Mr Chairman

Thank you very much for the opportunity to introduce this contribution and to comment on the Report of the Rapporteur's Group.
 

Introduction

INTUG made a presentation to the ITU Workshop on 3G Licensing concerning international mobile roaming. It was proposed there that INTUG take the issues concerning the prices of international mobile roaming services to ITU-T Study Group 3. The suggestion came very helpfully from the delegate from the Syrian Arab Republic.

INTUG asks that the Working Party to consider the actions necessary to ensure that the principle of cost orientation is applied to international mobile roaming on 3G IMT 2000.
 

International roaming

The wholesale prices are determined by administrative means, by a small number of operators far from any competitive market. In competition law terms this is known as joint dominance or, in more inflammatory language, a cartel.

Users have enormous difficulty in finding and understanding pricing information. There is almost no price transparency and negligible customer response in selection of operators when roaming .

Our concern is that these problems will simply be carried forward into 3G unless action is taken. Indeed there is a risk of increased problems of abuse of market dominance.

International roaming is an important issue for the roll-out of services with IMT-2000. For this to be successful, it is essential that the correct pricing principles be applied.

Roaming onto 2G and 2.5G networks will be a crucial part of that for many years to come. Therefore the early 3G roamers will encounter the existing 2G market failures.

INTUG set out its position on Global Roaming in a Position Paper issued in 2000. The requirements asked for by users are not technically difficult. A primary consideration is the ability to buy mobile voice telephony, data communications and services on a global, regional or a continental basis, rather than country by country.

International mobile roaming for 2.5G in the form of GPRS hardly exists today. It is available in a few countries, with very high prices and very poor and unpredictable data transfer rates. This is stopping larger users from adopting the service. They are are refusing to adopt it, until the prices are very much reduced and the "footprint" is very much extended.

The present arrangements between operators make it hard for a user to complain. The home operator can always blame the foreign operator. The customer has no direct contractual arrangement with the foreign operator and may not even speak the language. The foreign administration or national regulatory authority supervising the operator is unlikely to address a problem presented from abroad by someone who is neither a citizen nor directly a customer of the operator.

We need to see a mechanism to address problems.

If I understand the position of the mobile operators it is that they should be able to include in cost-oriented roaming charges the costs of their licence fees. If this is accepted and obviously we strongly oppose it, then it would make roaming in those countries potentially expensive.
 

Price information

I wonder who if anyone here checked their prices for roaming before coming to Geneva or perhaps here using the Wireless LAN. Perhaps one or two for voice. I doubt if anyone is roaming with GPRS, let alone knows the tariffs.

Roaming charges are and remain very, very obscure for the vast majority of users. While they are so hard to find and to comprehend it is difficult to see how customers can be expected to respond as they would in a market. The lack of transparency allows the operators to maintain very high prices.

In 3G the charging will be much more complex, reflecting the diversity of services. Means need to be found to make this information available and comprehensible to customers.

However, in 3G there are also technology solutions, such as on-screen displays of prices. It might be interesting to know from whom I would accept calls here in Switzerland at my incoming roaming rate of € 1.1737 per minute.

Real-time pricing information will be especially important for pre-paid customers.

Indeed it is not clear that the IMT-2000 Rapporteur has fully allowed for charging mechanisms for pre-paid customers who might be roaming. In some countries, as much as 90% of the customer base is pre-paid.
 

Short Messaging Service

In the last eighteen months, mobile telecommunications operators have taken a series of measures to increase their revenues through changing tariffs for SMS. In particular, they raised, sometimes from zero, the charges for an SMS sent to from one Member State to another. They have also raised the charges for all SMS sent while roaming.

These actions might appear to be concerted and could give the impression of collusion. Moreover, the new charges do not appear to be cost oriented. We are concerned that similar problems will occur with new services on IMT-2000.
 

IMT-2000 Rapport

Let me make clear, that we do not accept that cost-orientation includes all costs. It should not include the costs of the speculative acquisition of one operator by another, nor the outrageous sums paid by some operators for licences in certain countries. Nor should it include customer acquisition costs.

We find the Report to be a little odd, it seems to lack coverage of crucial aspects, in particular:

• price transparency
• IP-based services as against circuit-switched voice services
• m-commerce applications
• users roaming with pre-paid cards
• possibilities of carrier (pre-)selection

Item 3.3 requires a customer to register for roaming. One of the points users have been making for the last few years is that we do not want to have to see roaming. We want to be able to buy a multi-country footprint of service at a single tariff. At worst, the Recommendation should not preclude this.

Item 3.6 does not seem to allow for pre-paid card holders, where the value of the card might be debited by the roamed operator without a billing record being sent back to the home operator.

Item 3.6 appears to be based on the model of the GSM MoU Standard Terms for International Roaming Agreements (STIRA) and the Inter-Operator Tariff (IOT). It should be recalled that the European Commission is examining the legality of these agreements and could well find them to be in breach of competition law. The ITU should be very careful not to be seen to be endorsing illegal agreements between operators.

Item 4.1.7 indicated which operator is responsible in the event of a dispute. It does not indicate to which regulator or administration a customer might appeal. Without recourse to some organisation or ombudsman, confidence in roaming may be lacking.

Item 4.3.2 includes an option in which the cost of a call to a roaming user is met by the caller. While there may be applications for such a service it is problematic on two grounds. Firstly, it is unclear that the legal requirements about the provision of clearl tariff information to the calling party could be complied with. It would be necessary to alert the caller to the accurate cost of the call, depending on the location of the called party. Moreover, it would be necessary to bill the called party that tariff on a single telephone number, but based on a charge from a foreign operator generated for a single call. This option will require considerable further study.

Data protection

We must consider the data protection issues necessary to ensure customer confidence with the new services. This is a very serious responsibility for operators and for administrations. It is a major potential obstacle to many of the services which providers want to introduce. We may need to refer this issues to colleagues and to other agencies with the appropriate expertise.

For example, as in item 4.5.2 the return of billing information from the roamed operator to the home operator might not be compatible with the data protection regulations in the roamed country. It will be necessary to comply with the OECD Principles and, for example, the European Union Data Protection Directive and Communications Data Protection Directive.
 

Conclusion

We cannot afford a repetition in 3G markets of the abuses found in the 2G roaming markets. We need to ensure that we get 3G roaming correct from the outset. We need clear principles, firmly applied.

The success of IMT-2000 will depend upon truly global roaming based on the principle of cost-orientation. This must be applied to a wide variety of services: voice, data, messaging, applications and so on.

The support of Study Group 3 is requested to the application of the well established principle of cost-orientation to international mobile roaming charges, using all technologies (GSM, CDMA and IMT-2000).
 
 

This page is maintained by the webmaster.

Last updated 13 June 2002.