Dual-Band Operation and Domestic Roaming for Public Mobile ...
Dual-Band Operation and Domestic Roaming
for Public Mobile Radiotelephone Services in the 800/900 MHz Band and
Personal Communications Services in the 1.8 GHz Band
the Telecommunications Authority, Hong Kong
28 August 1998
On 21 May 1998, the Telecommunications Authority (TA) issued
a consultation paper entitled "Consultation Paper on Dual Band Operation and
Domestic Roaming for Public Mobile Radiotelephone Services (PMRS) in the
800/900 MHz band and the Personal Communications Services (PCS) in the 1.8
GHz band" (hereinafter called the “Consultation Paper”). The objective of the
consultation is to seek the views from the industry on issues related to dual band
services and domestic roaming between GSM 900 networks and GSM 1800
2. By the end of the consultation, the TA received 9 submissions from
mobile operators and interested parties. A summary of the views and comments
received is in the Annex. This paper gives the considered views and decisions of
the TA on the introduction of dual-band services and domestic roaming between
GSM 900 and GSM 1800 networks.
How Should Dual-band Services be Regulated?
3. All commenters are generally supportive of the TA’s view that the
introduction of dual band services is to the benefits of the consumers. Many of
them highlight a number of advantages of dual band operation. The introduction
of dual band services is a natural evolution of technological advancement which
enables greater cost-efficiencies, improves productivity, allows service
differentiation, provides better grades of service and maximizes available
spectral resource to improve service quality and lower the price. It also allows
consumers to have wider choice on operators and broader range of innovative
4. As regards views on how to regulate dual band services, the
PMRS/PCS operators consider that the introduction of the dual-band services is a
commercial decision and it should be left to market forces. There is no need for
the TA to impose any regulatory measures such as setting a moratorium to
restrict operators to deploy better and more efficient technology which will
ultimately bring significant benefits to consumers. Shun Hung Kai Properties
Ltd. comments that the TA should not create any regulatory barriers to prevent
operators from improving efficiency and capacity through better usage of
resources. Shun Hing Technologies Co. Ltd. suggests that the TA needs not be
involved in the regulation and let the operators settle among themselves.
5. The standalone PCS operators consider that the introduction of
dual band services affords the PMRS/PCS operators a network that has
substantially more spectrum than is available for the standalone PCS operators.
The advantages of this additional spectrum include better trunking efficiency and
the ability to increase service quality, through co-location and targeting current
capacity hot-spots, at a faster rate than is feasible for the standalone PCS
operators. To ensure a level playing field, they propose that the TA should
introduce a one-year moratorium for the use of dual band services and to ensure
that all the conditions of the PMRS and PCS licences are fully upheld. They also
request the TA to allocate, or assure that additional spectrum is allocated, to each
standalone PCS operator and take an active role in ensuring that all operators are
allowed to gain access to critical sites.
6. As explained in the Consultation Paper, the TA considers that
dual-band technology enables PMRS/PCS operators to use the spectrum
resources more efficiently and to improve network coverage and service quality.
By sharing the resources between the GSM 900 and GSM 1800 networks, the
PMRS/PCS operators could reduce both the network operating costs and
administrative costs in the long run. Thus, the deployment of this new and
improved technology will give consumers significant benefits in terms of
competitive pricing, improved network coverage, enhanced quality of service
and other service innovation. Concerning the argument that the PMRS/PCS
operators will have significant advantages over the standalone PCS operators in
terms of coverage, the TA has explained in the Consultation Paper that, initially,
a network with dual band services would inevitably have better coverage
compared with a standalone PCS, but the difference would be diminishing over
time and would in around one year’s time become insignificant to a large
proportion of customers. In fact, two standalone operators point out in their
submissions that their PCS networks would become fully competitive by mid-
1999. This affirms the TA’s view that the difference in network coverage
between GSM 900 and GSM 1800 networks would diminish in around one
year’s time. Furthermore, with the introduction of mobile number portability in
early 1999, the TA believes that it would help, to a certain extent, to increase
competition and ensure a level playing field for the operators.
