interconnection in sadc- something old, some new ... · pdf fileinterconnection in sadc-...

Interconnection in SADC- something old, some new, something borrowed, something ‘blue’...

Dr Alison Gillwald, Executive Director, RIAAdjunct Professor, Graduate School of Business, University of Cape Town, Management of Infrastructures.

1

Up to a two line subtitle, generally used to describe the takeaway for the slide

Conceptual framework for Sector

2

Up to a two line subtitle, generally used to describe the takeaway for the slideTermination Rates: MonopolyTermination Rates

3

•Monopolies require price regulation •Termination rates at cost of efficient operator

Termination Rate

- Incentives to invest in new technologies to reduce costs and expand product offerings

- Promotes competition - Promotes economic efficiency- Promote universal service by encouraging rapid uptake through

low retail prices

‣ MTR = Wholesale revenue and Wholesale cost

4

New Entrant

IncumbentMobile

Operator

Benefit of size:Off-net Price > On-net price = expensive to be called for people of smaller network (Initially, mostly on-net calls, after switching mostly off-net calls)

New entrant needs to compete with its off-net prices with the on-net prices of incumbent to gain market share

5

They use termination revenue to subsidise access and usage (Two sided market or waterbed effect argument)

Dominant Operators will argue

‣ If MTRs are lowered:- Retail prices will increase- There will be less subscribers- Operators will invest less

‣ However, the opposite is the case- Increased competition leads to lower retail prices and more

subscribers- Operators have to invest more to stay competitive

6

Two-sided market argument

‣ Interdependent prices: Price are being determined interdependently, ie changing the price for the one side will change the price of the other side

‣ No cost causation: No direct link between incremental cost for a good or service and the price

7

Readers Newspaper Advertisers

Two-sided Market

‣ Interdependent prices: Price are being determined interdependently, ie changing the price for the one side will change the price of the other side.

‣ No Cost causation: No direct link between incremental cost for a good or service and the price.

8

Relationship between wholesale price and

‣ Prices are not interdependent- No unidirectional relationship between

termination rates and retail prices exists

- Reduction in MTR affects net-payer and net-receivers differently

‣ Cost causation is clear for off-net

9

Argument 1Wholesale Price: contractually fixedRetail Prices: Many prices varying product by product and change frequently

MTROn-NetPeak

On-Net Off Peak

On-Net Off Off Peak

OFF-Net Peak

OFF-Net Off Peak

OFF-Net Off Off Peak

Fixed Peak

Fixed Off Peak

Fixed Off Off PeakOn-Net SMS

OFF-Net SMS

Product 2

Product 1

Product 3....

10

Termination rates are mostly symmetrical ... contradicts the two-sided market argument

Argument 2

‣ If asymmetry then smaller has higher MTR

‣ MTR cannot be increased because of higher market share (newspaper example)

Operator 1

Operator 2

11

Argument 3MTRs are wholesale costs and wholesale revenue at the same ‣ Reductions in termination revenues at

same time as reductions in termination expenditure

‣ Who benefits from termination rate reductions depends on many factors

- Generally net-payer pay less and net-receiver receive less

- However, net-receivers may also receive

12

Operators have a choice to pass on MTR reductions - nothing automatic.

Argument 4

13

MTR reductions can be passed on to subscribers = lower off-net pricesShould it not be passed on, then the operator makes more money for each outgoing minute Concrete choices an operator to maximise profitsNo automatic response in retail prices to changes in termination rateRetail prices are complex and diverse and pricing strategies are driven by user profiles and market niches, not by revenue replacement

Price interdependence has to work both ways

Argument 5

‣ If termination rates and retail rates were interdependent, then one would also be able to observe increases in termination rates while retail prices decrease

‣ Interdependence of prices has to work in both directions

‣ If lower termination rates lead to higher retail prices, why has no one suggested increasing the arbitrarily set terminations rates.

14

Predicted outcome of a ‘two-sided’ market

Waterbed Effect Argument

‣ The ‘waterbed effect’ describes a situation where if mobile termination rates go down, some other prices need to go up, usually retail prices

‣ Assumes that all operators react the same way (even net interconnection payers)

‣ Assumes operators base their decisions on revenue replacement rather than profit maximisation

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sMobile Termination Rates 2009 in US cents

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Mobile Termination Rates 2009 in US cents

17

Comparison of mobile termination rates in US cents (FX=average 2012)

18

Kenya

Ghana

Namibia

Zambia

Nigeria

Botswana

Uganda

Rwanda

South Africa

Tanzania 7,2

6,6

5,5

5,4

5,3

5,2

5,0

3,7

2,6

1,2

Source: Research ICT Africa, 2012

Interconnection Cases Namibia, Kenya, South Africa

19

Case Study Kenya

MTR US cents

Mar 2007 Mar 2008 Mar 2009 July 2010 July 2011 July 2012 July 2013 July 2014

1,131,321,642,542,54

5,056,01

7,14

Monthly cost of OECD Low User basket in US cents, based average exchange rate for 2011 based on OECD 2006 Definition

Jan-10 Sep-10 Jan-11 Sep-11 Oct-11 Sep-12

2,12,12,12,12,1 1,81,81,81,81,8

3,9

2,02,02,02,02,0

5,8

2,52,72,32,3

6,3

7,3

!"#"$% &%$'() *$"+,( -.

