Consultation response: reply to public consultation Ds 2017:7 Communication for our common security
IT&Telekomföretagen has been given the opportunity to submit a consultation response to the ministry memorandum Ds 2017:7 "Communications for our common security" and would like to express the following.
There is no doubt that the emergency services need a future-proof platform for mobile communication. It is a prerequisite that this is done in a way that covers the needs of these actors in their socially critical activities while the solution is socio-economically justifiable.
Spectrum in general, and the 700 MHz band in particular, is crucial to sharpen Sweden's competitiveness. However, it is clear to IT&Telecom that the authorities involved and responsible have not coordinated their respective positions and areas of responsibility to a sufficient extent to ensure efficient future use of the 700 MHz band. IT&Telekomföretagen notes that the authorities' short-term actions and lack of coordination have also made it difficult for the operators to find long-term solutions for the benefit of competition, and ultimately for Swedish consumers.
IT&Telekomföretagen believes that the analysis and calculations on which the committee's proposals are based have serious shortcomings on key issues. Neither adequate technical alternatives to a separate blue light network, the vulnerability and capacity of this network, competitive neutrality, nor costs and implementation time have been sufficiently highlighted. There is no doubt that there are both better and less costly solutions with state control and ownership that are less vulnerable, more future-proof and provide better capacity than the solution proposed by the inquiry.
From a socio-economic perspective, it is crucial that government intervention does not distort competition in the market. It is also in this area that IT&Telecom companies have the strongest concerns about the proposal. Sweden is currently in a good position in terms of access to future-proof and robust digital infrastructure. A crucial reason for this is that there are several infrastructure competitors in the Swedish market. Functioning competition in the market is our primary means of ensuring a selection of high-quality and affordable services for Sweden's consumers, businesses and authorities, including the services needed by the so-called blue light authorities.