7. In line with the light-handed regulation and technology neutral
approach adopted in regulating mobile services, the TA maintains his view that
there is no need to impose any special regulatory restriction on dual-band
operation. The development of dual-band services is hinged on technological
development and the timing of its introduction should be left to the market forces.
Imposing a moratorium on the launch of dual-band service will unnecessarily
interfere with commercial operation and unduly impede the technological
development of mobile services in Hong Kong. This would not serve the interest
of the public and the mobile industry.
8. In their submissions, the standalone PCS operators request for
additional spectrum for equalizing the imbalance between the PMRS/PCS and
standalone operators. The TA considers that there is currently spare PCS
spectrum in the 1.8 GHz band and any PCS operators including the standalone
PCS operators could apply for use of the spare spectrum at any time if they meet
the established criteria such as the efficient use of spectrum and traffic demand.
Spectrum requirements for new services that depend on the availability of more
spectrum would also be considered by the TA. If the standalone PCS operators
have justifications to prove that their competitive position would be eroded after
the introduction of dual band services or they have difficulties in planning their
network coverage or capacity due to the insufficiency of spectrum, they may
apply to the TA, together with their justifications, for the allocation of additional
9. After consideration of the submitted views and comments, the TA
reaffirms his position that the introduction of dual band services should be
permitted as long as such services are introduced in a manner that fully complies
with the licensing conditions.
10. The introduction of dual band services requires the allocation of
the same Mobile Network Code (MNC) to networks in the 800/900 MHz band
and 1.8 GHz band operated by the same operator. As the policy of permitting
dual band operation without restrictions has been adopted, the TA sees no reason
not to approve application for using the same MNC for networks in the different
bands to facilitate dual band services.
11. The TA re-iterates that the PMRS/PCS operators will not be able to
evade the licence commitments by providing the dual-band services. The
PMRS/PCS operators are required to fulfill their milestone commitments under
the PCS licences in full by implementing the required PCS facilities, not to be
replaced by PMRS facilities. In order to help mobile operators to expedite the
development of their network coverage, the TA will continue to provide
assistance to all mobile operators in accessing confined areas such as shopping
malls and tunnels, and to share use bottleneck facilities on an equitable basis,
such as the establishment of common antenna facilities in Country Parks.
12. In the Consultation Paper, the TA has proposed that domestic
roaming could enable the standalone PCS operators to make use of the well-
established GSM 900 network facilities so as to enhance their PCS network
coverage. The TA is of the view that domestic roaming between GSM 900
networks and GSM 1800 networks is useful in promoting fair and effective
competition between PMRS/PCS operators and standalone PCS operators.
However the submitters do not seem to support the idea of domestic roaming.
13. Two standalone PCS operators are of the view that domestic
roaming is not the best options they would strive for owing to a number of
shortcomings. Seamless call handover would not be possible which would be
perceived by subscribers as a degradation of service quality. The service quality
will be dependent on the roaming network and it is hard to predict and control.
Operators will need to make substantial investment in modifying their billing and
administrative and supporting systems in order to incorporate roaming charges
in to the customers bills and to settle the charges amongst operators. The service
offered by domestic roaming is restricted to basic voice service only, and other
value-added and proprietary services offered by the home mobile network could
not be retained.
14. The PMRS/PCS operators object to the imposition of mandatory
domestic roaming. They consider that PMRS/PCS operators would face problem
in planning their GSM 900 network capacity as the increased traffic arising from
the PCS roaming subscribers could not be predicted. As a result, the quality of
service offered to both their own GSM subscribers and PCS roaming subscribers
would be compromised. If the market demand warrants the use of domestic
roaming, mobile operators would have the commercial incentive to enter into
reciprocal domestic roaming agreements amongst themselves.
