COFEK July 2011 Study on the Kenya Communication Sector

COFEK Mobile Termination (MTR), Mobile Number Portability (MNP) and Cost of Internet

Mobile Termination (MTR), Mobile Number Portability (MNP) and Cost of Internet in Kenya as at July 2011


About Consumers Federation of Kenya COFEK is Kenya’s independent, self‐funded, multi‐sectoral and non‐profit society, registered on 26th March 2010 as a membership society under Cap. 108 Laws of Kenya. Our members are ordinary consumers and professionals from various walks of life and areas spread across the country who see the need to own and support COFEK vision, mission and values.

We boast of a Council of 20 officials who represent the Federation at the national level. Those Council members are led by the Chairperson, Secretary General and other officials (professionals) heading specific sectors such as Security; Banking; ICT; Roads; Transport; Water; Energy; Agriculture; Education; Tourism; Food; Health and drugs; Supermarkets; Electronics; Environment; Aviation; Automobiles; Insurance; Local Authorities, among others.

We work with Government of Kenya, mainstream media, trade unions, regulatory agencies, private sector and other non‐state actors in achieving consumer solutions and more so on restoring consumer pride and confidence. Our advocacy is based on authentic information as backed by continuous research. Our work is informed by the need to empower the consumer through requisite legislation, policies, civic awareness on consumer rights and other attendant issues.

Our diverse expert‐filled Governing Council assists our lean secretariat to carry out the enormous task of salvaging Kenya's consumer interests that have remained under attack since the country attained independence in 1963.

As such, our work emphasizes the need for a conducive environment to allow for competitive trade and business. We strongly believe that what is good for the consumer is good for business. We fight monopolies and price control tendencies. We fight counterfeits and unfair business practices. We sound alerts on market recalls. All in all, we yearn to see the 100% restoration of consumer pride and confidence in Kenya!

Note on Authors:

Aaron Thuo is an 8 year ICT consultant and has previously worked for Comcast in the U.S.A and Wananchi Group in Kenya. His management career in these organizations has spanned training, operations, project management and customer service. Recent consultancy work in Kenya has included feasibility studies for fiber network infrastructure providers in satellite Kenyan cities and other data, voice& video solutions in Kenya. He holds Bachelor’s of Science degree in International Business from USIU‐A and a Masters in Technology from Eastern Michigan University.

Charles Kihungi is seasoned financial expert with more than 8 years of investment banking, corporate finance, and financial management and fund management experience in Africa. Mr. Kihungi was the Director of Strategy and Business Development with Wananchi Group Ltd. At Wananchi, Mr. Kihungi was in charge of Wananchi’s regional expansion and was in charge end to end sourcing target acquisitions in the greater East African region. Mr. Kihungi also held various posts at CFC Stanbic Investment Bank including, Head of investments, Portfolio Manager and Principal Corporate Finance Analyst. Mr. Kihungi graduated with an Honors Bachelor of Laws (LLB) degree from the University of Sheffield and a Master of Science in Financial Management degree from Middlesex University in England. Mr. Kihungi also Holds a Postgraduate diploma in Corporate Finance from Suffolk University in Boston USA. Mr. Kihungi is a qualified Lawyer and an advocate of the High Court of Kenya. Mr. Kihungi is the founding director of Tri‐magus Ltd, a financial consulting firm in East Africa.

Copyright 2011

For more information contact;

The Secretary General Consumers Federation of Kenya (COFEK) Meky Place, Block F Suite 45 Ngong Road/Ring Rd Kilimani Junction P.O Box 2733‐00200

City Square, Nairobi 00200

[email protected]

254‐20‐3861718, 2300859, 3861719

254‐20‐3861719

0715555550, 0736965590, 0770700007

W http://www.cofek.co.ke

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Executive Summary

This paper commissioned by COFEK was undertaken between June 2011 and July 2011 to analyze and understand the following;

a. Analyze and advise of the current state of Kenya’s Mobile Termination Rates in the wake o f a

Presidential directive in June 2011 to the regulator‐ CCK to halt further downward revision of mobile termination rates

b. Scenario and Outlook of the Mobile Number Portability effected in April 2011 c. Review the integrity of Kenya’s internet costs vis‐à‐vis the expectations of the landing of the

fiber optic cables

The last 5 years in the Telecommunication arena in Kenya have been particularly dynamic with increased investment and new entrants in the Voice & Data arenas.

I. Mobile Termination Rates (MTR)

The Communications Commission of Kenya (CCK) opined that interconnection is critical tool for the operation of a competitive market1.The CCK has thus intervened to regulate MTRs as a tool to influence interconnection and the competition in the telecommunications market. This paper examines regulatory intervention into MTR’s and delves into the effectiveness of the interventions in encouraging competition, increasing mobile penetration and reducing mobile charges. A case study on the effects on MTR on voice revenue for a provider is also presented.

The paper will examine the independent regulators role in ensuring a competitive and fair industry and delves into quality of service from mobile operators.

II. Mobile Number Portability (MNP)

The much touted move to introduce Mobile Number Portability (MNP) in April 2011 was introduced with high expectations amid heightened marketing efforts by MSPs to bring on‐ board new customers. The market had just experienced downward revision of termination rates a few months earlier and much lower subscriber rates. What soon followed as the porting process got underway were accusations on anti‐competitive behavior between MSPs including sabotage to frustrate porting efforts, disruption of service for longer than was communicated to porting subscribers and civil suits.

It has been argued that Mobile Number Portability introduced soon after downward revision of Mobile Termination Rates has played a role in the low success rate of MNP. Official data from the regulator CCK is not yet available at the time of this report, however according to an East

African Standard2 article published on April 5th 2011, 45,000 porting requests had been received a month after implementation. Anecdotal industry sources put the number at less than 30,000 by end of June 2011. This only accounts for a paltry 0.18% of the total number of mobile subscribers. To be sure, MNP is a win for consumers and industry too however the downward

1 Determination No.2 of 2010 on pure Long Run Incremental Cost (LRIC) based Interconnection Rate regime.

2 East African Standard, June 5th 2011

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revision of MTR, lack of education, negative press on disruption of service for porting customers and the club effect seem to curtail the successful implementation of number portability.

III. Cost of Internet

With increasing efforts and plummeting voice revenue, MSPs have shifted their efforts to growing their data business. The CCK 2nd quarter 2010/20113 compliance reports indicate that Kenya has 4.7 million data subscriptions with 98% of these resting with the Mobile Service Providers.

