I hope this email finds you well.
Having not had the dates and venue for the cost to communicate programme and roadshow.
I was unable to voice and submit my written response to this program.
Sometimes its better late than never so I found it in my heart to send through my thoughts and hope that the powers that be will act on them.
SMS has always been a basic medium of communication for the poorest.
South African Operators MTN & Vodacom saw fit to price this basic service out of reach from many South Africans.
The cost associated with providing a successful sms with a delivery receipt is less than 5c.
Listed below is and Excerpt from a mybroadband article on cost of providing an sms.
Industry experts estimate that the true cost for an SMS to mobile operators is between 2c and 5c, raising questions as to why the retail cost is up to 80c per SMS.
There are currently discussions around the potential introduction of an SMS termination rate, raising concerns that it may increase the price of SMSs to consumers (there is currently no interconnect – termination – fee on SMS messages).
Srinivasan Keshav, a professor at the University of Waterloo in Ontario, showed through detailed analysis that the true cost of an SMS message to an operator is less than 0.3 US cents (2.6 cents).
Professor Srinivasan Keshav
Assuming that Keshav’s analysis is correct, an SMS rate of 80c per text message translates into a profit margin of around 3,000% (three thousand percent).
This highly inflated retail price for SMSs in South Africa, Streicher argues, is quite possibly the reason why the operators have dealt with this issue without involving ICASA.
Then we have to ask ourselves why did Vodacom + MTN + Cell-C overcharge customers all these years.
The answer is simple – not enough competition to drive prices down and Nobody policed their pricing.
If Vodacom or MTN declared it cost X amount then it was taken as a given neither the DOC or ICASA took the time to commission costs and pricing structures and remedies to ensure lower Tariffs.
Summation : A Termination rate of 3c per SMS be set for all Operators and a CAP price of 20c per SMS be set with immediate effect NO more than 20c per SMS can be charged in RSA excluding VAS sms.
Mobile Voice calls in South Africa were largely reserved for the rich and those that could afford it even paid the lowest Tariff.
Sounds strange but True , the facts speaks for themselves when prepaid users were paying R2-85 per minute for Voice Calls Contract users on VodaCom were paying R1-40 per minute.
Mobile & Fixed Termination rates have largely been held to the highest possible Tariff to thwart competition and protect revenue from this source.
Fixed Termination Rates as described below from Romania should be as low as 3c per minute whereas Mobile Termination Rates should be as low as 12c per minute from an Efficient Operator.
Vodacom and MTN held these rates as high as possible until recent when ICASA under pressure enforced a Glide Path and cut these rates however our Termination Rates remain one of the highest in the world.
DOC together with ICASA needs to drop these rates to what European Operators are subjected to. Mobile Operators are licenced to provide a service and derive Profits from originating calls and not derive their bulk revenue from calls being completed on the network.
Summation : Fixed Termination Rates be set at 5c per minute anytime and Mobile Termination Rates be set at 12c per minute anytime.
Romanian Regulator Looks to Cut Mobile Termination Rates
Published on: 30th Aug 2013
¬Romania's telecoms regulator is holding a public consultation on changes to the mobile and landline termination rates that should be applied by the telecoms networks.
The regulator proposes that, starting from 2014, the maximum tariff for fixed call termination drop from 0.67 to 0.15 eurocents/minute, while the maximum tariff for mobile call termination would plunge from 3.07 to 0.86 eurocents/minute.
The maximum rates will become mandatory for all the network providers in Romania, identified as having significant power in the fixed and respectively mobile markets for call termination in Romania: 51 providers of fixed networks and 6 providers of mobile networks.
ANCOM said that it based the proposed rates on the efficient costs of service provision, using working hypotheses, information sent by the network providers, as well as modelling practices used in the European Union, the models having been already publicly consulted in the fourth quarter of 2012.
"I do believe that these measures will further foster competition, thus stimulating the development of increasingly efficient networks, which are used by more and more users, for ever more volumes of diversified services", declared Catalin Marinescu, the ANCOM President.
Mobile Data is the primary source of access for ordinary Black people to the Internet. Yet Operators have chosen to charge as much as R2 a megabyte which works out to R2000 per gigabyte.
Yet those that can afford a bundle pay the lowest Rates. Bundled internet can be as low as R40 per Gigbyte of Internet Data.
This clearly shows that the poorest pay the highest Tariffs and the wealthy pay the lowest Tariff. This is a serious area of concern and needs Strong regulation.
