Caller Party Pays or Mobile Party Pays? Feedback to IDA

This is a response to Singapore's Infocomm Development Authority's request for public feedback in Jan 2002 on the mobile calls pricing regime in Singapore. In question is whether Singapore should move from Mobile Party Pays (MPP) system to Caller Party Pays (CPP) system. This was my feedback to the IDA.

1. CPP v MPP for voice

CPP is long overdue. For a consumer point of view, the fundamental criteria
is "control". Under an MPP system, I have no control over my own mobile
costs because this is dependent on third parties, some unknown. (Even if
callers are known parties, why should I pay for someone to gas away at me?)

The weaknesses of the currrent MPP system is masked by the innovative
packaging done by mobile operators, who package a certain number of minutes
for both incoming and outgoing mobile calls. However, this is at the expense
of transparency, and until today, I can never verify whether I truly used up
my 120 minutes or whatever per month. An unsatisfying situation.

There is also inefficiency in the sytem and a transfer of value to fixed
line operators. Example: I have called so many people on their mobile from a
fixed line phone, and they say to me, "Can you call me again on my fixed
line phone, I'm at the office now." Potentially several attempts later,
sometimes through office phone automation systems, I finally get hold of the
person I was calling before, but I have lost a few minutes in the process.

If the call is important enough to the caller to call the mobile number of
the intended recipient, the caller should also be prepared to pay for it.
Again, this is an issue of control, the control to influence my calling
priorities.

Moving to CPP would however mean fixed line operators paying a termination
fee to mobile operators. I think this can be worked out so that termination
fees are at a level where the impact on mobile operators are duly
compensated for loss of receiving call revenues.

I can't figure out the technicalities of how Starhub does their free
incoming calls, but hey, I'm a loyal Starhub customer because of that.

2. CPP or MPP for data.

I suspect that you'd probably not want to regulate as yet as to what mode of
charging services will dominate - the fact of the matter is that no one
knows what business model works.

But the principle should be "control to the mobile consumer". For example,
everything should be permission based. If I request for pull data, I should
be charged for it. If I asked for push data, I should be charged for it. If
I wanted to send a video pic to a friend, I should be charged for it.
Whether it is by bytes or by subscription or by whatever, follow the Isle of
Man experiments, let the particular service provider decide based on his
best commercial judgment. IDA should not decide for him.

Contrast this with other data which I don't request, e.g. m-coupons as I
visit come to the proximity of a retail store - this should be charged to
the retailer - hey I didn't ask for it, so why should I pay for it (unless I
have given consented to my network operator to pay for an m-coupon service).

I suspect that the market will settle down to a point where the consumer
will be charged a general subscription fee for an always-on data capability,
(which can be packaged with a certain amount of data transfers) but anything
beyond this will require the consent of the consumer to be charged.

3. Impact of CPP or MPP for data on growth of data segment

Highest growth will happen if control is in the hands of the consumer and
charges are transparent to her. There's nothing worse than uncertainty or
ambiguity to delay a purchase of a product/service (if you want to see a
classic example of this, note the "lack of visibility" cited as a reason for
delaying corporate technology purchases in the US, precipitating a recession
there). If you allow the data equivalent of the current MPP regime for voice
where you're uncertain about your costs, you will stifle the penetration of
2.5 and 3G. For an uncertain technology, please don't add any more hurdles
on adoption.

4. Actions to stop spamming under MPP regime

This I believe you need to come down hard on, even to the point of
regulation if necessary (e.g. set up equivalent of Advertising Standards
Authority of UK where companies can be publicly censured and possibly fined
for spamming mobile consumers - negative publicity in the media is
sufficient deterrent. Personal communication devices are exactly that,
they're personal. For some, it's used only for urgent matters and getting
spam on them is really an invasion of privacy. I've been getting spam on my
mobile for chatlines and I'm fuming... Not too sure whether the network
operator or some other person is responsible, but I ain't pleased.

5. Comments on FMI framework

Hard to get my teeth into this as a consumer, but I'm sure the network
operators will have a field day here.

Post-script - ths conservative suits at IDA eventually decided on status quo i.e. an MPP regime - Singtel was supportive as was M1 (wouldn't they be?). StarHub, as the newest kid on the block, was entering the market at this time and championed the opposite CPP approach.

StarHub creatively managed to do free incoming calls (a defacto MPP) as their best selling feature. Singtel and M1 sat on their thumbs and stuck with MPP to see their market share taken away by StarHub. By 2005, all operators were offering CPP plans, and no more is heard from anyone about the MPP regime. But StarHub is now No. 2 mobile player, overtaking M1 in 2004.

Kudos StarHub! It just shows that notwithstanding what regulators do, consumers, if given the choice, will vote with their feet!