Safaricom’s end‐year results for FY 2011 indicate a strong performance in data, increasing their fixed and mobile data revenue by 85.6%, adding 2.26 million customers in that financial year.

Increased access to affordable data enabled phones has contributed significantly to increasing data penetration. Initiatives by some of the MSPs to manage end‐user cost of acquiring computing devices including laptops have also helped.

A myriad of data bundles and packages are been marketed aggressively by both the fixed data and mobile providers. Acquisition costs in equipment fees and deposits have however remained high and while some providers have lowered the actual data costs in attractive and affordable data bundles, other fees are lumped on. Equipment, installation costs charged by some of the providers have not changed significantly a year after broadband speeds became available.

While cheap international bandwidth is now available, investment on last mile infrastructure to residential areas and high populace locales has been slow and the market offering remains for the most part, dial‐up‐like speeds. While fiber builds are capital and time intensive, priority in construction of last mile fiber builds are taking place in income‐rich neighborhoods with low to mid density. It may thus be a long time before majority of the population begins to experience true broadband speeds similar to what is available in developed countries.

IV. Conclusions

Mobile Termination Rates

While an in‐depth study on the impact of Mobile Termination Rate Reductions is needed, it is this papers

findings that the CCK interconnect determinations that begun in 2007 have slowly begun to take steps to

reduce dominance and appear to continue to create a competitive environment. MTR reductions and

the subsequent heighted competition particularly in 2010 between the MSP’s, have falling consumer

costs in mobile airtime spending have been a boon for their customers and we are witnessing a

heightened competitive environment.

3 Source: CCK Quarterly Sector Statistics Report 2nd Quarter October – December 2010/2011

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However the concerns raised by some MSP that the current MTR’s are higher than their costs may need

to be examined lest MTR’s have an effect on increased investment in infrastructure, jobs and the

possibility of a new telco entrant.

As the case study we conducted on Safaricom indicates profits from Voice revenues which have been

historically high will be harder to realize going forward. That said MSPs are re‐strategizing and coming

up with new offerings in bundles of data and voice, bundling, data, mobile money which may

compensate for the declining voice revenues. Infrastructure sharing and outsourcing non‐core functions

are also options that operators are investigating and should continue to be encouraged. Examples from

mature markets provide a glimpse into how the market dynamics may shape up in Kenya. Telcos in

Europe & the USA have evolved from purely voice companies to offering data, video and managed

services. Indeed we have already begun to see heightened activity with the telcos bundling voice with

data, offering video through strategic partnerships. Operators will need to continue to innovate and

offer increasing value to their subscribers.

Mobile Number Portability While the full impact of MNP is yet to be seen from released figures, , it is still too early to tell how the

market has fully reacted to MNP however from a consumer stand point, the administrative process and

consumer education could have been done a lot better and there may still be some time time for

industry players to remedy the process.

Cost of Internet The question on whether to let competition, operators and the market determine internet data costs is

one that requires a closer look. In particular there is a need to look at how more mature countries have

approached regulation of broadband internet and the effects on such regulation on access and

penetration.

The benefits that were supposed to be reaped by the vast majority of Kenyans from broadband

connectivity may take several more years to realize. While internet penetration has increased, costs

charged by the different providers are disparate. Government and the industry regulator have a major

role in setting the tone, facilitating, incentivizing and promoting bandwidth roll‐out to areas that

operators wouldn’t necessarily build infrastructure out to yet promise other benefits in increasing access

to information, education, e‐health etc. While the regulator has recently been facilitating negotiations

to lower consumer costs on Internet, a more vigorous approach is called for in pricing, access in rural

areas and infrastructure sharing.

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COFEK Mobile Termination (MTR), Mobile Number Portability (MNP) and Cost of Internet 1 Introduction ..........................................................................................................................................................9

1.1 Methodology and Approach .................................................................................................................................9

1.2 Structure of the Report .........................................................................................................................................9

2 Mobile Termination Rates (MTR)........................................................................................................................10

2.1 Recent History on MTR .......................................................................................................................................10

2.2 Mobile Tariffs – June 2011 ..................................................................................................................................14

2.3 Mobile Termination Rates World Perspective ....................................................................................................15

2.4 Mobile Termination Rates Debate – Kenya: June 2011 ......................................................................................17

2.5 SMS .....................................................................................................................................................................18

2.6 Brief Financial Case Study on Safaricom after MTR Reduction...........................................................................19

2.7 Mobile Number Portability .................................................................................................................................19

3 Cost of Internet in Kenya ....................................................................................................................................21

3.1 Market offering at a glance.................................................................................................................................21

3.2 Fiber Infrastructure Development ......................................................................................................................22

3.3 Mobile Data Costs at a Glance ............................................................................................................................23

3.4 Fixed Broadband –WiMax ...................................................................................................................................24

3.5 Fixed Broadband – Fiber Costs .............................................................................................................................25

4 Other Issues. .......................................................................................................................................................27

4.1 Environmental Impact.........................................................................................................................................27

4.2 Consumer Redress ..............................................................................................................................................27

5 Conclusions .........................................................................................................................................................28

5.1 Mobile Termination Rates ..................................................................................................................................28

5.2 Mobile Number Portability .................................................................................................................................28

5.3 Cost of Internet ...................................................................................................................................................28

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List of Tables

Table A ‐ Mobile, Charges and Penetration 2004‐2006 ............................................................................ 10

Table B ‐ Cost-based Interconnection rates - March 2007 ......................................................................... 11

Table C ‐ Mobile Charges and penetration 2007‐2010............................................................................... 12 Table D‐ CCK‐ MTR Rate Reduction Schedule2009 ‐ 2013 ......................................................................... 12 Table E ‐ Pre‐Paid Tariff Comparison .......................................................................................................... 14 Table F – Intra‐ Network Calls Q2 ‐ 2010/2011 ......................................................................................... 15 Table G – World FTR Regulation Snap shot ............................................................................................... 15 Table H ‐ SMS Termination Rates ............................................................................................................... 18 Table I ‐ SMS Termination Rates for Mobile Operators ............................................................................... 18 Table J – Current SMS Rates ....................................................................................................................... 18 Table K ‐ Safaricom Voice Revenue (2007 ‐ 2011) ...................................................................................... 19 Table L ‐ Safaricom Voice Revenue/Subscribers – 2007 ‐2011................................................................... 19 Table M ‐ Data Market Share Q1 ‐2010/2011 to Q2 2010/2011................................................................ 22 Table N – Prepaid Data Bundles ................................................................................................................. 24 Table O – WiMax Costs ............................................................................................................................... 24 Table P – Fiber Cost .................................................................................................................................... 25 Table Q ‐ Internet Costs Increase/Decrease ............................................................................................... 26

