A country’s citizens benefit most when the private and public sectors work together in a spirit of openness and trust. To this end, the GSM Association is committed to supporting governments and regulators in their efforts to introduce pro-investment telecommunications policies. The Mobile Policy Handbook: An Insider’s Guide to the Issues is a window into industry perspectives, a signpost to regulatory best practice and a portal to more information.
Business
Environment
Base-Station Siting Approval
:Read moreBACKGROUND
INDUSTRY POSITION
- Mobile network infrastructure has become a key indicator of socio-economic development, and achieving ubiquitous access to mobile telephony, including mobile broadband, is a major policy objective in most countries.
- Base stations provide geographic coverage and additional network capacity where needed. New mobile services require additional, technology-specific infrastructure.
- To ensure national coverage, mobile operators may be required as a condition of their licence to install base stations throughout their market area, giving every citizen the opportunity to access mobile services.
- Mobile network operators face a variety of requirements and conditions, depending on the country, in securing permits for base-station deployment. Procedures can be defined at different government levels, even though the local authority (e.g., the municipality) is the main point of referral. Regional or national requirements may also have to be met.
Debate
- What procedures should be implemented to avoid undue delay in infrastructure installation?
- Should EMF exposure limits be specified in mobile operator licences?
Explicit planning approval processes for mobile base stations should be defined, to avoid lengthy delays in network deployment. - Exposure guidelines recommended by the World Health Organisation (WHO), such as ICNIRP, which are based on sound scientific evidence and are subject to ongoing expert review, should be respected, and other rollout restrictions in reference to environmental impact should be limited.
- We support mechanisms to avoid delays related to bureaucratic inefficiencies, including exemptions for small installations, collocations or certain site upgrades, ‘one-stop shop’ licensing procedures and tacit approval.
Competition
:Read moreBACKGROUND
INDUSTRY POSITION
- Mobile is the most widely adopted consumer technology in history, and a regulatory model that fosters competition — in particular, the liberalisation of telecommunications services and infrastructure, and the provision of sufficient spectrum to facilitate a widespread, low-cost mobile network roll-out — has been key to achieving this level of adoption.
- Other contributing factors, notably the technical evolution of analogue, digital and IP-based mobile networks, have led operators to enter new markets, to deploy voice and data networks and to expand the number of customers internationally.
- A majority of countries decided early on in the licensing process to ensure that there was competition in the mobile communications marketplace by licensing at least two providers per area. As more bands have become available, new competitors have often captured licenses, increasing the level of competition.
- In addition to mobile network operators, resellers or mobile virtual network operators (MVNOs) provide additional retail competition.
Debate
- What is the appropriate level of competition in a given market?
- What measures can governments take to achieve appropriate competition without stifling innovation?
We believe governments should focus on measures that facilitate competition in the mobile sector rather than over-regulating it. Excessive regulation can stifle innovation, raise costs, limit competition and harm consumer welfare. - Mobile markets should, in principle, be open to competitive entry, for example through the provision of licences and spectrum to entrants on equivalent terms to those of existing or incumbent operators.
- However, mobile is capital-intensive, and sufficient scale is needed for mobile operators to function profitably while keeping prices affordable for their customers. Forcing the addition of more competitors doesn’t necessarily increase competition.
- Allocating spectrum to organisations that don’t have the ability to deploy or heavily invest in infrastructure is an inefficient allocation of a scarce resource.
- We consider that, whatever the institutional framework, there is always a choice between ex ante and ex post intervention. Where markets are competitive (i.e., where there is no finding of significant market power), ex ante regulation is normally inappropriate. Competitive constraints on operators should be sufficient to drive an efficient outcome for consumers.
- Governments are increasingly relying — rightly so — on ex post competition law to achieve regulatory benefits in the mobile communications sector, which is a vibrantly competitive sector.
Resources
Report: Competition and the Mobile Sector in Developed and Developing Countries
Mobile Broadband, Competition and Spectrum Caps
Report: Licensing to Support the Broadband Revolution
Competition has done wonders for the mobile voice market, and now I hope it will bring more prosperity by delivering mobile broadband, especially where there are no fixed networks.
— Martin Cave, Visiting Professor, Imperial College Business School
Gateway Liberalisation
:Read moreBACKGROUND
INDUSTRY POSITION
- International gateways (IGWs) are the services through which international calls are sent and received.
- Although most developed markets now have fully competitive international telecommunications markets, many countries in Asia Pacific, the Middle East, Africa and Latin America are yet to liberalise IGWs, and monopoly supply continues.
- Historically, fixed incumbents were granted monopolies over IGWs. The assumption was that an IGW monopoly would allow a country to keep its international charges high, and profits would help the fixed incumbent to fund the network rollout and generate valuable tax revenue.
- Changes in technology (e.g., the deployment of VoIP services) have substantially lowered the cost of entry in the provision of international services, thereby significantly increasing competition, whether legitimised through regulation or not.
Debate
- Which structure — monopoly or liberalised — best serves a country and its citizens?
Gateway liberalisation delivers substantial economic benefits to a country. These include lower international prices, more international bandwidth and lower costs in the provision of international services to operators. - IGW liberalisation has the ability to deliver lower retail prices, better services and wider benefits for the country as a whole (e.g., by lowering the cost of business and facilitating trade and investment, thereby raising employment and living standards).
- For developing countries to fully participate in a globalised world, their IGWs must be fully liberalised to allow competition and private investment.
- By allowing IGW monopolies to operate, governments are faced with significant regulatory and law-enforcement costs to prevent illegal bypass, while losing out on the tax revenue that could be generated by legal services.
Resources
Report: Gateway Liberalisation: Stimulating Economic Growth
The evidence shows that liberalisation actually stimulates investment and that the fear of loss of international revenues is illusory…. Combined with the wider economic benefits to a country and its government, IGW liberalisation is a rational and best practice regulatory response to the IGW monopoly.
— GSMA Research report on the Benefits of Gateway Liberalisation, 2007
Infrastructure Sharing
:Read moreBACKGROUND
INDUSTRY POSITION
- Common in many countries, infrastructure sharing arrangements allow mobile operators to jointly use masts, buildings and even antennas, avoiding the unnecessary duplication of infrastructure.
- Infrastructure sharing can provide additional capacity in congested areas where space for sites and towers is limited.
- Infrastructure sharing may expand coverage into previously unserved geographic areas. This is facilitated via national roaming or by reducing subscriber acquisition costs (SACs) by sharing sites and masts or the radio access network (RAN).
- Infrastructure sharing has the potential to strengthen competition, reduce the number of towers, reduce the carbon footprint of mobile networks and reduce costs for operators.
Debate
- Under what circumstances should regulators oversee, approve or manage sharing arrangements?
- Should regulators allow mobile network operators to voluntarily share infrastructure?
- Are infrastructure sharing arrangements potentially anti-competitive?
Governments should have a regulatory framework that allows voluntary sharing of infrastructure among mobile operators. - The regulatory framework of a country should facilitate all types of infrastructure sharing arrangements, which can involve the sharing of various components of mobile networks, including both so-called passive and active sharing.
- While it may at times be advantageous for mobile operators to share infrastructure, network deployment remains an important element of competitive advantage in mobile markets. Any sharing should therefore be the result of commercial negotiation, not mandated and not subject to regulatory constraints or additional fees.
- Infrastructure sharing agreements should be governed under commercial law and, as such, subject to assessment under general competition law.
- In some cases, site sharing increases competition by giving operators access to key sites necessary to compete on quality of service and coverage.
Intellectual Property Rights
:Read moreBACKGROUND
INDUSTRY POSITION
- The emergence of the internet as a place for buying, sharing and downloading content has created challenges for policymakers and stakeholders, including combatting piracy, stimulating demand for legal offers, reforming content licensing and clearly establishing consumer rights.
- Mobile operators are caught between intellectual property rights (IPR) holders, such as artists or publishers, and customers in the debate on piracy. Mobile operators face the potential of being liable for any content transmitted over their network, complying with burdensome monitoring obligations and disclosing user information without court orders.
- In Europe, the debate about piracy is gathering momentum, with several EU Member States imposing obligations on ISPs to cooperate with rights holders in fighting piracy. Most Member States have introduced copyright levies on devices such as MP3 players and mobile phones that could be used to copy and share protected content.
