MTN SUBMISSION ON THE TELECOMMUNICATIONS AMENDMENT BILL Submission to PPCC 28 September 2001 Presented by: Sifiso Dabengwa

AGENDA FIXED MOBILE SECTION 37(1) AND 37(3) FREQUENCY SPECTRUM INTERCONNECT E RATE NUMBER PORTABILITY

FIXED MOBILE The term “fixed mobile” creates ambiguity Could be construed as encroaching on mobile operators rights Telkom (and SNO) able to offer fixed wireless services by virtue of licence conditions Thus “fixed wireless” for local access only MTN proposes the term “fixed-wireless”

Where to implement fixed wireless? FIXED MOBILE (cont) Where to implement fixed wireless? In areas approved by ICASA ICASA to prescribe economic and technical criteria to ensure geographic limitation

SECTION 37 MTN Deemed Licence MTN is deemed to be a Mobile Cellular Licensee in terms of section 37(1) The process to be followed as contained in the proviso is very near completion and needs to be finalised Deleting the proviso will create uncertainty MTN recommends that: The proviso should not be deleted until the MTN and Vodacom licences have finally been re-issued

SECTION 37 (cont) SECTION 37(3) MTN currently provides national calls, international calls as well as other value added services in terms of its licence Section 37(3) makes this current position very clear This section should be retained and not deleted

SECTION 37 (cont) SECTION 37(2)(d) MTN submits that this section should be retained so that mobile cellular licensees would be able to self provide links at a time to be set by the Minister

1800 MHz MTN welcomes the proposed assignment of 1800 MHz frequency spectrum Application process must be consistent Spectrum pricing Should promote efficient use of spectrum Use the existing pricing regulations, or Set fees at level that will minimise impact on consumer MTN submits that no deemed licences relating to frequency spectrum should be granted to Telkom and SNO

SECTION 40A Under-serviced area licensees These licensees are to provide all telecommunication services, including VoIP This is a measure to address rural access issue Ensure that PSTS operators do not negatively impact on these licensees

INTERCONNECT Section 43(4)(b) Propose that the interconnect process remains as is stated in the current subsection 4(b) ICASA tasked with issue of interconnection Propose that no additional role players be added

SECTION 45 - E-RATE 50% discount be applicable to all calls to an Internet service provider MTN recommends that: Interconnection fees between operators for conveying or completing such a call to an ISP, also be subject to a 50% discount

SECTION 89 - NUMBER PORTABILITY There are different methods available to provide number portability Instead of prescribing a method in the Act it is proposed that ICASA determine the appropriate method in consultation with the operators This will ensure that: A method is chosen that is best suited to SA Cost effective implementation that will not adversely impact on customers Implementation plan by ICASA in consultation with industry

Thank You