List of Charts

Chart A ‐ Mobile, Charges and Penetration 2004‐2006 ............................................................................. 10

Chart B ‐ Mobile, Charges and Penetration 2007‐2010.............................................................................. 11

Chart C–Market Share – June – Dec 2010 .................................................................................................. 13

Chart D–Calls Consumed – April – Dec 2010 .............................................................................................. 14

Chart E – MTR Rates in Africa .................................................................................................................... 16 Chart F – Mobile Penetration %.................................................................................................................. 16 Chart G ‐ Mobile Service Providers Data Subscribers ‐ December 2010 .................................................... 21

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List of Abbreviations

CCK – Communications Commission of Kenya

COFEK – Consumers Federation of Kenya

MNP – Mobile Number Portability

MSP – Mobile Service Provider

MTR – Mobile Termination Rate

SMS – Short Message Service

WiMAX – Worldwide Interoperability for Microwave Access

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1 Introduction�COFEK commissioned this study to analyze and understand the following;

1. Analyze and advise of the current state of Kenya’s Mobile Termination Rates in the wake of a

Presidential directive in June 2011 to the regulator‐ CCK to halt further downward revision of

mobile termination rates

2. Scenario and Outlook of the Mobile Number Portability effected in April 2011

3. Review the integrity of Kenya’s internet costs vis‐à‐vis the expectations of the landing of the

fiber optic cables.

1.1 MethodologyandApproach�The methodology and approach for this interim report included a literature review of available data and

regulations related to the subject matter and interviews with stakeholders. The report includes data that

was available to us as of July 2011, including regulator returns and data.

1.2 StructureoftheReport�This report provides the consulting team’s preliminary findings. The report is divided into three distinct

segments that cover the following:‐ Section 2 Mobile Termination Rates (MTR’s) : this section provides historical background to the

regulation MTR’s, analyze s the current state of MTR’s, Looks at MTR’s from a world

and African perspective and finally tackles the debate on MTR’s in Kenya. This section

also includes a brief case study on Safaricom Ltd to gauge the effect of MTR’s the

profitability of market players and also looks at SMS termination rates and briefly looks

at Mobile Number Portability

Section 3 Cost of Internet in Kenya: Looks at the consumer cost of internet by looking at the

current market offering, developments in fiber infrastructure, the current mobile data

costs and fixed broadband offerings.;

Section 4 Other Issues: This section looks at the environmental impact of electronic waste and

consumer redress concerns;

Section 5 Conclusion: This section provides a summary of the findings of this report.

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Kenya Shillings


2 MobileTerminationRates(MTR)��

�2.1 RecentHistoryonMTR�

�In 2006, the CCK commissioned a network cost study with the overall objective of determining the appropriate costs and prices of various telecommunications services. Figure A shows the status of the mobile market charges and the mobile penetration rates before the study was commissioned.

Table A ‐ Mobile, Charges and Penetration 2004‐2006

Year 2004 2005 2006

Charges to same network (Ksh) 20.18 19.23 18.89

Charges to another mobile network (Ksh)

32.38 27.37 26.69

Mobile Penetration (%) 7.77 15.74 21.62

Source CCK Annual Report 2008 (Year end June) Between the two years, while calling charges still remained high, they fall slightly particularly on off‐net calls and we saw penetration rates increase by nearly 300% from 7.77% in 2004 to 21.62% in 2006.

Chart A – Mobile Charges and Penetration (2004‐2006)

Mobile Charges & Penetration 35

30

25

20

15

10

5

0

2004 2005 2006 Charges to same network (Ksh)


Mobile Penetration (%)

25%

20%

15%

10%

5%

0%

The study indicated that all mobile operators had a monopoly on terminating calls into their networks. On the basis of the findings of the report and stakeholder consultation the CCK came to the conclusion that there was need for regulating interconnection rates in order to promote fair competition on retail tariffs. The Commission noted that lowering interconnection charges would provide the impetus for lowering retail prices, expanding the market and subscriber base.

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The commission was also of the opinion that the MTR’s regime would prevent operators with Significant Market power (SMP) in the interconnection service market from abusing their dominance.CCK Determination No. 1 of 2007 issued on 22nd February 2007 prescribing a glide path to bring down the

termination rates towards the cost of an efficient operator as shown in Table B.4. The determination also set a cap on offset call rates at Ksh 30/minute.

Table B - Cost-based Interconnection Rates (with effect from 1st March 2007 in KES.)

Mobile Termination

1 March 2007

6.28

1 January 2008

5.27

1 January 2009

4.42 Source: CCK

The commissions first regulatory intervention of MTR’s broadly achieved some of its objectives in that between October 2007 and December 2009 the average mobile charges decreased by 66% for on‐net calls and 69% for off‐net calls. Showing that since the CCK mandatory MTR reduction was 29% the rest of the price reduction could be attributed to competition. During the same period mobile penetration grew from 30% to close to 50%

Chart B – Mobile Charges and Penetration (2008‐2010)

Mobile Charges & Penetration

25

20

15

10

5

0

Oct‐Dec Oct‐Dec Oct‐Dec Oct‐Dec

2007 2008 2009 2010

70.00%

60.00%

50.00%

40.00%

30.00%

20.00%

10.00%

0.00%

Charges to same network (Ksh) Charges to another mobile network (Ksh)

Mobile Penetration (%)

4 LRAIC cost modeling exercise and set a retail price cap on off‐net calls.

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Table C ‐ Mobile Charges and penetration 2007‐2010

Year 2007 2008 2009

2010 Oct-Dec Oct-Dec Oct-Dec

Oct-Dec

Charges to same network (Ksh) 16.43 8.98 5.6

2.78


22.63 13.26 7

3.54

Mobile Penetration (%) 30.51 43.64 49.7

63.2

Source CCK Quarterly Statistics

However the retail price differential between on‐net and off‐net calls had not changed significantly5 and the market was still dominated by one major player in terms of market share (See Chart A below). These market conditions were studied by the CCK in 2010. The study indicated “instances of market failures”

where the on‐net to off‐net price spread was thought to be perpetuating a “club effect6”,

On the basis of this second cost study and sector wide consultations the CCK’s then made the Interconnection Determination No 2 of 2010. This determination aimed to address several issues that were identified as key barriers to competition in the sector including off‐net to on‐net price ratios, cross network money transfers and number portability.