Whilst Internet access has dropped due to many undersea cables landing in SA mobile Internet Access is still out of reach to the ordinary Black Man.
Due to poor or patchy Fixed line Internet access the Poor Black People in townships have no choice but to use mobile Internet via USB 3G dongles.
If we are to ensure every black person in rural areas get access to the internet then yes we have to ensure its affordability.
Rural people are poor and provision must be made for them to interact into the modern world.
The vast amount of information available on the internet can change peoples lives.
Telkom Mobile launched 50 Gigabytes of Data at R999 which works out to R20 per Gigabyte.
Summation : Mobile Broadband costs be capped at 20c per megabyte for adhoc access. No more than this Tariff may be charged by any Operator.
Spectrum Usage : Vodacom + MTN + Cell-c have been given too much spectrum in high demand bands.
As Mobile operators they have hogged the high demand bands 900mhz – 1800mhz – 2100mhz
Refarming needs to provide Telkom Mobile with 6mhz of 900mhz frequency to allow for a more level playing field and to drive their efficiency.
The current Operators are not utilizing their spectrum efficiently and this warrants serious attention.
Less spectrum requires more towers and more towers mean more capacity and efficient planning which in turn provides for a better service.
Most countries award around 6mhz of 900 band 12mhz of 1800 band and 10mhz in the 2100 band which is International Best practice.
When the Operators licences were renewed they was no conditions attached to it. Given the fact the networks have established themselves and are receiving net returns.
On expiry of GSM Mobile Licences companies are prepared to negotiate at any lengths to avoid losing the right to provide the service for more years to come.
We have failed to even place Obligations on the Mobile Operators of 30 Free SMS and 30 Free megabytes of data with a minimum of 30 Free Voice minutes to any network as a basic right to our citizens every month.
The DOC and ICASA have failed once again. This could have been an Obligation attached to Operators renewing of their Mobile Operating Licences.
Less than 2mhz of the 900mhz spectrum is used in rural areas to provide GSM voice.
ICASA needs to look at reuse of spectrum held by the current operators. Eg. Telkom Mobile can roll out 900mhz towers on 3G using about 6mhz of spectrum.
Summation : Spectrum is public property why should Operators use little and hoard the rest at our expense Re-use to be strictly enforced. ICASA issue a public comment document on this matter immediately.
LTE – LTE is around the corner and it’s the new way of Technology but if the current Operators get their hands on this spectrum we will never see the benefits of this revolution of SPEED on wireless.
The wholesale model needs to be considered here and 3 Operators per province needs to be active with the duplication of Fibre ducts and cables to be avoided at all costs.
We have 9 provinces
Each Operator needs to Build networks in 3 provinces ONLY and that will be their service area and they can wholesale their services to any Operator who wishes to use the network to provide services.
Example.
Gauteng-Limpopo-North West
Kwa-Zulu Natal - Free-State-Mpumalanga
West-Cape – Eastern Cape – Northern Cape
9 Wholesale model licences to be issued.
If ICASA chooses to issue an ITA.
West-Cape – Eastern Cape – Northern Cape – Vodacom
West-Cape – Eastern Cape – Northern Cape - Airtel
West-Cape – Eastern Cape – Northern Cape - Econet
Kwa-Zulu Natal - Free-State-Mpumalanga - MTN
Kwa-Zulu Natal - Free-State-Mpumalanga - Neotel
Kwa-Zulu Natal - Free-State-Mpumalanga - Orange
Gauteng-Limpopo-North West – Cell - C
Gauteng-Limpopo-North West - Telkom Mobile
Gauteng-Limpopo-North West - Internet Solutions
Nine Wholesale Model Licences have been created by doing this.
Smaller area for rollout of services and concentrated for an effective fibre network to be built or existing fibre to be used.
Quicker time to market.
Jobs created from this model would be unimaginable. As every company will seek to be operational soonest.
9mhz of 800mhz spectrum with 30mhz of 2600mhz spectrum to be issued.
Competition will be on price and service and Customer will have choice between all operators.
Wholesale Tariffs to be approved by ICASA in consultation with all Operators.
Infrastructure growth and Investment will be phenomenal for our country.
NO LOCKING OF DEVICES TO BE ALLOWED EITHER BY SOFTWARE OR HARD CODED - INTEROPERABILITY TO BE ENCOURAGED.