15. The TA is aware that there are some inherent deficiencies in
domestic roaming and the service quality achievable by this functionality could
not match with that offered by dual-band services. Domestic roaming might also
increase the operating and administrative costs of network operators. However,
as pointed out in the Consultative Paper, domestic roaming between networks
operated by different operators would be useful in overcoming some existing
coverage problems. For example, coverage for one network may not be available
within certain indoor areas or at certain locations in the Country Parks. It may
not be possible, due to physical, economical or other constraints, to extend the
coverage of all networks to all areas. Domestic roaming between networks
operating in the same band, or different bands, would help improve customers
which would otherwise be deficient in coverage.
16. Two PMRS/PCS operators are of the view that domestic roaming
does not constitute “interconnection” of telecommunications systems or services
because roaming will not require the passing of calls between the networks.
Roaming simply involves a signalling interface between the networks. They are
of the view that roaming does not fall within the jurisdiction of the TA under
section 36A of the Telecommunication Ordinance.
17. The TA does not agree with the narrow interpretation of section
36A as suggested by the two PMRS/PCS operators. According to section
36A(3)(a), the type of interconnection referred to in this section is an
arrangement for interconnection to and between telecommunication systems or
services licensed, or exempted from licensing, under the Telecommunication
Ordinance. The policy objective of section 36A is to prevent telecommunication
systems or services from being operated as isolated services. The
interconnection is to allow customers of one system or service to have access to
customers connected to, or services provided by, another system or service.
Domestic roaming is to enable customers of one mobile network to gain access to
the services provided by another mobile network. There are at least two types of
interconnection involved in a domestic roaming arrangement. The first is
interconnection between the mobile networks to enable customer verification
data to pass. The second is interconnection through circuits established by radio
between the customer’s mobile station (which itself is a telecommunication
system exempted from licensing under the Telecommunication Ordinance) and
mobile network providing the roaming service.
18. Notwithstanding the TA’s belief that powers exist under section
36A of the Telecommunication Ordinance for him to determine the terms and
conditions of the interconnection arrangement to implement domestic roaming,
the TA notes that even the standalone PCS operators are not fully supportive of
the domestic roaming arrangement. Taking into consideration the views from the
industry and the fact that some standalone PCS operators have almost completed
their network rollouts, the provision of domestic roaming will have marginal
effect on improving their PCS network coverage, the TA decides that he would
not mandate the provision of domestic roaming at this point in time. The
provision of domestic roaming will be subject to bilateral agreement between
mobile operators. If mobile operators cannot agree on the terms and conditions
of interconnection and charging arrangements for domestic roaming agreement,
the TA will make a determination under section 36(A) of the Telecommunication
19. The TA concludes that the introduction of dual band services by
mobile network operators should be allowed as long as they would fully comply
with the licence conditions. The TA would not mandate the provision of
domestic roaming, but he would consider making a determination of the terms
and conditions for domestic roaming under section 36A of the
Telecommunication Ordinance if he receives requests from mobile network
operators for him to do so.
20. Any enquiries on this Statement should be addressed to the
Telecommunications Authority at the following address:-
Office of the Telecommunications Authority
29/F, Wu Chung House
213, Queen’s Road East
[Attn: Senior Telecommunications Engineer (Technical Support 2)
Telephone no. 2961 6778
Fax no. 2803 5112]
Office of the Telecommunications Authority
28 August 1998
Summary of Comments and Views from Respondents on
Consultation Paper - Dual Band Operation and Domestic Roaming
for PMRS in the 800/900 MHz Band and PCS in the 1.8 GHz Band
The Office of the Telecommunications Authority (OFTA) received
altogether 9 submissions from the industry and interested parties on the consultation
paper. Their major views and comments are summarised in the tables below :
How should dual band services be regulated in Hong Kong?