The most controversial aspects in the 2nd determination were a phased reduction in MTR’s as noted in the figure below and a requirement for a dominant7 market player to implement a price cap for off‐net call prices to the level of their on‐net prices.

Table D ‐ CCK‐ MTR Rate Reduction Schedule‐ Yearly

Year Jun-09 Jul-10 Jul-11 Jul-12 Jul-13

Charges to same network (Ksh)

4.42 2.21 1.40

1.15

0.99

Source: Determination No. 2 of 2010

5 As at December 2009 the average price differential was between off‐net and on‐net calls 25% (2007: 37%) : CCK Quarterly statistics. 6 “Club Effect” arises when consumers tend to have a preference for a network with a large pool of subscribers in order to benefit from the

possibility to call and be called at a lesser calling rate by the largest possible number of subscribers 7 Dominance as determined by the CCK in line with their regulations.

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80.70%

75.90%

69.90%

9.10%

13.50%

15.20%

2.70%

4%

6.40%

7.40%

6.70%

8.50%

COFEK Mobile Termination (MTR), Mobile Number Portability (MNP) and Cost of Internet Chart C – Kenya’s Mobile Sector Market Share

90.00%

80.00%

70.00%

60.00%

50.00%

40.00%

30.00%

20.00%

10.00%

0.00%

Market Share ‐ June ‐ Dec 2010

Safaricom Airtel Orange

June

Sept

Dec

Source ‐ CCK Looking at Chart C one can note that as a percentage, Orange has seen growth increase by 83.8% in the same period recording an increase of 972,978 customers in the six months. Airtel saw market share increase to 15.2% in December from 9.1% in June, adding 2,138,061 customers in the same period. While overall Safaricom lost overall market share from 80.7% in June to 69.9% in the same six months although the MSP did in fact add 1,210,756 customers in the period. Year of year, mobile penetration has increased by 13% from 49.7% at the end of 2009 to 63.2% in December 2010.

Kenya’s mobile penetration rates per 100 inhabitants increased from 55.9 to 63.2 in the space of a quarter.

Consumers have reaped substantially from the MTR downward reduction and subsequent price wars.

According to the latest published CCK statistical data8 compiled from service providers quarterly returns

(2nd Quarter, October – December 2010/2011), local calls made on cellular networks increased by 1.4 billion minutes over the previous three quarters, representing 18.7% in increased calling minutes. It could be deduced that increased calling activity would mean other gains (economical, increased access and others benefits) to the approximately 25 million Kenyan mobile phone users (End 2010).

8 Source: CCK Quarterly Sector Statistics Report 2nd Quarter October – December 2010/2011

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Pre‐Paid Tariff Comparison Voice Calls SMS

MSP Tariff Name In‐network Inter‐network In‐network Inter‐

SMS network Safaricom Uwezo 3/‐ 4/‐ 1/‐ 2/‐ Airtel Haki Yetu 3/‐ 3/‐ 1/‐ 1/‐ Orange Orange 2/‐ 4/‐ 1/‐ 2/‐ Essar/Yu Amua 3/‐ 3/‐ 1/‐ 1/‐


Chart D – Calls Consumed

Calls Consumed ( Billion Minutes) April 2010 ‐ December 2010

8

6 6.05 6.63

4

2

0

7.45

Apr ‐ June July ‐ Sept Oct ‐ Dec

Source9 – Chart created from data contained in Communications Commission of Kenya (CCK) Quarterly Statistic Report (April – Dec 2010)

2.2 MobileTariffs–June2011�

�Below is a Table with the current mobile charges as at end June 2011. It clearly shows that there is now a smaller disparity between the on‐net off‐net charges.

Table E –Pre‐Paid Tariff Comparison

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Source: MSP Websites - June 2011

The on‐net/off‐net price disparities previously adopted by dominant MSPs has been mentioned in several Kenya specific MSP reports as a hindrance for new entrants and a ‘killer’ for smaller MSPs present a changing landscape that might prove to be a red herring at least in Kenya’s case where subscribers have multiple SIM cards from different providers . Published data from the regulator, CCK s reporting voice traffic by operator and tabulated for this report to provide a breakdown of intra‐network calls shows that while high off‐net tariffs have significantly reduced significantly across all operators the ‘club effect’ where consumers choose to remain where the largest pool of subscribers are, has remained on average, about the same and in‐fact may be prove to remain the same, particularly for the dominant operator, Safaricom with 89.22% of total calls received originating and terminating within its network. A smaller operator Essar operating under Yu with the lowest market share (6.4%) has 52.8% intra‐network calls, falling into the club effect, perhaps because of its smaller market share however the operator has several promotional offers to promote “calling circles” within their network.

9 Chart created from data contained in Communications Commission of Kenya (CCK) Quarterly Statistic Report (April – Dec 2010)

10 Source – MSP Websites – www.safaricom.co.ke, www.yu.co.ke, http://africa.airtel.com/kenya/, www.orange.co.ke

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COFEK Mobile Termination (MTR), Mobile Number Portability (MNP) and Cost of Internet Table F – Intra‐network Calls MSP Total Calls Q2 % of intra‐network calls

2010/2011 Safaricom 6,736,480,971 89.22%

Airtel 761,833,919 28.80%

Orange 118,768,571 21% Essar 271,783,003 52.80%Source –CCK Quarterly Statistics Reports (April – Dec 2010) to display volume of intra‐network calls

2.3 MobileTerminationRatesWorldPerspective�

�Worldwide, different countries have taken different approaches with some allowing market forces to determine pricing while others like Kenya have opted for regulation. The following table from ITU, the U.N agency for information & communication provides a concise summary of approaches taken in different regions.