- The European Commission adopted a proposal for a directive on collective rights management and multi-territorial licensing of rights in musical works for online uses in July 2012 and will review the directive on the enforcement of intellectual property rights (IPRED) by March 2013.
Debate
- Rights holders advocate strong laws and cooperation of internet service providers and telecom companies in fighting piracy. Civil society organisations defend consumers’ fundamental rights (freedom of expression, access to the internet) and strongly oppose any measures to combat piracy. Collecting societies oppose content licensing reform and defend national licenses.
Content licensing reform is needed to enable new business models for rights holders and commercial users, and attractive content offers for consumers. - The obligation to develop new content-licensing models should fall to content rights holders. Obligations on ISPs to monitor piracy should be nonexistent or take a light touch.
- Expanding the legitimate content market is key in fighting illegal file sharing. Mobile operators are keen to play their part in the market for online content, which is expected to reach over €120 billion in service revenue by 2013 globally, according to Juniper Research.
- Handset levies or a ‘global licence’ are not the right policy instrument to compensate rights holders for piracy.
- Current uncertainties over the direction of future licensing practices of collecting societies and the reciprocal agreements between them hold up the development of new business models and delay putting new content offers on the market.
- In Europe, we support a multi-territory and pan-European licensing of audiovisual works and encourage effective competition of collective management organizations within the EU by enabling choice for creators and users of rights.
International Mobile Roaming
:Read moreBACKGROUND
INDUSTRY POSITION
- International mobile roaming (IMR) allows customers to continue to use their mobile device to make and receive voice calls, send text messages and email, and use the internet while abroad.
- Regulators and policymakers have expressed concerns about transparency of IMR prices, bill shock and certain higher IMR prices. In Europe, which operates under a single economic and political framework, roaming regulation has been in place since 2007. EU structural solutions are to be implemented to increase competition with the aim of removing price cap regulation.
- International institutions such as the OECD, ITU and WTO are considering roaming issues. Additionally, regional and bilateral measures are being considered.
Debate
- The perception by some policymakers is that certain IMR prices are too high.
- There is a range of regulatory options to increase the transparency of roaming prices and to reduce roaming prices at a retail and/or wholesale level.
- Regions outside of Europe are considering a range of regulatory options to increase transparency of roaming prices and reduce roaming prices where they are considered excessive.
- A global comparison of IMR prices between countries shows that, although some roaming prices are higher, there are also some much lower roaming prices and a host of innovative tariff plans.
Roaming is a valuable service and is delivered in a competitive marketplace. Price regulation is not appropriate, as the market is delivering many new solutions. - The incidences of bill shock and different prices differ between and within regions. These could be due to structural differences, such as the existence of double taxation, international gateway monopolies and fraud. Additionally, other variables — such as income, GDP, inflation, exchange rate fluctuations, mobile penetration rates and the percentage of the population that travels internationally, as well as incidence of travel to other countries — impact IMR prices. These should be addressed before considering IMR regulation. It follows that regulators can only address concerns at the local, not global, level.
- Imposing a global or even regional solution may fail to address the source of regulatory concern, is likely to be detrimental to market performance and may lead to customer detriment in the long run.
- The mobile industry is committed to customer protection and views well-considered transparency measures as an effective tool to promote competition in IMR. In June 2012, the GSMA launched the Mobile Data Roaming Tranparency initiative to give consumers greater visibility of their roaming charges and usage of mobile data services when abroad. This initiative signals the voluntary commitment made by operators to promote and provide transparency of roaming services to consumers.
- The roaming market is competitive, with an increasing number of innovative price and tariff bundles to suit the needs of different consumers.
- Roaming is part of the overall service basket and should not be viewed in isolation. Intervention changes the commercial model for operators, which may adapt and review domestic services, or it may impact investment, such as the development of mobile broadband.
- Governments should only consider price regulation as a last resort, where transparency and innovative pricing and tariff bundles have failed to address consumer complaints — and only after carefully considering each local market by assessing the costs and benefits of any proposals, and only applying regulation when the benefits of regulation exceed the costs.
Mobile Termination Rates
:Read moreBACKGROUND
INDUSTRY POSITION
- Mobile termination rates (MTRs) refer to the fees charged by operators to connect a phone call that originates from a different network.
- The setting of regulated MTRs has attracted enormous attention in both developed and developing countries, and many different approaches and methodologies have been developed for this purpose.
- Regulators have generally concluded that call termination on each individual mobile network acts as a separate market and each operator of those networks enjoys significant market power in the supply of call termination to its own customers. Consequently, they have imposed various remedies on the operators to ameliorate or prevent market distortions, most importantly a requirement to set cost-oriented prices for call termination.
Debate
- How much should an operator be allowed to charge for terminating a call on its network?
- How should these rates be regulated, and if so, how?
The setting of regulated MTRs is complex and likely to require detailed costing analysis and careful consideration of the welfare and competition effects of intervention. - MTRs are wholesale rates, regulated in many countries, where a schedule of annual rate changes has been established and factored into mobile network operators’ business model. Sudden alterations to these rates can have a negative impact on investment and profitability.
- We believe national authorities are in the best position to analyse and determine the need for regulation in their own market, through a detailed, consultative process.
- In Europe and elsewhere, national regulatory authorities have legal powers to obtain relevant information from operators, and there is thus no basis for extraterritorial intervention in the matter of mobile call termination.
Resources
The Setting of Mobile Termination Rates: Best Practice in Cost Modelling
Report: Comparison of Fixed and Mobile Cost Structures
Report: Regulating Mobile Call Termination, Vodafone
Intervening in a competitive market is far more complex and challenging than the traditional utility regulation of the kind normally applied to monopolies in gas, electricity and fixed-line telecommunications. With mobile, every action is more finely calibrated. The benefits of intervention are more ambiguous and the error costs larger.
— Stewart White, former Group Public Policy Director, Vodafone
Net Neutrality
:Read moreBACKGROUND
INDUSTRY POSITION
- There is no single definition of ‘net neutrality’; it is often used in the context of prioritisation of traffic over networks. Some argue it is necessary to legislate that all traffic carried over a network should be treated in essentially the same way.
- Some countries have adopted net-neutrality rules. The US FCC introduced rules in 2010, and the mobile sector was exempted in all but transparency measures, subject to further review once the mobile broadband market had developed. The European Commission recently launched a consultation on net-neutrality related aspects.
- Traffic management has always been used in networks, for example to prioritise emergency communications. The recent focus of the net-neutrality debate is on promoting transparency and competition rather than specific legislation on traffic management.
Debate
- Should networks be able to manage traffic and prioritise one traffic type or application over another?
- For mobile networks, which have limited capacity, should fixed-line rules apply?
- Is it appropriate and proportional to introduce new rules in anticipation of a problem, before the problem has actually materialised?
We believe in an open internet, but to keep it open and working we need the flexibility to manage traffic and innovate. - Operators need to differentiate between application and device types so that they can manage the end-to-end quality of service and provide consumers with a satisfactory experience in line with consumer preferences.
- Traffic management is essential to efficiently manage the limited mobile network capacity, while the traffic over the networks keeps growing.
- Not all traffic is equal; for example, voice is time-sensitive and therefore needs prioritisation.
- Mobile operators must continue to have the flexibility to manage their networks to deliver consumer choice and innovative services and market propositions. Restrictive regulation would limit the flexibility required to build a sustainable, well-functioning network.
Resources
Just as content providers offer differentiated services such as standard and premium content for different prices, mobile network operators will offer different bandwidth products to meet different consumer needs. Customers are benefitting from these tailored solutions; only those who want to use premium services will have to pay for the associated costs.
— GSM Association
Taxation
:Read moreBACKGROUND
INDUSTRY POSITION
- The mobile telecommunications sector has a positive impact on economic and social development. It generates significant economic effects, such as creating jobs and increasing productivity, and delivers considerable social benefits.
- Sector-specific taxes are levied on mobile consumers and operators in some countries. These include special communication taxes, such as excise duties on mobile handsets and airtime usage and revenue-share levies on mobile operators.
- Some countries have applied surcharges on international incoming traffic, which can act as a tax on other countries’ citizens and residents.
Debate
- Do sector-specific taxes result in greater long-term harmful effects than short-term gains in tax revenues?
- What is the impact on government’s tax receipts of removing mobile-specific taxes, taking into account the wider positive economic effects?
