GSMA-ETNO response to BEREC Consultation on Monitoring Mobile Coverage
ETNO and the GSMA, who represent the telecoms sector in Europe, welcome the opportunity to comment on BEREC’s Preliminary Report on Monitoring Mobile Coverage. We hope the following detailed comments can serve as a constructive contribution to BEREC’s deliberations on this preliminary report.
ETNO and the GSMA, who represent the telecoms sector in Europe, welcome the opportunity to comment on BEREC’s Preliminary Report on Monitoring Mobile Coverage. We hope the following detailed comments can serve as a constructive contribution to BEREC’s deliberations on this preliminary report.
Various considerations that are relevant in the scope of this exercise, are equally relevant in the scope of the discussions around net neutrality and quality monitoring inter alia referring to Art. 4 of the Telecom Single Market Regulation. BEREC’s considerations in both exercises need to be fully aligned. ETNO and GSMA had jointly submitted to BEREC detailed positions on the latter previously.
Joint GSMA / ETNO response to BEREC Consultation on the BEREC Preliminary Report in View of a Common Position on Monitoring Mobile Coverage
8 November 2017
INTRODUCTORY REMARKS
ETNO and the GSMA, who represent the telecoms sector in Europe, welcome the opportunity to comment on BEREC’s Preliminary Report on Monitoring Mobile Coverage. We hope the following detailed comments can serve as a constructive contribution to BEREC’s deliberations on this preliminary report.
Various considerations that are relevant in the scope of this exercise, are equally relevant in the scope of the discussions around net neutrality and quality monitoring inter alia referring to Art. 4 of the Telecom Single Market Regulation. BEREC’s considerations in both exercises need to be fully aligned. ETNO and GSMA had jointly submitted to BEREC detailed positions on the latter previously.
GENERAL COMMENTS
The BEREC consultation focuses on one particular regulatory objective: gathering and presenting information on mobile coverage for the purposes of increasing transparency in the market. Transparency is meant to promote competition by helping customers make informed decisions when choosing among MNOs; it should also help verticals and developers that make investment decisions on products whose value relies on the availability of mobile coverage. We believe that this transparency, if properly managed, enhances as well the value of mobile networks, and therefore welcome any initiative aimed at improving the way information on mobile coverage is organized, gathered and communicated.
Regulators should concentrate their harmonization efforts on ensuring that the information gathered and presented is valuable for the intended users and uses, and is not counterproductive. This can be achieved only by following certain principles:
• The information should be accurate. Realistically, no measurement technique is 100% accurate. They are all based on samples and/or estimations. This does not mean that Regulators should refrain from their objective of increasing transparency, but a minimum high threshold should be required for any measurement technique sanctioned by a Public institution.
• The information should be unbiased. Focusing on certain aspects of coverage above others, or simplifying the information to make it more accessible, can sometimes give a distorted picture that should be avoided.
• Only information that is relevant should be gathered and published. Expanding the scope of transparency has costs and can compromise accuracy. We therefore encourage NRAs and BEREC to narrow the scope to the characteristics of mobile coverage that induce a customer to choose one provider over another, or a vertical to invest in services that are complementary to mobile coverage.
• The frequency of publication and the detail of the information presented should enhance competition, not degrade it. Competition Policy and Economic Theory conclude that transparency can limit competition when it allows competitors to react immediately to the deployment decisions of a particular MNO. Providing real-time information with extremely granular maps, for example, could do more harm than good.
We note that there are other justifications, beyond increasing transparency in the retail market, for NRAs and BEREC to monitor coverage and do it in a harmonized manner. Most importantly, spectrum agencies are tasked with designing and monitoring coverage obligations linked to spectrum rights of use. In this respect, we encourage BEREC to pursue further harmonization on the way coverage commitments in spectrum licenses are defined, for the following purposes:
• Increase certainty for licensees by avoiding open obligations that are difficult to value at the time of award and can result in conflicting interpretations when evaluating compliance.
• Facilitate spectrum trading through increased transparency of the rights and obligations attached to licenses
Mobile coverage can also be monitored simply for statistical purposes, to facilitate comparisons among regions and countries. These exercises are not as critical commercially and the potential impact on the market is therefore limited, but they can be politically more sensible. They should adhere to the same principles of accuracy, unbiasedness and relevancy, and whenever they are used to establish a hierarchy of regions, due account should be taken of differences in costs and benefits of providing mobile coverage.