Table G ‐ World FTR Regulation Snap Shot

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As it can be seen from the table G above Africa has the lowest call termination rates as compared to the rest of the world. Most of Africa also uses a cost based approach to determine the MTR’s. Chart E – MTR Rates In Africa, 2010

MTR Rates in Africa ‐ 2010 (US $ Cents)

20

15

10

5

0 MTR (USD $)

Source - Graph completed from data from Research ICT Africa

Across the African continent MTR rates have continued to slide downwards in the last few years. A comparative study on MTR rates in Africa completed by Research ICT Africa in 2010 reveals that Kenya has the second lowest MTR rates after Senegal. Mauritius and Ghana and Namibia have slightly higher MTR’s than Kenya. Looking at these five countries in terms of penetration, Chart F below shows that the all have penetration above 50% which shows that the correlation between low MTR’s and high penetration is not unique to the Kenyan Market. Chart F – Mobile Penetration (%) 2010

Mobile Penetration % ‐ 2010

129%

67% 71%

92% 63%

Namibia Ghana Mauritius Kenya Senegal

Source - Graph completed from data from Research ICT Africa

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2.4 MobileTerminationRatesDebate–Kenya:June2011��Across the board, mobile phone calling costs have reduced significantly averaging from between Ksh 26 in 2004‐2005 to current average rates of between KSH 2.75 and KSH 3.50 charged to on and off‐net subscribers respectively as of June 2011. More recently in June 2011, one player has zero rated all on‐ net calls for its subscribers.

Undoubtedly Mobile Termination Rates (MTRs) play a significant role in how Mobile Service Providers (MSP) operate, compete and price their products. As of July 2011, Kenya’s four MSPs have engaged in various price and marketing wars in an effort to woo voice subscribers to their networks. New entrant Bharti‐Airtel launched a price war in the midst of the industry regulator Communications Commission of Kenya (CCK) downwards shifting of the MTR rates in July 2010. Subsequently other operators followed similar moves to revise their tariff’s downwards. CCK’s termination rates schedule under the

Interconnection Determination No.2 of 201011 based on pure Long Run Incremental Cost (LRIC) called for a further 34% decrease in July 2011 however this was frozen in June 2011 following a Presidential directive to CCK as the Government studies the economic impact of the Telco price wars. The decision had been preceded by intense lobbying by all MSPs with Safaricom and Orange calling for a stop with minimal success lobbying CCK before the June 2011 deadline.

The executive order to independent regulator, CCK is interpreted in the public eye as a win for Safaricom and Orange following their strong opinions that the continued downward shifting of MTRs would be harmful to the economy equating to job losses, reduced sector investment by current players and a hindrance for new entrants. The Presidential directive was subsequently ratified by CCK following the Presidential order, a move that has been questioned the regulators role as an independent body whose

role is stipulated in the Information & Communications Act 1998 (Act No. 2 of 1998)12. Particularly section four and five stipulate;

4. “The Commission is independent, and subject only to the Constitution and the law, and must be impartial and must perform its functions without fear, favour or prejudice. 5. The Commission must function without any political or commercial interference.”

Kenya’s Competition Bill whose role it is to promote fair competition and in all areas of the economy, in Section 5 (d) further lays out the following;

1. If a body charged with public regulation has jurisdiction in respect of any conduct regulated in terms

of this Act within a particular sector, the Authority and that body shall― (d). ensure consistent application of the principles of this Act13

While further downward revision of MTR rates may be hurting the viability of the industry among other considerations, it is prudent that a comprehensive analysis be carried out by Government, industry and all stakeholders. The glide path in the MTR reduction schedule as set in the Interconnection Determination No2 of 2010 has called for tariff’s to fall from KSH 2.21 to KSH 1.44 however was halted pending a review of the 11

Source: CCK – Determination on interconnection rates for fixed & mobile telecommunications networks, infrastructure sharing & co-location -2010 12 Source: The Independent Communications Commission of Kenya Bill, 2010http://www.information.go.ke/index2.php?option=com_docman&task=doc_view&gid=19&Itemid=37 Accessed June 2011 1313 Source: The Competition Bill 2009. Kenya Law.http://www.kenyalaw.org/Downloads/Bills/2009/200903.pdf Accessed June 2011

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effects of lower termination rates on industry and the economy. The Prime Minister established a taskforce to study the effects but results are yet to be made public.

2.5 SMS�CCK’s study on the market in 2010 also dealt with the issue of SMS termination rates. Specifically the Analysis Mason study established that the incremental cost of offering SMS termination services for an efficient operator in Kenya was Ksh 0.015 per SMS while the average SMS termination charges at the time were Ksh 2 per SMS (See Table H)

Table H ‐ SMS Rates Year Q2 -07/08 Q2 -08/09 Q2 -09/10

Oct-Dec Oct- Dec Oct-Dec


4.47 3.00 1.80


5.00 3.50 3.50

Source: CCK. Addendum to Interconnection Determination No2 of 2010 Determination 2 of 2010 required operators to take note of the efficient operator rate and negotiate lower rates, which were to be filled at the regulator. However since the regulator did not specify a rate as was the case with MTR’s all operators could not agree on a reduced SMS termination rate. Consequently in December 2010 the CCK set a cap on the SMS termination rates via an addendum to Determination No. 2 of 2010 as show in Table I.

Table I ‐ SMS Termination Rates for Mobile Operators


Effective 1 January 2010

Effective 1 July 2011

Effective 1 July 2012

Effective 1 July2013

Nominal Ksh per SMS 0.60 0.20 0.10

0.05

Source: Addendum to Determination No. 2 of 2010 2.5.1 Current SMS Rates The current SMS rates charged by various MSPs as of June 2011 ranged between Ksh 1 and Ksh 2. With estimates of true actual SMS costs ranging from Ksh 0.05 to Ksh 0.15, SMS charges remain higher than the cap set by CCK.

Table J – SMS Rates MSP In‐network SMS Off‐network SMS

Safaricom 1/‐ 2/‐

Airtel 1/‐ 1/‐

Orange 1/‐ 2/‐

Essar/Yu 1/‐ 1/‐

Source ‐ MSP Websites

18


2.6 BriefFinancialCaseStudyonSafaricomafterMTRReduction�Taking into account the views of MSP’s that MTR’s were having a detrimental effect on their voice revenue we conducted a brief financial case study on Safaricom the largest MSP by market share.

Financial results from Safaricom released in May 201114however show voice revenue growth almost flat

at Ksh63.5 billion compared to Ksh63.4 billion in 201015 (see Table L). Overall, Safaricom’s revenue increased 12.9% year over year to Ksh94.83 billion with voice revenue offset by growth in the fixed/mobile data and MPESA growth. The growth from other services apart from voice is part of the diversification on MSP offerings and the industry is likely to see the same trend continue with this and other MSPs.

While previous Safaricom voice revenue, year over year between the 2007 and 2010 increased by between Ksh3 billion and ksh12billion, 2011 saw the lowest increase in voice revenue with a 0.6% increase.