Hong Kong Telecom CSL CSL supports the TA's preliminary view that the introduction
Ltd. (CSL) of dual band services should be permitted. It considers that a
“temporary moratorium” has no sustainable merits and it not
in the public interest to delay the offer of dual band services
simply to favour particular mobile operators by protecting
them from the dynamic effects of competition through
CSL is of the view that dual band service aims to ease the
capacity issues of the GSM 900 network, the enhancement of
the incumbent networks should not be considered as a threat
nor disadvantage to the standalone PCS operators. Consumer
benefit and public interest should far outweigh the alleged
“unfair advantages”. In addition, there will be a sufficient lead
time between now and full commercial ubiquity of dual band
handsets by which time the coverage of the standalone PCS
networks will have been significantly improved if each of the
PCS operators chooses to commit sufficient effort to the
roll-out of its network.
CSL agrees with the TA that there should be no moratorium,
either temporary or permanent, imposed on the provision of
dual band services.
Hutchison Hutchison is encouraged to note the TA's support for the
Telecommunications provision of a dual band services and the TA's
(Hong Kong) Ltd. acknowledgment that such services are in the interests of the
(Hutchison) consumer. Dual band services should be made available as
soon as possible. To hold up the launch of dual band services
and thus deprive consumers of the benefit of the technological
advance that such services offer would be grossly unfair. Any
question of a moratorium, temporary or otherwise, is both
totally unacceptable and beyond the power of the TA.
Dual band services should simply require compliance with
both the relevant operators’ PCS and GSM licences and no
new regulatory approval is required for dual band services.
Mandarin SUNDAY agrees that the introduction of dual band services
Communications Ltd. is to the advantage of the Hong Kong consumers. However
(SUNDAY) the advantages gained by PMRS/PCS operators over the
standalone PCS operators by the immediate introduction of
dual band networks, if left unaccounted for, only serve to
hinder SUNDAY’s ability to be competitive. The timing of
the introduction of dual band services is therefore of
importance to the commercial viability of the standalone PCS
The introduction of dual band network affords the
PMRS/PCS operators a network that has substantially more
spectrum than is available for the standalone PCS operators.
The advantages of this additional spectrum for the efficiency
of the network are well established. Deployment efficiencies
are advantageous to the PMRS/PCS operators who will have
the ability to increase service quality, through collocation and
targeting current capacity hot-spots, at a faster rate that is
feasible for the standalone PCS operators.
SUNDAY therefore proposes that OFTA -
• introduces a one year moratorium of the use of dual band
networks and services.
• ensures that all the conditions of all licences are fully
• allocates additional spectrum to each standalone PCS
• takes an active role in ensuring that all operators are
allowed access to critical sites.
New World PCS Ltd. NWPCS proposes that dual band operation should be allowed
(NWPCS) only when standalone PCS operators are given sufficient time
to negotiate for and conclude roaming agreement with GSM
operators. Only when integrated and standalone PCS
operators are able to implement domestic roaming, should the
TA mandate commencement of dual band implementation.
Peoples Telephone Co. Peoples Phone accepts and supports the view that the
Ltd. (Peoples Phone) introduction of dual band integration be allowed. However
OFTA should ensure that any benefits gained by the consumer
through allowing dual band integration are not reduced or
minimised by a reduction in the competitive environment.
Shun Hing Technologies Shun Hing welcomes the proposal of permitting dual band
Company Ltd. services in Hong Kong and has the suggestion that OFTA
(Shun Hing) needs not be involved in the regulation and let the services
operators settle among themselves.
SmarTone Mobile SmarTone agrees with the TA that dual band services should
Communications Ltd. be permitted and urges the TA allow immediate
(SmarTone) commencement of these services.
SmarTone comments that dual band technology enables
greater cost-efficiencies, improves productivity, allows
service differentiation, provides better grades of service,
maximise available spectral resource to improve service
quality and lower the price.
