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Data Market Inquiry Provisional Findings and Recommendations

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Data Market Inquiry Provisional Findings and Recommendations competition commission south africa DATA SERVICES MARKET INQUIRY PROVISIONAL FINDINGS AND RECOMMENDATIONS 24 April 2019 TABLE OF CONTENTS SUMMARY OF PROVISIONAL FINDINGS AND RECOMMENDATIONS 8 1. INTRODUCTION 20 1.1. Initiation and Terms of Reference 20 1.2. Call for Submissions 21 1.3. Public hearings 21 1.4. Status of this report and way forward 21 1.5. Structure of this report 22 2. OVERVIEW OF THE PROVISION OF DATA SERVICES 23 2.1. Supply, access and use of data services 23 2.2. The value chain 25 2.3. Broad economic characteristics of telecommunications services 27 2.4. Policy, legislative and regulatory environment 29 2.5. Approach to the remainder of the report 30 3. INTERNATIONAL PRICE COMPARISONS AND THE LEVEL OF PRICES 32 3.1. Submissions regarding international price comparisons 33 3.2. Existing market research on international price comparisons 37 3.3. Preliminary Findings 67 4. THE STRUCTURE OF DATA PRICES AND ANTI-POOR PRICING 69 4.1. Submissions on pricing to low-volume consumers 69 4.2. Assessment 72 4.3. Preliminary Findings 81 5. COST DRIVERS – SPECTRUM AND FACILITIES ACCESS ISSUES 83 5.1. Spectrum 83 5.2. Facilities access and pricing 93 6. MOBILE COMPETITION 98 6.1. Submissions 98 6.2. Competition at a retail market level 100 6.3. Wholesale markets 123 6.4. Preliminary Findings 132 7. FIXED LINE SUPPLY GAP 135 7.1. Value chain and business models 136 7.2. Assessment and key findings 143 1 8. PROVISIONAL RECOMMENDATIONS 146 8.1. Immediate actions on retail price structure and level 147 8.2. Addressing cost drivers: spectrum and facilities leasing 149 8.3. Enhancing competition: Wholesale mobile roaming and MVNOs 151 8.4. Development of alternative infrastructure for data services 153 9. APPENDIX A: VALUE CHAIN AND IDENTIFICATION OF MARKETS 156 9.1. Value Chain 156 9.2. Identification of broad markets for the assessment 164 9.3. Identified markets relevant to the inquiry 172 10. APPENDIX B: ECONOMICS OF TELECOMMUNICATIONS MARKETS AND INTERVENTION 173 10.1. Key features of telecommunications markets 173 10.2. Competition issues in telecommunications 180 10.3. Common remedies to address competition issues 184 11. APPENDIX C: POLICY, LEGISLATIVE AND REGULATORY ENVIRONMENT 190 11.1. Policy, legislation and regulations 190 11.2. Key players in the sector 197 11.3. Regulatory issues 200 11.4. Policy, legislative and regulatory developments 202 12. APPENDIX D: SUMMARY OF SUBMISSIONS AND KEY CONCERNS 211 12.1. Submissions received in response to the CfS 211 12.2. Submissions received for the public hearings 228 12.3. Other issues identified during the course of the Inquiry 243 13. APPENDIX E: DETAILED DISCUSSION OF VODACOM AND MTN SUBMISSIONS ON COMPARATIVE PRICE LEVELS 245 14. APPENDIX F: SPECTRUM 263 14.1. What is spectrum and why is it important? 263 14.2. Approaches to spectrum assignment and considerations 266 14.3. Spectrum assignment in South Africa 277 15. APPENDIX G: NATIONAL ROAMING 281 15.1. Operator views on national roaming 281 2 LIST OF TABLES Table 1: Tarifica overall ranking of mobile prepaid plans (Q2 2017) 42 Table 2: Prices for 500MB, 1GB and 2GB data bundles within BRICS (USD) (2017) 43 Table 3: Prices for MTN pre-paid data bundles across countries (USD) (2017) 47 Table 4: Cheapest prepaid 1GB data prices in South Africa and five other large African markets (USD prices per GB) 52 Table 5: SA’s prepaid data prices compared to four developed players performed (26 September 2016) 56 Table 6: South Africa’s rank for ITU prepaid and post-paid data prices (USD, PPP) across three samples (2016) 59 Table 7: Tarifica overall ranking of mobile post-paid plans (Q2 2017) 60 Table 8: SA’s post-paid mobile prices compared to four developed players (2016) 61 Table 9: BRICS ranking from 80 countries’ residential broadband tariffs (Q2 2018) 65 Table 10: African country ranking from 80 countries’ residential broadband tariffs (Q2 2018) 66 Table 11: SA Broadband prices compared to four developed countries (2015) 67 Table 12: The extent to which the implied prices of smaller bundles (i.e. 5MB, 10MB, 50MB, & 100MB) in South Africa exceed the prices of larger bundles (i.e. 1GB & 2GB) (Dec 2018) 73 Table 13: Selected small bundle sizes with short validity periods versus 1GB valid for 30 days for Vodacom (Mar 2019) 75 Table 14: Selected small bundle sizes with short validity periods versus 1GB valid for 30 days for MTN (Mar 2019) 75 Table 15: Effective data rates for various bands of data usage on the MTN network (indexed) (Feb 2018-Jun 2018) 77 Table 16: Effective prices for various bands of data usage on the Vodacom network (indexed) (Jan 2016-Aug 2018) 78 Table 17: Share of OOB data in total traffic and in total revenue