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Achieving a Roaming Free Europe

European roaming rates are not set by market forces because when a competitive market did not evolve in Europe, European legislators stepped in to set rates by legislative fiat. This paper argues that legislators’ tendency to set rates cautiously led to high wholesale prices that undermined smaller operators’ ability to put roaming-free offers into the market. Operators with larger footprints are less constrained by wholesale pricing since more roaming traffic is kept on-net. In this context, the outright abolition of retail roaming charges without wholesale backstops bestows a competitive advantage on larger operators. The paper notes the experience of the US where roaming persists for all operators but retail customers can avoid roaming charges subject to significant cut off limits. The effective wholesale roaming rate in the US is estimated at just above 1 eurocent per minute for voice while rates are observable for national roaming in Europe of 1 eurocent for voice, and 0.2 eurocent for data and 0.2 eurocent for SMS events. It is proposed that such rates would be appropriate for wholesale roaming in Europe and that these rates would facilitate pan-EU retail offers such as those observable in the US. Unlike the US, European operators charge each other termination rates to carry calls from other networks. This creates another barrier to pan-EU retail offers and creates tensions (and transfers) from low cost termination markets to high cost termination markets. This inconsistency of approach must be addressed if the elimination of intra-EU roaming is to be possible. It is suggested that low but consistent termination rates would be required to go with the low wholesale roaming rates and that these rates would need the speed and consistency of application delivered through a Regulation. The extension of retail caps to international calls and SMS is unwarranted and may have adverse effects on network valuation. Such a major policy initiative would benefit from a public consultation.