Page 81 - Trends in Telecommunication Reform 2016
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Box 2.5: Tower Limits in Indonesia                                                               Chapter 2
                   In Indonesia, the sector Ministry has restricted the construction of new towers in the vicinity
                   of existing towers in order to persuade operators to undertake infrastructure sharing. Under
                   the terms of the regulation, a new tower can be constructed only if, for some reason, the
                   existing tower cannot be shared . The regulation provides a guideline for the construction
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                   and development of joint mobile towers. Owners of mobile towers are required to give non-
                   discriminatory access to other telecommunication operators. The tower owners also must give
                   information about their tower’s capacity to potential access-seekers in a transparent manner.



               about the rules governing mandated network      mobile sector, there is little competitive benefit
               sharing, then there can be little objection as long   in expanding pure coverage, so infrastructure
               as they have the choice of whether or not to invest.   sharing is unlikely to harm competition. Similarly,
               But regulators should take care not to stymie   with most types of active network sharing in
               investment in the first place by instituting overly   the mobile sector, the impact on competition is
               rigorous requirements for mandated sharing.     fairly benign as long as sharing operators have
                                                               the ability to differentiate their services from one
                                                               another. However, once a sharing arrangement
               2.5.5   Grants and subsidies                    has achieved integration at the infrastructure
                                                               layer, it’s very difficult to unwind, leading to a
               There have been some successful examples of     potentially permanent reduction in infrastructure
               government use of modest grants and subsidies   competition.
               to overcome stiff resistance to network sharing,
               particularly from incumbent fixed-service
               operators. Box 2.3 showed how Singapore used    2.6.2   Potential for collusive dealing and
               a financial incentive to promote a co-investment   information sharing
               arrangement. In New Zealand, the government
               used a grant to provide an incentive to deploy   There is also the potential for collusive dealing
               an ultra-fast, FTTH network, inducing the fixed   between sharing operators. Regulators need to
               incumbent to structurally separate in order to   carefully evaluate this issue and engage in ongoing
               participate in the initiative.                  monitoring. Sharing of commercially sensitive
                                                               information among co-investors is a concern,
                                                               as well, but it may be an inevitable feature of
               2.6    Potential downsides to network           sharing arrangements. Appropriately structured
                      sharing                                  procedures and protocols can be implemented to
                                                               reduce the competitive impact of such information
               While there are potential downsides for         sharing.
               governments of network sharing and co-
               investment, they are generally regarded as fairly
               manageable, in the right circumstances. This    2.6.3   Reduced options for services-based
               section explores those downsides and how to     competitors
               cope with them.
                                                               A reduction in infrastructure competition may
                                                               lead to reduced options and more limited capacity
               2.6.1   Reduction in competitive intensity      being available for service-based competitors
                                                               such as MVNOs. This may not be such an issue
               Reduction in competitive intensity can be a     where sharing operators retain their competitive
               concern with network sharing, as competition    independence – the motivations for entering into
               will be confined to the services layer, rather   MVNO-type arrangements should not change
               than to both services and infrastructure layers.   in these cases. Limited capacity can be an issue,
               The common stance regulators have taken is      but most sharing or co-investment arrangements
               that, at least for passive network sharing in the   can be expected to provide sufficient capacity



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