High, discriminatory, sector-specific taxes deter the take-up and use of mobile services and slow the adoption of ICT more generally. Lowering such taxes could benefit consumers, businesses and socio-economic development. - While mobile operators recognise that governments apply taxes to finance spending and generate externalities in sectors where private investment is lacking, often these taxation models are not efficient. Fiscal policy that applies a special tax to the telecommunications sector are inefficient and cause distortions that crowd out private spending and, in the end, diminish welfare.
- The GSMA encourages governments to lower or remove mobile-specific taxes because the long-term benefits of a vibrant mobile telecommunications sector outweigh any short-term contributions to the government budget.
- Emerging-economy countries need to align taxation approaches affecting mobile broadband with ICT national objectives. If broadband is understood as a key social and economic development lever, taxes cannot represent an obstacle for diffusion. Lowering the taxation burden on the sector increases mobile take-up and use, creating a multiplier effect in the wider economy.
- Imposing a high tax burden on mobile sends the wrong consumption and investment signals, and limits the potential socio-economic benefits of a vibrant mobile telecommunications sector.
- Taxing international calls negatively impacts consumers, businesses and citizens abroad, and damages the country’s competitiveness.
Resources
Mobile taxation research and resources, GSMA
Report: Mobile Taxation: Surtaxes on International Incoming Traffic
Report: Taxation and the Growth of Mobile Services in Sub-Saharan Africa
Report: The Impact of Taxation on the Development of the Mobile Broadband Sector
It is encouraging to see a growing number of tax administrators recognize that ICT services are different from other services, because of their capacity to stimulate economic growth and social development…. Governments that have committed to following best-practice ICT regulation are now reducing or even eliminating some sector-specific taxes — ITU would like to see all governments follow their lead.
— Dr. Hamadoun Touré, ITU Secretary-General
Universal Service Funds
:Read moreBACKGROUND
INDUSTRY POSITION
- Universal service — characterised by telecommunications that is available, accessible and affordable — has been adopted as a policy goal in many countries.
- Some countries have established universal service funds (USFs) on the premise that operators will not extend service to certain underserved areas without financial incentives. USFs are typically funded by levies on operator revenue.
- Commentators in many countries cite a lack of transparency and objectivity in administering USFs. Most funds do not follow the principle of technical and competitive neutrality in awarding contracts.
- Operators are required to contribute a share of their revenue to USFs despite the expansion of service to the vast majority of countries’ citizens and huge accumulations of undisbursed funds.
Debate
- How successful are USFs in increasing access to telecom services across the population?
- Would other strategies be more effective?
- Is it time to rethink USFs and remove the levy on operators?
USFs have not proven to be an effective means of achieving universal service. - Liberalised markets and private-sector investment have delivered telecommunication services to the vast majority of the world’s population, and consumers benefit from innovative services at affordable prices.
- There is little evidence that USFs, funded through operator levies, are an effective or efficient instrument to achieve universal service.
- Governments should consider incentives that facilitate market-based solutions. They can help by removing sector-specific taxes, stimulating demand and developing the supporting infrastructure.
- USFs that already exist should be targeted, time-bound and managed transparently. The funds should be allocated in a competitive and technically neutral way, in consultation with the industry.
- There is a strong case for USFs to be stopped or at a minimum their levy lowered.
Resources
A survey of 64 USFs for GSMA in September 2012 shows that:
- More than $US 11 billion of collected funds was unspent.
- More than one-third of the USFs had not yet disbursed any funds.
- More than 80% of funds either lacked clear targets or had failed to meet them.
Spectrum Management
and Licensing
2.1GHz Frequency Band
:Read moreBACKGROUND
INDUSTRY POSITION
- The 2.1GHz band, referring to 1.7/2.1GHz (3GPP band 4: 1710–1755MHz paired with 2110–2155MHz) in most countries in the Americas and 1.9/2.1GHz (3GPP band 1: 1920–1980MHz paired with 2110–2170MHz) elsewhere, has been licensed for 3G mobile services in most markets. However, several countries are yet to release this spectrum for mobile.
- To make affordable, effective mobile broadband services possible, these governments are urged to license the 2.1GHz spectrum to operators for mobile services.
- In some markets, due to political instability or regulatory uncertainty, investors (including mobile network operators) may not advocate immediate licence allocation; in some cases the timing of spectrum allocation depends on local factors.
- Excessive per-MHz spectrum costs are an issue in certain markets, as a result of governments seeking to ration spectrum in order to maximise short-term revenue from the auctions — such as the European or Indian 3G (2.1GHz) auctions.
- In Europe, where the core 1.9/2.1GHz paired band is heavily used for 3G by Member States, the European Commission and the Electronic Communications Committee (ECC) are currently considering how best to achieve greater use of the unpaired spectrum associated with the 2.1GHz band.
Debate
- Should the 2.1GHz band be allocated entirely to mobile?
- How should the licences be awarded to maximise value to society?
- Should spectrum caps be employed to enhance competition?
We support the release of the 2.1GHz band for mobile. - The 2.1GHz band should be licensed for mobile use in all markets to enable the deployment of mobile broadband services.
- Governments should not look to generate excessive fees from the licensing of 2.1GHz spectrum, as this can negatively impact network deployment, increase consumer prices and limit the economic benefits. Excessive fees also can result in unsold spectrum, further impeding policy goals of delivering mobile broadband access to everyone.
- As with other potential data bands, allocations larger than 2x10MHz per operator are preferable.
- Releasing the 2.1GHz band for mobile is critical for governments to enable the digital economy and to prevent a growing digital divide.
- In markets where 2.1GHz spectrum has not been released, we urge governments to release it as soon as possible.
Resources
Report: Licensing to Support the Broadband Revolution
By identifying inactive SIMs and multiple SIM ownership, we have developed the most accurate measurement of the global mobile subscriber base, which shows that only 45 per cent of the world’s population has subscribed to mobile services.
— Anne Bouverot, Director General, GSMA, October 2012
2.6GHz Frequency Band
:Read moreBACKGROUND
INDUSTRY POSITION
- The International Telecommunication Union (ITU) has identified the 2.6GHz band (2500–2690MHz) as a global band for international mobile telecommunications (IMT).
- The 2.6GHz radio spectrum band is a ‘capacity band’ for mobile broadband, well-suited for the next generation of mobile technologies that respond to the soaring demand for data-heavy content, such as video.
- The band is identified for IMT in all regions and has the potential to be used in a harmonised manner on a global basis. The harmonised use will result in economies of scale for industry and cheaper handsets for consumers, as well as increased flexibility for roaming.
- The ITU has proposed three possible band plans:
- Option 1: 2x70MHz for FDD with a 50MHz TDD in the centre gap
- Option 2: FDD only
- Option 3: Flexible TDD/FDD arrangement
Debate
- Should the 2.6GHz band be released in conjunction with the Digital Dividend band (700MHz/800MHz) to meet urban and rural coverage and capacity needs for mobile broadband?
We support ITU Option 1 for a globally harmonised 2.6GHz capacity band. - Global momentum in licensing 2.6GHz spectrum is behind ITU Option 1, including CEPT markets, Brazil and Canada. Where auctions have offered flexibility, markets have chosen standard band arrangements.
- The 2.6GHz band will be critical in meeting the capacity requirements of mobile broadband.
- ITU Option 1 is a technology-neutral option, supporting both TDD and FDD technologies (e.g., LTE and Wi-MAX).
- The spectrum available in the 2.6GHz band provides for large carriers such as 2x20MHz, which is ideal for the deployment of LTE. Larger carriers:
- Improve network performance, offering faster data transmission and greater capacity
- Reduce deployment costs
- Improve handset performance
- Higher frequencies (e.g., 2.6GHz) are better-suited to high data rates required to serve large numbers of users in urban areas, airports and other high-traffic areas.
- Governments should not look to generate excessive fees from the licensing of 2.6GHz spectrum, as this will negatively impact network deployment, increase consumer prices and limit the potential economic benefits. Excessive fees also can impede policy goals of delivering mobile broadband access to everyone.
Digital Dividend
:Read moreBACKGROUND
INDUSTRY POSITION
- The Digital Dividend refers to the spectrum made available for alternative uses, following the analogue-to-digital television switch-over.
- For mobile, the freed-up spectrum has made two potential bands available, 790–862MHz (aka the 800 band) used in ITU-R Region 1 (including Europe, Africa and the Middle East) and 698–806MHz (aka the 700 band) used in ITU-R Region 2 (Americas) and Region 3 (Asia Pacific).
