ROAMING REGULATION CHOICE OF DECOUPLING METHOD

Transcription

1 BT response to BEREC s consultation on ROAMING REGULATION CHOICE OF DECOUPLING METHOD A consultation to assist BEREC in preparing advice to the Commission on its forthcoming Implementing Act

2 Roaming Regulation CHOICE OF DECOUPLING METHOD Page 2 of 5 Executive Summary 1. By way of background, BT can indicate that it has formal MVNO and reseller agreements in the UK, Spain and Italy. BT also buys in wholesale mobile access in other EU Member States. 2. We have previously expressed our concerns about the complexities, costs and unproven benefits of physical decoupling of domestic and roaming services, but recognise that (as per the current EU roaming regulations) the move towards this arrangement is now inevitable. 3. One of the key outcomes BT (and other wholesale resellers/mvnos) require from this consultation is the assurance that MNOs will not be permitted to abuse their dominance in the market and will be obliged to fully cooperate on a reasonable, fair and timely basis with their MVNOs/resellers. For example: MVNOs/resellers should be given fair and reasonable access on a timely basis by MNOs to the wholesale prices, covering all of the necessary services needed to deliver decoupled offerings to their customers, in a fully competitive way; MNOs should be required to make available to any MVNOs/wholesale resellers the functionality necessary for the latter to have sufficient time to develop their own competitive propositions in time for launch in July 2014 this necessarily includes sufficient technical information about the functionality well in advance of that date, as well as an opportunity to carry out meaningful tests of any interfaces to ensure that any technical issues as between MNOs and wholesale resellers/mvnos are resolved well in advance of July 2014; and we would expect BEREC s recommendations to tightly define the obligations that MNOs have in providing support and regulated wholesale prices to MVNOs/resellers. 4. A second priority is that the technical solution chosen to effect physical decoupling should not impose significant, or disproportionate, additional costs on any operators in the market, including wholesale resellers/mvnos, and should also not lock in wholesale resellers/mvnos to individual MNOs. This implies that there needs to be a sufficient level of standardisation and inter-operability in the technical solution chosen to effect physical decoupling, so as to ensure that wholesale customers have the ability to switch MNO providers without significant cost or delay, as this would restrict the competitiveness of the physical decoupling solution. 5. Thirdly, given the amount of resource that all providers will need to dedicate to implementing decoupling over the next two years, we strongly believe that effort should be concentrated into developing only one totally effective solution, which is standardised and inter-operable and can be used by all MNOs and all wholesale resellers/mvnos. 6. Finally, given the variety of choices that decoupling will provide to roaming customers the chosen solution must be easily understood by them, it must make provision for all types of mobile services (voice, SMS and data) and it must be guaranteed to provide seamless transfer for end-users. 7. From BT s perspective, of the options put forward by BEREC in its consultation, the best solution for implementation from July 2014 is the Single IMSI model. Response to BEREC s Questions

