Vodafone response to Commission’s Mobile Market study

Vodafone response to Commission’s Mobile Market study

The study shows that New Zealanders are well served by three competing national 4G mobile networks covering 98% of New Zealanders, competitive prices significantly below OECD averages (up to 67% below), committed investment to extend mobile coverage even further through the RBI2/Mobile Blackspot initiative, and exciting transformative 5G technology just around the corner.

“Vodafone has a long history of investing in and delivering world-leading mobile technology and innovation in New Zealand,” said Russell Stanners, Vodafone NZ CEO.

“Kiwis benefit every day from a thriving, competitive mobile market, evidenced by choice, affordability, three competing national networks, and 5G around the corner. Analysts (IDC) point to strong competition as a key reason for the decline in industry-wide revenue-growth, from 5.9% growth in the year to March 2017 to 0.7% in the year to March 2018. Given all of this, we question the rationale and need for the Commission’s spotlight on mobile competition.”

The study raises the small market share of MVNOs [Mobile Virtual Network Operators] in New Zealand.

Large MVNOs have typically only emerged in very large markets, such as Europe, USA and some parts of Asia. New Zealand has a greater number of MVNO operators than similar sized markets of Singapore, Ireland and Finland.

In other highly competitive international markets, many MVNOs struggle to differentiate their services where strong retail competition serves all parts of the market with affordable, compelling and innovative services, as we see in New Zealand. Internationally, there has not been regulatory intervention to subsidise MVNO development in competitive mobile markets.

In New Zealand, MVNOs can buy wholesale services from three competing mobile operators, and MVNOs have frequently shifted between competing mobile networks to secure the best competitive wholesale access. In addition, Vodafone has 15 wholesalers currently selling wireless broadband services to rural New Zealand over our mobile network, which is further evidence of competition at work delivering product differentiation and consumer choice.

The study also raises questions about new entry for a mobile network operator. Potential mobile entrants have all the regulation they need to enter and compete, including mobile roaming, cell site co-location, mobile interconnection, and number portability. Similarly, spectrum access is not an impediment to 5G entry, with MBIE expected to auction 3.5GHz, a key spectrum band for 5G, next year.

Vodafone strongly supports infrastructure competition for mobile networks – a model that continues to deliver significant benefits to New Zealanders including the choice to select a provider on things that matter to them.

We are confident network coverage, network competition and innovation will continue. We will review the paper in detail and make a submission to the Commission on the questions raised.

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