RBI2: Rural Wireless Coverage Maps

Dear Crown Fibre Holdings Limited,

In May 2014 the Ministry of Business, Innovation, & Employment along with NZRS Limited began to collect coverage data from 44 providers of telecommunications services [1], including numerous providers involved in delivering rural broadband. One of the stated purposes of the MBIE/NZRS exercise was "to ensure that MBIE holds accurate information about existing telecommunications infrastructure, to avoid inadvertent overbuilding of infrastructure in areas which already receive quality broadband through local providers." [2] A new "National Broadband Map" and data service was launched by NZRS in 2015 containing coverage data from many of these providers[3].

The RBI2 Request for Proposals to improve rural broadband coverage in New Zealand does not appear to consider this data. Thousands of locations considered by the National Broadband Map to have 5-30mbps wireless service have been classified by CFH as Category 1 End Users - users today who are not able to access a terrestrial broadband service greater than 5mbps.

CFH's RBI2 RFP document[4] states "Best efforts have been made to exclude areas in which there is already sufficient coverage, or where there is a medium-term plan for sufficient coverage, from the Rural Broadband Regions..." which would suggest CFH has considered the National Broadband Map in its planning exercises.

1.) Was coverage data held by NZRS offered to CFH for use in the RBI2 process?
2.) If so, was access to the data offered to CFH by NZRS for free or at a cost?
3.) Was the NZRS data considered when CHF built the Category 1 End User Database?
4.) If the data was not used, please provide specific examples of why it was not included.
5.) And if the data was judged as not fit for purpose, was NZRS given the opportunity to correct data issues? Did they do so?
6.) Please provide a timeline of events with regards to CFH / NZRS interactions around use of National Broadband Map data.

Understanding why Crown Fibre Holdings appears to have not used data collected from telecommunications providers in a joint MBIE/NZRS exercise is important to the telecommunications industry, and a full account of this situation would be appreciated.

Yours faithfully,

Jonathan Brewer

[1] https://fyi.org.nz/request/2920/response...
[2] https://dl.dropboxusercontent.com/u/2200...
[3] https://nzrs.net.nz/sites/default/files/...
[4] https://www.gets.govt.nz//CFH/ExternalTe...