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

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

3. 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”

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. SECTION 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

12. 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

13. Thank You