Draft Policy Directions - Please provide your feedback (new deadline: 22 Feb)

[RavenN]

How do you increase competition with NO Open Access Operator? The market is still limited to a few players that have exclusive access to the access networks.


WireFree

I'm not fundamentally opposed to Open Access - i just think its more complicated than we think, but i would be happy to see how ICASA details the Open Access process. I think you hit the nail of the head in your statement "exclusive access to the access networks". i think the wholesale requirements set by ICASA should be to allow wholesale access to the access network. There are many countries that have fewer mobile operators than we do, but have higher levels of competition. Competition is not only associated with a large number of players, but often with structural deficiencies in regulation, as is the case with interconnection in South Africa. Indeed, studies by Ofcom in the UK caution against too many non-viable operators fragmenting the market and actually increasing the potential for monopoly by dominant players

The MVNO model you describe above is simply price based competition, no service differentiation - aka the Virgin Mobile type model. An MVNO that owns it's own infrastructure also has the ability to offer converged services across different technologies (such a fibre, WiFi and possibly in the future over the Telkom LL) and not be limited to the vanilla mobile service offered by the host operator.

WireFree

The MVNO model is generally a sales and service offering (hence the "virtual") - but its not just price based. There is a huge amount of competition and innovation that can occur at the sales and service offering level which is not currently available - but it is distinct from facilities based competition. I think the 2 are complementary. Any Operator that has its own infrastructure will have to have some kind of spectrum. Hence i think awarding 800MHz on the local level in urban areas is an opportunity to increase facilities based competition. I dont think we should consider these MVNOs. Any operator competing on a facilities based level is just a MNO

[ruler.peaceful]

Looks good.

In my opinion spectrum is a national resource. Assignment of high demand spectrum should not be monopolised by a few entities. The spectrum assignment process should also aim to increase competition in the supply of wireless services as competition will help to drive down prices.Will Mybroadband be responding to the ICASA Framework for the Licensing of High Demand Spectrum?

[WireFree]

for the policy directions...this will have an impact on the ICASA process which will probably be kicked back a month

There are a few days left for the ICASA deadline and there have been no announcements of a new timeline.

[AvatarS]

dominic has been following up on this and we will post once we have an indication of the deadline.

[dominic]

informally i have been told this will happen...(really hoping so)

[ellipsis]

Updated document here: http://dl.dropbox.com/u/24829246/MyB...ons_270212.pdf

Have a read, and post your thoughts. I will edit if need be after that.
Please keep in mind that this is to be submitted on Wednesday, so don't leave it until Wednesday afternoon as I probably won't see it then

[WireFree]

Have a read, and post your thoughts. I will edit if need be after that.
Please keep in mind that this is to be submitted on Wednesday, so don't leave it until Wednesday afternoon as I probably won't see it then

There has been talk recently about Special Economic Zones. The Policy Directions should consider Licence Incentives for operators who provide access services (fixed and wireless) and backhaul services in these zones. This will help to ensure that the zones have access to competitive telephone and internet services.

Addition for 16: Awarding of spectrum should also give preference to operators, whose shareholders do not already have a direct or indirect shareholding in an operator with High Demand Spectrum.

With regards to award of spectrum to wholesale providers (or the request that operators offer wholesale services) to operators with no spectrum it is important that the wholesale services are provided on a usage basis with no floor charges (depending on the type of wholesale agreement). If excessive floor charges are imposed, then the entry of new operators in this market is limited. For example, a simple national roaming type agreement should not require floor charges as international operators who have roaming agreements with the local mobile operators are not required to pay floor charges (it is usage based). A national roaming agreement is one method of allowing operators with no spectrum to provide services on the wholesale providers' network.

[ellipsis]

Thanks, Wirefree. Will incorporate your comments and post the edited document later today.

Any other comments?

[RavenN]

Updated document here: http://dl.dropbox.com/u/24829246/MyB...ons_270212.pdf

Have a read, and post your thoughts. I will edit if need be after that.
Please keep in mind that this is to be submitted on Wednesday, so don't leave it until Wednesday afternoon as I probably won't see it then

Looking good

I am concerned that ICASA awards the High Demand spectrum without looking at a full breakdown of who owns what spectrum. There are options for LTE in other spectrum bands and i would ask that they consider requesting incumbents to relinquish spectrum if they want the high demand allocation.

[ellipsis]

Updated to include comments: http://dl.dropbox.com/u/24829246/MyB...ns_290212.docx

Any final feedback would be good. Submitting at 16h00 today.

[ellipsis]

Just to keep interested parties posted: Version above was submitted yesterday.