- These frequencies are ideal for mobile, offering good coverage characteristics, reasonable capacity and availability in sufficient blocks for efficient use of spectrum for broadband.
Debate
- Should Digital Dividend spectrum be licensed to incumbent television broadcasters or to others, including mobile network operators, who offer greater long-term economic or societal value?
- Which band plan should countries adopt?
- Currently in ITU Region 1, a ‘second Digital Dividend’ band is being debated, which would extend the Digital Dividend band down to 694MHz.
A share of the Digital Dividend spectrum should be allocated to mobile. - The switch-over to digital television gives broadcasters significantly more capacity for additional channels or high-definition television, even when a portion of the dividend is allocated to mobile.
- The economic benefits of licensing this spectrum to mobile are far greater than allocating it to any other service.
- With the good signal propagation characteristics of radio signals in the frequencies below 1GHz, the Digital Dividend spectrum offers an excellent balance between transmission capacity and geographic coverage.
- The Digital Dividend is a key enabler for universal broadband access, bringing socio-economic benefits to people in cities as well as rural and remote areas where fixed-line penetration is low. It is reasonable for coverage obligations to be employed to ensure efficient use of this spectrum.
- Regional harmonisation of the band is necessary to drive economies of scale (keeping handset costs low) and avoid interference along national borders.
- Governments should not look to generate excessive fees from the licensing of Digital Dividend spectrum, as this will negatively impact network deployment, increase consumer prices and limit the potential economic benefits. Excessive fees also can impede policy goals of delivering broadband access to everyone.
Resources
Position Paper: Asia Pacific Digital Dividend/UHF Band Plans
Report: Economic Benefits of the Digital Dividend for Latin America
Report: Licensing to Support the Mobile Broadband Revolution
Governments need to raise broadband to the top of the development agenda, so that rollout is accelerated and the benefits are brought to as many people as possible.
— Dr Hamadoun Touré, ITU Secretary-General
Limiting Interference
:Read moreBACKGROUND
INDUSTRY POSITION
- There is always the potential for radio transmissions to interfere with radio systems operating in adjacent frequency bands, due to transmitter imperfections or imperfect receiver filtering.
- There are technical ways to mitigate interference. New technologies have become much better at doing this, although they have costs in terms of equipment price, energy efficiency and the ability to operate on multiple frequencies.
- The basic solution is to define appropriate radio transmitter and receiver parameters to ensure compatibility between radio systems operating in the same or adjacent frequency bands. However this may not apply to some technologies that lack standards.
- The traditional way to manage interference has been to establish ‘guard bands’ that are left vacant. However, these guard bands reduce the overall efficiency of spectrum use. Other interference-mitigation techniques should be employed as much as possible to minimise this loss of usable spectrum.
Debate
- Are guard bands the only way to prevent interference between mobile bands and systems using adjacent bands?
- Should potential interference be solved ex ante by the national regulatory authority before allocating new mobile spectrum to operators, or should this be left to the MNOs?
Interference can be managed with proper planning and mitigation techniques. - Potential cross-border interference is usually addressed through bilateral or multilateral agreements between neighbouring countries.
- Excessive restrictions such as overuse of guard bands may, however, make the use of spectrum inefficient. To minimise guard band size and the cost of interference mitigation, radio system standards defining transmitter and receiver RF performance are necessary.
- Broadcasters are rightly concerned that mobile services introduced in the UHF band do not interfere with television reception, and mobile operators are equally concerned that this does not happen. A television receiver standard would improve the situation.
Resources
Technical paper: Managing Radio Interference
GSMA briefing paper on WRC Agenda Item 1.17 — broadcast interference
Fact sheet: Potential for Interference to Electronics
The increasingly congested skies above our heads require careful management and monitoring, on a global basis, with intensive cooperation and discussion to avoid the risk of interference. That is one of the most important parts of ITU’s work, as the sole global agency charged with managing the world’s shared radio spectrum and orbital resources.
— Dr Hamadoun Touré, Secretary-General, ITU
Planning for Future Spectrum
:Read moreBACKGROUND
INDUSTRY POSITION
- The number of mobile connections and the volume of data moving through mobile networks continue to grow rapidly. According to Cisco, global mobile data traffic will increase 18-fold between 2011 and 2016.
- In advance of WRC15, targeted for the last quarter of 2015, ITU study groups are investigating how much spectrum will be needed to meet the demand for mobile services in the future. The GSMA and its members are working through formal ITU processes to ensure adequate spectrum is identified for international mobile telecommunications (IMT).
- This spectrum needs to be harmonised and in bands between ca. 400MHz and 5GHz, the frequency range appropriate for wide-area services.
- Globally harmonised bands are agreed through the WRC process, and the mobile industry is active in this work programme.
Debate
- How much spectrum will be required by the mobile sector, looking ahead to 2020 or 2025?
- What will mobile networks of the future look like, and how should we plan for continued explosive growth?
- What new uses of broadband will emerge?
The mobile industry will need more harmonised spectrum to deliver the economic and social benefits of broadband. - Mobile will play an increasingly important part in delivering broadband services to all, especially in developing economies where fixed-line penetration is low.
- Unless additional appropriate and commercially viable spectrum is allocated to mobile, the industry will find it increasingly difficult to provide the quality of service and data rates that consumers want and expect, at an affordable price.
- Mobile data traffic has overtaken voice traffic, and is following an exponential growth path. This is driven by video consumption, smartphones and new form factors such as tablets.
- If we don’t make provisions now for rising data demand, the mobile sector could be constrained for many years, given the time it takes to achieve international consensus on spectrum.
- The industry requires bands of reasonable size (100–200MHz) that are near existing mobile bands or that offer potential for international harmonisation.
Resources
Global Mobile Network Traffic: A Summary of Recent Trends
Briefing paper: GSMA-Suggested Suitable Frequency Bands
Briefing paper: WRC Agenda Item 8.2 — Spectrum for IMT
International Telecommunication Union (ITU)
Broadband Commission for Digital Development
Based on the growth observed between 2008 and 2010, Analysys Mason expects more aggressive growth in total mobile traffic during the period to 2015 than has been observed in previous years…. On the basis of recent forecasts, we estimate that mobile traffic will grow at a compound annual growth rate of 42%, to reach 28,000 PB per year in 2015.
— Analysys Mason, June 2011
Spectrum Caps
:Read moreBACKGROUND
INDUSTRY POSITION
- Spectrum caps are an approach used by governments and regulators to manage the allocation of spectrum during auctions. The intention is to use spectrum allocations to ensure effective downstream competition and to prevent existing operators from using their economic strength to secure large spectrum assets, potentially giving them a competitive advantage in the future.
- Spectrum caps are increasingly used by regulators in determining auction rules, to encourage reallocation of spectrum and balance operator portfolios.
- New entrants and players with limited spectrum assets typically support caps on new spectrum allocations, while incumbents argue that the approach negatively impacts the quality of services they can deliver to consumers.
Debate
- Does the use of caps in spectrum allocation, in fact, result in the best social and economic outcomes?
- Are spectrum caps the best way to address market dominance?
Spectrum caps may be appropriate where there is not effective competition, but need to be deployed cautiously to avoid unintended consequences that may lead to poor outcomes for consumers. - Operators should not be penalised for using their spectrum assets successfully or be constrained in delivering new services. Usually operators with largest market share are the ones that need more spectrum to meet customer demand.
- Spectrum caps, when applied holistically, distribute spectrum among market players and potentially to new entrants. The caps, if imposed, should allow for all market players to deploy networks in a technically and economically efficient manner.
- Using spectrum caps with the specific purpose of facilitating market entry for new entrants can lead to spectrum fragmentation and market inefficiencies which, ultimately, will have an impact on consumers and businesses using the services.
- Whilst caps are a mechanism that prevent the possibility of spectrum hoarding and downstream market concentration, if defined too tightly they can harm the ability for market players to effectively and efficiently deploy next generation networks.
- While caps are a mechanism that prevent the possibility of spectrum hoarding and downstream market concentration, if defined too tightly they can harm the ability for market players to effectively and efficiently deploy next generation networks.
- Before applying spectrum caps, regulators should conduct a rigorous market analysis to ensure there are, in fact, other operators in the market whose access to spectrum would deliver greater societal benefits.
- Licensing rules relating to spectrum caps must give operators the opportunity to secure a portfolio of spectrum to deliver economically viable broadband services.