Safaricom increased prices and then dropped them again

Safaricom’s voice traffic in billion minutes

Jul-Sep 2010 Oct-Dec 2010 Jan-Mar 2011 Apr-June 2011 Jul-Sep 2011 Oct-Dec 2011 Jan-Mar 2012

5,265,22

6,27

5,415,254,92

6,01

Safaricom’s traffic and subscriber market shares

Jul-Sep 2010 Oct-Dec 2010 Jan-Mar 2011 Apr-June 2011 Jul-Sep 2011 Oct-Dec 2011 Jan-Mar 2012

65%67%68%69%68%70%76% 77%78%

88%86%86%86%94%

Safaricom share of traffic Safaricom share of subscribers

Safaricom’s key performance indicators for financial years ending in March Safaricom’s key performance indicators for financial years ending in March Safaricom’s key performance indicators for financial years ending in March Safaricom’s key performance indicators for financial years ending in March Safaricom’s key performance indicators for financial years ending in March Safaricom’s key performance indicators for financial years ending in March Safaricom’s key performance indicators for financial years ending in March Safaricom’s key performance indicators for financial years ending in March 2007 2008 2009 2010 2011 2012

RevenueKsh billion 47 61 70 84 95 107

RevenueUSD million 542 701 805 959 1 083 1 222

After-tax profitKsh billion 12 14 11 15 13 13

After-tax profitUSD million 137 158 120 173 150 144

Dividend paidKsh billion 3 2 4 8 8 8,8

Dividend paidUSD million 34 23 46 91 91 101

Subscribers in millionSubscribers in million 6,10 10,23 13,36 15,79 17,18 19,1EBITDA MarginEBITDA Margin 51,7% 45,9% 39,6% 43,6% 37,7% 35%Base stationsBase stations 1558 1899 2162 2501 2690

Voice Average Revenue per User (ARPU)

Ksh 356 294 303Voice Average Revenue per User (ARPU) USD 4,07 3,36 3,46Average minutes of use (MoU)Average minutes of use (MoU) 60,6 96 116

Average implied price per minute (ARPU /Average MoU)

Ksh 5,87 3,06 2,61Average implied price per minute (ARPU /Average MoU) US cents 6,71 3,50 2,98

Source: Safaricom annual reportsAverage exchange rate for 2011 used for conversionSource: Safaricom annual reportsAverage exchange rate for 2011 used for conversionSource: Safaricom annual reportsAverage exchange rate for 2011 used for conversionSource: Safaricom annual reportsAverage exchange rate for 2011 used for conversionSource: Safaricom annual reportsAverage exchange rate for 2011 used for conversionSource: Safaricom annual reportsAverage exchange rate for 2011 used for conversionSource: Safaricom annual reportsAverage exchange rate for 2011 used for conversionSource: Safaricom annual reportsAverage exchange rate for 2011 used for conversion

Impact of Termination rate reduction in Kenya

The reaction to the termination rate reduction was immediate, leaving no doubt about the causal relationshipRetail prices dropped by 60%, immediately the day after reduction was announced - Clearly no waterbed effect9.5% more subscribers in last quarter or 2010 quarterSafaricom is a good example of what happens if a dominant operator does not respond to competitive pressure or tries to increase price after cutting themIn both instance Safaricom lost market share and traffic to other operators

Example of international benchmarking and consensus.

