Mobile network performance forum

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Mobile network performance

forum


Discussion
p
aper

OCTOBER
201
3








Canberra

Red
Building

Benjamin Offices

Chan Street

Belconnen ACT


PO Box 78

Belconnen ACT 2616



T

+61 2 6219 5555

F

+61 2 6219 5353

Melbourne

Level 44

Melbourne Central To
wer

360 Elizabeth Street

Melbourne VIC


PO Box 13112

Law Courts

Melbourne VIC 8010


T

+61 3 9963 6800

F

+61 3 9963 6899

Sydney

Level 5

The Bay Centre

65 Pirrama Road

Pyrmont

NSW


PO Box Q500

Queen Victoria Building

NSW 1230


T

+61 2 9334 7700


1800 2
26 667

F

+61 2 9334 7799




Copyright notice






http://creativecommons.org/licenses/by/3.0/au/


With the exception of coats of arms, logos, emblems, images, other third
-
party material or de
vices protected by a trademark, this
content is licensed under the Creative Commons Australia Attribution 3.0 Licence.


We request attribution as: © Commonwealth of Australia (Australian Communications and Media Authority) 2013.


All other rights are rese
rved.


The Australian Communications and Media Authority has undertaken reasonable enquiries to identify material owned by third par
ties and secure permission
for its reproduction. Permission may need to be obtained from third parties to re
-
use their mat
erial.


Written enquiries may be sent to:

Manager, Editorial and Design

PO Box 13112

Law Courts

Melbourne VIC 8010

Tel: 03 9963 6968

Email:
candinfo@acma.gov.au




Contents





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iii


Overview

1

What the forum won’t address

2

Background

3

1. Consumer
experience of mobile network performance

6

2. Technical aspects of performance

8

Technology and hardware

8

Environmental/external considerations

8

Third
-
party networks and services

9

Network design and spect
rum management

9

Difference between network coverage and network performance

10

Network infrastructure development and management

11

Impacts of plan offers on performance

12

Wi
-
Fi as an alternative to network data

12

Devices commonly used to improve coverage

13

3. The consumer lifecycle

14

4. Current consumer information

16

Provider information

16

Coverage maps and plans

16

Handset information

16

Reception

16

Other

16

Other information sources

17

Comparison and other websites

17

Apps

17

Other crowdsourced information

17

Overseas approaches

18

Regulatory interventions

18

5. Possible approaches

19

No intervention

19

Industry intervention

19

Targeted intervention

19



Contents
(Continued)





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Appendix A

Questions

20

Appendix B

Review of mobile network information on
provider websites

21

Appendix C

Overseas approaches

27

Appendix D

App examples

33

Appendix E

The Australian regulatory landscape

36






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O
verview

In 2010

and 20
11
,

the ACMA undertook its
Reconnecting the Customer

(RTC)
inquiry

to examine the root causes
of
complaints about

customer service and complaints
-
handling across the telecommunications industry
,

and
what
strategies

could be used
to
im
prove

the situation
.
The final RTC inquiry report informe
d

the ACMA’s approach
to the
revised
Telecommunications Consumer Protections
(TCP)
Code
,

which it
registered in September 2012
. The revised TCP Code

has been accompanied by

a
renewed industry commitm
ent to customer service
, with
material
improvements
evident
.


However,
despite
a
decline in
general telecommunications
complaints
,

since
2010

there has been a steep increase in complaints to the Telecommunications Industry
Ombudsman (TIO) about mobile netw
ork performance
.


The ACMA is seeking to understand the
causes
of this rise in mobile network
performance complaints. Do the complaints indicate a systemic problem?

If so, will the
market deliver solutions or should regulatory interventions be considered?


The increasing complaint numbers suggest, at

the

very least, that
consumer

expectations of network performance are not aligned with their experiences of network
performance.

As Australian citizens become increasingly dependent on
m
obile
communications, it

is important that
these
services meet
the reasonable
social and
commercial needs of the Australian community.


On
14 November 2013,

in pursuit of a shared understand
ing

of the drivers and
significance of mobile network performance complaints, the ACMA wil
l hold
the
Reconnecting the Customer
:
Mobile network performance forum
.
Th
e

f
orum

is
intended to
bring together industry representatives, academics, consumer advocates,
regulators and citizens.

Further details about this event

and information on how to
reg
ister
will be available from
8

October 2013
at

www.acma.gov.au/mobilenetworkperformance
.


This discuss
ion paper is released in advance and
in
support of the
f
orum
.

Its purpose
is to provide
relevant

information to
those
grappling with the issues

and
to

identify
areas of focus for discussion at
the
forum
.

This paper explores:

>

t
he f
actors that shape
consumer

perceptions of good and bad
mobile network
performance

>

k
ey

technical aspects of mobile performance

and network management


>

t
he stages of the
consumer

lifecycle at which mobile performance
may be

most

relevant

>

t
he information currently available to Austral
ian consumers about the performance
of mobile networks.

The questions in the paper will be a useful starting point for questions and
contributions
at
the
f
orum
.

T
he ACMA
also

welcome
s

early responses
as a way to
shape
f
orum

discussions.


Early responses ma
y
be
made to
consumerinterests@acma.gov.au
.




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Overview questions

1.

What causes consumers to complain about mobile connectivity?

2.

How do consumers evaluate the network performance of their provider? Can
consumer
s compare the performance of different providers


networks?

3.

If there is a problem: what more could be done and who is best positioned to
implement?

M
ore specific discussion questions
are
throughout this paper,
with a complete
list at
Appendix A.


What the
f
orum

won’t address

The ACMA’s functions include the regulation of telecommunications under the
Telecommunications Act 1997

and
Telecommunications (Consumer Protection and
Service Standards) Act 1999
. These laws
do not

confer powers on the ACMA to direct
p
roviders to extend terrestrial mobile network coverage. Accordingly, the
f
orum

can
not
demand infrastructure improvements or

new build

to extend coverage. However,
there are links between coverage and
performance;

for example, where cell density
does not
meet demand in a certain location at a point in time.

Accordingly,
the
subjects of coverage and infrastructure

may arise in discussion of the causes of
complaints about
performance
.


The ACMA
notes

that d
uring the 2013
F
ederal
E
lection, the
Coalition

annou
nce
d

a
policy to invest $100 million to improve mobile phone coverage, consisting of:

>

$80 million to expand coverage along major transport routes, in small communities
and in locations prone to experiencing natural disasters

>

$20 million for a mobile black
spot program to address unique mobile coverage
problems, such as locations with high seasonal demand.

While t
his
policy is designed to provide
gr
eater coverage in certain areas,
the
f
orum
will primarily focus on
network performance

issues
.


The ACMA
does
d
eal with complaints about the placement of mobile base stations
where a carrier has not met its obligations under the industry code
C564:2011
Mobile
Phone Base Station Deployment
. However
,

the
f
orum

w
ill not be addressing the
impact of mobile infrastructure on communities

the focus will be
on
the issue of
consumer
information about network performance.







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Background

Mobile telephony in Australia is provided by three network owners

Telstra, Optus and
Voda
fone (the

carriers
’)
and a large number of resellers. Collectively, these are
referred to in this paper as

providers

.


At June 2012, there were an estimated 30.2 million mobile voice and data services in
operation in Australia, which equates to four mob
ile services for every three people.
1



When the TIO receives a complaint, it records one or more complaint issues against
the complaint. For mobile network performance, there are three possible complaint
issues

coverage, dropouts and slow data speed.


Fig
ure
1

depicts the aggregate of these complaint issues

over time
. It shows that
mobile network performance
complaint issues declined in the
12
months to March
2013

compared to

the previous
12
-
month period. This fall can be mostly attributed to
reduced compl
aint numbers
about

Vodafone companies.
Regardless of the recent fall
in numbers,
complaints about mobile performance issues remain

disproportionally
high when compared with other complaint types.


Figure
1

TIO mobile network perfor
mance complaints issues




Figure 2

throws a spotlight on the number of complaint issues over the most recent
12
-
month period,

by quarter
. This zoomed
-
in view

shows complaint issues rising from
about
7,500 in the September 2012 quarter to over 8,500 in

the March 2013 quarter.





1

ACMA
,

Communications

r
eport 2011

12
, p. 32.




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Figure 2
TIO mobile network performance complaint issues (disaggregated)




TIO complaints
will not

reflec
t

the
full magnitude
of
consumer

concern

providers
also
directly receiv
e

performance
-
related complaints and
successfull
y resolv
e

most
of
them

through their own complaint
s
-
handling processes
.

While a high success rate in
resolving complaints internally
is
a good outcome for consumers, it
is a

concern
if a
high number of
consumers have grounds to complain.



Factors
likely

t
o
have
contribute
d

to increasing demands
on

and expectations of
mobile networks include:

>

a
h
igh concentration of smartphone ownership

with 79

Android and iOS
(Apple)
devices

in circulation for every 100 adults aged 15 to 64
2


>

g
rowing mobile internet subscr
iptions (up 21.8 per cent in 2012)
3

driven by
significant rises in tablet ownership (37

per cent

owned tablets in late 2012
compared with 13

per cent

in 2011)
4

>

the
i
mpact of mobile coverage and performance on the useability of a wide range
of devices, from

multi
-
use devices such as tablets, laptops

and

notebooks to
single
-
use devices such as wireless EFTPOS terminals

>

g
rowing numbers of mobile
-
only users

an
increase of
20

per cent

in the 12
months to December 2012, consistent with growth rates in the previou
s two years
5

>

the
growing
volume of data downloaded by Australian wireless broadband
6

and
mobile handset users

an
increase

of

32.1

per cent

and
78.9

per cent

respectively
in the

June 2012

quarter, compar
ed

with the June 2011 quarter
.
7




2

Flurry
,

cited at ‘How Australia has outpace
[
sic
]

other mobile markets’, Tony Danova, BI Intelligence, July
2013.