Considering that dual band services are part of the natural
technological evolution for service enhancement and bringing
greater benefits to consumers as well as continually
contributing to the eminence of telecommunications in Hong
Kong, SmarTone recommends that dual band services be
Sun Hung Kai Properties SHK comments that given the tremendous benefits of dual
Ltd. (SHK) band operation to consumers on enhanced network coverage,
enhanced quality of service, wider choice on operators and
broader range of innovative services, the imminence of the
commercial availability of dual mode handsets as well as the
rapid development of technology, the TA should allow dual
band operation as soon as possible.
Dual band operation would enable PMRS/PCS operators to
operate more efficiently and expand their capacity by
improving the trunking efficiency of GSM 900 and GSM
1800 frequencies to achieve more cost efficient operations.
Mr. Alex Tsui (Interested Mr. Tsui agrees on the OFTA's view of GSM 900/DCS 1800
personnel) dual-band operation.
Domestic Roaming Issues
Hong Kong Telecom CSL CSL does not support the introduction of mandatory
Ltd. domestic roaming. The issue of domestic roaming should be
(CSL) dealt with by commercial arrangement if it proves technically
feasible and commercially viable between mobile operators.
CSL considers that any domestic intercarrier roaming service
provider in Hong Kong would experience severe difficulties
to maintain its service quality, both in the provision of
network services to its own customers, and in the provision of
network services to its roaming customers, due to the major
technical difficulties in providing overlapping coverage within
a dense area such as Hong Kong. Mandating domestic
roaming would immediately create the potential for major and
unpredictable network congestion.
In terms of the complexity of the issue, the effort and
additional capital investment spent by the domestic roaming
service provider in various aspects would result in long lead-
time and high provision cost.
CSL does not consider that domestic roaming could
effectively alleviate the problem of indoor and other coverage
constraints currently faced by the industry. There are many
unresolved issues including service quality, network identity,
network capacity, call drop due to non-seamless handover,
re-registration at home network, etc. which make this
arrangement unattractive to mobile operators for dealing with
constrained coverage issues. To promote competition in the
market, CSL considers that the standalone PCS operators
should be encouraged to build their own network rather than
using others to provide the service. By mandating the
imposition of domestic intercarrier roaming OFTA would
reduce the incentives for the standalone PCS operators to
complete any significant network rollout in areas other than
those high teledensity areas that would allow them to engage
in “cream skimming”.
CSL submits that a domestic intercarrier roaming service is
not the interconnection of telecommunications systems or
services because roaming will not require the passing of calls
between the networks. Roaming, both internationally and
domestically, simply involves a signalling interface between
the networks. Accordingly, CSL considers that under the
current legislation and regulatory regime there is no power
vested in the TA to mandate domestic intercarrier roaming on
the PRS licensees.
Hutichison Hutchison disagrees with TA's intention of involving himself
Telecommunications in mandating domestic roaming and setting the relevant
(Hong Kong) Ltd. charges. These matters should be left to commercial
(Hutchison) arrangements and beyond the power of the TA to mandate.
Hutchison considers that domestic roaming would result in
PCS customers experiencing service quality difficulties and
limitation problems and existing GSM customers being
subjected to deterioration of service quality. The lack of
seamless roaming as between networks with different mobile
network codes is a serious problem which will adversely
impact service quality and thus the reputation of the industry
in general. A PCS subscriber roaming onto a GSM network
will remain on the relevant GSM network until that GSM
coverage is lost or manual re-selection of PCS coverage is
made. This will inevitably result in PCS subscribers making
calls via GSM roaming arrangements which could have been
made on their home PCS network. This will give rise to
unexpectedly high bills arising out of the relevant roaming
charges and inevitable customer complaints. Domestic
roaming service would inevitably be restricted to basic voice
services and would not allow access to normal value added
services. GSM networks are already operating at near full
capacity and cannot accommodate additional requirements of
other operators. An influx of PCS subscribers roaming into
GSM freely would overload those GSM networks and
seriously undetermined quality of service leading to call
congestion and lower transmission quality.
