What is the benefit of LLU in a country with, maybe, 15% fixed line penetration and just one operator who has the core infrastructure (exchanges, DSLAMs etc) to support the utilization of the local loop for voice and broadband??? Surely Neotel/MTN / VC/ ECN etc. will not invest in exchange port infrastructure and DSLAMs...the cost thereof will be sky high (Capex and Opex wise, plus they will have to lease space in Telkom Exchanges to put the equipment down), and competing for....a dying market of fixed line services??? If they propose LLU on wireless, for that there is Local Roaming agreements (MVNO type agreeemnts like Cell-C has with Vodacom, Virgin - Red Bull- and Hello Mobile on Cell-C and 8ta has with MTN), so no restrictions there...pay the radio access usage rates of xc a minute or MB from the MNO, and bob's your uncle...up and running MVNO in a short space of time.
The benefit of LLU is about as diluted as Carrier Pre-Selection being launched after Number Portability (WTF???)....way way way backward thinking ICASA...but good luck non the less...