In Search Of Stronger Telecom Regulator
A GNA Feature by Samuel Dowuona
Accra, March 17, Ghanadot/GNA -
Within the past few months the mobile telecom industry in
Ghana has witnessed some flashy developments. But those
developments have not necessarily improved network quality.
As operators make huge showy expenses purporting to be
bringing some hi-tech and luxury services to their
customers, subscribers continue to experience a myriad of
age old network challenges such as dropped calls; cross
calls; speech mutation; calls not going through; wrong voice
prompts; no network access; error in connection and more.
The network operators claim they are spending huge sums on
network infrastructure by the day and yet subscribers of the
big operators in particular continue to lose money
instantaneously as a result of network challenges.
Available evidence shows that those operators are largely
preoccupied with jumping at every opportunity to promote
their corporate brands through aggressive marketing and PR
strategies rather than fixing their sticky networks.
It appears that the big telecom operators in Ghana are
generally advertising their features and not addressing the
issue of service quality. Subscribers are at a loss as to
what the National Communications Authority has been doing to
ensure that operators delivered on their licence obligations
The Minister of Communications, Mr Haruna Iddrisu has said
that there was an urgent need for a “stronger regulator” to
ensure a vibrant telecom industry. In the 2009 Budget
Statement, Government said it would monitor both the
regulator and the operators to ensure sanity.
But Mr Joshua Peprah, Director, Regulatory Administration of
NCA, says “to make NCA stronger it should be respected as
independent of government interference in the area of policy
implementation or should be minimal”.
The purpose of this article is to put the spotlight on some
developments in the mobile telecom industry and the NCA’s
positions on those developments.
is to demonstrate whether the NCA is showing enough strength
in regulating the industry.
The issues in focus are poor 2G network quality vis-à-vis
the introduction of 3.5G services; statistics reporting
vis-à-vis second network codes; street hawking and mobile
Within the month of January 2009 alone, Zain and MTN
launched 3.5 Generation (3.5G) services. Vodafone Ghana also
signed a US$120 million contract with Huawei for the supply
of 3.5G technology. Tigo and Globacom have also received
separate licences from the NCA to run 3G services.
Simply put, 3G is based on a Universal
Mobile Telecommunications System (UMTS) and it enables
subscribers to transmit data including pictures, video and
greater volumes of text at a higher speed on their phones.
It enables video calls, video conferencing and offers
permanent internet connectivity on the handset. 3.5G is a
relatively minor upgrade to 3G.
The NCA argues that “in essence, where 2G services needs to
be improved, adding a 3G network services can be another
viable way of redeeming the situation.
” In other words the operators with poor
quality service on 2G GSM networks are expected to correct
that through 3G.
The NCA, however, blames the poor quality
of service on “the resistance of local community groups to
building of telecom masts and towers needed to improve
coverage and to address capacity issues,” and assured that
consultations are ongoing with the appropriate bodies to
address the perceived fear of radiation hazards and to
create the environment for operators to build and deploy
more base stations to address the existing quality of
Certainly the concerns expressed in local communities about
the construction of new towers are inconsistent with those
communities’ stated desire for communication services.
But some operators strongly disagree with the NCA’s
assertion that 3G would help to solve network problems on
2G. One operator said “We don’t see how 3G licences and
networks would produce any improvement for the mass of
customers using 2G networks with quality of service
problems. There will be no mass migration of customers from
2G to 3G because the handsets and devices are too expensive
and the 3G coverage is not as good as 2G (GSM).” On the
average, 3.5G handset cost 300 Ghana cedis.
One of the 3.5G service providers, however, stated that “we
have 3G handsets that are comparably priced with non-3G
handsets on the market and a range of low cost handsets to
suit every budget”.
The other thing the 3.5G service providers are not telling
subscribers is that with 3.5G one needs to be closer to a
UMTS station than do 2G users need to be to a GSM station to
receive quality service. What this means is that the
operators must install even more UMTS stations than 2G
within a particular area to run 3.5G services efficiently.
MTN says their 3.5G is active in Accra and Kumasi and Zain
says they are active in Accra and yet they have refused to
answer questions on how many UMTS stations they have
installed. One hopes that the Right to Information Bill
would be passed sooner than later.
That is a problem particularly because even on the GSM
network, which is relatively in abundance, there are huge
call quality challenges. But there are more.
According to the NCA, network operators are required to
report on monthly basis the number of active subscriptions
for both voice and data services. The NCA defined active
subscriptions as those which are making and receiving calls
and text messages or accessing the internet as at the time
Based on those criteria, NCA says the five service providers
which are currently operational commanded a total of
11,962,224 subscribers as at January 2009.
The market leader, MTN has 6,592,243 subscribers; Tigo has
2,785,714 subscribers; Onetouch (Vodafone) has 1,733,711,
followed by Zain with 463,824 and Kasapa with 386,732.
The NCA says it conducts occasional network audit to verify
the authenticity of the figures reported to it by the
According to the NCA, audits are done particularly when
there are “unacceptable levels of congestion on a network or
deterioration in the call quality”. In such instance the NCA
takes raw data from the operator in question. A billing
verification exercise is also conducted when the operators
advertise new tariffs, obviously because of the financial
ramifications for the NCA.
But in separate responses to questionnaires this Writer
administered, the operators indicated that they were not
aware of any network audit that the NCA has been conducting
and that as far as they were concerned the NCA had always
recorded and worked with the subscriber numbers as quoted by
the individual operators.
Secondly, the operators said in practice there is no uniform
procedure for collating subscriber numbers so each operator
uses a different software system and they end up reporting
parallel subscriptions, where one subscriber, who may have
left one network to join another network ends up being
captured by both networks as their subscriber. This tends to
inflate the figures significantly for both networks.
