The opinions expressed in this editorial are those of the author and do not necessarily reflect those of Decima Reports. Industry Canada may have unwittingly stepped into a new and uncertain morass with its proposal to harmonize its spectrum licensing and fee regime (see lead article). Treasury Board policies dictate that any federal government department or agency must conduct a comprehensive review of fees with concerned parties with the goal of avoiding the imposition of "unreasonable cost burdens on clients." According to the Canadian Wireless Telecommunications Association (CWTA), Industry Canada has not provided evidence of such a review. Further, it wants a review of the impact of all government-imposed fees on the wireless industry. If it is true that the department has not conducted a thorough impact analysis of proposed fees on the country’s wireless operators, then it should before tabling a new harmonized spectrum licensing and fee regime. If it has, then that effort should be shared with the industry. It’s unclear at this point what will happen in light of Industry Canada’s apparent policy over-sight, and what steps can be taken to alleviate the CWTA’s concerns. But what is abundantly clear from the CWTA comments is that mobile wireless operators are paying too much in licensing fees compared to other industries and other jurisdictions. The issue appears to be illustrated quite succinctly at paragraph 50 of the wireless industry lobby group’s March 14 comments where it demonstrates the excessive amount of fees with which the industry is burdened. Cellular/PCS players paid more than 50% of all licence fees, or $137 million, collected by the department in 2001-2002, despite holding the rights to 0.22% of useable spectrum under 60 GHz. The current consultation concerns a total of 130 MHz. This contrasts with the 1,053 MHz of spectrum allocated to broadcast services. Calculated the same way for mobile wireless players, the CWTA indicates that broadcasters, even if they reached only 50% of the population, would be charged a spectrum licence fee rate of $0.0056 per MHz per POP. That is one-tenth of the rate proposed by Industry Canada for the mobile wireless industry. Maybe it’s time the department leveled the spectrum licence fee playing field for all spectrum users.