elvis_presley

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Moving back to the LOCAL LOOP question...

Have ICASA defined what they view as the wireless loop loop, taking into consideration that there is no fixed point of connect on the customer's side?

Yes, they did... from the article:

“Local Loop” means all physical media, including electrical, optical and radio frequency, used as the electronic communications facilities for the connection of an end-user or end-site to an access network aggregation point on the electronic communications network.

"Local" is being used in context of "Local to the user", not "Local to a fixed location".
 
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Paul Hjul

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This is the major problem we are having with SMP operators - MTN - VodaCom - Telkom
Current legislation states you have to interconnect at their nearest point of Connection / Switch.
Since MTN is not making the request and you are - you need to meet them at their Interconnection Point.

You will only be able to terminate calls on the MTN network if you do this.
How are your customers going to call other Networks ?
I am not seeing your problem - well that is a little facetious for me to say but you should be able to infer what I mean - they aren't connecting to you so you have to connect on their network where it exists and through the interconnect mechanisms they provide. They can't dictate which connection point you are using but rather that you have to meet them at an existing one. To get there you either need to provision your own infrastructure or use somebody else's infrastructure (cue facilities leasing) or a wholesale service for transit. Enforce the non-discriminatory pricing rules (including the charging your own retail arms the pricing) and the facilities leasing regulations and things play out.
 

DXL

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Yes, they did... from the article:



"Local" is being used in context of "Local to the user", not "Local to a fixed location".

I honestly did not pick this up really. Well spotted. MTN & Vodacom hope you read this.
 

Paul Hjul

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Yes, they did... from the article:



"Local" is being used in context of "Local to the user", not "Local to a fixed location".
the definition is so vague for a wireless loop that it is meaningless because the "wireless local loop" is manifestly a service not physical media
 

DXL

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the definition is so vague for a wireless loop that it is meaningless because the "wireless local loop" is manifestly a service not physical media

I have heard that Cell-C has a product in play for anyone to operate over their network as a MVNO.
However its a Cell-C product not yours :(
So technically they not opening their network to you the requester.
 

elvis_presley

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the definition is so vague for a wireless loop that it is meaningless because the "wireless local loop" is manifestly a service not physical media

Well you can nitpick over the language, but they explicitly and quite plainly included radio frequencies in that definition, so their intention is clear - this is the kind of thing they'll clean up as all this is still in the draft stages. If you read the rest of the document, linked below, and search for "wireless" - you'll see this most certainly is their intention, eg:

In terms of access to any form of local loop (fixed line copper, fixed line fibre and/or wireless access),

https://docs.google.com/viewer?url=...e-On-Draft-LLU-Regulations.pdf&hl&chrome=true
 

Paul Hjul

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its not nitpicking over language it is requiring that a regulator know what it is talking about before producing vague, disruptive, and selectively enforcable regulations.

As JvZ has essentially pointed out the idea of a wireless local loop is problematic for the cellular infrastructure - I content that a wireless local loop does exist in the GPRS design platform (access point names allow you to provide access to a local loop service) the definition given here as McD essentially points out the spectrum inclusion is idiotic.
 

elvis_presley

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its not nitpicking over language it is requiring that a regulator know what it is talking about before producing vague, disruptive, and selectively enforcable regulations.

I suggest you read the rest of the document - it's quite well written and does answer a lot of your questions.


- I content that a wireless local loop does exist in the GPRS design platform (access point names allow you to provide access to a local loop service) the definition given here as McD essentially points out the spectrum inclusion is idiotic.

Again, the article has the answer to this... Bitstream Access (basically APNs, like you say) - where "Bitstream Access" is "Logical Circuits" - ie. the operators don't have to literally share out their spectrum (Layer 1), but Layer 3 ( http://en.wikipedia.org/wiki/OSI_model#Layer_3:_network_layer ).

From the document:

It is hoped that this clearly differentiates between what is meant by the term "Bitstream" and the IP Connect product currently provided by Telkom SA SOC Limited to certain other licensees with respect to ADSL access. Further, it is hoped that this definition is sufficiently broad to cover the mobile / GSM / cellular / fixed wireless equivalent services, some of which are currently provided by some licensees.


Whoever wrote that document has exactly the same concerns as you and me, and is on top of it. Nice to see there's someone competent working on this on ICASA's side!
 

Paul Hjul

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I've read the whole document - TWICE

it isn't that the document is badly written that is a problem it is that ICASA is setting itself to bite into something where the legal mandate is exceeded and the MNOs will eat it for breakfast. The document is incredibly well written bull**** but it is still bull**** (in the Frankfurt sense of the work - one of my great scholarly goals in life is to publish a treatise on bull**** in a legal publication)
 

Paul Hjul

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BTW the OSI model really really has limited practical application especially in an NGN Internet orientated world. The OSI model goes back to an old circuit approach to telecommunications
 

elvis_presley

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BTW the OSI model really really has limited practical application especially in an NGN Internet orientated world. The OSI model goes back to an old circuit approach to telecommunications

Well it's quite pertinent here - the difference between physical and logical circuits is 100% relevant.
 

elvis_presley

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the MNOs will eat it for breakfast.

I don't see why they would? As of today, they all comply! I can go to any one of the MNOs and get an APN and sell access on it. As JvZ quite rightly said: "LLU has been available as a model in SA for years. It's called MVNO" - personally I think this broader reach of the LLU is to close potential loopholes for Telkom, in case they start doing something stupid like connecting customers via wireless from the street pole to the home or something, to keep their dirty paws on their precious local loop. I wouldn't put it past them.
 

