ETNO Response to the BEREC Public Consultation for the Draft Common Position on Monitoring Mobile Coverage
COMMENTS ON THE DRAFT COMMON POSITIONS [BoR (18) 132]
1. Objectives and key principles
- We fully support the objective to enable consumers’ informed choice between different network providers’ tariffs, based on reliable information on network performance.
- ETNO believes that monitoring Quality of Service (QoS) can be a positive and fruitful exercise both for European citizens and for European market players operating along the broadband value chain.
- ETNO supports cost-effective and appropriate steps to increase transparency to enable consumer choice and, by this, support network competition.
- The definition and publication of mobile coverage information should be consistent with the national requirements and mechanisms set by the NRAs. BEREC guidelines should only address those countries where no monitoring system for coverage and QoS has been implemented.
- When defining the criteria for the presentation of mobile coverage (through the display of maps), BEREC and NRAs should take into account the existing trade-off between the granularity of the information to be provided to the end-user and the necessary confidentiality of information about operators’ network elements localisation.
- The Open Internet Regulation already provides for publication requirements on mobile network performance with regard to available tariffs. Further best practices apply at national level, e.g. many ISPs’ publicly available coverage maps.
- The presented measures such as drive tests, coverage maps reflecting calculated performance, and even individual measurement can complement regulatory transparency requirements. However, these presented measures all have specific strengths and weakness that need to be considered.
- In addition, public information provided by third parties must not be confused with performance parameters to be published or included in the contract based on Art. 4 of the Open Internet Regulation.
- To truly enable an informed choice of consumers, the information provided should be accurate. This is also crucial to avoid unjustified consumer complaints of consumers with regard to potential discrepancies between inaccurate information provided by NRAs and providers’ performance commitments indicated in the contract.
- This does not mean that Regulators should refrain from their objective of increasing transparency, but any instrument to provide transparency – calculated speeds in coverage maps, drive tests and individual measurement through consumers – should require sufficiently high minimum quality standards. This also applies to the two instruments highlighted by BEREC: (1) Estimation and prediction of coverage, and (2) Field signal and service availability in specific location/time that is measured.
- Accordingly, we do not necessarily agree that there is a value-add for consumers to publish any available information on network performance. NRAs should rather focus only on reliable information on network performance, to avoid confusion and misleading conclusions.
- Beyond BEREC’s described objectives, mobile coverage can also be monitored simply for statistical purposes, to facilitate comparisons among regions and countries in the EU. Such information does not need to be published and, in that case, these exercises are not as critical commercially. The potential impact on the end-user market is therefore limited. Still, monitoring for these reasons should adhere to the same principles of accuracy, unbiasedness and relevancy. 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.
- We note that 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:
o 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.