3

ACMA
,

Communications report 2011

12

series, Report 3, p. 2.

4

Deloitte
,

V
ox Populi: State of the Media Democracy S
urvey

2
nd

Edition, 2013, p.

5.

5

ACMA research snapshot, 5 July 2013, Roy Morgan Single Source data, December 2012.

6

Wireless includes satellite, fixed wireless, mobile wireless via a datacard, dongle, USB modem or tablet
SIM card and other wireless broad
band. Excludes data downloaded via mobile handsets.






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5


The three carriers are

each rolling out 4G networks, starting with major population
centres. While 4G will enable faster downloads and a more efficient use of spectrum
,

growth in
demand for
data downloads
will

continue to put pressure on mobile
networks.

It has been projected t
hat under a moderate growth scenario, mobile
broadband traffic
in Australia

will grow
from less than 0.09m TB in 2009
to
1.33
m
T
B
in 2014
.
8


Quality of voice
,

service

and

data
speed are

important differentiators for providers

promoting their mobile service
s.
9

H
owever
,

each
user’s
experience
of
the
service
promoted will be different depending on such things as
:

>

t
he user’s location and the

network coverage

in that location

this is
often
associated with regional areas, meaning
the
availability of a network as
characterised by the lack of a voice or data signal on a handset or device

>

n
etwork c
ongestion

at the time of use

a less than optimal experience, often
associated with urban areas, where a user is unable to perform tasks due to heavy
traffic demands in a lo
cation

>

h
andset problems (such as firmware updates), website and app design.


The specific proble
ms a consumer may face include:

>

i
ntermittent signals

>

p
oor voice quality

>

c
alls not connecting or dropping out

>

SMS not transmitting or transmitting more slowly th
an expected

>

s
low page loads, uploads and downloads

>

d
ata sessions through websites or apps timing out.

While these problems will not always be
an indicator

of poor mobile network
performance,
consumer
s may be inclined to
attribute
their
problem to network
p
erformance
owing to
:

>

a
dvertising claims made by providers about aspects of performance of their
networks

>

a

lack of a common language or framework for consumers to use to compare
networks

>

e
xpectations that mobile network performance will equate or better a
user’s home
Wi
-
Fi experience

>

e
xpectations that an experience in a 3G coverage location will equate
to
that of a
4G coverage location

>

l
ack of understanding about the source of the problem they are experiencing
;

for
example,
the reality
that performance
may
fluctuate depending on the number of
users for available cells.






7

ACMA
,

Communications report 2011

12
, p. 20.

8

Network Strategies Report No
.

29028, 16

June
2010.

9

Ovum Mobile Industry Survey Asia
-
Pacific 2012

2013, p. 11.




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1.
Consumer

experience of
mobile network performance

A consumer study across 12 countries recently conducted by Ericsson
concluded
that
network performance is the main driver of loyalty to ope
rators.
10

Yet just over 30 per
cent of users stated that they experience problems every day when using their
smartphones to browse the web or use apps, and as many as 60 per

cent experience
these problems weekly.
11

The same study found that user satisfaction

with voice
quality in most location types was much higher than for data speed and data
coverage.
12



The
less than
optimal performance of a mobile network may inhibit a consumer’s
ability to:

>

s
end and receive emails, calls or texts

>

d
ownload and use mobile
apps

>

b
rowse the
i
nternet

>

s
tream videos

>

a
ccess online banking, make payments and transfer funds

>

m
ake emergency calls

>

d
o business

>

e
ngage with
g
overnment
13

>

a
ccess important information such as directories, maps, weather reports and ‘the
cloud’.

In Australia, c
onsumer satisfaction with mobile phones is generally high for service
reliability (67

per cent

satisfied or very satisfied) and lower for internet access (57

per
cent
).

Recent c
hanges in
Australian
consumer behaviour in the use of mobile devices
include:

>

a
n 85 per cent increase in the number of adult smartphone users downloading
apps
14

>

s
hifts in preferences
to
us
ing

mobile devices over fixed for several activities
including research and information, banking and finance, and general usage
15

>

i
ncreases in video
streaming and downloading

>

a
necdotal use of video streaming for

non
-
visual


purposes,
for example,

listening
to music.

Before a consumer uses a mobile device, they may take the following steps to
consider whether their network is likely to provide a relia
ble experience:




10

Australia was not one of the countries fea
tured.

11

Ericsson Consumerlab,
Keeping Smartphone Users Loyal
, June 2013, p. 5.

12

Ibid,

p. 8.

13

The Federal Government’s Digital First policy requires all agencies to ensure individuals and businesses
are able to complete all ‘priority services’ using smar
tphones and tablets by December 2017.

14

ACMA
,

Communications report 2011

12

series, Report 3, p. 2.

15

Roy Morgan Single Source June 2012, as cited in ACMA
,

Communications report 2011

12

series, Report
2, p. 15.






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>

o
bserve whether there are signals on the handset for both voice/SMS (if
applicable) and 3G/4G data

>

c
onsider if those signals are constant or intermittent

>

c
hoose to move location to obtain better signals or consider other means to
improve re
ception such as using
Wi
-
Fi
or a booster.

Mobile phone users may have the following difficulties that will
affect
their experience:

>

Voice calls

a call may not connect to the second party. The quality of the
conversation may be
affected
by breaking up or cr
ackling.

>

SMS/MMS

a message may not transmit or may not be received, or may transmit
more slowly than expected.

>

Data

uploads or downloads may be slower than expected or sessions may
unexpectedly time out. These problems may be common
,

isolated to particula
r
websites or apps (
for example,

a website for a sporting code may experience peak
demand) or
isolated to
peak times of the day.

A

good experience will be one where a consumer

when and where they want to

can:

>

speak clearly and continuously with another per
son

>

send and receive timely SMS messages

>

use the internet, e
-
mails and other data applications efficiently
.

A less than optimal experience may be broadly characterised as
frequent,
intermittent

or incidental
:

>

Frequent

difficulties may be experienced where

the main location
to
use a service,
such as at home or at work, is located in a

black spot

where there is no
or poor
coverage. Black spots may exist within a general area that affects a significant
number of households and consumers who use mobile

devic
e
s within that area or
may be confined to a small number of households for indoor use only.

Many

black
spots
can

be identified by network testing
.

However, only comprehensive
testing
program
s

will lead to comprehensive black

spot identification. Moreover,
some
highly localised black

spots may not

be apparent even through a comprehensive
testing program and will not be known to either provider or
consumer

prior to

a

contract

being entered into
.

>

Intermittent

issues might
occur during
regular use of a service
at a wide variety of
locations and/or times of day. For example, a consumer may experience slow
download speeds in certain locations at times of peak demand for cell availability,
but at other times experience a satisfactory service.

>

Incidental
difficulti
es

may arise where a consumer uses the service in a location
that is altogether removed from

everyday life

. For instance, where the user takes
leave in a rural location.

What does good mobile connectivity look like for consumers
?

4.

How do consumers
identi
fy and
describe
difficulties

they experience with their
mobile service?

How do consumers respond to less than optimal experiences?

5.

What are the main causes of complaint and are these changing over time?





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2. Technical aspects of
performance

The performance

of a mobile network is dynamic
and
is affected by numerous
factors

n
ot all
of which

are
within

the provider
’s control
. The capacity of a network to
deliver voice, SMS and data services to an individual user is broadly determined by
the following factors:

>

t
echnology

and
hardware

>

e
nvironmental/
external
considerations

>

network design and
s
pectrum management
.

This section
discusses these factors and

explains some differences in terminology that
relate to performance and coverage.


Technology and hardware

The mo
bile handset and how it is used can have a bearing on an end
-
user’s
perception of the performance of a mobile network.
H
andsets currently available on
the market var
y

greatly in both design and construction.
S
ome handsets will have a
better ability
than ot
hers
to
:

>

receive wanted signals from the mobile network


>

reject any unwanted (interfering) signals from other sources.

The ACMA understands that

the design of
one popular smartphone’s

internal antenna
mean
s

that
,

if users h
o
ld the handset in a particular
way, the reception
i
s adversely
affected
,

resulting in a poor end
-
user experience.



Similarly, an end
-
user may have a different experience of a mobile network by using a
car kit with an external antenna
rather than

holding the handset close to the head.

W
hen a handset is held close to the head, some of the signal
may

be attenuated by
the body, resulting in a loss of signal. The effect of this signal loss can be significant
,

particularly if the end
-
user is in a fringe reception area.


In addition to the han
dset, the transmission technology used can also affect the user’s
experience of a mobile network. End
-
users in Australia currently have access to 2G,
3G and 4G mobile networks. The transmission techniques used by a 4G network
make it capable of achieving s
ignificantly higher data transmission rates than a 3G or
2G network

under similar conditions
.


Environmental/external considerations

The geographic surroundings and environmental conditions at the time of a call being
made can have a significant impact o
n mobile network performance. For example, a
signal path may be severely degraded if a user is attempting to make a call inside a lift
or in the basement of a high
-
rise building. Physical obstructions (such as tall buildings,
hills or trees) can cause mobi
le signals to be attenuated or lost.