Namibia:Interconnection

‣ Consultative workshop on interconnection models ... agreement that benchmarking

‣ Policies, act (not in place till today) and licence required cost based termination rates

‣ The final study benchmarked international best practice, termination rate trends and termination cost to derive at an interconnection model

‣ Various interconnection models were discussed with in an iterative process

‣ The final consensus solution was only reached after the completion of the study

27

Benchmarking‣ Process of establishing interconnection rates based on cost

of termination in other jurisdictions‣ Undertaking full forward-looking cost modelling is

challenging, expensive, time-consuming, and often required information is not available

‣ Cost benchmarks may need to be adjusted for population density, local area size, extent of urbanisation, traffic patterns and call durations, input prices, scale economies, exchange rates, taxes etc

‣ Whatever country or operator seems similar enough, there are always enough factors which are different to expose the

28

Conditions for the selection

‣ The billing system needed to be based on Calling Party’s Network Pays (CPNP)

‣ Countries had already or were in the process of implementing cost based termination rates

‣ A pragmatic criteria was the availability of data‣ EU and selected African Countries

29

Reducing MTR to cost of efficient operator (1-2 Euro cents), EU Recommendation from 7 May 2009Symmetric termination ratesGlide path to allow operators to adjust their business models

Step 1: Benchmarking Regulatory best practice

Termination Rate Trends in Euro cents

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-./012# 345657# 897:;76# <12=09;# 80;7>5# ?@# A769;#

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Ofcom’s Proposed MTRs (April 2010 UK pence)

2010/11 2011/12 2012/13 2013/14 2014/15

0,50,9

1,5

2,5

4,6

0,50,9

1,5

2,5

4,3

Vodafone/ O2/ Orange/ T-Mobile, H3G H3G

CPNP Countries that had cost data availableAdjusting cost benchmarks to Namibia was not possible, incumbent prefered not to provide cost dataCommon sense check based on annual reports and traffic volume

Step 2: Benchmarking Cost of Termination

Mobile termination costs Namibia (N$/ZAR): MTC being the most efficient operator

Current MTR

MTC total expenditure per minute

MTC opex per minute

MTC direct cost and depreciation per minute

MTC direct cost per minute

MTC 50% of dircet cost and depriciation per minute 0,24

0,34

0,48

0,97

1,02

1,06

Mobile termination cost per minute in N$/ZAR 2009: target rate 0.30 (including 25% mark-up)

Tanzania LRIC + mark up

Australian Efficient Operator (44% market share)

Swedish Efficient Operator

French Efficient Operator (upper level)

MTC’s estimated cost of termination

Austrian Efficient Operator

Telecom Namibia’s estimated cost of termination

French Efficient Operator (lower level) 0,12

0,14

0,23

0,24

0,24

0,26

0,35

0,59

Step 3: Namibian Benchmark Model

Termination rates = cost of an efficient operatorTechnologically and service neutral (in line with Namibia’s ICT policies and the Act)Facilitate emergence of IP-based NGNsRecommendation should be implemented in terms of the current licence conditions and act

Leo Telecom Namibia MTC

Model 1: Immediate N$0.30

Model 2: Symmetric glide path to N$0.30 that started 1 July 2006Model 3: Symmetric glide path to N$0.30 starting 1 July 2009

Model 4: Asymmetric glide path to N$0.30 starting 1 July 2009

MTC model: reduction to N$0.60 until 2011

2nd choice: if accompanied by other

regulatory interventions

2nd choice: Removing distortionary factors immediatelybut request higher transit charge for outgoing international calls

No comment

2nd choice: if accompanied by other

regulatory interventions

1st choice: Compensates for market distortions of past

years

No comment

Rejected: sees no reason to wait to remove market

distorting factors

Rejected: only gradually removes market distortions and

disadvantage TN and consumers unjustifiably for two years longer

No comment

1st choice: because of current traffic

imbalance

Rejected: only gradually removes market distortions and

disadvantage TN and consumers unjustifiably for two years longer

No comment

Rejected: same as for Model 3

Rejected: same as for Model 3 Otherwise: Drop in EBITDA margin to 37% because

of having to compete on a

level playing field

After several consultations with all operators: Industry consensus

Immediate drop of termination rates to N$0.60 to catch up with the region and international developmentsGlide path to the estimated cost of an efficient operator + 25% mark-up, ie NS0.30Immediate fixed-mobile convergence of termination ratesIt gives time to MTC and Leo to conduct LRIC studies and contest the results

Mobile and Fixed Termination rates in Namibia

Jan 2009 July 2009 Jan 2010 July 2010 Jan 2011

4,165,54

6,938,319,14

4,165,54

6,938,31

14,68

MTR FTR

Prices for off-net callsgeneral price developmentProfitability of incumbent operator (predicted EBITDA margin 36%....)

