Harsha de Silva, LIRNEasia’s Consultant Lead Economist, has made a submission in response to BTRC’s Call for Comments on a draft regulatory and licensing guidelines on renewal of mobile telecommunication services in Bangladesh. The submission focuses on a few important issues, relating to economic efficiency, transparency and good governance. The guidelines propose a license renewal fee of BDT 10 crore from each operator. An additional fee of BDT 150 crore per MHz of GSM 1800MHz band and CDMA frequency; and/or BDT 300 crore per MHz of GSM 900MHz band from each operator for the initial assignment of spectrum, and a subsequent annual fee is also proposed. LIRNEasia questions the seemingly arbitrary justification used to set the upfront lump-sum license renewal fees.