1. COMMENTS RE TELECOMMUNICATIONS AND BROADCASTING SERVICE FEES AND APPLICATION FEES 28 AUGUST 2012

2. LICENSE Telecom in terms of Section 45 of the Act, holds a technology neutral license to render telecommuni- cations services and was issued on 18 May 2011 Telecommunications services is defined as services whose provision consists wholly or partly in the transmission or routing of information on telecommunications networks by means of telecommunication processes but does not include broadcast services

3. TYPE OF TELECOMMUNICATONS SERVICES OFFERED BY TN Telecom Namibia provides the following services in respect of its licence: 1.Postpaid Services: - Lines rental, Value added services, Calls, VSAT, Switch & Telephone installation 2.Prepaid Services: - Switch & Cards 3.Interconnection: - Local & International 4.Data & IP Services - Internet access services, ADSL, Wimax, CDMA, Metro Ethernet, IP/MPLS, Iway, ISDN & Telematics 5.Other Services:Customer premises equipment & Switchboard

4. OTHER INCOME Telecom Namibia has other sources of income and same are reflected as such in its Annual Financial Statements which includes inter alia redundant assets sales, disaster recovery, revenue generated from Directory Services.

5. Recommendation – License Fees It is recommended that the license fee should be based on income derived from telecommunications services only. As such other sources of income of the companies should be separated from the income derived from telecommunications services. The announcement of the dominant position should also be taken into consideration due to the fact that the dominant player will have conditions imposed on its license in terms of Section 78 In this respect we recommend a 1% of telecommunications related turnover of the dominant operator and 1.5% for all the other operators.

6. Recommendation – Application Fees It is our opinion that the fee for Renewal of licenses (ECNS & ECS) in the amount of N$10,000.00 is too high and we recommended that it be reduced to N$5,000.00. This is in view of the application fee which is N$10,000.00