Voice subscribers have continued to increase albeit modestly in FY 2011 compared to earlier years. Safaricom has seen mobile voice revenue growth decline sharply in the year following MTR introduction (2011). Table K – Safaricom Voice Revenue

Safaricom Voice Revenue (2007 ‐ 2011) FY (Billions KSH) Voice Revenue Growth YOY Subscriber Growth

(millions) 2007 41.5 (not available) (not available)

2008 54.2 30.6% 10.23 million

2009 58.7 8.3% 13.36 (30.6%)

2010 63.4 8.0% 15.79 (18.8%)

2011 63.5 0.6% 17.18 (8.8%)

Source –Safaricom Annual Results – 2007 ‐2011

Table L – Safaricom Voice Revenue/ Subscribers (2007‐2011)

Safaricom Voice Revenue/Subscribers 2007 ‐ 2011

41.5

Voice Revenue (Billions) Voice Subscribers (Millions)

54.2 58.7 63.4 63.5

10.23 13.36 15.79 17.18

1 2 3 4 5

Source –Safaricom Annual Results – 2007 ‐2011

14

Source : Safaricom Ltd FY 2011 Results Announcement – May 2011. http://www.safaricom.co.ke/fileadmin/About_Us/Documents/Full_Year_2010- 2011_Results_Presentation.pdf Accessed July 2011 15

Source : Safaricom Ltd FY 2010 Results Announcement – May 2010. http://www.safaricom.co.ke/fileadmin/Investor_Relations/Documents/2010/FY_2010_Results_presentation%20%282%29.pdfAccessed July 2011

19

COFEK Mobile Termination (MTR), Mobile Number Portability (MNP) and Cost of Internet 2.7 MobileNumberPortability�In simple terms, number portability has given consumers the option to switch their mobile provider and keep their phone number. When all things work well, both consumers and operators benefit. Increased choice, a level and competitive playing field as far as MNP goes are all benefits to Mobile Number Portability. Following the introduction of MNP, the Kenyan mobile provision market has witnessed several marketing campaigns from operators intended to woo subscribers to their networks. Considering global practices elsewhere, it is argued that a lot more time should have been spent on ironing out administrative processes and on consumer education on the process. Seemingly, loss of communication and other services such as mobile money served as a disincentive for consumers that may want to port

Preparation for launching MNP took significant efforts by operators that industry sources place to have cost close to Ksh 1 billion. While official data from the regulator, CCK is not yet available as of June 2011, newspaper reports put the number of successful porting requests at just under 45,000.

It is arguable that the precedence and timing of the downward revision of termination rates did not provide as much of an incentive to see any significant number of porting requests to any one network that would see MNP as a game changer.

While it may be too early to tell what the eventual impact of the introduction of portability in Kenya has been, what is clear is that while the introduction was welcome, the administration of MNP, subsequent accusations between operators and law suits have not served it well in gaining the public’s confidence.

The ‘stickiness’ of products such as mobile money considered a key feature in this environment may play a role in seeing how the future of mobile portability plays out. Discussion on sharing on money transfer platforms may present another angle to mobile portability that would see customers unwilling to port due to this one feature, reconsider.

What number portability may end up doing is that we will see the mobile operators work much harder to retain their existing customer’s thereby increasing service quality and other complaints and that would be a welcome move and a win for consumers. On Mobile Portability, it is perhaps still too early to tell how the market has fully reacted to MNP as the official statistics are not yet available however from a consumer standpoint, the administrative process and consumer education could have been done a lot better.

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3 CostofInternetinKenya��

�3.1 Marketofferingataglance��Increased and international connectivity to broadband bandwidth in Kenya was welcomed with high expectations from Kenyan consumers, industry and Government. So far, MSPs are emerging as biggest winners, increasing their product offering and buffing up declining voice revenues. Traditional Internet Service Providers (ISPs) appear to be struggling against the mobile companies in subscriber numbers.

Increased investment in the sector has seen infrastructure developments, new entrants and a growing home‐grown software development scene producing locally applicable applications for use in mobile and web devices.

The four Mobile Service Providers (MSPs) all have a data offering and by all accounts have by far the largest number of subscribers when compared to traditional internet providers (Less than 2%). Safaricom has the largest data market share at 92% of the total data market (CCK).The other three MSPs are showing increasing strength and heightened marketing efforts to capture their share of the data business. In February 2011, Orange CEO Michael Ghossein stated the company’s goal to increase data

revenue contribution from 15% to 40% by December 2011.16 Between April 2010 and December 2010,

data subscriptions increased by over 1.6 million subscribers to account for 4,716, 977 subscribers17. (Note that these are not users but subscriptions).

Chart G ‐ Mobile Service Providers Data Subscribers‐ December 2010

Airtel, 214,497

, 0 , 0 , 0

, 0

Orange, 82,697 , 0

Essar/Yu, 680,494

Safaricom, 3,706,785

Source: Data from CCK Quarterly Statistic Report, Q2 2010/2011

16 Source - http://www.businessweek.com/news/2011-02-01/telkom-kenya-plans-to-boost-share-of-revenue-from-data-services.html Accessed June 2011 17 Source - CCK Quarterly Statistic Report, Q2 -Oct – Dec 2010/2011

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Table M – Data Market Share Q1 ‐2010/2011 to Q2 2010/2011 Data Operator Q2 ‐ 2010/2011 Q 1 2010/2011 Market Share %

Safaricom 3,706, 785 2, 977, 584 92.18%

Essar 680, 494 Airtel/Celtel 214,497 149,053 4.61%

Telkom ‐ Fixed Data

4,285 11,638 2.40%

Access Kenya 9,211 7,512 0.23%

KDN 5,369 5,451 0.17%

Africa Online 1,329 1,608 0.05%

Flexible Bandwidth

1,390 1,198 0.04%

Swift Global 1,200 1,133 0.04%

Call Key Networks Ltd

800 800 0.02%

Others 520 516 0.02%

Source ‐ CCK Quarterly Statistic Report, Q2 ‐Oct – Dec 2010/2011 3.2 FiberInfrastructureDevelopment�While Mobile Service Providers (MSPs) have rolled out data services through their existing voice base stations, other fixed infrastructure providers have concentrated their efforts in dense areas that promise to show a good return.

