Large parts of the telecom industry oppose the idea of direct localized spectrum allocation to users of local private networks, especially when talking about spectrum around 3.5GHz, raising the following concerns: Interference. Building multiple local network installations near each other, or local networks covering moving objects such as trains or boats, may lead to issues with interference, causing technical challenges. Wireless operators argue that the best way to prevent this is by awarding all spectrum to them on a nationwide basis and allowing them to manage such situations. It is true that such situations need to be professionally managed. However, other entities including for example some tech companies may be able to help with this. In theory, different entities may own the spectrum, manage its flexible allocation among multiple users and operate local networks using it. Handover. Local private networks have naturally limited coverage. If such networks were built by the nation-wide wireless operators, seamless handover to nationwide networks can be provided, which means that devices leaving territories covered by the local networks stay connected without disruptions. This will be relevant for some, but not all local network use cases. For operating connected in-factory machinery as part of industrial automation, for example, local coverage may suffice. It is also possible that a well-functioning national wholesale wireless market may provide such solutions. Utilization of the spectrum. The telecom industry sometimes claims that the allocation of valuable spectrum for use by local entities would lead to underutilization of such spectrum in most of the national territory, where no local entities would apply for such spectrum use. However this does not need to be the case. Regional spectrum allocation schemes may allow spectrum unused by local business and landowners in some areas to be used by other parties, including the telecom companies. Moreover, high frequency spectrum is unlikely to be used for full nationwide coverage anyway. Size of the spectrum block. The telecoms industry and other experts claim that larger blocks of spectrum in the 3.5GHz range can be fundamentally better utilized for innovative techniques such as spectrum slicing. Telecom operators often propose to use 80-100MHz block size as desirable. The discussions about the block size do indeed have substance. However, this does not automatically imply that the best utilization is achieved when all such blocks are exclusively in hands of the legacy wireless operators. Price of the spectrum. The wireless industry sometimes suggests that if a large spectrum block was allocated outside its scope, the limited amount of the remaining spectrum would lead to excessive spectrum prices. This is a valid concern, also based on the German 5G spectrum auction experience. However, this issue can be addressed for example by allowing operators with smaller spectrum allocations to share spectrum. If some operators wanted exclusivity, they may have to economically assess what price they are ready to pay for it vs. a perfectly plausible scenario of spectrum sharing, or even using regionally allocated spectrum in some geographies. Skills of network building. The wireless industry may argue that it is ideally skilled to build and operate private wireless networks. The wireless operators certainly have skills in network building, but tech ansd other companies may learn such skills. Moreover, nothing stops the wireless operators from selling such skills to businesses, which secure local access to the spectrum for themselves (we have already seen this for example in Germany). Harm to telecom value, which would adversely affect telecom innovation. It is fair to admit that private 5G networks may lead to some disruption to telecoms future business opportunities. It is equally true, however, that the so called ‘spectrum hoarding’, i.e. allocation of all precious spectrum towards one particular business model to effectively suppress this type of disruption, would likely boost the telecoms’ incentive to seek rent from the spectrum as opposed to innovating aggressively. Telecoms showed this lack of innovation in the previous business cycles. Arguably, telecoms need to win innovation-driven competitive battles by providing superior service to their customers, not by securing full spectrum-related entry barriers. A reasonable and fair disruptive pressure on the telecoms industry may therefore encourage its own innovation. “ Telecoms need to win innovation-driven competitive battles by providing superior service to their customers, not by securing full spectrum-related entry barriers” 36

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