A memorandum submitted by the association of telecommunications companies of Nigeria (ATCON) to the senate committee on communications as input to its public hearing on matters relating to quality of service (QoS) and obvious non-co-location of facilities among service providers in the Nigerian telecommunications sector
We are pleased to have received an invitation from the Chairman Senate Committee on Communications to submit a memorandum to the Public Hearing to investigate the fundamental issues concerning Quality of Service; immediate and remote causes of poor Quality of service; reasons and solutions to the obvious non-co-location of facilities among service providers as contained in the Guidelines on Co-location and Infrastructure Sharing issued by the Nigerian Communications Commission, with a view to making appropriate recommendations on the issues.
We commend the Senate for wanting to get to the root of the problems and proffer solutions to them. We present, herewith, our views hoping that they would help the Committee in the discharge of this vital legislative assignment:
1. Fundamental Issues Confronting Quality of Service
i) Destruction of Telecom Service Equipment: This has become regular occurrence as all telecomm operators in Nigeria have stories to tell in this particular regard. We suggest that figures be obtained from Telephone Operators as this particular challenge is estimated to be costing the industry billions of Naira annually and constituting serious hindrances to better quality of service from the operators. To substantiate further, it costs about N24, 750,000 to install a single base station together with its tower, special antennas and two generators to power the station. This equipment are like the central nervous systems of communications because they allow subscribers make and receive calls but are now targets of vandals and thieves.
ii) Challenges of Multiple Regulation and Taxation: This is another problem that the telecommunication industry is saddled with as the Federal Government, State Government and Local Government all want to regulate the telecommunications industry and it has further contributed to the bane of telecoms industry. Heavy taxes imposed on telecom companies at the federal, state and local government levels have placed major obstacles, which slows down network expansion thereby compromising quality of service. In the case of telecommunications, it is the federal government that has the exclusive right to regulate the industry which led to the establishment of the Nigerian Communications Commission (NCC) backed with an Act to effectively perform that function. However, events in the recent past suggest that other federal agencies as well as states and local government are now making efforts to usurp NCC’s functions in the telecommunication industry. It has become a common practice for any government agency be it federal or state to solicit for one levy or the other from operators while some demand that operators secure approvals from them which come with very high fees before they can build infrastructure. The list of taxes and levies from states and local governments include but not limited to planning permit fee, Tenement Rate, Business Premises Registration fee, Effluent Discharge Fee, Environmental Impact Assessment Fee, Advert Rate, Site Analysis Report Fee, etc.
iii) Inadequate Power Supply: The role of power in telecom service delivery cannot be over-emphasized. Telecom companies largely depend on stable availability of power to function optimally. The Nigerian power situation, due to the very abysmal performance of PHCN is poor; this has made the telecom operators to depend on alternative power supply to run their Base Transceivers Stations. This is very expensive. For instance, telecom operators use an average of twenty five thousand litres of diesel every month to power their base stations. With over 25,000 base stations across the country by all telecommunications operators, there is an average of 50,000 at 2 generators per base station. The cost of the diesel is not inclusive of the cost of logistics incurred in procuring and transporting the diesel as well as the cost of servicing the generators. There are places which are not connected to the National Grid, the operations are 100% powered by generators, in those locations. The adoption of solar and hybrid power in some base stations have not resulted into any significant savings. These have impacted negatively on the operational capacities and increase in operational and capital expenditure of telecom firms in Nigeria with end result of poor quality of service delivery. The over N5 billion spent monthly by operators on power generation could be reinvested in further coverage expansion to address the congestion on the network which resulted to poor quality of service. While the operator’s OPEX (operating expenses) shows 80% for power generation in Nigeria, it is mere 5% in Malawi where power from the grid is stable.
iv) Conflict of Roles and Responsibilities amongst Government Agencies: This has also become a common phenomenon in the Nigerian Telecom Industry as there are overlapping and duplications of duties by federal and state agencies. A typical example of these is the recent face-off between NESREA and NCC over jurisdiction to intervene in specific regulation issues leading to the closure of a number of base stations.
V) Problem of Inadequate Capacity in the System
There is a problem of inadequate network capacity both in terms of number of base stations, network switching capacity and transmission network capacity. These contribute partly to the problem of poor call set up rates, high rate of call drop outs and poor call completion rates. Nigeria with a population of more than 160 million people had about 20,000 base stations at the end of 2010. The UK with just about 60 milliom people had more than 50,000 base stations at the same period. Thus, Nigeria needs more than 100,000 base stations to service its huge population. On the issue of transmission capacity, there is low availability of fibre backbone linking various parts of the country coupled with the slow pace of deployment of high capacity microwave backbone links. It is believed that more investment would be made towards network expansions when the operating environment becomes friendlier.
2. Proposed solutions to the Non-co-location of Facilities among Service Providers as Contained in the Guidelines on Co-location and Infrastructure Sharing issued by the Nigerian Communication Commission:
i) Advocacy: One of the solutions to the obvious non-co-location of facilities among service providers is that the government, regulatory agencies and relevant stakeholders should make all operators to see themselves as partners in the industry and not only as competitors. .
ii) Provision of incentives to co-location firms for the erection of sites in less attractive areas: Records have shown that most co-location sites are situated in urban areas, leaving out the rural areas. The Association is of the opinion that government should come up with incentives to encourage the co-location companies to provide services in the rural areas
iii) iii) Enforcement: NCC should exercise its power under the law to enforce the adoption of collocation as in accordance with the guideline it has stipulated in the Collocation Guidelines.
In view of the aforementioned causes of poor quality of service in the Nigerian Telecommunications Space, we hereby, as a summary, recommend as follows:
a) The issue of multiple taxations and regulations should be addressed
b) Government should treat telecom infrastructure as critical national infrastructure that deserves special protection and there should be a law to that effect.
c) Special Arrangements should be initiated with all state government in respect of Right of Way by Nigerian Communications Commission with the support of Federal Ministry of Communication Technology.
d) Approval for building of telecom facilities should be prompt and without unnecessary delays.
e) There should be concerted efforts at educating the public on the importance of Base Transceiver Station and the need to protect it against vandalism.
f) Number Portability implementation should be expedited.
g) A speedy liberalization strategy is necessary in the power sector to enable a quick realization of the goal of providing uninterrupted power supply to the Nigerian people and industries including the Telecoms industry.
h) NCC should increase its engagement with the Operators with a view to understanding their challenges and working together to resolving them.
We would like to note that the challenge of poor quality of service in the telecoms industry is not insurmountable. There is greater need for cooperation among all stakeholders to resolving the problem. We are confident that if the above stated recommendations are adopted, there would be considerable improvement in the Quality of service delivered.
Engr. Lanre Ajayi David Robert
National President, ATCON
Download copy of this report here Memorandum to the Senate Committee on Quality of Service (3001)