Radiofrequency (RF) interference can block handsets from accessing a carrier’s
mobile network. Some common interference sources include other
radiocommunications transmitters, television mast head amplifiers and elect
rical and
electronic devices.







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An end
-
user’s experience of the mobile network can sometimes be adversely affected
at particular times of the day or year. During certain periods, the mobile network may
be subjected to loads beyond its capacity
,

resulting in

the end
-
user either experiencing
slow network performance
or
,

in worst cases
,

being unable to access the network at
all. Examples of these periods include during popular public events (
for example,

sports events and festivals) and certain periods of the y
ear (
for example,
Christmas
and New Year’s Eve).


Third
-
party networks and services

The performance of third
-
party networks and services can affect the performance of
particular mobile services. End
-
users are increasingly
using mobile networks to
access
i
nternet
-
based services. As these services rely on
,

and are delivered in conjunction
with
,

third
-
party networks and services, poor performance of those networks and
services may cause or exacerbate slow response times. Although the performance of
third
-
part
y networks and services is outside the control of the mobile network provider,
end
-
users may
still
associate any poor network performance with the provider.


Network design and s
pectrum management

Inadequate provisioning or poor management of
radiofrequenc
y
spectrum

resources

can have adverse effects on the performance of a mobile network. Typically, the
greater density of
cell sites a network has, the greater its capacity to manage the
varying loads experienced by the network. During peak demand, having
an

adequate
density of cell
sites
gives
the network greater flexibility to either accommodate the
traffic or distribute the load with an available adjoining cell.


In addition to the
density
of cell sites, provisioning each cell with the appropriate
spectru
m capacity is an important aspect of network management. It’s important to
note that while carriers can
gain access to
spectrum to deploy their mobile networks,
the amount of spectrum available is finite and must be shared among the carrier’s
end
-
users.


Planning for the purchase of spectrum is an essential element of servicing expected
future needs. For example, the Australian digital dividend auction conducted by the
ACMA in 2013 resulted in the allocation of spectrum that will enable the purchasers to
f
urther roll out 4G across Australia, enabling faster and more flexible uses of mobile
technologies and dissemination of data.



When carriers purchase a licence to use a segment of spectrum for their mobile
networks, they are responsible for managing that
finite spectrum to ensure maximum
efficiency. By employing effective
network
management techniques, a carrier can
maximise the re
-
use of the finite spectrum available whil
e

minimising the potential for
interference from nearby cells.


Australia’s three tel
ecommunications carriers have made a $10+ billion investment in
mobile networks, spectrum purchases and spectrum licence reissue fees over the past
two years.
16

While an adequate
density
of cell sites with the appropriate spectrum
capacity helps to facilita
te effective mobile network performance, there are no
regulatory requirements for carriers to provide a cellular service in a particular
geographic location. A carrier will typically make a commercial decision whether to
service a particular area, or in so
me instances, may enter into an agreement with
g
overnment to provide coverage in selected areas (
for example,
along national
highways).


Carriers also have
established
processes to consider co
-
location of infrastructure and
share sites where feasible to o
ptimise deployment.




16

AMTA/Communications Alliance submission to
ACMA, August 2013.




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The performance of mobile networks in some locations may be affected by the
capacity of carriers to install new facilities, where there is opposition from local
residents to the installation of mobile towers

or where space on optimal b
uildings or
towers is not available.



Difference between n
etwork coverage
and
network
performance

Network coverage is the geographical area that is serviced by a carrier’s cellular
network.

As this geographical area is typically derived using software too
ls that predict
the likely areas of coverage, not every location within the coverage area will have
been tested for actual coverage.


In contrast, network performance is the ability of a network to deliver a
functioning
service (such as telephony, data or
SMS) to end
-
users located within a coverage area.


Network coverage and network performance are distinct, but related, concepts that are
often confused. There are multiple factors that contribute to network performance, with
coverage being just one of tho
se factors.
However, in the
f
orum
, the ACMA is focusing
on issues that are related more directly to network performance.


The distinction between
network
coverage and network performance is perhaps best
illustrated in the instance where an end
-
user may be
able to gain access to a mobile
network, as indicated by the signal strength indicator on a handset

but

is unable to
initiate and/or maintain a telephone call or download data at an adequate speed. In
this instance, despite having coverage in a particular
area, an end
-
user may still
experience poor or slow network performance. This could be attributed to numerous
factors, including congestion, as a result of the cell having to divide its finite capacity
among many users during peak periods or outages in oth
er parts of the network.


Figure 3

(for illustrative purposes only) shows that the ability of a
mobile
device to
be
used for

certain services may vary depending on the extent of coverage. For example,
in many cases, as an end
-
user moves further away from
the centre of a cell site, the
maximum achievable data rate will decrease, meaning that data
-
intensive services are
likely to experience a degradation in performance. This may, in effect, restrict the
ability of those data
-
intensive services to operate eff
ectively when an end
-
user is
located at the edge of a coverage area.


Figure 3 Mobile use and coverage








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Network infrastructure development and management

In order for providers to give timely and accurate information to consumers about the
performanc
e of their mobile networks, they need to have robust monitoring systems to
identify and fix problems
,

and to plan for long
-
term improvements.


Carriers undertake a number of measures of their own volition to manage existing
network traffic
, including
encou
raging the migration of customers to the more efficient
4G network,

and

promoting the use of
Wi
-
Fi
and femtocells in the customer’s home or
the use of
Wi
-
Fi
in other locations.

The ACMA is aware of at least one carrier that is
using the migration of custom
ers to 4G to alleviate congestion on its 3G network
. T
he
application of
Wi
-
Fi
is discussed below.


Planning may also be undertaken to anticipate major events, ranging from content
management, such as caching popular downloads (for example, the AFL website

on
weekends) to planning for expected demand on services more generally (such as
upcoming major events that may require more
spectrum resources or greater network
density via the use of temporary cell sites like

cells on wheels

).


Increasingly, provider
s are also likely to consider pricing as a tool to manage network
congestion. For example, at an industry conference in April 2013,
Telstra

raised the
possi
bility of

congestion pricing for both fixed and mobile broadband services, which
would involve charging more for bandwidth at high
-
demand times of the day. The
Australian Competition and Consumer Commission

(ACCC)
also
highlighted
congestion pricing as an emerging regulatory challenge at a later event.


Congestion pricing, sometimes referred to as dynamic pricing, may take the form of
charging less or more for a

service at a particular time of day, charging a monthly
premium for priority access or providing this feature at no additional charge. For
example, Singapore provider Starhub offers free 4G SmartAccess, which is priority
data access, on certain plans. An
issue for the consumer is that there appears to be
no means by which it can be certain
that
priority access

is being received
.


In order to manage services efficiently, a carrier may choose to prioritise certain types
of traffic over others. For example, i
t may enable web browsing and voice/video traffic
ahead of services such as Bittorrent. A carrier may also choose to give higher priority
to traffic generated by premium users on its network.


Carriers may have their own
k
ey
p
erformance
i
ndicators
to
moni
tor performance
,
including

call set
-
up and congestion rates.


Testing may take place to check the robustness of networks and associated
equipment. For instance, a carrier could test the interoperability of a handset and its
operating system with
its

networ
k. This may assist carriers to recommend handsets
that are fit for a particular purpose. Carriers may also test voice call and data speed
quality in dispersed locations through drive tests
, or

use apps to receive data to inform
themselves about network per
formance. For example, in July 2013 Optus announced
that it was updating its
Optus Now

app
to

collect data
that

identif
ies

areas that require
upgrading. Information that will be collected includes locations of black spots and call
dropouts, the strength of

coverage inside buildings and any mobile phone faults.



Sometimes outages may occur that fall outside usual performance parameters. These
may be caused by equipment failure, weather
-
related events or unusual peak demand
for services (for instance, an acc
ident causing traffic delays may place strain on voice
services as commuters make calls).





12

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Carriers may provide feedback mechanisms for consumers to report on coverage and
quality of service issues. For example, Telstra provides a
web form

where customers
can advise Telstra of coverage issues
.


In the event that network development does not keep pace with demand,
customers
may expect

to be informed about performance issues and
any plans by the carrier to
address these issues in the
future
. Carriers make significant investments in network
infrastructure driven by competitive forces.
However,
these

may sometimes be
constrained by the requirement

to comply with the Communications A
lliance Industry
Code
C564:
2011

Mobile Phone Base Station Deployment

that obliges carriers to
consult with affected communities about the planning and installation of mobile phone
netwo
rk infrastructure.


Impacts of plan offers

on performance

A recent survey found that while many operators in the Asia

Pacific have moved to
volume
-
based data plans, 68 per cent of respondents don’t expect mobile operators to
be able to charge for voice an
d SMS on a volume basis, in the next four years.
17

Of
those respondents, 26 per cent believe that operators will have to stop charging for
voice and messaging services within two years
.
18

This trend appears to be due to the
threat of

over
-
the
-
top


services
(OTT), where a consumer could, for example, make
free calls or SMS on a mobile app, using data. An increase in the uptake of unlimited
voice and SMS plan offers can place increased pressure on mobile resources and this
can impact on the performance of the
mobile network.