Safaricom in diversifying its mobile offering has invested on fiber infrastructure and through their Safaricom Business product has access to over 1000km of metro fiber in Nairobi and Mombasa through strategic partnerships and has access to over 180 fiber ready buildings mostly in Nairobi, Mombasa and other key outlying cities. The company also has anchor Investments in two sub‐marine cables, Teams & Seacom.

Access Kenya has in the past few years been building their fiber infrastructure concentrating in the cities of Nairobi & Mombasa. Reports indicate that their Nairobi 150 Kilometer network covers 250 commercial buildings.

The Wananchi group begun their fiber construction efforts in the higher income Kilimani, Kileleshwa and Lavington neighborhoods two years ago and are just now spreading to other parts of the Southern parts of Nairobi offering data services to residential with speeds of up to 10Mbps.

Jamii Telecom in January 201118 announced plans to target 100,000 homes in Nairobi targeting home users in the select locales of Karen, Lavington, Parklands, Kilimani, Kileleshwa, Lang’ata, South B, Nyayo Estate Embakasi, Gigiri and Runda in Nairobi in their first phase. The firm has also built other backbone networks in other cities including Mombasa, Thika, Nyeri, Naivasha, Nakuru, Kisumu and Eldoret.

18 Source – Business Daily, Jan 17th 2011

22


While mobile data services have augmented and in all accounts taken a huge chunk of the data business, access to affordable high speed broadband connections is fundamental to development if the public are to reap the benefits promised by the introduction of the undersea cables. Widespread deployment of ‘last mile’ fiber infrastructure to end‐user homes will take a while before fruition. Operators have raised the capital intensive nature of the business, way leaves and vandalism to infrastructure as some of the hindrances to mass deployment. Steps are in place to increase penalties for vandalism.19

Whereas the situation in Kenya is showing that providers will not necessarily build out in high density locales the dynamics in play in that most of Africa has low income areas. Developed countries face a slightly similar challenge in that service providers have avoided building out in rural low density areas. Governments and local authorities in these countries have implemented incentives and solutions to

correct this. In the USA a Broadband stimulus plan20was passed in the U.S congress to accelerate and expand broadband access to rural area. In Europe, local authorities and municipalities in Europe are opting to build out fiber infrastructure in their own localities. Old models where providers build their own infrastructure may prove to be unsustainable for the providers, consumers and the environment. Recently Kenyan MSPs have announced several initiatives to share mobile towers and this may be the model that data services providers may need to follow to maintain costs and pass on the benefits to consumers. The Government has recently begun spearheading the infrastructure sharing to reduce data costs and encouraging the conversation between municipalities and providers. Reporting on

Government efforts, the Business Daily21 the Information ministry Permanent Secretary has been quoted on new efforts to engage local authorities to invest in infrastructure and lease out to providers. Recently, the President has voiced concerns on the cost of internet stating “Internet services are going to play key role in the development of this country, however, the high Internet prices still remain a

barrier and which I direct must be looked into to make it affordable.”22 3.3 MobileDataCostsataGlance��Between April 2010 and December 2010, data subscriptions increased by over 1.6 million subscribers to account for 4,716, 977 subscribers. (Note that these are not users but subscriptions).

The different providers have a plethora of packages and fees packaged in different offerings and a like for like comparison is impossible but for a few key elements. The consumer faces a variety of purchase factors to consider including the initial acquisition costs in equipment fees and the different bundle offerings.

19 Source – Business Daily, June 20th 2011 20 Source - http://www.broadbandusa.gov/ Accessed June 2011 21 Source – Business Daily, July 11th 2011 22

Source – Business Daily, July 11th 2011

23


Mobile Dongle Devices – Pre‐Paid Data Bundles

Table N – Pre‐Paid Data Bundles

Access Type – Dongle Device

Equipment Fee – Dongle @ 1,999/‐

Deposit – None

Bundle Cost

80MB 250/=

200MB 499/=

600MB 999/=



Deposit – None

Bundle Cost

100MB 150/=

200MB 250/=

400MB 450/=



Deposit – None

Bundle Cost

100MB 250/=

250MB 500/=

750MB 1,000/=



Deposit – None

Bundle Cost

100MB 100/=

300MB 250/=

1Gb 750/=

Source: MSP Websites. www.safaricom.co.ke, www.yu.co.ke, http://africa.airtel.com/kenya/, www.orange.co.keJune 2011. Prices are excusive of taxes in most cases. Contention ratios may vary across different providers

(Note that this is a comparison of June prices. In July 2011, Safaricom doubled the bandwidth available to some packages)

3.4 FixedBroadband–WiMax�The fixed data/broadband packages provide a dedicated unlimited capacity to subscribers and are easier to budget for. The table below shows a sampling of four of the largest fixed data providers. Access is provided through WiMax, a technology that uses over the air frequency to transmit data. It should be noted that coverage is dependent on where the provider has installed a base station to serve customers.

Table O – WiMax Bundles

Access Type – WiMax

Equipment Rental – Nil

Installation Fee ‐ Nil

Deposit – None

Package Cost

256Kbps

512Kbps

1Mbps 5,999/= Safaricom



Installation Fee –17,000/=

Deposit – None

Package Cost ‐ 128Kbps

to4,000/=256/51Kbps ‐ 128Kbps to

256Kbps/1Mbps 6,000/=

‐ 128Kbps to

512Kbps/1.3Mbps 9,000/= Access Kenya


Equipment Rental – 500/=

Installation Fee –2,999/=

Deposit – None

Package Cost

256Kbps 2,499/=

512Kbps 3,499/=

1Mbps 5,499/=

Zuku/Wananchi


Equipment Fee – Nil

Installation Fee – 20,000/=

Deposit – None

1:2 Contention Ratio Package Cost

128Kbps 10,850/=

256Kbps 15,000/=

512Kbps 23,000/= KDN/Swift‐Global

Source: MSP Websites. www.safaricom.co.ke, www.zuku.co.ke,http://www.accesskenya.com, http://www.swiftglobal.co.ke/ June 2011 Prices are excusive of taxes in most cases. Contention ratios may vary across different providers

24


3.5 FixedBroadband–FiberCosts�As users demand more bandwidth, Telco’s and other data providers have begun rolling out fiber broadband to residential and business users.

