An Open Letter to the Telecommunications Regulator of Samoa Regarding GPRS Data Rates

By: Citizens’ Coalition for Accountability in Telecommunications in Samoa (CCATS)

Dear Mr. Morgan,

Thank you for the information you provided in response to our request to assess and resolve the serious issues we have raised and submitted to you on 16 October 2007. These were also published in a recent article in Samoa Observer. You provided us with proposed GPRS data rates from both providers (and referred to them as published) along with some of your comments. SamoaTel’s data rates were of course the subject of our article; Digicel’s data rates (suddenly appearing out of nowhere) have not to our knowledge been published, nor their data service advertised (thus maintaining an effective monopoly for SamoaTel in this area - if consumers can’t find out about an alternative service, there is no competition) so it’s useful to have them. However, we would like to think that the role of your office is stronger than information gathering or representation of the views of providers – or even “suggesting that they may need to consider” measures to ensure equity of service accessibility while acknowledging that they “may wish to wait”. Of course any sensible profit-making organisation in that position would “agree to look into options” while continuing to exploit the situation to their advantage. Surely, if the government has signaled the need for there to be some sort of universal access/service provisions made, we should not have to wait for the letter of the policy to be hammered out before the important principles underlying it are acknowledged, and outrageous violations thereof curtailed?  Policies and legislation are not the only tools for keeping organisations in line – moral pressure, as through publicising the negative impacts of their actions, can also influence. We also believe that, ultimately, all this should not detract from the fact that a well established fibre optics infrastructure is already in place countrywide and, while it is grossly under-utilised, it is ready to easily be tapped into in order to provide equal or fair access for the majority of population in Samoa. 

Regarding the proposed GPRS data rates: it is unnecessary to rehash the issue, as our article was clear and comprehensive. Nevertheless we will reiterate the main issues at this point considering the false information relayed to you by SamoaTel about promo rates, picture transfer rate, benchmark, competitive pricing, etc. To keep it short: our concern is only relating to these rates being applied to data access (using a PC or laptop) for those who have not received the benefit of landline or equivalent. High data rates (and both providers’ rates are truly astronomical) for low-use “luxury” services are one thing, and not the prime concern of this coalition. But when the captive audience in rural areas is suddenly lumped in with the casual mobile data user, and unattractive data plans are introduced under the guise that they are comparative and competitive to local ISP dialup rates - then there is a huge problem that needs to be addressed from the regulatory point of view subject to immediate regulatory intervention. Note that the 40 sene per MB rate was said to be competitive with ISP rates from the beginning, and not billed as a “promo” rate. (How is it also possible for two rates which differ by 50-fold be comparable and competitive to ISP rates at the same time?)

And once again, to have a complete picture, let us dispel the myth of comparative and competitive rates: Mobile data rates (measured by amount of data used) and ISP dialup rates (measured by the time online and/or amount of data used) cannot be accurately compared. One can only strike a rough comparison by finding a common denominator, in which case since the data throughput of both landline dialup and GPRS data is roughly the same, the amount of data transferred can be used as a rough measure for a crude comparison. As an example let’s first take the current casual rate of a local ISP, iPasifika.

 $1.35 for off-peak or $4.10 peak using a dialup landline ISP connection to internet is nothing like the $400 cost of using SamoaTel GPRS data for the same download amount (and practically taking as long or longer). Now, downloading 200 megabytes while staying online, let’s say 20 hours (10 hours peak and 10 hours off-peak) one pays only $54.50 with ISP dialup whereas one pays $2000 for the same download amount with SamoaTel Casual GPRS Data rate at 2 sene per KB! Compare this with the 200 MB data plan at $149 where all the allowable download would be used up and one starts paying steep data rates per KB from that point on. Again, big difference between $54.50 and $149 plus! Comparing the lowest ISP plan ($29 monthly fee for unlimited download, 25 hours free and $2.75 excess) with the 30 MB SamoaTel Data Plan yields similar huge disparities of rates! Even with EDGE (currently not enabled and requiring expensive additional modem or high-end mobile phone), though this comparison would be slightly skewed, there still will be huge price disparities (we can substantiate if necessary). Are we missing something here? This is truly outrageous and we believe the public has been misled hence a fraudulent act by the service provider(s).

Bear in mind that the internet is an increasingly content-rich environment and heavy in terms of downloads: documents to upload and download, pictures to receive and send, streaming audio and video for research and productivity, frequent automatic Windows, installed software and Anti Virus updates, online banking, distance learning, etc. are all part of the web experience! And all this adds up at the end – one really doesn’t have to be extremely wealthy in order to have a semi decent web experience – that is in Samoan terms of course. Not really intending to compare (we are more realistic than that) but just to put things in perspective: unlimited high speed mobile internet (EDGE) is offered in US for $5.99 per month attached to a voice plan or $29.99 stand-alone!  

Since we have arrived at this point, let’s take another step forward and ask the logical question: how fair and competitive are the local ISP rates anyway? And why are we so desperately trying to measure up to their standards? After all, most of these dialup rates have remained unchanged in a price-fixing scheme for the past decade or so – mostly due to unnecessary high data rates imposed by the monopoly international internet gatekeeper SamoaTel! Is this yet another regulatory issue? Definitely!

What to do? Considering the circumstances we propose to mandate a special, extremely low (we are talking about like 1 sene and not $20 per megabyte) casual GPRS Data rate offered by both mobile providers in lieu of a Universal Access/Service policy for those who don’t have the benefit of a landline phone and those who are on a landline waiting list (some for over 5 years) until the situation is rectified! We acknowledge that these types of special circumstance rates are generally offered at cost but as you may appreciate our view, any cost analysis the provider(s) may come up with, cannot be trusted for obvious reasons, especially in such a loose regulatory framework. And if the cost of providing GPRS data is indeed high, then this reflects poor strategic management and lack of foresight on part of the provider and so they have to accept their mistake, take a loss by providing the service anyway, go back to the drawing board, and maybe this time for real, re-evaluate the cost of landline provisioning, etc. What they should NOT do, (and as we understand, this as your prime duty as a Regulator to prevent) is to instead squeeze it out of us poor people in Samoa cunningly and unjustifiably!

We’ll await your initial assessment followed by concrete, binding and timely measures to address the clear issues we have raised before and reiterated here in this reply.

Best regards,

Citizens’ Coalition for Accountability in Telecommunications in Samoa (CCATS) 

PS: We have made this part of our reply to you a public document for the benefit of the broad public and in order to have a written record contrasting verbal rebuttal circulating around by the providers still clinging to their rationale of “comparative and competitive data rates”!
 
Website:  www.ccatsamoa.info