Cross-submissions to the Ministry of Economic Development's consultation on the allocation of the 700MHz "digital dividend" spectrum has now closed.

Primary Focus argued that the issues of:

• equal opportunity of access; 
• the creation of a new urban/rural digital divide; 
• the burgeoning demand from mobile users (as distinct from fixed users) 
• usage of existing mobile spectrum
• economic benefits

means the digital dividend spectrum must not be allocated to mobile operators.

 Download the full report here.

Our earlier submission, which can be downloaded here, also argued that should the spectrum be made available to mobile operators, then the proceeds of the auction process ought to be allocated to rural broadband.