- Market dominance should not be addressed through spectrum caps, but through antitrust measures.
- Alternative licence conditions relating to network deployment and spectrum usage may, in many circumstances, lead to more effective outcomes for consumers than specific spectrum caps.
Spectrum Harmonisation
:Read moreBACKGROUND
INDUSTRY POSITION
- Spectrum harmonisation refers to the uniform allocation of radio frequency bands across entire regions.
- Common frequency bands for mobile, between neighbouring countries and across regions, offer many advantages:
- Lower costs for consumers, as device manufacturers can mass-produce less complex devices that function in multiple countries on a single band
- Availability of a wider portfolio of devices, driven by a larger, international market
- Roaming, or the ability to use one’s mobile device abroad
- Less cross-border interference
- There are a limited number of bands that can be supported in a mobile device. Each new band supported increases the device cost, reduces the receiver’s sensitivity and drains the battery.
- Harmonised bands have enabled huge economies of scale, leading to unprecedented use of mobile telephony worldwide.
Debate
- How big does a market need to be before the commercial benefits of harmonisation become marginal?
- How harmonised does a band need to be to realise the benefits of harmonisation?
- In the future, will cognitive technologies enable devices to tune dynamically to any band — removing the incentive for countries to harmonise?
Spectrum harmonisation is critical and will remain so for the foreseeable future. - Harmonisation leads to economies of scale for device manufacturers, which in turn lead to cheaper devices for consumers and a greater uptake of mobile services.
- While global harmonisation of mobile bands would be ideal, it is rarely possible or practical. Therefore, harmonisation within ITU-R regions, at least, is crucial.
- Even small variations on standard band plans can result in device manufacturers having to build market-specific devices, with costly consequences for consumers.
- All markets should harmonise regionally where possible, as this benefits the entire global mobile ecosystem. There is no advantage to going it alone.
- Cognitive radio technologies will not reduce the need for harmonised mobile spectrum anytime soon. Harmonisation to a limited number of internationally recognised band plans is the only way to achieve large economies of scale.
Resources
Report: The Benefits of Releasing Spectrum for Mobile Broadband in Sub-Saharan Africa
Report: Economic Benefits of the Digital Dividend for Latin America
A lot more harmonised spectrum is required if mobile broadband in sub-Saharan Africa is to provide sufficient capacity to users at affordable prices. Currently, mobile operators in a typical sub-Saharan African country have access to around 360MHz of spectrum between them for mobile services. In contrast, operators in many high-income countries have access to 550MHz of suitable spectrum.
— Plum Consulting, 2011
Spectrum Licence Renewal
:Read moreBACKGROUND
INDUSTRY POSITION
- Many of the original 2G licences are coming up for renewal in the next few years. An issue for many licensing authorities is what should happen to spectrum rights as licences approach the end of their initial term.
- The prospect of licence expiry creates significant uncertainty for mobile operators. A transparent, predictable and coherent approach to renewal is therefore important, enabling operators to make rational, long-term investment decisions.
- While market circumstances dictate the best approach to renewal, an open and consultative approach with operators will lead to the best outcomes.
Debate
- How long before the end of a licence term should governments determine the approach to licence renewal?
- Should spectrum licence holders presume they will have the option to renew when the licence reaches the end of its term, unless otherwise specified in the licence?
- Should governments reshuffle allocations, change bandwidths and/or licence conditions on renewal?
Governments should have a transparent and predictable regulatory framework for renewing spectrum usage rights. - The award of spectrum usage rights should be completed well before an existing licence expires — ideally upon initial issuance of a licence along with a renewal expectancy or at minimum three to five years in advance — to ensure continued investment in networks.
- Governments and regulators should provide a clear and open spectrum road map to allow operators to plan their investments with a clear understanding of spectrum availability, costs and obligations.
- There should be a presumption in favour of licence renewal, minimising the risk of service disruption to customers.
- Reasons for not renewing licences should be limited to cases of spectrum replanning, market failure that has led to a lack of competition, or the serious breach of licence conditions.
- Spectrum replanning must be timely and carried out in consultation with the industry and in an open and transparent way.
- The cost of renewing spectrum usage rights should be based on achieving the best outcome, rather than maximising short-term revenue for government.
- Spectrum refarming and reallocation should follow international or regional best practices and be conducted according to predetermined procedures.
Spectrum Trading
:Read moreBACKGROUND
INDUSTRY POSITION
- Spectrum trading is a mechanism by which mobile network operators can trade spectrum resources to improve the efficiency or capacity of their networks.
- The regulatory framework should facilitate trading spectrum usage rights, allowing organisations to trade assets with restrictions only applied where there are compelling reasons, usually related to competition concerns.
- GSMA recognises that spectrum should be distributed in a way that ensures competition in downstream markets. Governments may wish to balance the interests of operators engaging in voluntary spectrum trading with the objective of ensuring distribution of spectrum to promote competition.
Debate
- Should spectrum-trading arrangements between mobile network operators be allowed?
- What role should regulators play in overseeing such arrangements?
- What regulatory procedures are required to ensure transparency and notification of voluntary spectrum trading?
Countries should have a regulatory framework that allows operators to engage in voluntary spectrum trading. - Spectrum trading creates increased flexibility in business planning and ensures that spectrum does not lie fallow, but instead is used to deliver valuable services to citizens.
- If there is no compelling reason to restrict the trade of spectrum usage rights, it should be facilitated within the regulatory framework.
- Spectrum trading agreements are governed by commercial law and subject to the rules applicable to such agreements. They may be subject to assessment under competition law.
- It makes sense for governments to be notified of spectrum trading agreements and to grant approval. Notification requirements preserve transparency, making it clear which entities hold spectrum usage rights and ensuring that trading arrangements are not anti-competitive.
- Governments should implement appropriate and effective procedures for handling notification requests of spectrum trading agreements.
Spectrum Valuation and Allocation
:Read moreBACKGROUND
INDUSTRY POSITION
- Spectrum valuation and licensing is a complex area. Allocation of spectrum can be achieved by administrative procedure, where governments decide how to allocate, by ‘beauty contest’, where licensees are selected by specific attributes or proposals, or by auction, of which there are numerous variations.
- Spectrum valuation is inherently difficult. Benchmarking across markets is hard, and economic valuations difficult to apply. Today, most governments use auctions to license spectrum, as this is the most efficient approach.
Debate
- How is the value of spectrum best determined?
- What is the most effective allocation approach — auction or beauty contest?
- What are the main considerations for auction design, to achieve the government’s desired outcomes?
- Should governments design auctions to maximise short-term revenue or to ensure an economically efficient means of allocating a scarce resource?
Fair allocation of spectrum at a reasonable cost to industry will maximise the value generated by a spectrum band. - The cost of spectrum usage rights should be based on achieving the best outcome for society, rather than generating short-term revenue for government.
- Reserve pricing for spectrum auctions should be set at a level that discourages frivolous and speculative bidding, but not so high as to discourage participation from serious bidders. Setting excessive reserve prices can leave spectrum unsold, an undesirable outcome for many reasons: it results in latent spectrum and inefficient use of a valuable resource; it undermines the legitimacy of auction prices by creating artificial spectrum scarcity; and future attempts to license unsold spectrum could be challenged by bidders that paid more in the first auction.
- Where spectrum is scarce and in high demand, market-based award procedures ensure that spectrum bands are not left idle, but are allocated to the services valued the most, and to operators best-equipped to deliver them.
- Throughout the auction design and execution process, regulators should work with stakeholders to ensure the auction design is fair, transparent, nondiscriminatory and appropriately designed.
- There is no one-size-fits-all design for spectrum auctions. Each auction needs to be designed according to market circumstances the objectives of the auction.
- Allocating spectrum to organisations that don’t have the ability to deploy is a poor allocation of a scarce resource.
- Usage restrictions reduce the value of spectrum. By setting clear rules for spectrum use — such as coverage obligations or technical restrictions — the value of spectrum can be gauged more accurately.
Resources
Report: Licensing to Support the Broadband Revolution
The countries that get their spectrum policy right will achieve widespread access to affordable and innovative mobile broadband services. Strong communications infrastructure, in turn, brings significant wider economic benefits including in boosting productivity and living standards.
