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The Association Of Communication Service Providers (ACSP)
 

The Association Of Communication Service Providers (ACSP)

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    The Association Of Communication Service Providers (ACSP) The Association Of Communication Service Providers (ACSP) Document Transcript

    • Radiocommunications Agency ("RA") Public Wireless Networks – Exemption of User Stations Response to the consultation document dated November 2002 by THE ASSOCIATION OF COMMUNICATION SERVICES PROVIDERS Contact: Jacqui Brookes 21 February 2003 www.acsp.org.uk
    • 1. Introduction The Association of Communications Services Providers, ACSP, represents the interests of providers of communication services to customers. ACSP was launched in February 2001, having previously been known as the Service Providers Interest Group, SPIG. Background information and a list of ACSP members may be seen on the website, www.acsp.org.uk 2. Economic and competitive considerations The cost of calls to mobile phones from fixed line phones and from mobile phones connected to other mobile networks in the UK and calls originating on overseas networks is too high. ACSP welcomes the Competition Commission's report into the cost of calls to mobiles and the Director General's decision to apply price controls. However, until these price controls are applied and their effects on other mobile costs (on net calls for example) are assessed it will not be possible to fully gauge the impact on the future economic benefits of GSM Gateways. The market for mobile call termination can never be fully competitive because of the limited access to scarce spectrum resources and since the mobile networks in their totality are like the "last mile" in fixed networks where the provider has a monopoly. In the absence of any competition, the use of GSM Gateways is the only way to drive down costs of calls to mobiles. All the UK mobile operators ("MNOs") choose to set prices for mobile to mobile on net calls which are not consistent with their cost, this makes the use of GSM Gateways even more attractive when compared with the exorbitant interconnect charges demanded by MNOs. This presently makes direct interconnection with the MNOs uneconomic for fixed operators and leads to increased costs for mobile terminating calls transited through BT. MNOs are free to enter the fixed line market but fixed operators are unable to enter the mobile market. 3. Technical considerations The MNOs have information that, if shared with GSM Gateway operators, could avoid cell/call congestion, maintain quality of service and enable the originator's CLI to be passed to the called mobile handset. There are no other technical reasons that might prevent GSM Gateways being legalised. 2 GSM Gateways- ACSP response www.acsp.org.uk 21 February 2003
    • 4. Benefits of legalisation 4.1 The legalisation of GSM Gateways would: - promote the interests of and maximise the benefits for consumers, purchasers and other users in the United Kingdom in respect of the prices charged for, and the quality and variety of, telecommunication services provided and telecommunication apparatus supplied; - maintain and promote effective competition between persons engaged in commercial activities connected with telecommunications in the UK; - promote efficiency and economy on the part of such persons, particularly the MNOs in the use of spectrum; and - enable persons producing telecommunication apparatus in the UK to compete effectively in the supply of such apparatus both in and outside the UK. 4.2 Emerging services New services employing fixed GSM data modems for telemetry and control such as building equipment/environment monitoring, alarms, vending machines, ATM and POS systems where the costs are much lower than the equivalent leased line or dial up service are viable and would be allowed to grow. 5. Legislation It would be a simple matter to amend the Wireless Telegraphy (Exemption) Regulations 1999 (SI 1999/930). 6. Radiocommunications Agency proposals 6.1 Proposal 1 ACSP agrees with the proposal to amend the definition of 'user station' to cover any customer of the network, irrespective of its fixed or mobile status. 6.2 Proposal 2 ACSP agrees with the proposal that the restriction on the type of service that may be provided via network user stations shall be withdrawn. In each case ACSP reasons for agreeing with the proposals are given in Sections 2 to 5 of this response. 3 GSM Gateways- ACSP response www.acsp.org.uk 21 February 2003
    • 7. Additional considerations In implementing the proposed changes to legalise the use of GSM Gateways RA/ DTI should take steps to ensure that commercial users of GSM Gateways are not: 7.1 otherwise prevented from: 7.1.1 becoming or continuing to be customers the relevant MNO; 7.1.2 connecting such equipment to the networks; 7.1.3 using the equipment to provide commercial services; and 7.2 subject to discrimination as compared with the generality of mobile users of the relevant network. oooOOOooo 4 GSM Gateways- ACSP response www.acsp.org.uk 21 February 2003