This is important because it means the figures quoted to
justify why an operator qualifies to acquire an additional
network code may not be real.
Thirdly, even though the NCA says
operators are supposed to file monthly reports, in practice
they file reports on quarterly basis as per the NCA’s own
90-day activity criteria.
To quote one operator, “NCA asks us at the end of each
quarter (not monthly) how many customers we have according
to the 90-day activity criteria – that means the customer
should have used his phone for something in the previous 90
days. As far as I know, they just accept the numbers we give
them. We don’t recall any subscriber number audit at our
place, and since each network has different software
systems, I don’t know how NCA could audit that.”
Meanwhile, investigations by this writer
indicate that some of the operators capture simcards sold to
distributors as active subscriptions. At least one of the
new entrants is on record as having been caught in that
practice in neighbouring Benin.
There are also indications that some operators are hitting
their rivals below the belt by buying simcards of their
competitors in huge quantities to destroy in an attempt to
keep their rivals out of the competition. But strangely all
those destroyed simcards are captured as active
subscriptions and the NCA takes those figures on the face
It seems the NCA is carried away by the financial
ramifications of having a fast growing mobile phone
community in the country as the “inflated” figures show so
they do not pay closer attention to whether the operators
report the right figures or not.
Second Network Codes
One of the operators intimated that NCA made a proposal to
network operators to acquire second network codes (05X
range) at a standard cost of one million dollars each. NCA
says the standard cost covers allocation, management and use
of the code. This means MTN paid at least a million dollars
for their newly launched 054 to enable them to attract more
subscribers unto their congested GSM network. MTN says its
024 range of numbers is exhausted, but given the possible
significant inflation in subscriber numbers, one would have
expected the NCA to investigate that claim further before
selling the additional code to MTN.
The question also arises - if NCA does network audit to
check congestion and deteriorating call quality, how did MTN
justify a request for a second network code with the myriad
of call quality problems? Where does subscribers’ interest
come in as per Section 5(c) of NCA Act, Act 769, 2008; which
states that “The Authority (NCA) shall in performance of its
functions have regard to the protection of the interests of
consumers or users of communications networks or
communications services and in particular to the interests
of consumers’ choice, quality of service and value for
Thanks to the NCA, subscribers keep having raw deals from
some operators and added to that, they are also contributing
to the overwhelming problem of street hawking in their bid
to reach subscribers and potential customers in the middle
of the high streets.
Lately one finds more young people dressed in MTN, TIGO and
Onetouch sleeveless jackets selling recharge cards and
simcards in the middle of high streets competing with
motorists. Beside the fact that they are a nuisance, they
are also living dangerously selling on the streets.
Mr Armah Ashittey, the new Greater Accra Regional Minister
has declared war on street hawking and this puts the mobile
network operators and their trading partners in the line of
Mr Kwasi Amoafo-Yeboah, Chief Executive Officer of Itel
Ghana Limited, agents for MTN, said even though street
hawking was a nuisance, it served as a major source of
employment for the youth. He, therefore, challenged the
Government to find alternative sources of employment for the
youth before thinking about clearing them off the streets
“else they will resort to all kinds of anti-social
activities like armed robbery, pick pocketing and other
But it is common knowledge in this country that designated
hawkers’ markets constructed with taxpayers’ money have been
abandoned and turned into refuse dump sites and dungeons of
lunatics and anti-social characters.
Moreover the practice in other jurisdictions is that,
vendors of recharge and simcards operate from street corner
stores and sheds and not in the middle of high streets. The
regulator must show strength as per Section 5(d) of the NCA
Act, which enjoins the NCA to have regard for the impact of
the activities of operators on the environment.
One would have thought that the Consumers Association of
Ghana (CAG), would be up in arms at least pushing the NCA to
ensure that the operators lived up to the quality of service
indicators as required by Article 3(l) of the NCA Act, Act
769, 2008, but Dr Ferdinand Tay, President of the CAG, told
this Writer that the Association did not concern itself with
issues of network quality. According to Dr Tay, the
Association only dealt with issues concerning tariffs in the
Asked why network quality was not on CAG’s menu? Dr Tay
conveniently passed the buck, saying; “since you are a
journalist, you can talk about it freely but if we did, we
stand the risk of being accused by some operators that we
are being sponsored by other operators to do a dirty job”.
From this standpoint does this Writer need anybody again to
tell him that he is taking a great risk with this article?
In any case, GNA is a statutory organisation and this falls
squarely within its mandate.
Mobile Number Portability
Obviously there is no one to fight for consumers, not CAG or
even the legally mandated NCA. But there is a way out; the
NCA can at least empower the subscribers to fend for
themselves. Mobile number portability (MNP) could be a first
step to empowering subscribers to take up the responsibility
of getting off congested and problematic networks and yet
keeping their numbers including the network code.
The MNP system allows a number to be
“ported” from the original network that had the number, to a
new network of the customer’s choice. This way the
subscriber gets to keep contact with family, friends and
business associates through the same number even though on a
But the NCA told this writer that
it wanted to approach the implementation of MNP with
circumspection because it was “cumbersome and costly” and
that the experience of other jurisdictions indicated that
the benefits of MNP were not commensurate with NECO 10
Economics Telecom Quality
The NCA must be told that a “stronger regulator” is the one
who seeks the interest of subscribers. Indeed, outside of
the interest of subscribers the business of regulation is an
exercise in futility, because why should there be a
regulator if there is no need to ensure quality standards,
value for money, choice and affordability for subscribers.
It is, however, refreshing to know that the new Minister of
Communication is ready to get MNP off the ground. This
coupled with Government’s closer monitoring of the NCA and
operators; it is the hope that subscribers would have better