MVNO Services raises concerns over NBTC spectrum auction plans, criticizes “TIMO” theory

In its submission to the NBTC’s public hearing, the company, deeply invested in fostering a competitive MVNO landscape, expressed profound concern over unresolved market issues and the introduction of an unproven concept.

MVNO Services argues that a simultaneous multi-band auction risks solidifying the current stagnant market structure for another 15 years. They point to several critical issues that remain unaddressed by the regulator:

• Merger Conditions: Capacity allocation for Mobile Virtual Network Aggregators (MVNA) and Mobile Virtual Network Operators (MVNO), pricing, and service quality.
• MVNA/MVNO Promotion: Lack of clear strategies to foster the growth of these.
• Wholesale Pricing Frameworks: Absence of transparent and fair wholesale pricing mechanisms, crucial for the MVNA/MVNO business model.
• Overall Lack of Competition: The need for measures to stimulate a more competitive market, which would allow for more MVNOs to enter the market.

The company strongly recommends a phased auction approach, initially limited to one or two spectrum bands, only after the NBTC addresses these outstanding issues and enforces existing regulations.

To ensure genuine commitment to wholesale network access, MVNO Services proposes stricter qualification criteria for license applicants. They suggest requiring applicants to demonstrate evidence of an existing wholesale agreement with an MVNA/MVNO, or at least a signed “Head of Terms” document outlining key agreement terms. This measure aims to address the persistent lack of network access for MVNAs/MVNOs and ensure efficient utilization of national spectrum resources.

“TIMO” Theory Deemed Unsuitable and Unproven

MVNO Services vehemently opposes the inclusion of the “Thailand Independent Market Operator (TIMO)” theory in the spectrum auction framework. They argue:

• Lack of Empirical Evidence: TIMO is a theoretical concept with no proven track record in the telecommunications industry.
• Potential for Delays and Uncertainty: Introducing TIMO would create delays and uncertainty, hindering investment and service expansion, negatively impacting MVNA/MVNEs.
• Inapplicability to Telecommunications: The company contends that TIMO’s concepts, potentially suitable for the energy sector, are not applicable to the heterogeneous nature of telecommunications spectrum.
• Existing Regulatory Enforcement Issues: MVNO Services argues that the NBTC should focus on effectively enforcing existing regulations rather than introducing unproven theories.
• Cost and Effectiveness Concerns: The establishment of TIMOs would incur additional costs and complexities, hindering MVNO market development, and therefore negatively impacting competition.
• Consultant’s Lack of Knowledge: Concerns were raised that the consultants pushing the TIMO theory lacked sufficient knowledge of the Thai telecommunications market and the MNO/MVNA/MVNE/MVNO ecosystem.

MVNO Services urges the NBTC to:

• Enforce existing regulations to ensure Mobile Network Operators (MNOs) comply with capacity allocation requirements for MVNAs/MVNOs.
• Study successful MVNA/MVNO models from the many countries that have already successfully introduced such for years, and apply it to the Thai market.