— Competition Economists Group, 2012
Technology Neutrality and Change of Use
:Read moreBACKGROUND
INDUSTRY POSITION
- Technology neutrality is a policy approach that allows the use of any noninterfering technology in any frequency band. In practice, this means that governments allocate and license spectrum for particular services (e.g., broadcasting, mobile, satellite), but do not specify the underlying technology used (e.g., 3G, LTE or WiMAX).
- Many of the original mobile licences were issued for a specific technology, such as GSM or CDMA, which restricts the ability of the licence holder to ‘refarm’ the band using an alternative, more efficient technology.
- Refarming refers to the repurposing of frequency bands that have historically been used for 2G mobile services (using GSM technology) for newer technologies, including third-generation (UMTS technology) and fourth-generation (LTE technology) mobile services.
Debate
- Should governments set the technical parameters for a band’s use or should the market decide?
- Should licence conditions restrict operators’ ability to deploy more efficient technologies and adapt to market changes?
- How do you manage interference between services and between operators using different technologies?
We support a technology-neutral approach to the use of mobile frequency bands. - Adopting harmonised, regional band plans for mobile ensures that interference between services can be managed. Governments should now allow operators to deploy any mobile technology that can technically co-exist within the international band plan.
- Technology neutrality encourages innovation and promotes competition, allowing markets to determine which technologies succeed, to the benefit of consumers and society.
- Spectrum allocations for IMT are technology-neutral. IMT technologies including GPRS, EDGE, UMTS, HSPA, LTE and WiMAX are standardised for technical co-existence.
- Governments should amend technology-specific licences to allow new technologies to be deployed, enabling operators to serve more subscribers and provide each subscriber with better, more innovative services per unit of bandwidth.
- The ability to ‘refarm’ licensed spectrum is good for economic and social development and should be allowed.
Resources
Position Paper: Change of Use of Spectrum
Report: Licensing to Support the Broadband Revolution
We know that the choice of the wrong standard can lock our economies into long periods of economic underperformance, while market-led solutions have consistently provided a much better environment for technology selection.
— European Commissioner Viviane Reding, 4 December 2006
Consumer
Protection
Child Online Protection
:Read moreBACKGROUND
INDUSTRY POSITION
- Children require a safe and secure environment to allow them take advantage of the benefits of new technologies.
- Mobile phones, like any tool, can potentially be used in a way that harms children.
- As mobile becomes the predominant method by which teenagers and younger children access the internet, the GSMA and its members have a role to play in ensuring a safer mobile experience for them.
Debate
- Is the ICT industry doing enough to protect children when they are online?
- Some governments expect online child protection to be addressed solely through technology. Can technology alone protect young people from online threats, or are education and awareness equally essential components?
- Should governments impose regulations on mobile operators or service providers?
The mobile industry has taken active steps in the area of child online protection and broader issues such as illegal content. The GSMA has led the way in self-regulatory initiatives dealing with issues such as parental controls, education and awareness, and online child abuse images. - Mobile operators need to be vigilant in their work to protect and support younger customers, while ensuring the mobile experience for young people is positive and enriching.
- The GSMA is engaged with international initiatives related to child online protection, including the ITU’s Child Online Protection programme, and actively engaged with governments and regulators looking to address this issue.
- Addressing child online protection is best approached through multi-stakeholder efforts.
- The GSMA leads several initiatives related to young people’s use of mobile services:
- To drive industry-wide initiatives designed to protect young people using mobile services
- To promote the safe and rich use of mobile services for the benefit of young people
- To provide useful research documents and point to further information
- To provide a better understanding of how young people across the world use their mobile devices
- The GSMA also runs the Mobile Alliance, a global mobile industry initiative to help combat child sexual abuse content. The Alliance’s objectives are to create significant barriers to the misuse of mobile networks and services for hosting, accessing or profiting from child sexual abuse content and to help stem and ultimately reverse the growth of online child sexual abuse content.
Resources
European Framework for Safer Mobile Use
GSMA and NTT DOCOMO research on children’s use of mobile
Mobile Alliance Against Child Sexual Abuse Content
I always point to mobile as an exemplary illustration of how self-regulation can achieve results.
— John Carr OBE, eNacso
Electromagnetic Fields (EMF) and Health Policy
:Read moreBACKGROUND
INDUSTRY POSITION
- There is concern in some countries about the safety of the radio frequency signals used for mobile communications.
- The consensus of many expert groups and public health agencies, such as the World Health Organization (WHO), is that no health risks have been established from exposure to the low-level radio signals used for mobile communications.
- The mobile industry has been working with national and local governments to help address public concern about mobile communications.
- The public can be reassured by the adoption of evidence-based national policies concerning exposure limits, siting antennas, consultation and the provision of information.
Debate
- What procedures should be implemented to avoid undue delay in approvals for antenna siting?
- What electromagnetic field (EMF) exposure limits should be specified for base stations?
We encourage national authorities to implement EMF-related policies based on established science, in line with international recommendations and technical standards. - The WHO and the International Telecommunication Union (ITU) recommend that governments adopt radio-frequency (RF) exposure limits based on the International Commission on Non‐Ionizing Radiation Protection (ICNIRP) guidelines.
- Large differences between national limits and international guidelines can foster confusion for regulators and policymakers and increase public anxiety.
- Consistency is vital. We urge governments to:
- Base policy on reliable information sources including the WHO, trusted health authorities and academics
- Set a national policy covering the siting of masts, balancing effective network rollout with fair consideration of public concerns
- Confirm that operators meet relevant RF levels by seeking declarations of compliance based on international compliance standards from organisations such as the International Electrotechnical Commission (IEC) and, perhaps, by conducting periodic measurements of a sample of sites
- Adopt EMF limits for mobile devices that are harmonised with the ICNIRP recommendations and use international testing standards
Resources
WHO overview: Electromagnetic Fields
WHO: EMF Standards and Guidelines
ICNIRP — International Commission on Non-Ionizing Radiation Protection
Scientific assessments of risk and science-based exposure limits should not be undermined by the adoption of arbitrary cautionary approaches.
— World Health Organization
Electromagnetic Fields (EMF) and Health: the Science
:Read moreBACKGROUND
INDUSTRY POSITION
- Research into the safety of radio signals has been conducted for more than 50 years.
- This body of evidence has contributed to the development of human exposure standards, including safety factors that provide protection against all established health risks.
- The World Health Organization (WHO) established the International EMF Project in 1996 to assess the health and environmental effects of exposure to electromagnetic fields (EMF) from all sources. The WHO reviews ongoing research and provides recommendations for research to support health risk assessments.
- The WHO estimates that, since 1997, over $200 million has been spent addressing EMF research recommendations.
Debate
- Mobile phones and other wireless technologies have become an integral part of everyday life. But does using a mobile phone regularly, or living near a base station, have any implications for our health?
The consensus of many expert groups and public health agencies, such as the WHO, is that no health risks have been established from exposures to the low level radio signals used for mobile communications. - Scientific knowledge in this area is now more extensive than for most chemicals.
- The WHO has identified areas for continuing research to support future health risk assessments.
- GSMA has supported an active program of addressing concerns about the possible health risks from the radio signals used to provide mobile services.
- GSMA research priorities have been guided by the WHO research recommendations and expert reviews from around the world.
- GSMA and its members have worked to support the needs of health risk assessments, to develop safety standards and to provide information to inform policy development.
- Studies are conducted at independent institutions, follow good laboratory practice and are governed by contracts that encourage open publication of findings in peer-reviewed scientific literature.
Resources
GSMA: Mobile and Health resources
World Health Organization International EMF Project
Current evidence does not confirm the existence of any health consequences from exposure to low-level electromagnetic fields.
— World Health Organization
Environment and Climate Change
:Read moreBACKGROUND
INDUSTRY POSITION
- The information and communication technology (ICT) sector is responsible for approximately 2% of global CO2e emissions, and this proportion is increasing. The mobile industry is responsible for a small fraction of ICT greenhouse gas emissions, but energy is a significant cost for mobile operators, especially in emerging markets.
- Research has identified the potential for mobile applications to reduce the greenhouse gas emissions in other sectors — transportation, buildings and smart grids, for example — by the equivalent of four to five times its own emissions footprint.
- The European Union, in particular, is pushing for the ICT sector to use detailed carbon accounting to help the EU meet carbon reduction targets.
Debate
- Should the ICT industry reduce its own greenhouse gas emissions in parallel with putting effort into ICT-enabled emission reduction in other sectors?