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Why do you say that? They already comply. It won't affect them in the slightest.
Then why did all the MNOs oppose it so vehemently at the LLU hearings? You are looking at a MNVO model.

Remember that they can refuse access to their networks at this stage and are not willing to share facilities at ALL their sites.

This is what will change.
 

Paul Hjul

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but they have to share facilities at all their sites - they simply don't and they need to be fined 500k each time they refuse. The MVNO model is not really an LLU thing at all - neither is it really an LLU service nor is it an LLU of any wireless based circuit. However MNOs being held to facilities leasing isn't something LLU regulations will help with - enforcing facilities leasing would do that.

I really am repeating the same tune here but writing bad regulations rather than enforcing existing principles is a sure fire way to stall things. Tell Telkom that come 1st March 2014 and they will be held to 500k fines for facility leasing violations and that MWEB and Neotel are ready to request the most lucrative loops - even at R 600 a month leasing - and the game changes.

* specifically look at the idea of Telkom setting a price of R600 for a line access from exchange to customer premises in the cherry picking exchanges. They now need to render that as the price to their own retail operations as well and so the voice arm runs a massive loss having to "pay" (really just an accounting record) wholesale for all lines at that pricing and suddenly you have proof of actionable uncompetitive behaviour. I suspect Telkom will actually come in at a R400 line access pricing approach as a wholesale cost and that the voice revenue model could support this and that in reality in the long run the actual rental costing for last mile copper is R250 VAT incl. If Telkom spins their copper into an SPV this particular issue is also sorted out properly.
 

elvis_presley

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Then why did all the MNOs oppose it so vehemently at the LLU hearings? You are looking at a MNVO model.

I don't remember specifically what they objected to - got more info? If it were tower sharing, that's a very different issue, and I don't think they should be required to do that.

Remember that they can refuse access to their networks at this stage and are not willing to share facilities at ALL their sites.


Not quite sure what you mean about "ALL their sites"? - I'm on Afrihost for my Internet access on my phone (via MTN) - and it's active at every MTN site? If you mean ISPs seeking APNs, these guys won't refuse anyone that's knocking at their door with a big pile of money.


Edit: there is the possibility that the regulations will establish a baseline price for the MNOs to carry 3rd party traffic on their networks, in which case you're right - they will moan - but let them - they've been overcharging way too long.
 
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elvis_presley

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I really am repeating the same tune here but writing bad regulations rather than enforcing existing principles is a sure fire way to stall things.

Not sure why you have so much hate for this document - it's agreeing with you all over the place. It's an explanatory note calling BS on all Telkom's stupid and flawed arguments, and seeking to clarify points to create better regulations; it's hacking Telkom's potential arguments off at the knees so when they do drag ICASA to court on 1st March, they don't have to drag things out, they can, as you rightly point out, start that R500k/facility fine ASAP.

I like stuff like this, just telling Telkom they've dug themselves into a hole cos they're crap:

This reduction is linked not only to the introduction of alternatives for access to communications but also the cost base and quality of retail service provision by Telkom,

I think it's awesome. We're busy watching ICASA growing a backbone.
 

Paul Hjul

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I have no hate for the document, what I loathe is creating room for the regulator to shoot itself in the ass which is what ICASA is doing. Growing a backbone would be to say - fine Telkom there is an opportunity for you to play ball and use our good offices to get an LLU strategy going or you can face the runner which the FLR will lead to if we start fining you. The people at Telkom who understand this **** understand the hole that exists, what ICASA needs to do is show them that the fire hose is on its way and that there is a rope they can use to come out.

Also the process itself is Telkom's case in court not Telkom's argument
 

Paul Hjul

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I don't remember specifically what they objected to - got more info? If it were tower sharing, that's a very different issue, and I don't think they should be required to do that.




Not quite sure what you mean about "ALL their sites"? - I'm on Afrihost for my Internet access on my phone (via MTN) - and it's active at every MTN site? If you mean ISPs seeking APNs, these guys won't refuse anyone that's knocking at their door with a big pile of money.


Edit: there is the possibility that the regulations will establish a baseline price for the MNOs to carry 3rd party traffic on their networks, in which case you're right - they will moan - but let them - they've been overcharging way too long.
you are misunderstanding the essence of facilities leasing - and in the process the entirety of the problem which ICASA is failing to do its job on: Physical infrastructure - not the network itself so on your OSI model Layer 1 stuff and a the supporting bits like wayleaves - must be available for leasing on a non-discriminatory basis by ECNS licence holders if the facility meets certain criteria - the big things being difficult to replicate cost effectively and the player having a strong position in the market. The physical copper in the local loop definitely falls into the line of mandatory facilities leasing, however the DSLAMs don't - so ISPs would have to use other facilities at the exchange (and rent them from Telkom) and get their own backhaul network up to make LLU work for them and only on a full loop basis, but so is the towers (sites) that the MNOs operate. Vodacom and MTN have traditionally set up towers and do a bit of tower sharing but under facilities leasing Vodacom and MTN are able to impose facilities leasing on Telkom and equally Telkom can impose facilities leasing on Vodacom and MTN and CellC. MickeyD and JvZ will have to give the details but there is clearly some breakdowns of this principle -> no doubt there are issues about interference and covering the costs of an EPA and all sorts of hitches - VC not wanting men in ugly yellow clothes wondering about their sites and MTN fearing CellC technicians from China. I am pretty sure that Telkom Mobile is the biggest player to benefit from a broader practice of facilities sharing.
 
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