While there have been significant increases in downloads on mobile phones, the
number of consumers with unlimited data allowances does not appear to have
contributed to this trend. In the December 2012 quarter, just 1.1

per cent

of the
Aus
tralian population had an unlimited mobile data plan
,

down from 1.8

per cent

in the
March 2012 quarter.
19

Should the number of consumers on unlimited data plans
continue to fall, this may relieve some pressure on IP (data) elements of networks.


Rich Commu
nication Suite services (RCS) move voice and messaging capabilities
from

traditional circuit
-
switched technology to delivery over IP. While these services
are in their infancy and are primarily promoted by vendors (service providers to the
telecommunicatio
ns sector), long
-
term performance issues may be data
-
focused.


Wi
-
Fi
as an alternative to network data

Wi
-
Fi
may be accepted as an alternative in instances where a consumer is
experiencing difficulties with data performance
. T
he ACMA has found that there i
s a
growing consumer acceptance of Wi
-
Fi, reporting a 32.1 per cent increase in
Wi
-
Fi
hotspot users in 2012
.
20

There will often be a trade
-
off between the convenience of
using a network and possible savings to the consumer. Tablet users appear to exhibit
a
greater acceptance of
Wi
-
Fi
use. In July 2012, 50 per cent of tablet owners used a
Wi
-
Fi
-
only device, 47 per cent used a device with
Wi
-
Fi
and mobile network access
and the remainder had mobile

network
-
only devices.
21



Internationally, industry has indicat
ed it considers offloading data to
Wi
-
Fi
as a means
to relieve pressures on network congestion

for example, in 2012, 32 per cent of
respondents to an
A
sia

Pacific operator survey

identified Wi
-
Fi as the most effective



17

Ovum Mobile Industry Survey Asia

Pacific 2012

2013, p. 3.

18

Ibid
, p. 2.

19

Roy Morgan Single Source.

20

ACMA
,

Communications report 2011

12

series, Report 3, p. 2.

21

M.
Mackay,
Australian Mobile Phone Lifestyle Index
, Eighth edition, Mob
ile Industry Group, Australian
Interactive Media Industry Association, September 2012.






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way to handle macro
-
network pressures

and it is speculated that once most operators
have commercialised 4G, Wi
-
Fi offloading will become increasingly important for traffic
management.
22



D
evices commonly used to improve coverage

A mobile booster is a powered radiofrequency amplifier that is connected to the mobile
handset to increase the transmitted and received signals, increasing its ability to
communicate with the mobile base station.
It

is illegal for end
-
users to possess or use
a
booster. While a booster increases the range of the handset that it is connected to, it

de
-
sensitises the mobile base station to the other handsets within the same cell site.
The overall effect is that the bas
e station does not

see

these other handsets and
other users
may be prevented from making a call. The ACMA has been actively
raising public awareness of this issue.



Mobile repeaters are designed to improve the mobile coverage of poor signal areas.
Unlik
e mobile boosters
,

which can only service a single handset at a time,

mobile
repeaters are designed to service multiple handsets simultaneousl
y. The use of a
mobile repeater is only permitted if authorised by the holder of the applicable
radiocommunication
s licence (which in practice is usually the mobile carrier
). The
ACMA has been working with the
federal government
to restrict the supply of these
devices to the Australian market. Under recently revised arrangements, a supplier may
only supply
device repe
ater
s

to
people with

an appropriate licence or
those
authorised
by the licence
-
ho
lder to operate the device. These arrangements are intended to
prohibit the supply of repeaters to unlicensed end
-
users and
reduce the number of
reported incidents of interfer
ence caused by the
ir

unauthorised use.


The ACMA is aware that both Telstra and Optus supply products that are designed to
improve the indoor reception of their respective 3G networks. Telstra’s Mobile Smart
Antenna is a mobile repeater that can be purchas
ed and legally used by Telstra
customers. Optus’
s

3G Home Zone uses femtocell technology to extend the indoor
coverage of its network. Unlike the Telstra product
,

which only requires mains power
for operation, the Optus product requires the end
-
user to hav
e a broadband
connection for the product to work.



What are the major
impacts on network performance

and are these sufficiently
explained
?

6.

Have the matters raised in this section adequately captured the technical factors
that impact on network performanc
e, including future pressures?

7.

To what extent do
providers explain technical issues that affect the consumer
experience
?

Do consumers regard such explanations as excuses? If so, h
ow
might this be addressed?

8.

Does
network performance
-
monitoring provide
accur
ate information to consumers
in a dynamic environment where performance is
affected
by demand and network
developments?




22

Ovum Mobile Industry Survey Asia

Pacific 2012

2013, p. 14.




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3.
The consumer lifecycle

It is useful to reflect on

the
consumer experience with mobile
networks

by refer
ring

to
the
consumer lifecycl
e. The ACMA
also
used this approach
in its

RTC

public inquiry.


The lifecycle of a consumer’s experience with mobile network performance
has

four
phases:

>

p
re
-
purchase
expectations

>

t
he purchase decision

>

e
xperience of use in the life of
the contract

>

d
ecidin
g whether to switch providers.

Pre
-
purchase
expectations

General consumer expectations begin to form
well befor
e a
ny

decision to purchase

is
made
.

These will be based on a range of information sources

including:

>

p
ersonal experience with one or more network
s/providers

>

a
necdotal information
from

family and friends

>

a
dvertising

>

o
ther c
onsumer
-
targeted information and websites

>

m
edia

stories
.

The purchase decision

The extent to which network performance is a consideration in the purchase process
is
unclear
. In 20
11, the ACMA found that the main considerations when selecting a
provider for mobile services
we
re price (48 per cent), network coverage (34 per cent)
and the range of products/services offered (21 per cent).
23

As discussed above,
network coverage is
only o
ne

aspect of the consumer’s network performance
experience.



However, n
etwork performance
may
be
a
consideration in

a
consumer’s decision to
purchase from a particular provider
where
that
consumer

has
:

>

been influenced by
marketing claims or

negative repor
ts by other consumers


>

specific needs based on the location(s) of typical use

>

had a negative
experience with network performance

in the past
.

During the contract

While using a mobile service, a consumer who ex
periences network performance
issues
of
concer
n may:

>

f
orbear

for example
,

by tolerating the

poor experience or developing strategies to
minimise inconvenience

>

e
xplore ‘self
-
help’ avenues

for example,

talking with family and friends about their
experiences, crowdsourcing information from the broader co
mmunity using

self
-
help

user forums such as

Whirlpool





23

ACMA,
Community research into telecommunications customer service experiences and associated
behaviours
, M
ay 2011
,

p. 25.






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>

s
eek information from the provider

by visiting its website or making an enquiry via
its customer care channels

>

m
ake
a complaint to the provider

or device manufacturer
seeking resolution of the
issue
s of concern
,
potentially
escalating
the

complaint
to the TIO if
it is
not resolved
satisfactorily.

Swit
ch
ing

During the life of a contract
,

and in particular

at the conclusion of its fixed term, a
consumer
will decide

whether to stay with
the current
prov
ider or change, with
th
eir

experience of
network performance
a
factor
.


Approximately 67

per cent

per cent of Australian consumers use post
-
paid contracts or

plans

for their mobile products
.
24

While these products are attractive to consumers
typically
off
ering
’value bundle’ services and

subsidised handsets, the
y

also typically

involve
early termination fee
s
that
pose a
barrier to
switching
.


Prepaid customers
face lower barriers to
switch
ing

providers.
However
,

it

is estimated
that they
only
account for 3
3

per cent

of total subscribers.
25


When is information on mobile network performance most important in the
consumer lifecycle?

9.

How do consumers compare network performance when making a purchasing
decision? Is there currently sufficient information?

10.

Do
es t
he ability to switch providers offer
sufficient protections for consumers who
are dissatisfied with their mobile
network
experience?

11.

Do provider complaint
s
-
handling avenues
include reasonable measures
for
consumers
to resolve dissatisfaction with their
mob
ile network experience
,
including redress where appropriate
?

12.

Does market failure contribute to difficulties consumers may face? If so, how is it
characterised?

13.

At what point in the lifecycle would better information for consumers make a
material difference

to consumer satisfaction
?





24

IBISWorld Industry Report J7122:
Mobile Telecommunications Carriers in Australia
, December 2012,
pp
.

17

18.

25

Ibid.




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4. Current
consumer information

The market currently delivers information to consumers on some matters that will
affect their experience of mobile network performance.

Much of this is made available
by providers.

Other informat
ion is provided by independent commercial and non
-
government organisations.


Provider

information

Coverage maps and plans

Each of the three mobile network operators provide
s

information on
its
website about
its
network
,

typically focusing on

coverage
(esp
ecially maps)
and
planned
improvements or upgrades

often localised to a consumer’s address
. Resellers also
provide information on their respective websites.
Some examples

of the
type
s

of
information provided
are

at Appendix B.


Handset

information

Some pro
viders also offer information about the suitability of particular handsets for
particular uses.

For example, Telstra’s Blue Tick system denotes handsets suitable for
rural handheld coverage.



Reception

A range of information on how to improve mobile recep
tion is available to consumers.
Industry initiatives include the Mobiletips website, which provides tips on how to
enhance mobile reception

and answers questions about
coverage

and the
Radio
Frequency National Site Archive
, where information on base stations can be located.


One example of carrier information is T
elstra’s web page on how to
maximise
coverage
.


Other

Carriers actively engage with
consumers via
social media
on
network performance
issue
s
;

for ex
ample,

Telstra Crowdsupport.