- Many companies disagree with detailed carbon accounting, which is complex and has no agreed methodology. Should the mobile sector focus, rather, on measures to reduce emissions, energy and costs through energy efficiency?
The mobile industry is measuring its energy consumption and taking action to reduce greenhouse gas emissions. The industry is also developing applications that can lead to emissions reductions in other sectors. - Mobile’s Green Manifesto includes a forecast that global greenhouse gas emissions per connection will drop by 40% by 2020 versus 2009.
- GSMA launched the Mobile Energy Efficiency (MEE) benchmarking service, which now includes 26 mobile network operators, accounting for more than 170 networks. MEE enables operators to compare their networks internally as well as externally against four energy indicators.
- GSMA is collaborating with the EC and the ITU to ensure that the MEE methodology is adopted as a global standard.
- Analysis of 34 mobile networks shows that total network energy consumption increased only slightly from 2009 to 2010, despite considerable growth in mobile connections and traffic. Total energy per unit traffic declined by approximately 20 per cent and energy per connection declined by five per cent.
Resources
Mobile Energy Efficiency on GSMA.com
Mobile’s Green Manifesto 2009 and 2012 update
“Mobile communications has the potential to enable emissions savings of at least 900 million tonnes CO2e in 2020 — five times the mobile industry’s own emissions. Analysis of 34 mobile networks worldwide shows total energy per unit traffic declined by approximately 20 per cent, and energy per connection declined by five per cent, from 2009 to 2010.”
— Mobile’s Green Manifesto, June 2012
Mandatory Prepaid SIM Registration
:Read moreBACKGROUND
INDUSTRY POSITION
- A number of countries have introduced mandatory registration of prepaid SIM cards in an attempt to counter terrorism and improve the efficiency of law enforcement.
- To date, there has been no evidence to suggest that a prepaid SIM registration policy leads to a reduction in mobile communications-based crime.
- Some governments have been considering prepaid SIM registration in the context of introducing e-commerce and e-government services for citizens.
- A few countries have examined the merits of such regulation, but concluded against it, mainly because the potential loopholes and implementation challenges were considered excessive. These challenges include:
- Customers failing to understand the consequences of not registering and having their SIM deactivated without warning
- Social and economic exclusion of people and groups who previously relied on prepaid SIMs
- The creation of more criminality, including black markets for illegally registered or stolen SIM cards
Debate
- To what extent will the benefits of mandating prepaid SIM registration outweigh the costs/risks in a specific market?
While we take a neutral stance on mandatory registration of prepaid SIM cards, governments considering such regulation should first conduct impact assessments and examine local market conditions - We believe the successful adoption and implementation of prepaid SIM registration regulation depends on careful consideration of a number of factors including the following:
- Identity requirements (Does the country hold good ID records? Registration depends on available forms of identification that are robust against counterfeiting.)
- Points of sale (Where can consumers buy prepaid SIMs?)
- Public awareness (Do consumers know what to do?)
- Availability and means of registration (Are they straightforward, including in rural and isolated areas?)
- Implementation timescales (Are they practical and realistic?)
- Consequences of nonregistration (Is regulation flexible?)
- Retention of registration (How will this be done, and is it proportionate?)
- Reserve powers of the National Regulatory Authority
- Administrative sanctions for noncompliance (Need to be clear)
- The technological capabilities/flexibilities of the market (e.g., ability to use secure electronic databases, as opposed to paper copies, etc.)
Resources
Article: Implications of Mandatory Registration of Mobile Phone Users in Africa
Article: Rwanda SIM Cards to Be Registered Electronically
Article: Uganda to Streamline SIM Card Registrations
Article: Kenya CCK to Restart SIM Registration
Article: Nigeria NCC to Disconnect Unregistered Subscribers Soon
Blog post: SIM Card Registration Around the World
Article: The Hindu: Prepaid Cellphone Users Short-Changed?
Customer identification can become a constraint in countries with an insufficient identification infrastructure, if no alternative methods for identification are allowed…Regulators should more thoroughly analyse the costs and benefits of mandatory registration, because these could affect market dynamics in unintended ways.
— Nicola Jentzsch, 2012, from Implications of Mandatory Registration of Mobile Phone Users in Africa
Mobile Device Theft
:Read moreBACKGROUND
INDUSTRY POSITION
- Unfortunately, there are criminals who seek to gain from the trade of stolen mobile phones, feeding a black market in handsets obtained through mugging and street crime.
- Policymakers in many countries are concerned about the incidence of mobile phone theft, particularly when organised crime becomes involved in the bulk export of stolen handsets to other markets.
- In 1996, GSMA launched an initiative to block stolen mobile phones, based on a shared database of the unique identifiers of handsets reported lost or stolen. Using the International Mobile Equipment Identifier (IMEI) of mobile phones, GSMA maintains a central list — known as the IMEI Database — of all phones reported lost or stolen by mobile network operators’ customers.
- The efficient blocking of stolen devices on individual network Equipment Identity Registers (EIRs) depends on the secure implementation of the IMEI on all mobile handsets. The world’s leading device manufacturers have agreed to support a range of measures to strengthen IMEI security, and progress is monitored by GSMA.
Debate
- What can industry do to prevent mobile phone theft?
- Should regulations be imposed on mobile device registration?
- What are the policy implications of this rising trend?
Although the problem of handset theft is not of the industry’s creation, the industry is part of the solution. - If lost or stolen mobile phones can be rendered useless, they will have no value on the black market, removing all incentive for thieves.
- GSMA encourages its member operators to deploy EIRs on their networks to deny connectivity to any stolen device. Operators should connect to GSMA’s IMEI Database to ensure devices stolen from their customers can be blocked on networks that use the database.
- IMEI blocking has had a positive impact in many countries, but for a truly effective anti-theft campaign, a range of measures must be put in place, not all of which are within the control of the mobile industry.
- National authorities have a significant role to play in combatting this criminal activity. It is critical that they engage constructively with the industry to ensure the distribution of mobile devices through unauthorised channels is monitored and that action is taken against those involved in the theft or distribution of stolen devices.
- A coherent regional information-sharing approach involving all relevant stakeholders would make national measures more effective.
- Some national authorities have proposed national ‘whitelists’ to combat mobile terminal theft. The GSMA opposes this approach, which could impede the free movement of mobile devices around the world and would be considered illegal in some countries.
Resources
OAS briefing paper on the theft of mobile terminal equipment
Security Principles Related to Handset Theft
IMEI Security Weakness Reporting and Correction Process
Case Study: Mobile Phone Theft in Costa Rica
Q&A: Consumer precautions against mobile phone theft
News Release: Latin American Mobile Operators Commit to Combat Mobile Device Theft
“Handset theft has increased significantly in recent years, and handsets are becoming more attractive to thieves. Every stolen phone causes misery, possible violence and psychological consequences for mobile users.”
— James Moran, Security Director, GSMA
Mobile Security
:Read moreBACKGROUND
INDUSTRY POSITION
- Security attacks threaten all forms of ICT, including mobile technologies.
- Consumer devices such as mobile handsets are targeted for a variety of reasons, from changing the IMEI number of a mobile phone to re-enable it after theft through to data extraction or the use of malware to perform functions that cause harm to users.
- Mobile networks use encryption technologies to make it difficult for criminals to eavesdrop on calls or intercept data traffic. Legal barriers to the deployment of cryptographic technologies have been reduced in recent years and this has allowed mobile technologies to incorporate stronger and better algorithms and protocols, which remain of significant interest to hackers and security researchers.
- The emerging area of Near Field Communications (NFC) has raised the concept of electronic pickpocketing, or hacking into someone’s NFC-enabled account from close proximity. This potential threat has received more attention as NFC applications gain market traction.
Debate
- How secure are mobile voice and data technologies?
- How significant is the threat of mobile malware, and what is being done to mitigate the risks?
- Do emerging technologies and services create new opportunities for criminals to steal information, access user accounts or otherwise compromise the security and safety of mobile networks and those that use them?
The protection and privacy of customer communications are at the forefront of operators’ concerns. - The mobile industry is committed to maintaining the integrity of its communications services. While no security technology is guaranteed to be unbreakable, the barriers to compromising mobile technologies, and UMTS and LTE in particular, are extremely high, rendering any but the most technically complex attempts ineffective.
- Although mobile malware has not reached predicted epidemic levels, the GSMA is aware of the potential threats and has established a Mobile Malware Group to coordinate the operator response to identified threats. The group facilitates the prompt exchange of information between industry stakeholders and encourages best practice to manage and handle malware by producing comprehensive guidelines for its members.
