Letter from Mr Keith Porteous Wood
I am a parliamentary researcher but am submitting
this short response to the call for evidence in my private capacity.
(i) Do you consider charges for making and
receiving calls on mobile phones when in a different EU Member
State to be appropriate or excessive as some have argued? EXCESSIVE
Do you think there is currently sufficient competition
in the market? NO
Comment on above two questions:
Calls from UK landline to US landlines and mobiles
can be as little as 2 p per minute. Yet calls to EU mobiles is
10 times that, which suggests extortionate fees in the EU relative
to the US, where there seems no logical reason for the cost base
to be any lower. Part of the reason these high costs is the massive
charges made by the Chancellor in auctioning off air space, which
is in effect a huge hidden tax on mobile phone usage.
Frequent European travellers end up paying massive
roaming charges, even with Vodafone passport at around 75p supplement
per inward an outward call for minimal marginal cost by the operators
that are mainly in European groupings. Other operators are much
more expensive still. This is a constraint to trade because users
feel constrained not to use their mobile phones when abroad because
of the excessive cost but are nevertheless traveling freely and
frequently in the EU.
(ii) Is it appropriate for the Commission
to introduce legislation to cap the cost of roaming? YES
I suggest a £1 a month maximum cap. Regulators
should not forget that operators will gain huge extra traffic
and volume if they reduce these charges. Given the minimal marginal
cost, they might even end up making more profit without the roaming
charges.
(iii) Do you think that the mobile telecoms
industry has done enough in the last two years to address, through
self-regulation, concerns expressed by the Commission? NO
Are National Regulatory Authorities in a co-regulated
environment able to address these concerns on their own? NO
(iv) Does the proposed Regulation risk narrowing
down the space for competition and thereby harming innovation
and investment in the sector? NO
(v) Do you think that the pressure for lower
roaming charges could potentially spill-over into higher prices
for other mobile telephony services? NO (please see response
to ii)
Would you anticipate any other unintended consequences
that may affect consumers? NOT ADVERSE ONES
(vi) Do you think that the proposed regulation
will allow non-EU operators to take advantage of lower wholesale
roaming prices in the EU through international trade agreements
and arbitrage opportunities? YES
(vii) Is the Commission's estimate that 147
million EU citizens are affected by excessively high international
mobile roaming charges accurate? YES
Do you have any other figures to offer? NO
(viii) Do you think that the UK and French
proposal for a sunrise clause during the initial period after
the Regulation comes into force can better achieve the desired
effect? NOT SURE
Should legislation apply solely to wholesale fees
rather than retail tariffs? DEFINITELY NOT, and it should be forced
to come into effect very soon, not allowing the operators to drag
their feet, which they are past masters at doing.
7 February 2007
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