Some providers, such as Optus, invite customers to
participate
in
regular
surveys
about their experience of the network experience
, in order

to collect historical data. In
July 2013
,

Optus announced an update to its
Optus Now

mobile app for Android to
collect network information from its customers with an opt
-
out option. However, the
survey results and Optus Now app
seem designed
to inform

Optus’
s

network
maintenance and improvements rather than consumers
, as the information g
athered is
not made public
.


Some independent market research, such as JD Power’s
2013 Australia Wireless
Network Quality Study
,
is available for purchase
.

The JD Power
study provides a five
-
scale rating for the comparative national performance of networks
. However, the
detailed methodology
and

results are not usually available to consumers.








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Other information sources

Comparison
and other web
sites

Comparison websites focus on other aspects of mobile services, such as pricing and
inclusions, rather than n
etwork performance.


Whirlpool

is an Australian broadband user website, with over 58
7
,000 registered
accounts as at September 201
3
. The website hosts forums that discuss broadband
and related areas, using an open mode
ration policy. Representatives from many
Australian service providers, hardware vendors and merchants use Whirlpool as a
n

un
official support and communication channel.


Apps

There are a significant number of mobile apps available for consumers

to
:


>

test th
e performance

of their mobile device and network

>

crowdsource information on performance more generally

>

r
eport faults to carriers.

Two examples
, including one developed by the Australian Communications
Consumers Action Network (ACCAN)
,

are at Appendix D.


Other app examples include:

>

Cell phone coverage

>

Mobile Pulse

>

CellMapper

>

OpenSignal

>

SignalCheckPro

>

CoverageMapper

>

CallMapLog

>

Cell Signal Tester
.

Apps
are
useful for recording and reporting problems as they happen. However
,

f
ragmentation of the use of apps
d
epicting

mobile coverage can diminish the
ir ability to
offer
meaningful

‘big picture’ insights
.


Other crowdsourced information

Information for and by consumers can also be crowdsourced on traditional website

platforms and through social media. For exampl
e, in 2010
a
consumer established the
website
www.vodafail.com
, in response to concerns by Vodafone customers about
performance issues. The website provided an opportunity for customers to voice their
concerns in a cen
tral and public space, in turn placing pressure on Vodafone to
address customer concerns. Over 16,000 customers provided coverage details that
were aggregated into a coverage map. Vodafail generated over 150,000 visits and
450,000 page views in little more

than three weeks, generated by media reports and
social networking sites
.
26






26

www.vodafail.com/VodafonesSit
uationYesterdayTodayandTomorrow
-
Final.pdf




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Overseas approaches

Appendix C provides a detailed overview of overseas regulator
y approaches to the
provision of

inform
ation to

consumers about mobile network performance and re
lated
regulatory measures. The breadth of responses suggests some widespread concern
about the importance of mobile connectivity for consumers.


These approaches can be characterised as follows:

>

pre
-
sale information:

>

consumer guides or fact sheets

>

network
coverage map requirements

>

advertising standards

>

contract termination rights

>

q
uality of
s
ervice:

>

minimum standards of performance

>

publication of actual performance

>

penalties or consumer compensation when standards are not met

>

consumer tools for measuring p
erformance.

Regulatory interventions

Appendix E provides an overview of the
relevant

regulatory landscape in Australia.

In
summary, the tools available to the ACMA include:

>

a
n ability to request and
,

in some circumstances
,

to direct industry to develop
cod
es

(notably
limited
in respect to network design features or performance
requirements)

>

t
he power to determine an industry standard where a request for an industry code
has not been complied with, or if directed by the
m
inister

to develop such a
standard.

W
hat information is most helpful to consumers?

14.

What types of information about mobile network performance are most useful to
consumers?

15.

What channels or parties are best positioned to provide comparable information to
consumers?

16.

Do coverage maps provided by

carriers and resellers enable consumers to readily
understand and compare likely performance in locations of importance to them?

17.

Are there other
ways
providers could
communicate likely network
performance

to
consumers based on anticipated uses or network
congestion
?
For example,

while
travelling
,
p
eak times

versus

non
-
peak times. How would any further information
be best presented?

18.

Do apps provide useful information for consumers?
Would there be value in taking
steps to encourage consumers to use a common
app to gather and compare
information?







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5. Possible
a
pproaches

There are three broad approaches

to

deal with any issues identified through
the
ACMA’s
consultative process
. These are:

>

l
eav
ing

the market to resolve these issues over time

>

e
ncourag
ing

industr
y to develop self
-

or co
-
regulatory intervention

>

t
argeted regulatory intervention.


No intervention

This approach assumes that
,

in time, competition will drive improvements in the
delivery of information about mobile network performance and consumers will

become
better informed as the market for mobile device products and services matures.


It recognises that there are number of non
-
targeted regulatory tools

such as the
TCP

Code and Australian
c
onsumer
l
aws

that may provide some relief to consumers
who
ha
ve
difficulties

using mobile devices.


Industry intervention

This
approach is appropriate where

industry
is

motivated and best placed to address
the

issues identified
.



For example, industry addressed
the identified
need for improved consumer
information
at the point of sale by developing Critical Information Summaries. It would
be open to industry to develop improved information mechanisms or tools that
specifically deal with

mobile network performance.



Targeted intervention

This option would be availab
le if issues of significant consumer detriment are identified
and
industry does not act to ensure there are appropriate safeguards in place
.


The ACMA has a
limited
range of powers to interven
e
, including

the ability to make

standards
and
service provider

rules
in certain circumstances.

These are addressed in
detail in the
final report

of the

RTC

inquiry.
27

Any regulatory
interventions would
be
subject to the review of the Office of Best Practice Regulation
.


A significant limiting factor is
s
ection 115 of the
Telecommunications Act
, which states
an industry code or standard has no effect
on
the extent to which compliance i
s likely
to require a telecommunications network to meet particular performance requirements.


The ACMA could also take steps
falling short of formal rule
-
making
. For example, it
could develop a monitoring and reporting program for mobile services
, similar

to

that
being considered by the ACCC for
fixed broadband services
. However
,

as outlined in
Appendix E, the ACMA has provided performanc
e
-
reporting for mobile networks
before

but

discontinued
it

in 2005 as part of a
g
overnment push to reduce regulatory
burden and due to concerns about its effectiveness
. Accordingly,

the usefulness to
consumers of any proposed new reporting
would need to be

careful
ly

consider
ed
.




27

Since the RTC inquiry, the ACMA has acquired powers to make service provider determinations setting
out rules that apply to service providers
for
a customer’s interests.




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Appendix A

Q
uestions

1.

What causes consumers to complain about mobile connectivity?

2.

How do

consumers
evaluate the network performance of their provider? Can
consumers compare the performance of different providers’ networks?

3.

If there
is a problem: what more could be done and who is best positioned to
implement?

4.

How do consumers identify and describe difficulties they experience with their
mobile service?

How do consumers respond to less than optimal experiences?

5.

What are the main cause
s of complaint and are these changing over time?

6.

Have the matters raised in this section
(
Technical aspects of performance
)
adequately captured the technical factors that impact on network performance,
including future pressures?

7.

To what extent do provider
s explain technical issues that affect the consumer
experience? Do consumers regard such as explanations as excuses? If so, how
might this be addressed?

8.

Doe
s network performance monitoring provide accurate information to consumers
in a dynamic environment
where performance is
affected
by demand and network
developments?

9.

How do consumers compare network performance when making a purchasing
decision? Is there currently sufficient information?

10.

Does the ability to switch providers offer sufficient protections f
or consumers who
are dissatisfied with their mobile network experience?

11.

Do provider complaint
s
-
handling avenues include reasonable measures
for

consumers to
resolve dissatisfaction with their mobile network experience,
including redress where appropriate?

12.

Does market failure contribute to difficulties consumers may face? If so, how is it
characterised?

13.

At what point in the lifecycle would better information for consumers make a
material difference to consumer satisfaction
?

14.

What types of information about mo
bile network performance are most useful to
consumers?

15.

What channels or parties are best positioned to provide comparable information to
consumers?

16.

Do coverage maps provided by carriers and resellers enable consumers to readily
understand and compare likel
y performance in locations of importance to them?

17.

Are there other ways providers could communicate likely network performance to
consumers based on anticipated uses or network congestion?
For example,
while
travelling
,
p
eak times v
ersus

non
-
peak times. How

would any further information
be best presented?

18.

Do apps provide useful information for consumers? Would there be value in taking
steps to encourage consumers to use a common app to gather and compare
information?







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Appendix B


Review of mobile network
inf
ormation on provider websites

Carriers

Telstra

Figure
B
2

Telstra mobile coverage




Telstra provides a detailed mobile coverage map and the facility for consumers to
check the network coverage at any Australian address. The ma
p allows the user to
check for coverage by network type (4G & Next G, Telstra’s advanced 3G service), by
voice or data services, and with or without an external antenna. The map also
indicates the types of communication uses that are suitable when using di
fferent parts
of the network (for example, whether the network can be used for voice, picture, TV
video and broadband), and gives typical data speed ranges available in an area.



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Unlike other network operators, Telstra’s coverage map does not distinguish be
tween
indoor and outdoor coverage.


Information is also provided about factors that affect coverage and how coverage can
be maximised.

For example, Telstra’s website has information about the use of
external antennas (
for example,

when camping) or when tra
velling (car antenna kit) to
improve coverage at locations at the edges of its network, and about the suitability of
certain handsets for different coverage areas. They also offer a product (Telstra
Mobile Smart Antenna
®
) to improve indoor coverage.


