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BEREC REPORT ON IMPACT OF FIXED-MOBILE ... - berec - Europa

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BoR (11) 54<br />

The level of cost differences as well as capacity differences between mobile and fixed<br />

services, geographic differences in bandwidth and differences in network coverage are<br />

generally considered most important for broadband substitutability. As far as voice<br />

substitutability is concerned, the key parameters are the level of cost differences<br />

between mobile and fixed services and differences in network coverage.<br />

6.12. Differences in the information used for FMS analysis<br />

Voice vs. Broadband<br />

In general, the type of information considered in an analysis of FMS for voice and<br />

broadband is similar. In particular, the information which NRAs classify as relevant and<br />

a key parameter in their national context tends to be the same for voice and<br />

broadband.<br />

The main differences between voice and broadband services in the information<br />

considered for FMS analysis relate to the specific characteristic of these services 55 .<br />

Retail vs. Wholesale<br />

This report is focused on an analysis of FMS and its implications on market definition at<br />

a retail level. However, the questionnaire tried to identify the most relevant points to<br />

consider regarding the analysis of FMS at a wholesale level.<br />

In general, if FMS does not exist at the retail level it is not feasible to have FMS at the<br />

wholesale level (if retail consumers do not perceive fixed and mobile offers as<br />

substitutable it is not likely that operators will consider the possibility of changing from a<br />

fixed wholesale access to a mobile wholesale access or vice versa). For this reason<br />

the information that is relevant for FMS analysis at the retail level is also relevant for<br />

FMS analysis at the wholesale level.<br />

Besides this “retail level information”, if an NRA is interested in analysing the possible<br />

existence of direct substitution at the wholesale level, a specific FMS analysis<br />

considering “wholesale level information” is necessary 56 . This information would be<br />

used to analyse the possibility of operators changing from a fixed wholesale access to<br />

a mobile wholesale access and vice versa.Relevant factors to consider include<br />

theavailability and conditions of the fixed and mobile wholesale access (price, service<br />

characteristics, QoS, etc) and the cost involved to switch between fixed and mobile<br />

access.<br />

55 e.g. the downstream bandwidth is usually considered a very relevant information to take into account when analysing<br />

FMS in broadband services that is obviously not applicable for FMS analysis in voice services<br />

56 By direct substitution we mean: operators changing from fixed/mobile wholesale access offers to mobile/fixed<br />

wholesale access offers.<br />

45

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