Archived — Letter from Clearnet
October 22, 1998
Telecommunications Policy Branch
300 Slater Street
Dear Mr. Helm:
This refers to Industry Canada's Gazette Notice DGTP-015-98 entitled "Review of the Spectrum Cap Applied to Providers of Personal Communications Services" and dated October 16, 1998.
At the outset, Clearnet commends the Department in its decision to initiate a public review to solicit comments as to whether to continue, modify or rescind the application of the aggregation limit on the amount of spectrum that can be held by providers of PCS, cellular and similar public high-end radio telephony services. As a major wireless service provider offering SMR, ESMR and PCS services, Clearnet is very interested in this matter. We support liberalization of the cap. We will be separately providing comments addressing the specific questions raised by the Department in the Gazette Notice.
The purpose of this letter, however, is to advise the Department that the expected timeframe of early spring 1999 for a decision will be problematic with respect to a cost-optimized ESMR deployment in the Toronto/Golden Horseshoe area. We note that Clearnet is currently licensed for 13.7 MHz of spectrum in the 806-821/851-866 MHz band in this region. As a result of the cap, 3.7 MHz of this spectrum has been unavailable for ESMR use to date and continues to be utilized to provide analog SMR service.
Therefore, as further provided for in Section 4 – Invitation to Comment of the Gazette, please accept this letter as Clearnet's application requesting temporary relief with respect to the imposition of the cap in the Toronto/Golden Horseshoe area with respect to the additional 3.7 MHz of spectrum. Should the Department prefer to use a "round" figure, such as 4 or 5 MHz, obviously Clearnet would have no objection.
Clearnet would be pleased to meet with you to review the above information and provide any additional clarification necessary. Please do not hesitate to contact me at 416-279-3014.
Serge M. Bertuzzo
Director, Regulatory & Government Affairs
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