Tels
tra provides a user
-
friendly technical overview of
its
GSM (2G), GPRS, 3G HSPA
and 4G networks and the main differences in terms of the speeds and services they
support. This page highlights attributes of the Telstra Mobile Network, with a focus on
high po
pulation and area coverage, fast data transfer speed, network reliability and
high definition voice quality. Although Telstra does not detail its network monitoring
activities, a link to enable users to report coverage black spots is available on its
mobil
e coverage map page. A troubleshooting page is also available for users who are
experiencing problems with phone reception or dropped calls.


Telstra offers a coverage guarantee to customers on its BigPond mobile broadband
data plans
that
allows them to re
turn a device within 10 days without paying an early
termination fee if the device does not work due to poor or no network coverage.


Information on Telstra’s website about network development centres on its recent 4G
(LTE) network upgrade. Features of it
s new 4G network, such as enhanced data
speeds and its availability is shown on Telstra’s mobile coverage map, integrated with
its 3G network coverage.


Optus

Optus provides a detailed mobile coverage map that enables users to check the
network coverage i
n an area or at a particular address. The coverage shown is
referred to as outdoor coverage. Users can view the applicable coverage when using
the device alone, where a separate antenna is needed and where future coverage is
planned. Coverage of the Optus
2G, 3G

and 4G networks is shown. To help
consumers, the map indicates which bands a particular device will need to be
compatible with to use (
for example,

3G dual band devices must be capable of using
2100 MHz and 900 MHz bands).


Optus is promoting its 4G

network capability as enabling much faster download
speeds, making it easier to use services such as high
-
quality video and music
streaming and file
-
sharing. Optus gives consumers specific information about its 4G
availability on dedicated web pages and h
as integrated its current 4G coverage into its
coverage map. Optus offers two types of 4G services
:

>

4G, which uses FD
-
LTE (Frequency Distribution

Long Term Evolution
technology)

>

4G Plus, which uses TD
-
LTE (Time Division

Long Term Evolution technology).

T
he Optus website notes that 4G Plus is available in Canberra and certain areas in
Sydney, Melbourne, Brisbane and Adelaide, where it is being rolled out. Consumers
are cautioned that they require mobile plans and a mobile device that is specifically
compat
ible with 4G or 4G Plus to use these networks. Simple labelling is used on
Optus’
s

mobile devices to help customers know whether they are compatible with
these 4G networks.







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Figure B2 Optus mobile coverage



Technical support is available to Optus custo
mers on a dedicated phone number.
Optus also has trouble
-
shooting web pages about difficulties with various services
such as making calls, sending messages and internet use. To improve mobile
reception in the home, Optus offers a product called ‘3G Home Zo
ne’, compatible with
its 3G network.


An overview of the technical aspects of Optus’
s

mobile network is provided, along with
information about its national management centre for monitoring network performance.
Optus also offers FAQs to help customers dete
rmine whether an issue they are
experiencing is network
-

or device
-
related. An Optus mobile app is also available
that
displays signal strength and provides crowdsourced network data back to Optus.
Optus uses this information to monitor its network perform
ance. The website also
describes network improvements at a national level and notes what the carrier is doing
for mobile coverage in regional communities.





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Vodafone

Figur
e B
3

Vodafone mobile coverage




Vodafone’s mobile network coverage checker map a
sks users for the type of mobile
device they are using (
for example,
iPhone 4S) and shows mobile coverage according
to that device. Users can see coverage for voice and SMS for indoor and outdoor
conditions, where data services are available and which part

of the network is
available for data services (
for example,

3G). It also displays areas covered by
different parts of the network (2G, 3G, 4G) and the frequency bands used so that
consumer
s can check device compatibility, as well as areas where network
im
provements are planned within
three
,
six
,
nine
and 12 months. Coverage maps also
show local network interruptions. Terms used to describe coverage areas such as
‘Good Outdoor and Indoor’, ‘4G Indoor’, ‘3G Coverage’
are
defined in the map legend.


Vodafone
has several web pages explaining technical aspects of
its
mobile network in
user
-
friendly language, including a range of FAQs about
its
network. These pages
help consumers understand the frequency bands that are used for each part of
Vodafone’s network (
fo
r example,
3G, 4G) and provide a list of mobile phones
showing the bands they are compatible with. Information is also provided about the
meaning of network symbols that appear on mobile displays, frequencies and
networks they indicate are being used (
for
example,

GPRS, HSPA, and LTE).






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25


Major network outages across Australia can be checked on the Vodafone website.
Users can also search for any recent local network outages or issues by postcode.
Vodafone does not have a contact number dedicated to technical i
ssues
;

however
,

its
website has a service centre
that
offers network trouble
-
shooting tips. In addition,
Vodafone offers a network guarantee that allows new customers to cancel their
contract in the first 30 days without early termination fees if they are
unhappy with the
network.


Improvements and upgrades to the Vodafone network at a national level are also
described, with a focus on replac
ing

existing equipment and addi
ng

new mobile sites
to improve coverage, reliability and speed. The depth and breadth
of population
coverage in regional areas is also being increased. Network improvements highlight
Vodafone’s new 4G network. Vodafone
has
dedicated information about
its
4G
service, including its coverage, significantly faster data speeds and how the networ
k
improves customer mobile experience.


Resellers

In June 2013, ACMA staff conducted a desktop survey of mobile service resellers to
examine the information provided about the network coverage for their mobile
products. The websites of 21 resellers were ex
amined and included resellers of
services using each of the three carriers.


The survey found that all resellers sampled were displaying mobile coverage
information on their websites for their mobile services. In accordance with the TCP
Code, these were pr
esented in the form of maps or diagrams and were all relatively
easy to find.


The effort that

various

resellers went to in providing user
-
friendly mobile coverage
information, and the level of detail shown, differed considerably.
Four

resellers
(19.1

per

cent
)
provided a link to their network provider’s own mobile coverage web
pages to show the relevant coverage information. However, the large majority
(80.
9

per cent
) provided coverage information on their own website. Of the latter
group, nearly all rese
llers relied on coverage maps that had been prepared by the
operator of the network they used. Only one reseller claimed to have prepared its own
maps.


Of surveyed resellers us
ing

coverage maps of their network providers, most (69

per
cent
) incorporated v
arious interactive features.
These

include
d

location finders to
enable the coverage at a specific address, a zoom function, the ability to selectively
show the coverage of different parts of a network (
for example,

2G, 3G or 4G
coverage) and the ability to

change colour contrasts to see maps more clearly.
Interactive maps also frequently showed separate coverage areas for outdoor, outdoor
with external antenna and future service coverage.


A

minority of resellers surveyed (31

per cent
) present
ed

static cove
rage maps, based
on maps prepared by the network operator they use. Static maps do not include many
of the interactive features available on other reseller websites. For example,
they
do
not allow viewers to zoom in and out of parts of the network or allow

a specific address
to be shown. This makes it harder for consumers to be confident about the level of
coverage in their area. Resellers who use static coverage maps typically presented
the overall network coverage in a series of smaller maps covering stat
e and capital
city areas.


In addition to mobile coverage, most resellers included information about other factors
affecting network performance. These resellers cautioned consumers that local
conditions such as network traffic and

a location

inside concre
te buildings or other



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solid barriers could prevent or interfere with mobile reception. Handset quality and
software were also often stated as factors that could affect mobile reception.


A minority of resellers (19.1
per cent
) provided information about i
mproving mobile
coverage performance or reception quality. Where information was provided, it tended
to be limited to suggestions to use an external antenna or ensure that the most up
-
to
-
date mobile software was installed.







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Appendix C

Overseas
approaches

T
he information below provides an overview of activity by overseas network providers
and regulators to address the information needs of consumers for mobile network
performance.


Several overseas telecommunications regulators are taking steps to ensure that

network providers are more transparent about the quality of service that consumers
can expect. Some approaches by regulators are primarily aimed at raising consumer
awareness of network performance as a factor to consider before a purchase. These
approach
es typically involve providing general advice about mobile services. Other
approaches deliver more targeted information about the coverage and network
performance that customers can expect from a mobile service.


Some regulators have introduced measures t
hat offer consumer protections against
poor mobile service after a purchase, such as mandatory ‘trial periods’
. O
thers have
gone further by requiring service providers to include
Q
uality of
S
ervice requirements
in customer contracts or by setting minimum n
etwork performance standards.


Overseas network operators have responded to the difficulty that consumers have in
assessing the quality of different mobile services. In most cases, operators provide
network coverage maps for consumers to check the level of

coverage in their area.
Service providers may also offer information about how to maximise reception, the
differences in expected reception between indoor and outdoor areas or what types of
mobile handsets are best suited to a particular element of their
network.


Pre
-
sale information from regulators

Guides or advice for consumers to consider before committing to a new mobile
service, as well as consumer warnings, are

available from several regulators.
Information is typically presented in plain language a
nd is accessible online.
Regulators also help consumers find other useful information about network
information on mobile providers’ websites.


The UK regulator, Ofcom
, has a
‘Maximising Mobile Coverage’ guide
that
offers tips
and practical steps for peop
le to take to get the best mobile coverage available. It
includes advice about checking before a purchase (
for example,

looking at coverage
maps, pre
-
testing a network with a pre
-
paid service, asking about network
guarantees), and improving coverage at hom
e and while travelling. Ofcom also has
separate information about mobile coverage checkers and gives links to coverage
maps of UK network providers. It also has its own coverage information (see next
section).