Having not had the dates and venue for the cost to communicate programme and roadshow.
I was unable to voice and submit my written response to this program.
Sometimes its better late than never so I found it in my heart to send through my thoughts and hope that the powers that be will act on them.
SMS has always been a basic medium of communication for the poorest.
South African Operators MTN & Vodacom saw fit to price this basic service out of reach from many South Africans.
The cost associated with providing a successful sms with a delivery receipt is less than 5c.
Listed below is and Excerpt from a mybroadband article on cost of providing an sms.
Industry experts estimate that the true cost for an SMS to mobile operators is between 2c and 5c, raising questions as to why the retail cost is up to 80c per SMS.
There are currently discussions around the potential introduction of an SMS termination rate, raising concerns that it may increase the price of SMSs to consumers (there is currently no interconnect – termination – fee on SMS messages).
Srinivasan Keshav, a professor at the University of Waterloo in Ontario, showed through detailed analysis that the true cost of an SMS message to an operator is less than 0.3 US cents (2.6 cents).
Professor Srinivasan Keshav
Assuming that Keshav’s analysis is correct, an SMS rate of 80c per text message translates into a profit margin of around 3,000% (three thousand percent).
This highly inflated retail price for SMSs in South Africa, Streicher argues, is quite possibly the reason why the operators have dealt with this issue without involving ICASA.
Then we have to ask ourselves why did Vodacom + MTN + Cell-C overcharge customers all these years.
The answer is simple – not enough competition to drive prices down and Nobody policed their pricing.
If Vodacom or MTN declared it cost X amount then it was taken as a given neither the DOC or ICASA took the time to commission costs and pricing structures and remedies to ensure lower Tariffs.
Summation : A Termination rate of 3c per SMS be set for all Operators and a CAP price of 20c per SMS be set with immediate effect NO more than 20c per SMS can be charged in RSA excluding VAS sms.
Mobile Voice calls in South Africa were largely reserved for the rich and those that could afford it even paid the lowest Tariff.
Sounds strange but True , the facts speaks for themselves when prepaid users were paying R2-85 per minute for Voice Calls Contract users on VodaCom were paying R1-40 per minute.
Mobile & Fixed Termination rates have largely been held to the highest possible Tariff to thwart competition and protect revenue from this source.
Fixed Termination Rates as described below from Romania should be as low as 3c per minute whereas Mobile Termination Rates should be as low as 12c per minute from an Efficient Operator.
Vodacom and MTN held these rates as high as possible until recent when ICASA under pressure enforced a Glide Path and cut these rates however our Termination Rates remain one of the highest in the world.
DOC together with ICASA needs to drop these rates to what European Operators are subjected to. Mobile Operators are licenced to provide a service and derive Profits from originating calls and not derive their bulk revenue from calls being completed on the network.
Summation : Fixed Termination Rates be set at 5c per minute anytime and Mobile Termination Rates be set at 12c per minute anytime.
Romanian Regulator Looks to Cut Mobile Termination Rates
Published on: 30th Aug 2013
¬Romania's telecoms regulator is holding a public consultation on changes to the mobile and landline termination rates that should be applied by the telecoms networks.
The regulator proposes that, starting from 2014, the maximum tariff for fixed call termination drop from 0.67 to 0.15 eurocents/minute, while the maximum tariff for mobile call termination would plunge from 3.07 to 0.86 eurocents/minute.
The maximum rates will become mandatory for all the network providers in Romania, identified as having significant power in the fixed and respectively mobile markets for call termination in Romania: 51 providers of fixed networks and 6 providers of mobile networks.
ANCOM said that it based the proposed rates on the efficient costs of service provision, using working hypotheses, information sent by the network providers, as well as modelling practices used in the European Union, the models having been already publicly consulted in the fourth quarter of 2012.
"I do believe that these measures will further foster competition, thus stimulating the development of increasingly efficient networks, which are used by more and more users, for ever more volumes of diversified services", declared Catalin Marinescu, the ANCOM President.
Mobile Data is the primary source of access for ordinary Black people to the Internet. Yet Operators have chosen to charge as much as R2 a megabyte which works out to R2000 per gigabyte.
Yet those that can afford a bundle pay the lowest Rates. Bundled internet can be as low as R40 per Gigbyte of Internet Data.
This clearly shows that the poorest pay the highest Tariffs and the wealthy pay the lowest Tariff. This is a serious area of concern and needs Strong regulation.
