PSA: Three playing fast and loose with national coverage

ED E

NB: This is 50/50 Mobiles vs Midband but the technical userbase is here thus I've used this sub.
Disclaimer: My GSM knowledge is basic, would welcome pro input.


Not that public can do anything about it really, its interesting to see what'll happen here.

Three, 5th October 2015:

Following the acquisition of Telefonica Ireland last year, and the ComReg Multiband
Spectrum Auction in 2012, Three is currently in the process of a major network refresh and
roll out programme. The outcome of this programme will be to provide increased coverage
and capacity for both voice and data services to the now combined customer base of Three
and also to its wholesale MVNO customers. To achieve this, it is necessary to replace the
existing legacy access networks with a single integrated solution.
Three Ireland currently holds two separate licences to use radio spectrum in the 2100MHz
band for the provision of 3G services. In order to facilitate an efficient technical roll-out, a
requirement has emerged for Three to interchange (swap) the centre block from each of the
two 2100MHz licences. Three views this as a minor technical amendment to the licences.
No other licensee is impacted by the change, and there is no change to the licence
conditions.
Three requests ComReg to make the amendment, the full details of which are explained in
the attachment to this letter

Vodafone, 29/02/2016

ComReg are undermining the commitments by
not allowing 2 contiguous blocks of 2100 spectrum to be readily available to a new entrant.
This seriously undermines the effectiveness of the commitment and the attractiveness of the
spectrum available.

Negative change in lower density areas.
This proposed amendment will allow Three to build a lower capacity network in lower density
areas than committed to in the 3G licence assignment process :
• this will reduce the ability of new MVNO to establish market share in rural areas,
limiting their ability to move to being an MNO.
• The consolidation of network sites that Three discuss is a natural outcome of their
merger and therefore does not need ComReg to approve this proposal.

In ComReg’s Assessment the regulatory principle in Regulation 16(2) is used as a guiding
principle to ensure there is no discrimination. But by allowing Three to use twice the
spectrum assignment of 2100 of other operators at a new lower set of coverage
commitments Comreg are actively favouring one operator and discriminating against other
operators.

Vodafone obviously have a commercial interest here but their points appear all to be valid. If Meteor got their game together they'd have objected too.

Simplification of what this would allow:
Urban:
3 Chunks Main Network
3 Chunks Secondary Network
Rurual:
2 Chunks Main Network
1 Chunk Secondary Network

Possibly related is the fact that last week Three took their network temporarily offline to restructure (there's a delay between decisions and their publication by COMREG).

Worth keeping a watch now as Three are becoming more like Eircom of old with too much spectrum under the whims of Hong Kong.