on the MTN and Vodacom network 78 Table 18: Operator subscriber numbers (2018) 104 Table 19: Number of mobile sites per operator (2017) 118 Table 20: Roaming charges comparison 127 Table 21: Effective roaming rate per MB in the Vodacom/Rain roaming agreement using June 2018 access fees 127 Table 22: Overall rate table for the roaming agreement between MTN and Cell C 129 Table 23: Variable roaming rate for the roaming agreement between Vodacom and Telkom 129 Table 24: Effective roaming rate per MB in the Vodacom/Rain roaming agreement using June 2018 access fees 129 Table 25: AlwaysOn Wi-Fi prices 141 Table 26: Estimated national fibre infrastructure market shares 161 Table 27: A list of markets identified by ICASA and vertical links between them 166 Table 28: Composition of the GSMA MCI 249 Table 29: BRICS countries GDP/capita (PPP $), growth rates, consumption per user 254 Table 30: Regression coefficients of ITU prices and prices/GDP per capita on log GDP per capita (2016) 259 Table 31: Spectrum Assignment to major MNOs in South Africa 279 3 LIST OF FIGURES Figure 1: Data contribution to operator service revenue (2015 – 2018) 23 Figure 2: Vodacom national coverage by technology layer (Jan 2015 - Dec 2018) 24 Figure 3: Telecommunications sector value chain 26 Figure 4: Mobile prepaid data prices in USD (PPP), 500MB (2016) 39 Figure 5: Mobile prepaid data prices for BRICS in USD (PPP), 500MB (2016) 40 Figure 6: Mobile prepaid data prices for African countries in USD (PPP), 500MB (2016) 40 Figure 7: SADC prices (USD) for 500MB prepaid data bundle (2017) 44 Figure 8: SADC prices (USD) for 1GB prepaid data bundle (2017) 45 Figure 9: SADC prices (USD) for 2GB prepaid data bundle (2017) 46 Figure 10: Vodacom 1GB retail tariffs across Africa (2017) 47 Figure 11: Vodacom 2GB retail tariffs (2017) 48 Figure 12: A4AI’s 1GB mobile prepaid prices in USD (PPP) for low and middle-income countries (2016) 49 Figure 13: RAMP Index cheapest prepaid mobile 1GB data prices for 50 African countries in USD (Q2 2018) 50 Figure 14: Cheapest prepaid mobile 1GB data prices for SADC countries in USD (Q2 2018) 51 Figure 15: Comparison of 1GB price for SA against 12 African countries (Q2 2014 to Q2 2018) 52 Figure 16: SA rank for 1GB price against 12 African countries (Q2 2014 to Q2 2018) 53 Figure 17: Comparison of 1GB price for SA against 41 African countries (Q3 2015 to Q2 2018) 54 Figure 18: SA rank for 1GB price against 41 African countries (Q3 2015 to Q2 2018) 54 Figure 19: Mobile post-paid data prices in USD (PPP), 1GB (2016) 58 Figure 20: Mobile post-paid data prices for BRICS in USD (PPP), 1GB (2016) 58 Figure 21: Mobile post-paid data prices for African countries in USD (PPP), 1GB (2016) 59 Figure 22: Fixed data prices in USD (PPP), minimum 1GB data cap per month (2016) 63 Figure 23: Fixed data prices for BRICS in USD (PPP), minimum 1GB data cap per month (2016) 63 Figure 24: Fixed data prices for African countries in USD (PPP), minimum 1GB data cap per month (2016) 64 Figure 25: The extent to which the implied price/GB of a 100MB bundle exceeds the price of 1GB bundle (Jan 2014 - Nov 2018) 73 Figure 26: The extent to which the implied price/GB of a 50MB bundle exceeds the price of 1GB bundle (Jan 2014 - Nov 2018) 74 Figure 27: The extent to which the implied price of 20-30MB bundles exceed the price of 1GB bundle (Jan 2014 - Dec 2018) 74 Figure 28: Vodacom’s indexed usage per subscriber 79 Figure 29: MTN’s indexed usage per subscriber 79 4 Figure 30: Telkom’s indexed usage per subscriber 79 Figure 31: Operator Service Revenue share (2018) 102 Figure 32: Operator Service Revenue share (2015 – 2018) 102 Figure 33: Operator Subscriber market share (2018) 103 Figure 34: Operators subscriber market share (2010 – 2018) 103 Figure 35: Operator Data Revenue share (2018) 105 Figure 36: Operator market shares, Data Revenue (2015 – 2018) 105 Figure 37: Operator market share, Prepaid Data Revenue (Q3 2016 - Q1 2018) 106 Figure 38: Operator data traffic market share (June 2016 – March 2018) 106 Figure 39: 20-30MB prepaid bundles valid 1 month (in Rands) 108 Figure 40: 100MB prepaid bundles valid 1 month (in Rands) 109 Figure 41: 1GB prepaid bundles valid 1 month (in Rands) 109 Figure 42: Cell C prepaid prices for different data bundle sizes 111 Figure 43: Post-paid contract with 1GB without device (in Rands) 112 Figure 44: Post-paid contract with 5GB without device (in Rands) 113 Figure 45: Prepaid revenue per GB 114 Figure 46: Prepaid revenue per GB (indexed) 114 Figure 47: Capital intensity of mobile operators (2001-2018) 119 Figure 48: Revenue and capital expenditure of mobile operators (2017) 119 Figure 49: ICASA’s cost model (cost per data megabyte in 2017) 120 Figure 50: Vodacom’s churn rates for contract customers (year ended 31 March 2001- 31 March 2017) 122 Figure 51: IP Connect 142 Figure 52: Telecommunications sector
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