Hutchison is of the view that PCS operators should build their
own networks to provide the required coverage. When PCS
licence bids were submitted there was no entitlement to GSM
roaming. To force GSM operators to allow PCS subscribers
to roam onto their networks would amount to appropriation
of the GSM operators’ assets.
To force domestic roaming on the industry would discourage
investment by PCS operators. A reduction or lack of PCS
investment will result in PCS customers in the longer term
suffering from service limitation and higher call charges
arising from resultant excessive roaming onto GSM
networks. The cutting back of investment will result in lower
service standards and lower returns. This will start a vicious
circle that will ultimately result in cost cutting and closure or
consolidation of networks, all leading to the reduction of
employment opportunities and employee redundancy.
Hutchison is of the opinion that the TA has no jurisdiction to
mandate domestic roaming under section 36A of the
Telecommunication Ordinance or otherwise. Roaming is
quite different in concept to interconnection and falls outside
the scope of section 36(A) of the Ordinance. Domestic
roaming does not constitute “interconnection”. It involves
the origination of a call on one network and its termination on
another. It is essentially a carrier to carrier relationship. To
treat roaming as interconnection would entail treating all
arrangements between owner of handsets and network
Mandarin SUNDAY believes that domestic roaming with a GSM
Communications Ltd. 900 operator does not offer an equivalent dual band service
(SUNDAY) for the standalone PCS operators. Networks that are
domestically roaming cannot hand off calls and therefore the
call drops. Dropped calls give the impression to the
subscriber that they are using an inferior network. The
requirement to use another network only serves to underline
the superiority of that network's coverage, thereby
undermining the position of the original network. Revenue
will be lost for calls that are continued on the GSM 900
network even when back in an area covered by GSM 1800
due to the need to pay roaming fees rather than collect
standard air time fees. There is a very short window of
opportunity to recover the administration and logistic costs if
domestic roaming would not be required by SUNDAY after
having a fully competitive network in mid 1999.
Domestic roaming is not a feasible operational or commercial
solution for matching the supremacy afforded the PMRS/PCS
operators by dual band service. SUNDAY does not see
domestic roaming as useful in promoting fair and effective
competition but rather believes that it clearly serves to
underline the differences in the networks and thereby directly
hinders SUNDAY's ability to be competitive.
New World PCS Ltd. There is an inherent risk that GSM operators will grant
(NWPCS) favouritism to their affiliates while discriminating other
standalone PCS operators, which are literally competitors of
NWPCS proposes that PCS calls roam to GSM network
should have the roamed calls separately identified in
customer's bill and roaming calls should be considered as
premium rate service which should be separately chargeable
and should not be covered under the standard service plan.
GSM operators offering domestic roaming should offer the
same roaming rate to all PCS operators.
The TA should actively involve in commercial discussion
between mobile operators on roaming arrangement to ensure
only relevant cost are recovered. The TA should also
intervene if necessary to ensure the implementation of
domestic roaming will not be unnecessarily delayed to give
advantageous headstart by PMRS/PCS operators.
Peoples Telephone Co. Peoples Phone is of the view that the introduction of domestic
Ltd. (Peoples Phone) roaming is not the best option. Domestic roaming is only
advocated as a necessary entry condition of PCS entrants
where there is a sparse population but not Hong Kong.
Taking into consideration its network rollout, Peoples Phone
envisages that domestic roaming would be useful for a period
of six months and it would not be commercially viable for the
three standalone operators to do so as it would involve a
major investment in terms of money.
Other reasons for not supporting domestic roaming are
service quality will depend on its competitors’ standards,
ability to provide Value Added Services may be complicated
through a non-proprietary network, the display of customer’s
terminal will show the name of its competitor’s network,
handovers between its network and that of its competitors are
impossible, less revenue will be gained from call minutes as it
will be charged for domestic roaming minutes, and significant
investments may have to be made to allow its billing systems
to accept call detail records that are generated from switches
in other networks.