With the take
-
up of 4G services, several regu
lators provide consumer information
about this new technology. Ofcom provides basic details about what 4G is, what
people can expect when using it, the types of mobile services it is suited to (
for
example,

video streaming), typical download speeds relativ
e to 3G and the total
coverage across the UK when it is rolled out.


Hong Kong’s regulator, the Office of the Communications Authority

(OFCA)
,

warns
consumers that not all mobile networks in Hong Kong are compatible with all

4G
-
enabled devices and advises

consumers to check compatibility of a device with a
particular network before purchasing.





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Coverage maps

Network coverage maps are the most widely available tool offered by overseas
network providers
for consumers
to check network coverage information. M
any have
coverage maps on their websites
that
allow consumers to check network details
including coverage of different parts of the network

2G, 3G and 4G

potential data
speeds, where different mobile services can be used and planned future coverage.
The le
vel of detail presented varies significantly between providers within and between
countries.


Coverage maps
largely
appear to be an industry
-
driven initiative to help consumers
check coverage and distinguish the coverage levels between providers. However,
some telecommunications regulators have mandated
that
mobile providers
mak
e

network coverage maps available to consumers. For example, the new Canadian
Wireless Code

introduced recently requires post
-
paid contracts to include how
customers can access compl
ete service coverage maps.


Ofcom provides mobile coverage maps

for UK consumers
. Ofcom’s maps show the
level of outdoor coverage data provided by all network operators in 201 administrative
authority areas (cities, town regions and counties) throughout th
e UK.
28

Consumers
can view coverage for 2G and 3G services separately and
,

with each mobile service
type, the percentage of coverage can be seen based on geographic area or number of
premises in a selected administrative authority. Ofcom also ranks each adm
inistrative
authority by the level of mobile coverage on a
five
-
point scale, with each ranking
assigned a different colour on
the
coverage maps.


Advertising

The information presented to consumers in advertising and marketing materials about
network perfor
mance has also drawn attention from some overseas regulators. Since
1 April 2012, Singapore
an

telecommunications authorities require internet service
providers (ISPs) to publish broadband (mobile and fixed) download speeds that
customers are likely to expe
rience,
both
on their websites and in other advertising
materials. The German regulator, Bundesnetzagentur, is also consulting on a package
of measures to help consumers understand the network performance they can expect
from their mobile provider.
29

This p
ackage includes consumer fact sheets
with
easy
-
to
-
read information on the minimum and maximum
achievable data transfer
speeds

also set out clearly in their contract
.


Consumer protection regulations

Mobile customers are also starting to benefit from new co
nsumer protection rules and
service provider policies that allow them to leave a contract if they are unhappy with
the network performance experienced. Under Canada’s Wireless Code, new mobile
service contracts allow consumers to cancel a mobile phone cont
ract and return the
handset at no cost within 15 days (30 days for people with a disability), if they are
unhappy with the service.


Bundesnetzagentur is canvassing the idea of special termination rights as one of
several possible responses available to co
nsumers if their mobile provider does not
meet certain network performance measures promised at the time of purchase.


The provision of a handset at significant discount to the consumer may present a
barrier to exit. The OECD released a paper in 2013 revi
ewing mobile handset
acquisition models among its member countries. It identified a number of countries
that enforce maximum periods for contracts
,

after which customers are entitled to have



28

Ofcom website, UK Mobile Services Map 2
012,
http://maps.ofcom.org.uk/mobile
-
services/
, 23 July 2013.

29

Media release from Bundesnetzagentur, 10 May 2013
,

www.bundesnetzagentur.de/cln_1931/SharedDocs/Pressemitteilungen/EN/2013/130510_KeyElementsTran
sparency.html;jsessionid=070E46EAB1DA6547D5F5303A9E7BF091?nn=4045
30
.






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their handsets unlocked.
30

The paper also addresses some approache
s by
jurisdictions to bundled offers (handsets and services) but notes the economic and
social benefits to many consumers from not having to purchase a handset upfront.


Performance comparisons

Quality of Service

An increasing number of regulators are intr
oducing policies to give consumers up
-
to
-
date measurements of the network performance of mobile providers available in their
area. This information can be used to compare network quality before a consumer
makes a purchasing choice. Having current informati
on of key network performance
measures also allows mobile users to check whether or not the performance
advertised at the time of sale is being delivered.


Some regulators require or encourage the availability of metrics such as mobile
connection and dropo
ut rates, voice quality, upload and download speeds, and latency
times. This information can be required to be published and renewed regularly by
service providers in advertising and on the
ir

websites.
Apps and w
ebsites are also
being made available that a
llow consumers to take measurements of their own
network performance experience, rather than rely entirely on information produced by
service providers (or regulators) and that may not apply to a
consumer
’s location. For
example, the
US
Federal Communicati
ons Commission
(FCC)
has a mobile
broadband performance app

Measuring Broadband America

that is also used to
provide intelligence towards a regular study of performance.

In some cases, regulators have gone further by setting minimum standards of mobile
cov
erage and network performance. Where these are not met, service providers can
be liable for significant fines or compensation to consumers.


Benchmarks imposed by regulators

In Spain,
Q
uality of
S
ervice standards exist for mobile phone and internet service
s
(and fixed
-
line services) and apply to operators

with an annual turnover of more than
€20 million. Operators must publish separate quarterly reports on their website for
mobile phone, internet and fixed
-
line phone service quality. Mobile phone reports
include measures of:

>

q
uality of voice connection (se
parate measures for calls to fixed and mobile
phones)

>

p
ercentage of failed calls over the network

>

p
ercentage of mobile calls that drop out.

Similarly, quarterly reports on internet service (fixed and wireless) include:

>

p
ercentage of successful user access
(probability that a user can gain access to
the network and the internet)

>

p
ercentage of failed data transmissions (probability of failure of a transmission of a
file from a server)

>

d
ata speeds achieved (minimum, maximum and average speeds).

These reports a
re also published on the Spanish telecommunications regulator’s
(SETSI) website and provide links to the provider’s website where they publish their
own
Q
uality of
S
ervice data. SETSI also notes on its website when there are
reasonable doubts about the rel
iability of quality of service data.


In Spain, commitments of service quality are put in contracts for mobile phone (pre
-
paid and post
-
paid) and internet service contracts. Contracts set out service



30

Mobile Handset Acquisition Models
, OECD Digital Economy Papers No. 224, OECD (2013), p
.
5.




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commitments as quantifiable measures (
for example,

maxim
um hours per month
disruption to service), the compensation due to the customer when a breach occurs
and the means by which compensation will be paid (
for example,

upon request within
10 days of restoration of service).


In Argentina,
Quality of Service
me
asures are related to the degree of satisfaction
experienced by consumers at locations spread across the country. They also require
providers to publish their quality of service data and provide data for a site that allows
consumers to easily compare diffe
rent services.


The

InfoComm Development Authority of Singapore (IDA) has put in place minimum
coverage levels and quality of service standards for network performance for 3G
mobile services. Minimum coverage standards were raised in April 2012 to ensure t
hat
coverage extends to 99

per cent

of outdoor areas nationwide,
more than
99

per cent

of
new underground rail tunnels and
more than
85

per cent

coverage within each
building. Minimum

Q
uality of
S
ervice standards for mobile phones have also been set
for su
ccessful call rates and call dropout rates during peak times. Under the new
regulations, maximum call dropout rates have been lowered from

less than
five

per
cent

to
less than
one

per cent

per month. Operators may be subject to financial
penalties of up to

$50,000 for each instance of non
-
compliance (up from $5
,
000).


Singapore also requires all ISPs providing mobile (and fixed) broadband services to
residential customers to publish typical internet access download speeds likely to be
experienced by end
-
use
rs, as well as theoretical maximum speeds, prominently on
their website and in advertising materials. Broadband download speed measurements
must be checked at least quarterly. Large ISPs must meet additional
Q
uality of
S
ervice parameters.


Bundesnetzagentu
r has also recently announced proposals to require greater
transparency about the performance of mobile networks. While at the consultation
stage, these proposals would require minimum and maximum internet
network
speeds
to be set out in a customer’s contr
act. Providers would also need to measure actual
network speeds at a number of locations across Germany and publish the results. The
proposals suggest that if network speeds are below what is in customer contracts,
compensation for
affected
customers shoul
d be considered. Consultation on these
proposals end
ed

on 2 September 2013.


Greater transparency of
Q
uality of
S
ervice metrics

While not setting network performance standards, Hong Kong’s regulator, the Office of
the Telecommunications Authority (OFTA), h
as put in place requirements to provide
information about mobile broadband network performance to consumers. In 2010,
OFTA introduced a system of ‘performance pledges’, which involves mobile operators
publishing network quality standards that they aim to a
chieve. The performance
pledges cover aspects of network performance such as network reliability, service
restoration time and technical parameters (as well as other customer service
-
related
issues). The performance pledges are not service guarantees but a
re intended to give
consumers a reasonable indication of the normal level of service they can expect from
each provider.


The OFTA website includes links to the ‘
p
erformance pledge’ pages on each
operator’s website. Operators are also required to publish q
uarterly statistics on the
actual performance of their mobile broadband network. Consumers can compare the
actual performance of a network with the corresponding operator’s performance
pledges. Publishing this data aim
s to

encourag
e

operators to continue t
o improve their
network performance and customer service.


OFTA has also launched a website that enables consumers to measure the
performance of their mobile broadband service in an objective and independent way.