3 Roaming Regulation CHOICE OF DECOUPLING METHOD Page 3 of 5 Q1. Do stakeholders agree that the basic version of LBO should be introduced in July 2014? What are the elements that may hinder or facilitate the diffusion? We can see many benefits of LBO but, given that it does not offer a whole solution (in that it makes provision only for data services), we believe that the industry s resources should focus on an option that accommodates the full range of functionality that it is required by the regulations to deliver. Decoupling will be complex enough in reality without the industry diverting its resource into developing a solution that is inherently incomplete. Q2. Should co-operative efforts be made to develop a more user-friendly version of LBO for subsequent evolution? What kind of efforts would be most productive? Could you provide any cost estimations for the development of user-friendly interfaces? Can BEREC assist with this process? No. As per our answer to question 1, we question the value of developing a partial solution and believe that focussing on a single total solution would be most beneficial to all parties. Q3. Are there any measures which BEREC could consider to facilitate the ability of MVNOs and resellers to offer LBO? If so, can you provide clear evidence on the technical feasibility and the costs which would arise from such measures? As per our answers to questions 1 and 2, we do not think it is a good use of limited resources for industry to focus on LBO given its inherent failings. Q4. Do you agree that Dual IMSI should not be implemented in July 2014? Yes. Despite the significant amount of development that would be required, longer term this could be the most appropriate solution. Q5. Can you provide clear evidence on the feasibility and the costs which would be involved in making access to traffic steering possible (within the normal limits of steering technology) via Single IMSI + by 1 July (Any information you provide will be treated by BEREC as commercially sensitive, if you prefer). We have unfortunately not had sufficient time within the consultation period to do this. Further, as the timeframe for introducing the chosen solution will be tight across the whole of the industry, we would rather focus resource on the successful implementation of that solution rather than divert elsewhere. Finally, we believe the added benefits of Single IMSI+ are outweighed by the poor customer experience that could be introduced by the needs of the traffic steering solutions, e.g. swap out of SIM to allow special IMSI sub-ranges. Q6. What is your view of the difference in incremental competition benefits achievable, as between implementation of Single IMSI and Single IMSI +? Please provide as much justification as possible for your view. We recognise that there could be incremental benefits from Single IMSI+, but we are concerned about the additional costs and complexity that would be borne by MVNOs and resellers. Q7. Do you agree that a version of the Single IMSI family should be implemented in July 2014? Which elements are key to a successful implementation?

4 Roaming Regulation CHOICE OF DECOUPLING METHOD Page 4 of 5 Yes. And, further, we believe that Single IMSI is the only practical solution given that the regulations require decoupling to be introduced within a short timescale. As per the executive summary in this response, we believe that certain obligations must be placed upon MNOs to ensure that MVNOs/wholesale resellers are given the opportunity to operate in a fully competitive way so as to promote effective competition and ensure maximum benefit to roaming consumers. Q8. If steering is not implemented, do you consider that it would nevertheless be practical to implement systems which would allow decoupling providers to have an option to settle wholesale roaming charges directly with the visited network, on the basis of their own wholesale roaming agreements, as opposed to reliance on a roaming resale agreement with the end user s home network? If practical, please estimate the cost (if applicable) to your company of implementing such systems changes. Please also assess the competition benefits which you would foresee. It may be feasible, but it would almost certainly prove impractical for many small MVNOs and wholesale resellers to negotiate individual agreements with a sufficient number of MNOs. The focus should be on MNOs signing up agreements with MVNOs/wholesale resellers which are proper access arrangements, which include low wholesale prices and include seamless interconnection onto other visited networks. We note that MNOs will have such interconnection arrangements in place for their own retail customers anyway. Q9. Do you consider that there could be further enhancements to Single IMSI +, beyond the ones considered in this paper? (including elements that could simplify implementation and increase feasibility)? Please comment on the additional implementation costs and competition benefits. We have unfortunately not been able to scope out this issue within the consultation period. Q10. Do you agree that the obligations listed in Annex 1 are necessary? We have no comment to make on this at this time. Once the approach going forward becomes clearer, and sufficient information on it is made available, we may have comments at that time. Q11. Are there any additional necessary obligations or are there obligations that should not be included? We have no comment to make on this at this time. Once the approach going forward becomes clearer, and sufficient information on it is made available, we may have comments at that time. Q12. Do you have any comments concerning future evolution of the decoupling methods? Yes. To encourage competition, future developments must focus on keeping MVNO and wholesale reseller costs to a minimum, and on being standardised and inter-operable so that there is no impediment to MVNOs/wholesale customers switching MNO providers. Q13. Do you have any other comments? While decoupling may lead to increased competition and benefits for roaming consumers, it is also very complex and therefore potentially very confusing for roaming consumers, so industry focus must also be on getting the end user experience right.

5 Roaming Regulation CHOICE OF DECOUPLING METHOD Page 5 of 5 Contact Details Trevor Maguire BT Group, Strategy, Policy & Portfolio Tel: +44 (0) trevor.maguire@bt.com