How the European Roaming directive makes my life worse

One of the travel blogs I follow covered today the new EU directive on roaming charges, I complained quickly on Twitter, but as you can imagine, 140 characters are not enough to explain why I’m not actually happy about this particular change.

You can read the press release as reported by LoyaltyLobby, but here is where things get murky for me:

The draft rules will enable all European travellers using a SIM card of a Member State in which they reside or with which they have “stable links” to use their mobile device in any other EU country, just as they would at home.

Emphasis mine, of course.

This is effectively undermining the European common market of services: if you do not use a local provider, you’re now stuck to pay roaming just as before, or more likely even higher. Of course this makes perfect sense for those people who barely travel and so have only their local carrier, or those who never left a country and so never had to get a number in a different country while keeping the old one around. But for me, this sucks in two big and kind of separate ways.

The first problem is one of convenience, admittedly making use of a bit of a loophole. As I write this post I’m in the USA, but my phone is running a British SIM card, by Three UK. The reason is simple: with £10 I can get 1GB of mobile data (and an amount of call minutes and SMS, which I never use), and wit £20 I can get 12GB. This works both in th UK, and (as long as I visited in the previous 3 months) a number of other countries, including Ireland, Italy, USA, and Germany. So I use it when I’m in the USA and I used it when I went to 33c3 in Hamburg.

But I’m not a resident of the UK, and even though I do visit fairly often, I don’t really have “stable ties”.

It’s of course possible that Three UK will not stop their free roaming due to this. After all they include countries like the US and (not a country) Hong Kong in the areas of free roaming and they are not in Europe a all. Plus the UK may not be part of the EU that long anyway. But it also gives them leverage to raise the prices for non-residents.

The other use case I have is my Italian mobile phone number, which has been the same for about ten years or so, changing three separate mobile providers – although quite ironically, I changed from 3 ITA to Wind to get better USA roaming, and now 3 ITA bought Wind up, heh – but keeping the number as it is associated with a number of services, including my Italian bank.

Under the new rules I may be able to pull off a “stable links” indication thanks to being Italian, but that might require me to do paperwork in Italy, where I don’t go very often. If I don’t do that, I expect the roaming to become even more expensive than it is now.

Finally, there is another interesting part to this. In addition to UK, Irish and Italian numbers, I have a billpay subscription in France through free.fr — the reason is that I visit France fairly often, and it’s handy to have a local phone number when I visit. I have no roaming enabled on that contract though, so the directive has no effect on it anyway. That’s okay.

What is not okay in my opinion is that the directive says nothing about maintaining quality of service when roaming, it only impose prices. And indeed Free.fr sent an update this past July that, due to a similar directive within France, their in-country roaming will have reduced speeds:

De ce fait, les débits théoriques maximums atteignables par abonné sur
le réseau de l’opérateur partenaire en itinérance 2G/3G seront de
5 Mbit/s (débit descendant) et de 448 kbit/s (débit montant) à compter
du 1er septembre 2016 jusqu’au 31 décembre 2016. En 2017 et 2018, ces
débits seront de 1 Mbit/s (débit descendant) et 448 kbit/s (débit
montant). Ensuite, ils seront de 768 kbit/s (débit descendant) et 384
kbit/s (débit montant) pour l’année 2019 et de 384 kbit/s (débit
descendant) et 384 kbit/s (débit montant) pour l’année 2020.

So sure, you’ll get free roaming, but it’ll have a speed that will make it completely useless.

My opinion on this directive is that it targets a particular set of complaints by a vocal part of the population that got screwed sideways by horrible roaming tariffs of many European providers when on vacation, and at the same time provide a feel-good response for those consumers that do not actually care, as they barely, if ever, leave their country.

Indeed if you travel, say, a week a year in the summer outside of the border, probably these fixed limits are pretty good: you do not have to figure out which is the most advantageous provider for roaming in your country (which may not be advantageous in other circumstances) and you do not risk ending up with multiple hundreds of euros of bill from your vacation.

On the other hand if you, like me, travel a lot, and effectively spend a significant amount of the year outside of your residence country, and you even live outside of your native country, well, you’re now very likely worse off. Indeed, with the various 3 companies and their special roaming plans I was very happy not having to have a bunch of separate SIM cards: in Germany, USA, Austria I just used my usual SIM cards. In UK, France and Italy I had both a free-roaming card and a local one. And instead before that I ended up having Vodafone SIM cards for the Netherlands, Czech Republic, Portugal and very nearly Spain (in that case I used Wind’s roaming package instead).

Don’t get me wrong: I”m not complaining about European meddling into mobile providers. I used to have a tagline for my blog: “Proud to be European”, and I still am. I’m not happy about Brexit, because that actually put a stop to my plans of moving to London eventually. But at the same time I think this regulation is a gut reaction rather than a proper solution.

If I was asked what the solution should be, my suggestion would be to allow companies such as 3 and Vodafone to provide an European number option. Get a new international prefix for EU, allow the companies that have wide enough reach to set up their own agreements locally where they do not have network themselves (3 and Vodafone clearly have already a wide reach) by providing a framework for capping the cost as applied to providers. Then get me a SIM that just travels Europe with no additional costs, and with a phone number that can be called at local rates everywhere (you can do that by ensuring that the international prefix maps to a local one in all the countries). Even if such a contract is more expensive than a normal one, the frequent travellers would be pretty happy not to have to switch SIM cards, phone numbers, and have unknown costs appearing out of nowhere.

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