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This gives consumers additional information

to compare against
the
performance
pledges of their provider.


The regulator in Bahrain, the Telecommunications Regulatory Authority (TRA)

monitors key performance indicators (KPIs) of licensed operators. The TRA publishes
Q
uality of
S
ervice reports on th
e performance of mobiles (annually), fixed broadband
(quarterly) and WiMAX services (annually).


Measurements published by the TRA are conducted from the point of view of the
consumer (
that is
,

using handsets and services available to consumers, testing a
t
locations across Bahrain). The KPIs are measured for
:

>

voice services (percentage of successful
two
-
minute calls completed)

>

SMS (percentage received in two minutes,
30

seconds, 15 seconds)

>

mobile broadband (time to establish internet connection, successfu
l data transfers,
and average and minimum download time)

>

video streaming.

Testing is done at scores of locations, under various conditions (indoor, outdoor,

in
-
car) and at different days and times.


The US and UK appear to be moving to a similar approach

of greater transparency
about network performance, rather than setting minimum benchmarks. In 2010, the
FCC sought comment on how to assess mobile broadband network performance and
coverage, as well as information from providers about how they measure the
ir own
network performance and coverage. Last September, the FCC began a public
discussion about the best ways to measure mobile broadband. The focus on mobile
broadband performance is an extension of an earlier program that monitors fixed
broadband servic
es.


As part of its initiative to
give
consumers more information about the quality of mobile
broadband networks, the FCC has also launched a testing app. The app allows users
to check in real time the performance of broadband speeds being experienced.


Of
com has conducted a public consultation about
Q
uality of
S
ervice measures
,
seeking
comment on its paper,
Measuring mobile voice and data quality of experience
,
in January 2013
.
31

This paper asked for public feedback about what information would
be valuable
to consumers when purchasing mobile services, what data would be
required to produce this consumer information and how best to collect it.


The Ofcom paper commented that there were likely to be a number of core
characteristics of ‘quality of experience’
of a mobile service that consumers would
benefit from knowing. These include
:

>

operator
-
specific information that allows a comparison of rival networks

>

how mobile services perform in locations where
people
live and work

>

variations of the likely quality of e
xperience depending on local factors (
for
example,

indoors or outdoors, travelling on a train)

>

time factors (
for example,

peak and non
-
peak times).




31

Measuring mobile voice and data quality of experience
, Ofcom consultation paper issued 23

January
2013. Consultation ended 1

April
2013
,

http://stakeholders.ofcom.org.uk/consultations/mobile
-
voice
-
data
-
experience/
.





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The paper also suggested some likely metrics that may be useful to consumers such
as
the
probability of a m
obile call being completed successfully,
the
probability of call
dropouts, clarity of the call and the time for an SMS text message to be delivered.
Similarly, useful metrics of internet services may include the probability that an internet
connection can
be made, and the speed, stability and responsiveness of applications
and data transfers. This consultation closed in April

and Ofcom is reviewing the
information received.






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Appendix D

App examples

MyMobileCoverage

The MyMobileCoverage app provides the follo
wing functionalities:

>

Data speed test for latency, downloads and uploads (see Figure D
1
).

>

Scalable coverage maps for carrier networks (
see F
igure
D2
)
.

>

Crowdsourced geographic information on difficulties users experience with
dropped/failed calls, no servic
e and no data (
see F
igure
D3
)
.
This functionality
enables reporting to carriers
.

>

Ranking comparisons of providers for different uses
.

>

Notifies users when coverage is lost or a phone call dropped out.


Figure D1 MyMobileCoverage app









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Figure D2
Examp
le of scalable coverage map





Figure D3
Example of user difficulty data








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ACCAN Phone Rights

ACCAN launched its Phone Rights app in March 2013. The app enables consumers to
record where and when they are expe
riencing poor mobile reception.
It

li
nk
s

a
snapshot of the smartphone screen showing the number of reception bars with the
phone’s location

and generates a simple report. This report can be emailed from the
app and used to support a customer complaint about poor mobile reception. Figure D4
sh
ows a typical report generated by this app.


The app includes
a video guide on what
to

do about poor mobile reception.


Figure
D
4

ACCAN Phone

Rights

R
eport example






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Appendix E

The Australian
regulatory landscape

The ACMA’s remit
extends to both

techni
cal regulation and consumer protection
regulation.


Telecommunications Act 1997

Among the key

regulatory tools available to the ACMA are industry codes and
standards under Part 6 of the
Telecommunications Act 1997

(the Act), which can only
apply in relatio
n to specific matters.


The
i
ndustry
c
ode
ACIF C519:2004

End
-
to
-
end network performance for the standard
telephone service

requires providers to meet minimum

levels of

performance for the
end
-
to
-
end carriage of the standard telephone

service

(STS)
over pu
blic fixed
telecommunications networks and public digital mobile telecommunications

networks.
This
c
ode does not provide a useful basis for measuring the overall performance of
mobile networks and the ACMA has found that compliance with this code does not
necessarily equate with a satisfactory end
-
user experience.


The primary limitation of the existing code is that it focuses solely on the performance
of the
STS,

which relates to voice telephony. This limitation arises because under
Part

6 of the Act, ind
ustry codes and standards are not permitted to require a
telecommunications network (or customer equipment, customer cabling or facilities) to
have particular design features or performance requirements, unless th
ey

relate to,
among other things, the quali
ty of STS, which
is
defined by voice telephony. The
current code is only able to address the performance of voice telephony carried on
mobile networks, and not other aspects of mobile network performance such as data
and SMS.


To date, no regulations have
been made that would allow an industry code or standard
to address mobile network performance more generally (beyond the performance of
the STS).


The
Telecommunications Consumer Protections Code C628:2012

(TCP Code) was
registered by the ACMA effective fr
om 1 September 2012. Industry developed this
code
,

adopting many of the proposals developed by the ACMA through its
RTC

public
inquiry
,

an 18
-
month
exploration
of customer service and complaint
s
-
handling
practices in the telecommunications sector. The RTC
found that for many consumers,
choosing a product and service provider is difficult.


Factors that contribute to the
se

difficulties include:

>

p
oor advertising and marketing practices that do not accurately represent key
features of telecommunications produ
cts

>

c
ritical information not disclosed clearly

>

r
eliance on representations made at the point
-
of
-
sale.

The TCP Code contains some rules that specifically pertain to mobile performance,
while others are more general in nature but have application to these is
sues.







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The following TCP Code protections apply to information offered to consumers:

>

d
escription of the service on offer in a document titled the
Critical Information
Summary
,

which must be made available to consumers at the point of sale,
including reta
il stores and websites

>

w
ebsite information about mobile coverage specifically, which may include maps or
diagrams

>

p
rohibition on advertising network coverage unless the coverage is

generally
available


to consumers in the claimed coverage area

>

a
ccurate, r
elevant and current information to consumers

>

a
ccurate description of products, including substantiation.

The TCP Code also requires providers to
give consumers
information about
their

particular needs where they are identified, and provide appropriate rem
edies where a
consumer has relied on inaccurate information to enter a contract.


It is too early to determine whether the

new

TCP Code is having a material impact on
the
level

of complaints to the TIO about mobile performance issues
. S
ome of the
above pro
tections were in place under the previous TCP Code (
for example,

availability of maps), while others came into force from 1 September 2012 (
for
example,
prohibition on advertising network coverage) or later (Critical Information
Summaries). However
,
compla
int issues of
about mobile performance
have been on
the rise
since
June 2012.



The ACMA issued
directions
to two Vodafone companies in December 2011 for not
meeting the requirements of the former TCP Code by failing to provide timely
customer information
about network performance issues in late 2010.


Telecommunications (Consumer Protection and Service Standards) Act 1999

(TCPSS Act)

By contrast with mobile services, the Customer Service Guarantee (CSG) scheme,
established under the TCPSS Act,
aids
residen
tial and small
-
business customers who
experience poor fixed
-
line telephone service by providing compensation payments for
late connections and fault repairs.


The CSG Standard specifies time frames for the connection of specified services, the
repair of fa
ults and the attendance of appointments by service providers. Customers
are entitled to compensation if these time frames are not met. The ACMA publishes
quarterly data on aspects of CSG delivery.


The Australian Communications Authority (one of the ACMA’s

predecessors)
published reports from carriers on the annual performance of GSM and CDMA mobile
networks

for
call dropout rates, congestion rates and population coverage. Telstra’s
performance was reported quarterly. Reporting on these metrics was disconti
nued in
September 2005 as part of a
g
overnment push to reduce regulatory burden. There
were also concerns about the comparability of the information provided. Appendix
C

outlines a range of performance measures that have been implemented by overseas
regula
tors. However, careful consideration needs to be given to the usefulness of such
measures in the Australian context, given the significant differences in geography
between Australia and very small nations such as Singapore and Bahrain. Any
measures used mu
st not only be comparable, but must be
sufficiently
granular to be
meaningful to consumers while not being so specific that the information is too
localised to serve as a general comparative tool.





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Australian Consumer Laws

The Australian Consumer Laws (ACL
), introduced on 1 January 2011,
give
consumers
a number of guarantees when purchasing goods and services. These include a
guarantee that services provided (
for example
,

mobile network services) are fit for any
disclosed purpose that is expressly or implie
dly made known to the supplier. An
individual consumer could make a complaint to the
ACCC

or its state/territory Office of
Fair Trading in the event that a mobile network service provider did not meet any of
the consumer guarantees.