The Commission proposed wholesale data roaming cap of €8.5/GB is anomalous and will distort competition in North-Eastern mobile markets where retail gigabyte prices are competitive
October 2016

UPDATED 27.10.2016 with Response of EU Commission DG Competition (letter dated 27.10.2016) to Rewheel’s concerns.

Key questions answered
  • How low should the wholesale data roaming cap be in 2017 to avoid the distortion of competition in North-Eastern domestic mobile markets where retail gigabyte prices are competitive?
  • Why the European Commission’s cost modelling methodology is dubious (produces fictitious high gigabyte costs)?
  • Why the Spanish regulator cost model (different consultant) produces five times higher gigabyte cost than the Commission’s model?
  • Does seasonality significantly affect the cost of data roaming services? A South European mobile operator questioned the claimed size of the calculated data roaming cost per gigabyte!
  • What is the financial impact challenger MNOs and MVNOs will face with the anomalous 8.5/GB wholesale cap?
  • Why BEREC, MVNO Europe and a number of North-Eastern mobile operators warned the Commission that the proposed wholesale data roaming cap will raise domestic prices, weaken competition and increase consolidation?
  • Why the Commission proposed wholesale data roaming cap appears to be carefully calibrated to €8.5/GB?
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