Table P – Fiber Costs

Access Type – Fiber


Installation Fee ‐ Nil

Deposit – None

Package Cost

256Kbps 13,999/=

512Kbps 17,999/=

1Mbps 27,000/=

3Mbbps 80,000/= 130,000

5Mbps /= 300,000

10Mbps /= Safaricom Business


Equipment Rental – 500/=


Deposit – None

Package Cost 1Mbps 999/=

4Mbps 1,999/=

8Mbps 3,499/=

Zuku


Equipment Fee – Not available


Deposit – 1 Month

1:2 Contention Ratio

Package Cost

256Kbps 9,500/=

512Kbps 14,000/=

1Mbps 25,000/=

2Mbps 46,000/= KDN/Swift‐Global



Installation Fee – Nil

Deposit – 15,000/=

Package Cost

256Kbps 16,000/= 512Kbps 18,000/=

1Mbps 25,000/=

Access Kenya Corporate

Source: MSP Websites. www.safaricom.co.ke, www.zuku.co.ke,http://www.accesskenya.com, http://www.swiftglobal.co.ke/ June 2011. Prices are excusive of taxes in most cases. Contention ratios may vary across different providers

A comparative analysis on fixed data residential subscriber costs between July 2010 and July 2011

reveals that while some providers have lowered costs, others have increased costs by as much as 67%.

Of the eleven fixed data packages that pricing was available; five had increased costs while the rest had

reduced. The reductions ranged from as low as 0.01% up to 26%.

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Table Q – Internet Costs Increase/Decrease

Source – Data from provider websites & promotional material including provider pamphlets

A true like for like comparison on each specific package offered by the various providers as above is

impossible to calculate as provider’s package their offerings differently and may include and or waive

fees such as installation costs and contention ratios often vary. On the whole however, it appears that

while mobile broadband pricing has decreased, fixed broadband that delivers unlimited broadband

speeds is out of reach for most Kenyans. While one company in particular, Zuku has recently introduced

1Mbps at KSh 999/=, installation costs may run up to Ksh 3,000/= and availability for the service is still

limited to certain select neighborhoods and buildings where return for the provider appears more

attractive.

26


4 OtherIssues��

4.1 EnvironmentalImpact�Over the past two years, the country has witnessed several operators digging their own underground

ducts and in some locales, several of these are installed by different operators side by side with each

operator carrying out construction activity. While this serves to increase the end‐consumer cost, the

environmental impact needs to be studied more closely and policies put in‐place to curb the effects and

disruption of other activities. Common trenching policies that have been enacted in other countries

where all operators are subject to sharing one trench need to be explored to ensure that costs remain

affordable and the environment is protected. Disposal of e‐waste is another environmental concern that needs a closer eye. The National Environmental Management Authority (NEMA) needs to set the tone in equipment disposal and proper handling of electronic waste. COFEK is already in talks with NEMA to set up the Kenya Electronic Waste Management & Coordination secretariat

4.2 ConsumerRedress�While published data from the CCK on consumer complaints is not available, operators and providers

are required to submit the volume of complaints and report on resolution to the regulator. Newspaper

reports & blogs provide some insight on the level of frustration some customers experience for proper

service delivery. Critical areas such as communication and mobile transfer and the services that rest on

these have become essential to the millions of consumers that rely upon them to conduct business.

While these services will sometimes experience failure, they need to be closely monitored and held to

high service level agreements.

Consumer redress has often not been easy for majority of aggrieved consumers in these areas and a

proper mechanism to report and resolve needs to be investigated and acted upon. It is desirous that the

regulator publishes reported data on complaints across all categories for consumers to have all the

information necessary to compare areas of consumer importance.

It is recommended that CCK publish operator returns that provide data on subscriber complaints in

quality, billing and others outside of which it may be desirous for consumer protection bodies to

consolidate and publish such data.

27


5 Conclusions��5.1 MobileTerminationRates�

�

�While further studies on the impact of Mobile Termination Rate Reductions are needed, we feel that the CCK interconnect determinations have been largely successful in achieving their objective’s in reducing dominance and creating a competitive environment. MTR reductions and the subsequent heighted competition between the MSP’s have had a significant impact on reducing consumer costs, increasing mobile penetration and are creating a competitive environment.

However the concerns raised by some MSP that the current MTR’s are higher than their costs may need to be examined lest MTR’s have an effect on increased investment in infrastructure, jobs and the possibility of a new telco entrant.

As the case study we conducted on Safaricom indicates profits from Voice revenues which have been historically high will be harder to realize going forward. That said MSPs are re‐strategizing and coming up with new offerings in bundles of data and voice, bundling, data, mobile money which may compensate for the declining voice revenues. Infrastructure sharing and outsourcing non‐core functions are also options that operators are investigating and should continue to be encouraged. Examples from mature markets provide a glimpse into how the market dynamics may shape up in Kenya. Telcos in Europe & the USA have evolved from purely voice companies to offering data, video and managed services. Indeed we have already begun to see heightened activity with the telcos bundling voice with data, offering video through strategic partnerships. Operators will need to continue to innovate and offer increasing value to their subscribers.

5.2 MobileNumberPortability�While the full impact of MNP is yet to be seen from released figures, it is still too early to tell how the market has fully reacted to MNP however from a consumer stand point, the administrative process and consumer education could have been done a lot better and there is room still time for industry players to remedy this. Unofficial newspaper reports only indicate only 0.18% of mobile subscribers have ported in the months following the launch of MNP.

5.3 CostofInternet�The question on whether to let competition, operators and the market determine internet data costs is

one that requires a closer look. In particular there is a need to look at how more mature countries have

approached regulation of broadband internet and the effects on such regulation on access and

penetration.

The benefits that were supposed to be reaped by the vast majority of Kenyans from broadband

connectivity may take several more years to realize. While internet penetration has increased, costs

charged by the different providers are disparate. Government and the industry regulator have a major

role in setting the tone, facilitating, incentivizing and promoting bandwidth roll‐out to areas that

operators wouldn’t necessarily build infrastructure out to yet promise other benefits in increasing access

to information, education, e‐health etc. While the regulator has recently been facilitating negotiations

to lower consumer costs on Internet, a more vigorous approach is called for in pricing, access in rural

areas and infrastructure sharing.

28

COFEK July 2011 Study on the Kenya Communication Sector

Documents

accesstypedongledevice equipmentfee dongle 1

whiletheregulatorhasrecentlybeenfacilitatingnegotiations tolowerconsumer costsoninternet

mobile moneywhichmay compensateforthedecliningvoicerevenues

mobile number portability

evolvedfrompurely voice companies

asthe case study

quarterly statistic report

subsequent heighted competition