Local Loop Unbundling: Consumers get a voice

Summary: MyBroadband and Ellipsis Regulatory Solutions submit Local Loop Unbundling (LLU) feedback to ICASA, supporting an open access approach to LLU. Full LLU in a phased approach suggested with Naked ASDSL being a priority.

The Independent Communications Authority of South Africa (ICASA) unveiled their long awaited Local Loop Unbundling (LLU) discussion document on 22 July 2011, and invited the public to participate and comment on the document.

ICASA asked the public and stakeholders for their feedback about the LLU process and the four potential Local Loop Unbundling options (full local loop unbundling; line sharing; sub-loop unbundling; and bitstream access).

LLU is a hotly debated issue with very different views on the process from the incumbent fixed line operator Telkom and its competitors such as Neotel and Internet Solutions.

Amidst all of the lobbying from companies to further their objectives when it comes to LLU it is easy for ICASA to overlook the voice of consumers. MyBroadband has partnered with telecoms regulatory experts Ellipsis Regulatory Solutions to make sure this does not happen.

Consumers were given a chance to give their views on the LLU process in the MyBroadband forums, and also vote on which form/s of LLU they would urge ICASA to implement.

Ellipsis Regulatory Solutions extracted the most reasonable views in the LLU discussions, and compiled a submission to ICASA on behalf of MyBroadband and its users.

This LLU submission was submitted to ICASA yesterday (15 September 2011), and ICASA’s Pumela Cokie from the regulator’s Markets and Competition Analysis Unit acknowledged receipt of the document.

MyBroadband has also requested a slot to make oral representations should ICASA decide to hold public hearings – a further step to ensure that the consumer’s voice is heard in the LLU process.

Some of the highlights from MyBroadband’s LLU submission:

  • MyBroadband users fully support the open-access approach to the regulation of the provision of electronic communications services
  • Competition at all layers in the network needed
  • The average consumer favours full LLU, with 90.4% of users opting for full local loop unbundling
  • A phased implementation of the unbundling options listed in the Discussion Paper would be preferred
  • Naked ADSL should be made available immediately
  • Access Line Deficit Recovery Scheme: Consumers do not want to be placed in a situation where they are penalised for Telkom’s inefficiencies, and consumers should also be informed as to how the access line deficit was accumulated
  • Open access should not be limited to the last mile held by Telkom, but should also incorporate mobile networks and all other possible access media

Important links

MyBroadband’s full LLU submission

Ellipsis Regulatory Solution

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Local Loop Unbundling: Consumers get a voice