Spectrum License Renewals in Australia - Response Paper

In their paper “The ACMA ESL Stage 3 Consultation paper reply comments on ACCAN submission” of July 19, 2025, Coleago Consulting make a number of errors and misrepresentations.

Many of the criticisms raised by Coleago are non-responsive and of the form “the point raised by Professor Holden is theoretical.” Other criticisms are essentially ad hominem in nature and non-substantive. A number of other points are not in contention and are irrelevant to the arguments in the ACCAN submission. 

This Response Paper, authored by Professor Richard Holden, offers a point-by-point response to the criticisms raised by Coleago.