Alternative roaming Providers (ARPs) must not be confused with the UK's World War Two Air Raid Precautions, which of course we will because the ARP Warden in this case is Neelie Kroes, the EC digital agenda commissioner.

Back in 2011 Kroes came up with a plan to rid the continent (she supposed) of the outrageous 'roaming' charges which have blighted many a European's holiday. "Roam at will and come home to find a huge bill" was, and is, the reality of mobile roaming in Europe. And it got worse as data roaming charges became an even more deadly trap for the unwary traveller or road warrior.

So Kroes hit on the idea mandating the separation of roaming and domestic mobile services so that pan-European market forces could swing into action and solve the problem.In addition to the usual price cap tinkering ...[we wrote back in 2011]... she is reported to be tabling a proposal to 'separate' roaming and domestic services, so that users will be able to opt for roaming services from an alternative provider. This way, it's hoped, some of those elusive market forces will swing into action and finally end the egregious pricing habitually experienced by Europe's business and holiday travellers.

"The separation threat might finally make Europe's mobile operators take notice since in theory such a move - if carried through - could create a new class of "virtual operators" specialising in roaming (argues the commission) and will collapse roaming prices.

Much will depend on how difficult it is for consumers to take on the new services and how seamlessly they can be made (or not) to interwork with their domestic services. [snip]

And there lies the problem.

Neelie Kroes followed through on the separation policy but there is now just one year (exactly) to go before Europe's operators must complete their technical preparations. By this time next year Europeans may opt to have separate domestic and pan-European (and global) roaming providers, except... the technical specifications for this new species of mobile network interworking have just been released, giving operators just 12 months to get all their ducks in a row: issue RFPs, select suppliers, develop, install, test and launch the technical ability to support their users when they need to be assigned to one of the new ARPs.

It will cost, it will cause headaches and there's no assurance that there will be any retail roaming providers in place and ready to request service when they do.

According to Jonathan Bell, VP of Product Marketing at signalling solution provider for ARPs, OpenCloud, the software rewrite required to detect when users leave native network coverage and roam to another provider is no trivial task. Not only must the user be properly assigned, but all his or her supplementary services must be supported as well. Under the regulation, things like voice messaging must be made seamlessly available to the user.

Then there are the different rules that apply in different countries over things like handling prepaid and postpaid accounts, how data charges should be accrued when a video is interrupted and so on.

There are other substantial costs on the ARP side. It looks likely (unless an ARP enabler role is established - see below) that ARPs will need a charging infrastructure for real–time credit control and to meet a slew of national regulatory obligations - things like alert texts when 80 per cent of a data limit is met - that sort of thing.

Some observers express themselves perplexed at the EU strategy here.

On the one hand the new commercial roaming arrangement calls for substantial investment in infrastructure from both the retail and wholesale sides of the new divide; on the other, the entire concept of roaming Europe at premium prices is under attack by the same commission's moves to push down on roaming charges and eventually make them disappear.

Who would want to invest in a new business which is already being undermined by planned regulation? According to OpenCloud's Jonathan Bell, it's hardly surprising that it's still not clear who will be the new retailers - even at this late stage.

"It could be new entrants or existing business roaming service providers," he says. "On the other hand it may be a 'who blinks first' sort of scenario. One of the European groups of national telcos may decide they have more to gain than lose by jumping in fast."

Another (anonymous) observer of the scene maintains that the most likely-to-succeed player on the retail side will be one of the very small European telcos (a Luxembourg or Jersey Telecom, for instance) since these have VERY small domestic markets so all the new business would be incremental - no cannibalisation involved.

OpenCloud's Bell, however, thinks that the small Euro telcos might rather play the role of enablers for third party pan European or even national retailers, somewhat like the MVNO-enabler role.

Or it could be that once the invitations are sent out, the venue booked and the food ordered, nobody turns up to enjoy the ARP party.

"Put that light out!"