Peoples Phone believes that the imposition of domestic
roaming would not adequately compensate the three
standalone operators for the significant advantages to be
gained by allowing PMRS/PCS operators to integrate their
networks. These advantages include dual band operators can
gradually increase spectrum in line with demand by putting
PCS-transmitters in areas first where congestion is a problem
and may balance between GSM and PCS, and therefore
creates a more efficient and cheaper network than any of the
standalone PCS operators could provide. Dual band
operation immediately relieves the PMRS/PCS operators’
capacity requirements in hot spot areas, thereby upgrading
their overall service quality in only a few months. PMRS/PCS
operators will be able to sell dual band phones from the first
day, providing full coverage almost instantly. Combining the
cell sites may allow the PMRS/PCS operators to roll out their
PCS network at considerably higher speed than any of the
three standalone PCS competitors.
However if OFTA makes decision to sanction domestic
roaming as a form of compromise, then Peoples Phone would
• Dual band network operations should not be permitted
until domestic roaming agreements with the three
standalone PCS are in place;
• OFTA will ensure that the introduction of domestic
roaming will be subject to fair compensation through
roaming charges and that the fair setting of
interconnection charges are applied which are based on
the reasonable relevant costs. Peoples Phone would also
encourage OFTA's involvement in determining a fair
• OFTA will set up a one year moratorium of all PCS
operators starting from the date of approval for the use of
dual band network integration;
• Assurance should be given from OFTA that the
standalone PCS operators be allocated frequency in
addition to the 10 MHz already reserved for them; and
• Assurance from OFTA that dual band network operators
must adhere to the advertising code of practice and not
promote their network be denigrating the single band
SmarTone Mobile SmarTone is seriously concerned that if domestic roaming is
Communications Ltd. mandated, the quality of services being provided to the
(SmarTone) consumers could be jeopardised both during normal
operations and in emergency situation.
Domestic roaming would introduce the significant risk of
leading to an "avalanche effect" in a crisis situation such that
there could be a significant and unexpected surge in traffic
that might overload a second network. Of critical importance,
is the fact that access to emergency services is threatened by
the introduction of domestic roaming.
Commercial negotiation will alleviate concerns regarding the
potential for "cream skimming" by operators.
SmarTone believes that domestic roaming does not contribute
to the betterment of mobile communications services in Hong
Kong and on the contrary, would significantly threaten mobile
service quality and, more specifically, access to emergency
services. Therefore, SmarTone would urge the TA to rely
upon commercial processes and market forces.
Sun Hung Kai Properties SHK comments that the TA should leave to the market to
Ltd. (SHK) reach any domestic roaming arrangement and the setting of
interconnection charges between operators through
commercial negotiations among operators. Domestic roaming
could enhance the coverage of operators and facilitate the
development of fair and effective competition in the market.
Shortcomings of domestic roaming include mandatory
domestic roaming forces PMRS/PCS operators to accept
substantial investment risk; service quality of PMRS/PCS
operators would be impaired since additional traffic from
standalone PCS operators could cause serious congestion in
their networks; infrastructure investment would be
substantially reduced to sub-optimal level as operators would
have no incentive to invest further to improve their
infrastructure; and "cream-skimming" of standalone PCS
operators is encouraged such that they only invest in areas
which are economically viable and rely on domestic roaming
in other areas. PMRS/PCS operators would be forced to
subsidise the rollout of standalone PCS operators.
Mr. Alex Tsui (Interested Mr. Tsui agrees on the OFTA's view of domestic roaming. He
personnel) foresees some technical difficulties in domestic roaming and
multi-band handover including "timer for return to HPLMN"
as the phase 1 SIM does not contain this timer; the mobile
might not camp to the most suitable cell before user initiates a
call and that will reduce the call setup successful rate, and
increase the call drop rate; inter-PLMN handover is
technically feasible to certain extend, the mobile has no
knowledge that it is being handed over to a different PLMN.
Once the call ends, the mobile should search and probably
camp to the PCS network as VPLMN if the HPLMN is not