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Yettel Bulgaria

Yettel

Provision of electronic communications services through a mobile network at a retail level

Lobbying Activity

Response to Initiative for reviewing and prolonging the “Roaming Regulation”

29 Apr 2021

Telenor Bulgaria EAD (“Telenor Bulgaria”) welcomes the overall approach taken in the legislative proposal for amending the Roaming regulation (EU) No 531/2012 (“The Proposal”) to step on the achievements of current act without significant amendments, while eliminating unnecessary and not working solutions such as the obligation for the separate sale of regulated retail roaming services, the so called “ local data breakout” obligation. We would like however to take the opportunity to share our concerns on some of the proposed amendments. Our comments concern the following topics: Maximum Wholesale Charges The Proposal introduces a new two-step glide path for the maximum wholesale charges applicable for data, voice and SMS. This approach will further prolong the ongoing reduction of wholesale charges beyond 30 June 2022. Overall, the proposed reductions are significant considering the long-term reference period of ten years and thus bear the risk of not fully reflecting all relevant costs to which we, as operators, will be exposed in the upcoming years. Special attention needs been taken with respect to costs related to the upcoming roll-out of 5G and this of future generations technologies over the reference period, as well as costs that would be generated to meet increasing requirements of cybersecurity. Moreover, costs related to 5G roll-out have not been included in the Axon cost model which served as a basis to the decision to prolong the reduction of wholesale charges. This fact was explicitly pointed out in the Commission Staff Working Document, COM(2019) 616 final. As data becomes more available with the approach of the commercial launches of 5G across the EU, a proper analysis of the underlying costs is, in our opinion, crucial given the step change introduced by this technology and the results of which have the potential to significantly alter the conclusions on whether or not there is room to further reduce wholesale roaming charges. We would therefore urge the Commission to maintain maximum wholesale charges at the levels applicable on 30 June 2022 and prolong their effect without modifications till 30 June 2032. Quality of Service While Roaming The Proposal introduces changes that aim at ensuring that roamers enjoy the same level of quality of service as when using the services at home. While Telenor Bulgaria takes the view that continuous improvement of quality of service, including in the case of roaming, requires a constant focus of mobile operators and reflects their best interest in terms of ensuring ever higher level of customer care, we would like however to share some concerns as to the means proposed to achieve this goal. • at the wholesale level The obligation to negotiate with roaming partners to ensure same level of service as at home is unclear and raises numerous questions. One concern is that such an obligation would in practice require operators to negotiate with virtually all network providers in order to reach and guarantee the same level of quality as domestic. This would significantly alter the existing logic of the negotiation process and contents of wholesale roaming agreements. Moreover, it would require introducing in the latter some form of commitment to service levels, which, from a capacity point of view, could be very difficult to ensure. It is worth pointing out that the relationship between roaming partners is based on ensuring mutual availability of networks subject to capacity constraints and an overall commitment not to discriminate between domestic and roaming users. If maintained this obligation would therefore require clear guidelines on what precisely to negotiate in the wholesale roaming agreements. In addition, a transition period will be needed as well to allow roaming partners to align their existing agreements with such an obligation. • at the retail level The Proposal is unclear on how a customer contract should describe a reasonable expectation for quality while roaming.
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Response to Voice call termination rates in the EU (Eurorates)

22 Sept 2020

Feedback as attached file.
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