Third Rate? We're talking a theoretical maximum downstream bandwidth of 7.2Mbps compared to the 42Mbps that Telstra's direct customers enjoy in capital cities and many regional centres. Telstra doesn't talk theoretical maximum speeds any more, only the speeds users are likely to experience, but these maxima provide a more meaningful description of 3G broadband variants than their official acronyms.
All three operators have three variants of 3G broadband deployed: HSPA (7.2Mbps max), HSPA+ (21Mbps) and dual carrier HSPA+ (42Mbps). The highest speeds being deployed in major population centres. Regional areas and the peripheries of major centres get only HSPA.
That's not the case with MVNOs on other networks. Both Optus and Vodafone have assured me that that their MVNO customers get exactly the same access to the network as direct customers.
Telstra, however, is extremely coy about the limitations of its wholesale 3G service and the MVNOs I've looked at make no mention whatsoever of it on their web sites or in any of their material, so far as I can tell.
Most of the companies retailing Telstra 3G services are not direct MVNOs of Telstra but are customers of intermediaries. ispONE and iTelecom are, I believe, the only two. Telstra named iTelecom as its first postpaid wholesale customer in March 2012 and ispONE as its first wholesale prepaid customer in November 2012.
In the iTelecom announcement Telstra was very upfront about the limitations of the offering, saying that the service "offers a 3G coverage footprint to 97 percent of the population and a typical download speed range of 550Kbps – 3Mbps."
By the time of the ispONE announcement, Telstra had clearly decided that being so open about the limitations of the offer was not a good idea. "The pre-paid mobile product will offer customers access to parts of Telstra's 3G 850/2100MHz network." I don't know about you, but I'd take that to mean some sort of restriction on geographic coverage.
The message hasn't changed. At Telstra's recent press briefing on its LTE expansion plans, I asked Telstra Mobiles executive director, Warwick Bray, about the wholesale 3G offering, and the answer was the same: they get access to "a portion of the network". He couldn't be upfront and say they were limited to 7.2Mbps downstream.
You'll find the same message on the web site of iTelecom Wholesale, buried pretty deep. "The solution utilises parts of Telstra's 3G 850/2100 MHz network," And buried even deeper http://www.itelecomwholesale.com.au/propositions/mvno-solution/network-coverage the definitive statement "The solution has a maximum download speed of 7.2 Mbps."
According to the ACMA "A Critical Information Summary will provide you with clear information about products, plans and services to enable you to easily compare what is being offered for both post paid and pre-paid services."
Therefore, it seems to me, the CIS for Telstra MVNOs' 3G services should clearly spell out that Telstra MVNO 3G is not the same as Telstra 3G, Vodafone 3G, Optus 3G or MVNO versions thereof in order for comparison to be made. In the ones I looked at, there was no such information.
The revised TCP code also ushered in the formation of a new body, Communications Compliance to monitor telcos' conformance with the new code. I put it to Communication Compliance's executive director, Christiane Gillespie-Jones, that such disclosure should be included in the CIS.
She replied: "The CIS, as the name says, is a summary of the most critical aspects of an offer and its content is described in quite some detail in the code. I think it may be stretching it a bit too far to expect it to provide all more or less important aspects of an offer. While some customers may find the information you refer to desirable to be provided in the CIS, I do not think that CSPs are in breach of the code for not providing this information in the CIS. Ultimately, this is a decision for the ACMA."
She added: "I note that you take the phrase 'part of Telstra's mobile network' to suggest a limited geographic coverage. Personally, I did not have this association. (How does it imply a geographic limitation when MVNOs are simultaneously advertising a 97% or 98.5% Telstra coverage?)
Well, of course it does not, but taken in isolation it provides at best no useful information and at worst is a deliberate attempt to hide the fact, which could easily have been stated, that the maximum speed available is 7.2Mbps.