ICT Policy Submission to ICASA - Draft for comments

ellipsis

Ellipsis Regulatory Solutions
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Hi

A draft is available from here - if you want editable format please pm

notes
- still incorporating some of the later posts
- the purpose of this exercise was to reflect your views as much as possible. we have made some small edits to remove things that will "close the ears" of the reader (e.g. changing "ICASA is pisspoor" to "ICASA is poor"). If you have a problem with any edit please pm.
- you will see that in the Annexure we have quoted what we thought were the more constructive posts received. If you are one of these please indicate whether you want to edit in any way and whether you want to (a) use your real name (b) use your nic or (c) have no name associated
 
No edit.
Real name and nick are same.
Happy to put name to it.
 
Had a quick skim through the report. Apologies if my articulation is not great. My previous posts were too short and written in a rush so I am just relaying putting points in the structure required. You don't have to use it.

Where do you think the problems are now?

1. The entry level broadband cost disparity between fixed line last mile broadband and wireless broadband offerings is not comparable to other countries and is a clear indication of the failure in deregulation and the defacto monopoly status that Telkom is afforded in the ADSL space.
An independent study Ovum in April this year showed ADSL and not cellular is the most expensive out of all broadband options in South Africa in affordability. The report also shows entry level ADSL in SA is the most expensive out of all the countries surveyed including Kenya. Source Ovum Report

2. Slower internet usage growth compared to other countries
For South Africa having the most internet users in Africa in 1994 to only having the 5th most in 2012 despite having the highest GDP and no shortage in undersea data cable connections I feel is due to the failure of telecoms deregulation. Source - Google report

3. South African Internet service providers see Telkom as the main stumbling block in getting affordable internet access seeing it is monopoly in providing fixed line ADSL access.
Source, Source

4. The Electronic Communication Act and Consumer Protection act are not being adhered to in that ADSL consumers are charged for a service they don't use i.e. voice line rental.

5. The Second National Operator not choosing to focus on competing with Telkom in the consumer broadband space and not using Telkom's last mile fixed line infrastructure which they are entitled to resulting in Telkom being the de facto monopoly.

6. Telkom not allowing open access to its exchanges i.e. The local loop is not unbundled


National Broadband Plan...

The wholesale unit of the NBN must be independent and not run by the incumbent to avoid conflict of interest and overcharging the consumer which is currently the case with Telkom's fixed line ADSL. Thus if Telkom's wholesale business isn't at the very least spun off into a separate entity then I can see no way that they can form any part of the NBN. For the NBN where it makes sense to share and use infrastructure from Telkom to save cost it should be leased from them at cost.

However if a totally separate independent entity without any participation of Telkom is created for the NBN then I have concerns of consumers in metropolitan areas being left out of the NBNs fixed line broadband access due to the timeframe, municipal hurdles and cost of setting up brand new infrastructure. A good example of this is the second national operator Neotel that targets businesses with fixed line internet access but instead uses wireless broadband offerings to consumers. This wireless only offering in high internet user densities has resulted in the SNOs consumer internet offering failing in reliability, speed and footprint resulting in them having an insignificant consumer broadband base. The NBN rollout plan must ensure the same scenario for consumers and small businesses in existing metropolitan areas is not repeated. Major South African cities must match their international counterparts in providing high speed last mile internet over fibre lines.



Possible errors
21.2. Separate Telkom into several smaller companies and give each a clear mandate.
I feel that only the wholesale business need to be separated from the commercial business to facilitate the requirement of full LLU and the open access model.
 
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@ skimread - thanks, will have a look through and incorporate once i find my brain
 
In point 21.14 you have a quote with the text "(with or without corrupt tolls)". I think the text in brackets should be removed as it is not relevant to the document and may not go down well with some readers. Possibly also change "stupidity" in the same point to "inconveniences".
 
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In point 21.14 you have a quote with the text "(with or without corrupt tolls)". I think the text in brackets should be removed as it is not relevant to the document and may not go down well with some readers.

good catch thank you
the sensitivities amongst those who read these are astounding :(
 
Change "stupidity" in the same point to "inconveniences".
 
Cool to see it all compiled like that. On page 18 it says the "last file" instead of "last mile" twice in a row.

Thanks. Those were typos in point 2 and 3.
In my quote in 23.4, change "have radio spectrum" to "have high demand radio spectrum"
 
Firstly - wow thats a serious document. Well done Dom & co.

I'd like to make one important edit to my section: replacing "interfere" with "intervene". Interfere has connotations that were not intended. Also, on pg 7 w/ my comment there is a contradiction between what I said & the summary sentence introducing it @data prices.

Forum nick or Anon is fine. Also, I hereby give dominic permission to edit as he see fit as long as the overall gist is preserved.

Also dom, please provide a timeline/deadline for this so that its clear when this will be finalized. I'd like to read through it in a bit more detail, but I'm dead tired atm so weekend would be better.

Some random stuff:

pg 8

The following suggestions were received for overcoming the obstacles identified in the previous
sector:

- Should probably read "section" not sector

pg 6
20.4. The long-standing lack of capacity at the Department of Communications

-Unclear to me. Capacity in what way? We don't want them hiring a bazillion extra staff members to improve capacity.
pg 10
Setting regulations and rules mandating infrastructure sharing to the maximum feasible
degree.

-Disagree with this point. Too much risk of cramping the style of the profit driven companies & making the end result worse. i.e. Companies having to work around extra rules. The government should rather set up a process where the companies have the *option* to coordinate using a central database service or something along those lines.
 
@ HavocXphere

unfortunately we have a deadline of 23h59 tonight ;) - bear in mind this is really a first salvo and it is our intention to have a good post-mortem on this process from a mybb perspective and how we can improve it

will process changes shortly but one of the principles we tried to follow was to accept what people had to say without being critical (as long as the comment was constructive - and there we did exercise discretion) - as a result there are conflicting views and not one mybroadband view. Given the nature of this nuthouse this is not at all surprising and I am not sure it would feasible to thrash out disagreements on which points should be included or not - so I am not going to action the disagreements you indicate above. Okay?*

working towards a general consensus on certain issues would be great - there are easy ones like naked dsl. The basic departure point needs to be communicating around an uncompromising consumer viewpoint. In this submission we thought the best way to do that would be to include those actual consumer voices.

*benign dictator voice (there is no question mark)
 
nuthouse!!!!

We're gonna get you!
gallxulo.gif
 
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