Dear MBIE (Radio Spectrum Management),

Under the Official Information Act 1982, I request:

1. All policy documents, ministerial briefings, or strategic reviews from 2020 to present regarding spectrum allocation for rural broadband and fixed wireless access services, including:
- Assessment of spectrum needs for rural connectivity providers
- Policy objectives for making spectrum available for regional broadband deployment
- Reviews of whether current spectrum allocation frameworks adequately support rural connectivity objectives

2. Information regarding the 3.3-3.34GHz spectrum allocation process conducted approximately 2022-2023, including:
- Policy rationale for offering 6-month "exclusive rights to apply" rather than direct spectrum licenses
- Assessment of whether 6-month timeframe was adequate for:
-- Technology platform selection and vendor engagement
-- Funding arrangement finalisation
-- Security clearance processes
-- Actual license application preparation
- Number of entities that obtained exclusive rights versus number that successfully obtained licenses
- Current status and usage of 3.3-3.34GHz spectrum in regions where exclusive rights were forfeited
- Any review or lessons learned from this allocation process

3. Any analysis of 6GHz spectrum availability and potential for rural broadband deployment, including:
- Assessment of 6GHz spectrum for fixed wireless access services
International approaches to 6GHz deployment (particularly USA's Automatic Frequency Coordination system)
- Whether RSM or MBIE has assessed developing AFC or similar coordination mechanisms for New Zealand
- Timeline for potential 6GHz availability for outdoor fixed wireless use
- Any industry consultation or proposals received regarding 6GHz access
- Whether spectrum availability constraints are identified as limiting rural broadband deployment

4. Any assessment of spectrum availability imbalances between different provider types, including:
- Spectrum holdings by mobile network operators versus fixed wireless operators
- Whether spectrum allocation policy considers competitive balance in rural connectivity markets
- Assessment of whether limited spectrum availability for WISPs/fixed wireless operators constrains their ability to compete with mobile operators or satellite services in rural areas

5. Any advice to Ministers regarding:
- Whether current spectrum management frameworks adequately support rural connectivity policy objectives
- Resource constraints within RSM affecting spectrum policy development or allocation processes
- International spectrum developments (WiFi 7, 6GHz, AFC systems) and implications for New Zealand policy
- Whether spectrum policy is coordinated with rural connectivity funding programmes and infrastructure policy

6. Any correspondence with telecommunications industry participants regarding:
- Spectrum needs for rural broadband provision
- Barriers to accessing spectrum suitable for fixed wireless deployment
- Requests for 6GHz access or AFC system development
- Feedback on 3.3-3.34GHz allocation process

Context: Spectrum availability is fundamental infrastructure for wireless connectivity services. The 3.3-3.34GHz allocation process appears to have resulted in spectrum remaining unused despite industry interest, while 6GHz spectrum that could enable significant capacity improvements for rural fixed wireless remains largely unavailable. I am seeking to understand whether spectrum policy adequately supports rural connectivity objectives and competitive market structure.

Yours faithfully,

Sam Brown

Dear MBIE Radio Spectrum Management,

Thank you for the scope clarification. I'm happy to refine part 6 to focus on substantive policy correspondence regarding the issues identified in parts 1-5.

Refined Part 6 Scope:

Substantive correspondence from telecommunications industry participants regarding spectrum policy for rural broadband, limited to:

Timeframe: 1 January 2022 - present (covers 3.3-3.34GHz process and 6GHz discussions)

Senders/Participants: Correspondence from or involving:
- Mobile network operators (Spark, Vodafone, 2degrees/One NZ)
- Fixed wireless/WISP industry associations (WISPA NZ, TUANZ)
- Major and regional fixed wireless operators
- Satellite providers (Amazon/SpaceX)
- Equipment vendors proposing policy positions

Topics (substantive correspondence only):
- Positions on 3.3-3.34GHz allocation process or exclusive rights framework
- Requests for 6GHz spectrum access or AFC system development
- Advocacy regarding spectrum availability for rural broadband
- Proposals for spectrum policy changes affecting rural connectivity
- Industry feedback on spectrum constraints or allocation barriers

What, in my view, constitutes "substantive correspondence":
- Policy positions, regulatory change requests, or advocacy for specific outcomes
- Submissions outside formal consultation processes
- Industry proposals for spectrum allocation approaches
- Lobbying for or against spectrum availability for particular service types

Exclusions to reduce scope:
- Meeting scheduling and administrative logistics
- Routine licence application queries
- Technical compliance questions
- Out-of-office replies
- Information already proactively released (provide links instead)
- Personal contact details

If this is still too broad, I'm reluctantly willing to:
- Further narrow to correspondence specifically about 3.3-3.34GHz and 6GHz only
- Accept just correspondence from the top 10 entities by volume (if you can identify them)
- Limit to correspondence sent to the Minister's office or senior RSM/MBIE officials only

Why this matters: The 3.3-3.34GHz process resulted in spectrum remaining unused despite industry interest. Understanding industry positions on spectrum availability for rural broadband - including informal lobbying before positions are formally documented - helps assess whether spectrum policy adequately supports rural connectivity objectives.

Please confirm whether this refined scope is manageable or advise further narrowing options.

Ngā mihi,
Sam Brown