2. Md.Iftakharul Islam, Telecom & Regulatory Expert
Email :rusho.bss@gmail .com
INTRODUCTION:
The Telecommunication sector in Bangladesh, specially the mobile sector, has shown
tremendous growth in last decade. The access to internet services is to some extend driven
by the mobile operators. However, broadband services in particular have so far been very
limitedly driver by to few Wi-Max operators and recently government owned operator
“Teletalk”. In line with the “Digital Bangladesh Vision” we understand that Government
wants to build an empowered information society, where everyone would be able to create
access, utilize and share information and knowledge easily and efficiently. Broadband can
improve the efficiency, availability, and reach of public and private sector ICT services in
areas of health, education and other socio economic areas.
The recent publication of 3G licensing framework is one promising step. The ICT industry is
eagerly waiting for the commercial launch of 3G/UMTS based services by the private
telecom operators which can surely demonstrate the strongest growth rates, the largest
volumes – and hence probably the lowest prices of both network equipment and terminals.
However as a part of the telecom industry, I would like to request the Government and the
regulators to kindly access the below concern which need to be addressed before we issue
the 3G License :
CHALLENGES OF 3G DEPLOYMENT :
The deployment of broadband infrastructure and services in Bangladesh faces a range of
challenges:
While increased broadband penetration is an important factor in strengthening the
economic development, the present socio economic condition (i.e. per capita
income) of the people doesn’t assure good business case for broadband network
deployment.
Ubiquity of broadband services drives demand for and hence development of
content, application and vice versa. The low penetration of PCs, Laptops, lack of
Bangla language supported application, low penetration of 3G enable handset and
unfamiliarity with the English language create challenges in terms of securing the
development of local content and access to international content.
The lack of competition in terms of international broadband connectivity leads to
very high cost of international IP traffic, in a global as well as in a South Asia
perspective.
3. Md.Iftakharul Islam, Telecom & Regulatory Expert
Email :rusho.bss@gmail .com
Transmission is a critical factor for 3G deployment. However, considering regulatory
obligation mobile operators will be solely dependent on NTTN operators in terms of
ensuring last mile connectivity for providing quality services to their customers. But
this will result in very high OPEX and slow deployment.
3G FROM INVESTOR’S PERSPECTIVE
With such a risk profile, funding of a 3G license and associated network deployment in
Bangladesh is likely to be challenging, in particular taking into account the recent high
volatility of financial markets.
This challenge will apply not only with regard to the licensee itself, but also with regard to
any external funding sources. From those points of view, it’s extremely important that
government contributes in limiting the total level of uncertainty through minimizing the
regulatory uncertainty. This will eventually help to:
Facilitate – and maybe reduce cost of - funding for license fee and network
deployment
Through the facilitation of funding provide for increased coverage, capacity and
quality
Increase the value – and hence the attractiveness - of the license.
The mobile sector is clearly a high-profile industry in terms of Foreign Direct
Investment in Bangladesh. A predictable regulatory regime for this sector will
contribute positively on the overall assessment of business environment in
Bangladesh.
With regard to the licensing guidelines for 3G, there are in industry view three areas where
long-term predictability and stability is of particular importance:
4. Md.Iftakharul Islam, Telecom & Regulatory Expert
Email :rusho.bss@gmail .com
SOME RECOMMENDATION & SUGGESTIONS FROM REGULATORY POINT OF
VIEW :
- Spectrum Price :
3G Spectrum pricing should be kept in such a level that secure the proper balance between
granting access to reduce entry barriers, and facilitating new and protecting existing
investments.
- Price regulation :
Needless to say, the financial risks associated with network construction are significantly
higher if there is a price regulation. This risk increases further if there is a risk of such
regulation without any indication on how this price regulation may be designed.
- Amount Spectrum allocation for 3G :
It is very positive to see that BTRC has reserved as much spectrum as possible (at least 50
MHz) for commercial use. Reduced spectrum availability increases network roll-out costs,
making some geographical parts of Bangladesh unattractive for 3G-roll out, and some
capacity demanding services unviable. This reduces the benefits for the Bangladeshi society
compared to a situation where spectrum is not artificially scarce.
- Number of licensee :
Restricting the number of available licenses compared to the maximum that could be
achieved given spectrum availability over a longer timeframe will not in general bring
advantages to the country. A large number of licenses would support increased competition
and increase the likelihood that 3G networks are actually established. More licenses would
as well lead to better services and lower prices towards the market
- Modification of License terms and conditions :
As any modification of license fees, spectrum fees and revenue sharing may have a
significant impact on the business case of any 3G licensee, BTRC shall not exercise the
power given in BTA to bring about any changes in license fees, spectrum fees and revenue
sharing etc.
- Technology Neutrality :
Int’l regulators are acknowledging that spectrum allocations should be made on a
technology neutral basis and spectrum refarming is international best practice (i.e. allowing
3G on 800/900/1800MHz)
5. Md.Iftakharul Islam, Telecom & Regulatory Expert
Email :rusho.bss@gmail .com
- New entrants :
The Bangladesh market is competitive already and the market can likely not sustain new
entrants – in any case there is likely to be no viable business case for new 3G only entrants
in the Bangladesh market
- Tariff Approval :
In particular with the wide range of services which must be expected to flourish when the
3G market develops in Bangladesh, tariff approval for each and every service is probably not
feasible. Rather, any service provider should have a clear requirement to make tariff
information easily available at time of entering into an agreement, and updated tariff
information should be readily available at any time, e.g. on a web site. Also, all marketing of
services should contain clear information on tariff.
- Access sharing :
There are quite a few markets where also companies who don’t have their own, complete
mobile network infrastructure, are allowed to offer mobile services to end customers
through utilizing the capacity of the mobile network operators. There are three main
categories of such access arrangements:
o Mobile Virtual Network Operator (MVNO)
o Simple Resale
o National Roaming
Industry and regulators clearly acknowledges that there are several advantages of reduced
entry barriers facilitated through MVNO, resale and national roaming.
