up request to DOIA 2324-0098
2324-0247 5/08/2023
Long term exposure limits for 4G and 5G frequencies, legal basis for these
limits and monitoring arrangements
2324-1226 4/12/2023
Telecommunication infrastructure equipment provider ownership, and
total number of masts in 2010 and 2023
2324-1236 5/12/2023
Communications regarding MR514 interference planning and licence
applications, and interference planning calculations
2324-1249 6/12/2023
Owners and users of cell phone towers in New Zealand
2324-1318 14/12/2023 Advice to Ministers on recognition of Māori interests in
telecommunication spectrum between 2022 and 2023
2324-1856 28/02/2024 Television broadcasting licences for TVNZ, Mediaworks, World TV Limited,
and Kordia Limited
2324-1923 7/03/2024
Correspondence, contracts and meetings with Spark, One NZ and
2degrees regarding allocation of 3.5Ghz band for 5G services, advice
provided to Ministers on this spectrum allocation, and government
departments and Ministers involved in these decisions.
2324-1983 13/03/2024 Radio licences or certificates requested by Wellington City Council since
1990, and licences or frequencies used for CCTV
2324-2340 23/04/2024 Dates created and effective for “Plan for Post-Auction Closure Process”
document
2324-2536 15/05/2024 Specific approved radio engineer emails and attachments in relation to
MR 514 spectrum licensing between July 2023 and May 2024
2324-2682 4/06/2024
5G towers around Tauranga and liability for damage to health
2324-2834 18/06/2024 Information supplied as part of specific licence audits
2324-2849 20/06/2024 Responses to complaint made regarding administration of Crown
Management Rights
2425-0132 11/07/2024 Costs associated with 5G towers and reasons for erection in rural areas
2425-0406 8/08/2024
Authorisation of EMF in New Zealand
2425-0574 26/08/2024 Users of WBAN (wireless body area networks) in New Zealand
REQ-
7/11/2024
Approvals, consents, correspondence, briefings and objections relating to
0006181
supplementary coverage by SpaceX and One NZ, and other satellite
mobile coverage. Legislation and other rules/regulations covering
supplementary coverage from space.
REQ-
10/11/2024 Investigations, reports and complaints regarding interference with Apple
0006228
Carplay, Android Auto, the 5GHz band and 5G cellular data in Auckland
