13 March 2026
Ref: DOIA-REQ-0027681
Sam Brown
Email: [FYI request #33735 email]
Tēnā koe Sam
Thank you for your email of 15 February 2026 to the Ministry of Business, Innovation and Employment
(MBIE) requesting, under the Official Information Act 1982 (the Act), the fol owing information:
“Under the Official Information Act 1982, I request information regarding the resources expended
on the 3.3-3.34GHz regional spectrum allocation process conducted approximately 2022-2023:
1. Staff time and internal costs
a) Total staff hours spent on policy development, design, and administration of the 3.3-
3.34GHz exclusive rights to apply process
b) Staff hours spent processing exclusive rights applications and associated correspondence
c) Estimated internal cost (salary/overhead basis) attributable to this process
d) Staff time spent managing the forfeiture process when exclusive rights were not
converted to licences
2. External and associated costs
a) Any external consultant, legal, or advisory costs incurred in designing or administering the
process
b) Any costs associated with advertising, public consultation, or stakeholder engagement
c) IT or system costs for managing applications or the allocation process
d) Any costs associated with post-process review or lessons learned activities
3. Outcomes achieved
a) Number of exclusive rights to apply granted
b) Number of exclusive rights successfully converted to spectrum licences
c) Number of exclusive rights forfeited or allowed to lapse
d) Current utilisation status of 3.3-3.34GHz spectrum in regions where exclusive rights were
forfeited (i.e., whether the spectrum remains unused)
e) Whether any post-process review or lessons learned document was produced, and if so,
please provide it
4. Opportunity cost context
a) Whether RSM assessed alternative allocation approaches (e.g., direct licensing, open
access, shorter-duration licences) and, if so, any comparative analysis of those
alternatives versus the exclusive rights approach chosen.”
I am refusing question 1 of your request under section 18(e) of the Act as the document al eged to contain
the information requested does not exist or, despite reasonable efforts to locate it, cannot be found.
Regarding question 2, I can advise that there were external costs of $51,966.98 relating to auction services
and $30,450 for legal cost of drafting contracts.
I am refusing part d) of question 3 under section 18(e) of the Act as the document al eged to contain the
information requested does not exist or, despite reasonable efforts to locate it, cannot be found. I do note
that information on the location of existing licences can be found on in the publicly available register of
radio frequencies and this data could be used to determine which areas spectrum remains unused. The
register can be found here:
rrf.rsm.govt.nz/ui?state=1.
For parts a) and e) of question 3 and question 4, there are seven documents that fal within the scope of
these parts of your request. A table detailing these is appended below at
Table one. I am releasing two of
these documents in ful and partial y releasing five documents. Some information has been withheld
under the fol owing sections of the Act:
• 9(2)(b)(i ), to protect information where making available of the information would be likely
unreasonably to prejudice the commercial position of the person who supplied or who is the
subject of the information;
• 9(2)(g)(i), to maintain the effective conduct of public affairs through the free and frank expression
of opinions by or between or to Ministers of the Crown or members of an organisation or officers
and employees of any public service agency or organisation in the course of their duty; and
• 9(2)(h), to protect legal professional privilege.
I do not consider that the withholding of this information is outweighed by public interest considerations
in making the information available.
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
Daniel O’Grady
Manager, RSM Policy and Planning
Table one: documents in scope
# Document name
Document date
Released or Reason for
withheld
withholding
1
3.3 – 3.4 GHz Options Analysis
Undated
Released in
-
full
2
[Draft for review] 3.30 – 3.4 GHz Regional
Undated
Partially
9(2)(b)(ii)
Broadband Internal Decision Document
released
9(2)(h)
3
Reflections on 3.30 – 3.34 GHz
Undated
Partially
9(2)(g)(i)
released
4
3.3-3.4 GHz licensing tracking
Undated
Released in
-
full
5
Exclusive rights holders finalized list
Undated
Partially
9(2)(a)
released
6
[Briefing #2223-2369] Decisions on 3.3-3.4 10 March 2023
Partially
9(2)(a)
GHz non-national spectrum assignment
released
7
[Briefing #2223-3164] Update on 3.30-3.34 24 March 2023
Partially
9(2)(a)
GHz regional broadband non-national
released
spectrum assignment