SINGTEL RESPONSE TO IDA CONSULTATION PAPER – NET ...

QoS and other quality matters. The information relating to expected and average
Internet access speeds will be largely irrelevant to business broadband end-users.
4.25. Therefore, SingTel submits that, if the IDA is to require that service providers publish
expected or average Internet speeds, that services available to business end-users
should be exempt from this requirement.
5. CONCLUSION
5.1. In light of the above, SingTel submits that there are no net-neutrality issues in
Singapore.
5.2. Furthermore, SingTel submits that bespoke regulation in the Internet services market
in Singapore is necessary for the following reason:
- the Internet services market is highly competitive in Singapore;
- existing levels of regulation are sufficient to address potential anti-competitive
conduct;
- services providers should be free to manage the efficiency of their networks,
improve customer experience and innovate to facilitate high-quality applications;
- SingTel complies with prevailing to publish service information and network
management practices; and
- SingTel already complies with minimum QoS standards and is transparent in
terms of its network management techniques;
- the publication of average or expected speeds is counter-productive and likely to
confuse consumers.
Page 20 of 20