Whilst Internet access has dropped due to many undersea cables landing in SA mobile Internet Access is still out of reach to the ordinary Black Man.
Due to poor or patchy Fixed line Internet access the Poor Black People in townships have no choice but to use mobile Internet via USB 3G dongles.
If we are to ensure every black person in rural areas get access to the internet then yes we have to ensure its affordability.
Rural people are poor and provision must be made for them to interact into the modern world.
The vast amount of information available on the internet can change peoples lives.
Telkom Mobile launched 50 Gigabytes of Data at R999 which works out to R20 per Gigabyte.
Summation : Mobile Broadband costs be capped at 20c per megabyte for adhoc access. No more than this Tariff may be charged by any Operator.
Spectrum Usage : Vodacom + MTN + Cell-c have been given too much spectrum in high demand bands.
As Mobile operators they have hogged the high demand bands 900mhz – 1800mhz – 2100mhz
Refarming needs to provide Telkom Mobile with 6mhz of 900mhz frequency to allow for a more level playing field and to drive their efficiency.
The current Operators are not utilizing their spectrum efficiently and this warrants serious attention.
Less spectrum requires more towers and more towers mean more capacity and efficient planning which in turn provides for a better service.
Most countries award around 6mhz of 900 band 12mhz of 1800 band and 10mhz in the 2100 band which is International Best practice.
When the Operators licences were renewed they was no conditions attached to it. Given the fact the networks have established themselves and are receiving net returns.
On expiry of GSM Mobile Licences companies are prepared to negotiate at any lengths to avoid losing the right to provide the service for more years to come.
We have failed to even place Obligations on the Mobile Operators of 30 Free SMS and 30 Free megabytes of data with a minimum of 30 Free Voice minutes to any network as a basic right to our citizens every month.
The DOC and ICASA have failed once again. This could have been an Obligation attached to Operators renewing of their Mobile Operating Licences.
Less than 2mhz of the 900mhz spectrum is used in rural areas to provide GSM voice.
ICASA needs to look at reuse of spectrum held by the current operators. Eg. Telkom Mobile can roll out 900mhz towers on 3G using about 6mhz of spectrum.
Summation : Spectrum is public property why should Operators use little and hoard the rest at our expense Re-use to be strictly enforced. ICASA issue a public comment document on this matter immediately.
LTE – LTE is around the corner and it’s the new way of Technology but if the current Operators get their hands on this spectrum we will never see the benefits of this revolution of SPEED on wireless.
The wholesale model needs to be considered here and 3 Operators per province needs to be active with the duplication of Fibre ducts and cables to be avoided at all costs.
We have 9 provinces
Each Operator needs to Build networks in 3 provinces ONLY and that will be their service area and they can wholesale their services to any Operator who wishes to use the network to provide services.
Example.
Gauteng-Limpopo-North West
Kwa-Zulu Natal - Free-State-Mpumalanga
West-Cape – Eastern Cape – Northern Cape
9 Wholesale model licences to be issued.
If ICASA chooses to issue an ITA.
West-Cape – Eastern Cape – Northern Cape – Vodacom
West-Cape – Eastern Cape – Northern Cape - Airtel
West-Cape – Eastern Cape – Northern Cape - Econet
Kwa-Zulu Natal - Free-State-Mpumalanga - MTN
Kwa-Zulu Natal - Free-State-Mpumalanga - Neotel
Kwa-Zulu Natal - Free-State-Mpumalanga - Orange
Gauteng-Limpopo-North West – Cell - C
Gauteng-Limpopo-North West - Telkom Mobile
Gauteng-Limpopo-North West - Internet Solutions
Nine Wholesale Model Licences have been created by doing this.
Smaller area for rollout of services and concentrated for an effective fibre network to be built or existing fibre to be used.
Quicker time to market.
Jobs created from this model would be unimaginable. As every company will seek to be operational soonest.
9mhz of 800mhz spectrum with 30mhz of 2600mhz spectrum to be issued.
Competition will be on price and service and Customer will have choice between all operators.
Wholesale Tariffs to be approved by ICASA in consultation with all Operators.
Infrastructure growth and Investment will be phenomenal for our country.
NO LOCKING OF DEVICES TO BE ALLOWED EITHER BY SOFTWARE OR HARD CODED - INTEROPERABILITY TO BE ENCOURAGED.