18 January, 2019
Joint GSMA-ETNO response to the BEREC public consultation on the BEREC Common Position on Mobile Infrastructure Sharing
Introductory Remarks on the Impact of 5G
The BEREC common position on mobile infrastructure sharing takes a backwards-oriented view on competition in mobile telecommunication services. For these common positions to be valid for the future, they need to at least take into consideration both, how mobile markets have developed and future the evolution of access networks, in particular, the changes when it comes to 5G networks. These future aspects need to be reflected in the analysis in order to ensure a competitive digital infrastructure for Europe.
5G will substantially change the overall network configuration and management, notably:
- 5G will provide true convergence of access networks among fixed, mobile, WiFi and satellite networks;
- Network architecture will be largely virtualised to enable network sharing opportunities without compromising MNO differentiation possibilities. For example, MNOs can have different NVF (Network Virtualised Functionality) software, while sharing the same access network hardware, which in turn can be owned by a neutral host hardware; and
- 5G will see all operators compete on services produced outside of core and access networks, with services and devices having network-agnostic access.
As a consequence, the technical evolution towards 5G is shifting the parameters of competition outside the network access layer. Active network sharing, as we know today, may simply not play the same role in a 5G ecosystem.
Therefore, the impact of active network sharing (as defined today) on competition is overestimated in the document. In the upcoming 5G environment, the access network ecosystem will be even more competitive as more technologies come into play. At the same time, this entails that a single operator probably may not operate a fully-fledged fixed, mobile, WiFi and satellite network without partnerships or sharing of various sorts. On the service level, the access layer services will be IP based, hence in direct competition with the OTT IP-based services.
Given this change in the network ecosystem, the need and rationale for sharing could increase, be it passive or active form. The savings enabled by sharing in terms of deployment costs can be very significant and make a difference in reaching the profitability thresholds, required for investments to be pursued.
Therefore, BEREC should be cautious not to set out restrictive recommendations that may create uncertainty or generate chilling effects on future innovation, thereby slowing down the introduction of 5G and the achievement of EU connectivity goals. BEREC should rather increase legal certainty for efficient investments that avoid redundant infrastructure and result in environmental and public health benefits.
In order to access the full PDF document, you may click on the button below.