- Reports of GSM eavesdropping capabilities are not uncommon, but such attacks have not taken place on a wide scale, and there are no known cases of eavesdropping on UMTS or LTE networks.
- The GSMA supports global security standards for emerging services and acknowledges the role that SIM-based secure elements can play, as an alternative to embedding the security into the handset or an external digital card (microSD), because the smart card has proven itself to be resilient to attack.
- The GSMA plays a key role in coordinating the industry response to security incidents, and it cooperates with a range of stakeholders including its operator members, device manufacturers and infrastructure suppliers to ensure a timely and appropriate response.
- The GSMA constantly monitors the activities of hacker groups, as well as researchers, innovators and a range of industry stakeholders to improve the security of communications networks. Our ability to learn and adapt can be seen from the security improvements from one generation on mobile technology to the next.
mYouth
:Read moreBACKGROUND
INDUSTRY POSITION
- Mobile technology is an intrinsic part of young people’s lives, in a way we could never have imagined only a few years ago.
- Children and young people are some of the most engaged adopters of mobile technology. They embrace the benefits and opportunities in a way that often outstrips the knowledge of parents, guardians and teachers.
- This is having a tremendous positive impact on their lives — teaching them new skills, allowing them to learn in different ways, exposing them to people from different segments of society, and encouraging creativity and innovation.
- Young people are future consumers and innovators, and their opinions count.
Debate
- For some time, the debate around young people and mobile has focused on protection from the harmful risks of the internet.
- Widespread recognition of the benefits that mobile brings to young people has helped changed the debate to a more positive discussion.
Mobile technologies are highly valuable tools for young people, in developed and developing countries alike. - Mobile devices and services enhance the lives of young people. This perspective needs to be embraced, encouraged and better understood by all stakeholders to ensure young people get the maximum benefits, including:
- Skills for employment
- Enhanced formal and informal education and learning
- Information and services to aid in health and well-being
- Improved social engagement
- Opportunities to be creative
- In terms of mobile industry innovation, the point of view of young people is critically important, as they are among the first people to have grown up knowing only a connected, always-on world. They are not only future consumers, but they include future innovators with the potential to bring in the next wave of innovation in mobile.
Resources
GSMA research: Children’s Use of Mobile Phones
Young people are the ‘first unconscious participants’ in an era when everyone has access to everything, everywhere, at every time.
— Tammy Erickson, HBR blog
Number Resource Misuse and Fraud
:Read moreBACKGROUND
INDUSTRY POSITION
- Many countries have serious concerns about number resource misuse, an abusive practice whereby calls never reach the destination indicated by the international country code, but are terminated prematurely through carrier and/or content provider collusion to revenue-generating content services without the knowledge of the ITU-T-assigned number range holder.
- This abuse puts such calls outside any national regulatory controls on premium-rate and revenue-share call arrangements, and is a key contributing factor to International Revenue Share Fraud (IRSF) perpetrated against telephone networks and their customers.
- Perpetrators of IRSF are motivated to generate incoming traffic to their own services with no intention of paying the originating network for the calls. They then receive payment quickly, long before other parts of the settlement.
- Misuse also affects legitimate telephony traffic, through the side-effects of blocked high-risk number ranges.
Debate
- Should the misuse of number resources be addressed through an international treaty?
- How can industry players collaborate to address this type of fraud?
Number resource misuse has a significant economic impact for many countries, so multi-stakeholder collaboration is key. An international treaty is not the correct instrument for combating this issue. - Number resource misuse is one of the topics currently being addressed by the GSMA Fraud Forum, a global conduit for best practice with respect to fraud management for mobile network operators.
- The Fraud Forum’s main focus is to identify and analyse techniques used to perpetrate fraud against member networks and to recommend practical, cost-effective solutions.
- Multi-stakeholder collaboration and coordination through best practices is key.
- When misuse is reported by a GSMA member, the Fraud Forum formally reports this to the ITU-T.
- The Fraud Forum is working to engage European regulators on tackling number resource misuse.
- The Fraud Forum shares abused number ranges among its members and with other fraud management industry bodies.
- The Fraud Forum works with leading international transit carriers to reduce the risk of fraud that arises as a result of number resource misuse.
Resources
GSMA’s fraud management resources are available to members only.
Privacy
:Read moreBACKGROUND
INDUSTRY POSITION
- The rise of the smart phone, combined with the growth in the mobile internet, has created a globally connected mobile ecosystem. This brings incredible opportunities and benefits to consumers and society.
- However, it is also creating concern over customers’ privacy and the security of their personal information when using mobile devices.
- Online privacy is subject to a patchwork of inconsistent industry and technology approaches, and geographically bound national and local laws (where they exist). But new mobile apps, services and data flows are global and immediate. These approaches and geographically-bound privacy laws are not interoperable and seem unable to provide an effective privacy experience for mobile users in a globally connected world.
- Research shows mobile customers want transparency, choice and control over their information. They are especially concerned about apps that ‘secretly’ access and use their personal information.
Debate
- What are the challenges that the mobile ecosystem is facing in addressing user privacy concerns?
- What are the implications if governments prescribe rules that differ in each country, or vary by platform or technology?
- How can the various players in the mobile ecosystem come together to identify mobile-friendly ways to help users make informed and meaningful decisions about their privacy?
We believe industry collaboration is crucial to identifying mobile-friendly ways to help users manage their privacy across the global mobile ecosystem, and to promote trust. - Customers want their privacy to be respected and protected, regardless of the type of device, platform or service they are using or where the service provider is based.
- Industry must work together to build and promote trust among users by agreeing globally relevant principles.
- Policymakers should apply the same rules to all players in the mobile ecosystem. Such rules must also reflect the global nature of apps and services and be interoperable between countries.
- Policymakers should ensure that data protection and privacy rules are clear and flexible enough to address potential future risks, while encouraging continued innovation in technology and information use.
- The GSMA is committed to working with stakeholders from across the mobile ecosystem to establish effective and consistent privacy experiences for mobile users, and to ensure that privacy is a key consideration whenever new mobile services are developed.
Resources
Mobile and Privacy on GSMA.com
Privacy Design Guidelines for Mobile Application Development
We believe that privacy matters. Through its Mobile Privacy Initiative (MPI) the GSMA published a set of universal Mobile Privacy Principles in 2011 that describe how mobile consumers’ privacy should be respected and protected. The GSMA has also published and members are implementing a set of Privacy Design Guidelines for Mobile Application Development.— Pat Walshe, Director of Privacy, GSMASpam
:Read moreBACKGROUND
INDUSTRY POSITION
- Attack techniques constantly change, as spammers identify new opportunities in the ever-changing technological, social, political and economic environment. Advances in spam detection and prevention have to follow these changing techniques.
- Spammers are not inclined to obey local or international laws. The only effective way to prevent spam is to stop the messages from being delivered.
- Spam is being discussed at many international law enforcement conferences and by multi-stakeholder organisations, including the Internet Engineering Task Force, and the Internet Governance Forum.
Debate
- How can spam-related threats be addressed in the context of mobile services?
- Are industry-led solutions the most effective approach?
We are committed to combatting mobile spam by implementing technical solutions and advancing spam-prevention mechanisms. - Technology allows spammers to easily cross borders and evade local laws and law enforcement. Effectively addressing the problem requires global collaboration in law enforcement and technology.
- Mobile network operators are defending against these threats, continually protecting the quality of the mobile service and reinforcing subscriber trust.
- The GSMA has developed a Mobile Spam Code of Practice, a coordinated effort among mobile operators to prevent spam on mobile networks.
- GSMA also introduced a Spam Reporting Service (SRS) which enables consumers to easily report spam using a universal short code, and allows participating operators to share attack intelligence and take action.
- We believe that an international telecoms treaty is not the correct instrument for combating spam, as this could potentially raise sensitive issues regarding commercial or political free speech.
- We also believe that formal regulatory measures to address spam should be introduced as a last resort, focused at the national level and only implemented after detailed impact assessments have been conducted.
Resources
Cloudmark spam-reporting clearing house
GSMA Mobile Spam Code of Practice
The GSMA Spam Reporting Service will not only help defend against today’s attacks, but proactively help protect our customers and our network from new and emerging mobile threats.
— Ed Amoroso, Chief Security Officer, AT&T
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