Step 4: Evaluating Impact

Cheapest product available for Low user OECD basket of incumbent (MTC) in Namibia

Low User Medium User High User

8,74,51,8

13,46,9

2,8

13,46,96,9

20,2

6,96,9

24,8

16,511,0

41,1

24,1

11,5

Sep-05 Dec-08 May-10 Mar-11 Sep-12 Sep-12 in 2005 prices

MTC 2005 2006 2007 2008 2009 2010 2011

Revenue N$ million 769 937 1!113 1!232 1!390 1!407 1!453

Shareholders’ Equity N$ million 646 903 999 1!136 1!153 1!166 1!121

Taxation N$ million 146.5 171.3 177.0 180.7 198.8 187 160

Net profit after tax N$ million 293 337 340 358 388 397 319

Capital Expenditure in million N$ 160 188 340 286 260 410 237

Total assets N$ million 915 1!169 1!329 1!608 1!632 1!791 1!696

Dividend N$ million 110.0 80.0 245.0 220.8 369.5 383,6 364

Dividend as % of after tax profit 96,7% 114,2%

Return on equity 45,4% 37,3% 34,0% 31,5% 33,6% 34,0% 28,4%

Profit Margin 38,1% 36,0% 30,5% 29,0% 27,9% 28,2% 21,9%

EBITDA margin 61% 60,2% 52,2% 50,9% 53,8% 55,8% 53,2%

Active SIM cards in 1000 403,7 555,5 743,5 1!008,7 1!283,5 1!535 1854,7

Full-time Staff 276 272 296 397 416 395 407

Monthly ARPU in N$ 159 141 125 102 90 54

Source: MTC Annual ReportsSource: MTC Annual ReportsSource: MTC Annual ReportsSource: MTC Annual ReportsSource: MTC Annual ReportsSource: MTC Annual ReportsSource: MTC Annual ReportsSource: MTC Annual Reports

Impact of Termination rate reduction in Namibia

No waterbed effectDominant mobile operator

More subscribersEBITDA margin 50+%3rd cheapest dominant operator in Africa

Case Study South Africa

Mobile Termination glide Path in South African cents

Peak Off Peak CommentSince 2001 125c 89c

March 2010 89c 77c political intervention

March 2011 73c 65c Gazette No. 33698, 29 October 2010

March 2012 56c 52cGazette No. 33698, 29 October 2010March 2013 40c 40c

Gazette No. 33698, 29 October 2010

15 April 2010

Loosing Billions

10% loss or 10% less revenue? There is a big difference

17 May 2010

400 million

less revenue in one

quarter

22 July 2010

17 November 2010

Staff retrenchment to offset impactVodacom: R800 million loss in revenue

1 March 2011

17 May 2011

Vodacom: R1.5 billion loss in revenue

R500 million net interconnect loss

17 May 2011

MTN: ZAR 2.5 billion lost in revenuesTelkom interconnect revenue dropped 37.4%

28 March 2012

“I know that it is counter intuitive, but it is what happens,” said

Knott-Craig.

January 2012 OECD Low User Basket costs in USD (FX= average 2010)January 2012 OECD Low User Basket costs in USD (FX= average 2010)January 2012 OECD Low User Basket costs in USD (FX= average 2010)January 2012 OECD Low User Basket costs in USD (FX= average 2010)January 2012 OECD Low User Basket costs in USD (FX= average 2010)January 2012 OECD Low User Basket costs in USD (FX= average 2010)

Country Name Cheapest product from Dominant OperatorCheapest product from Dominant Operator Cheapest product in countryCheapest product in country % cheaper than dominant Country Name Rank US$ Rank US$ % cheaper than dominant

Mauritius 1 2,39 5 2,39 Dominant is cheapestEthiopia 2 2,61 7 2,61 naNamibia 3 2,74 8 2,74 Dominant is cheapestKenya 4 2,85 1 1,90 33,4%Egypt 5 2,91 9 2,91 Dominant is cheapestSudan 6 3,53 6 2,46 30,5%Ghana 7 3,87 11 3,28 15,1%Libya 8 3,90 14 3,90 Dominant is cheapestRwanda 9 4,28 3 2,16 49,4%Guinea 10 4,62 2 1,93 58,1%Sierra Leone 11 5,04 13 3,88 23,1%Uganda 12 5,51 10 2,94 46,6%Congo Brazaville 13 5,63 17 5,63 Dominant is cheapestTanzania 14 5,82 12 3,75 35,7%Algeria 15 6,21 4 2,28 63,3%Tunisia 16 7,24 18 6,46 10,9%Senegal 17 8,11 24 8,11 Dominant is cheapestBotswana 18 8,16 20 7,66 6,0%Sao Tome &Principe 19 8,21 25 8,21 Dominant is cheapestNigeria 20 8,40 16 5,22 37,8%Madagascar 21 8,45 27 8,45 Dominant is cheapestMali 22 8,78 29 8,78 Dominant is cheapestBurkina Faso 23 8,88 28 8,53 4,0%Benin 24 9,10 22 7,92 13,0%Mozambique 25 10,00 33 10,00 Dominant is cheapestChad 26 10,14 34 10,14 Dominant is cheapestD.R. Congo 27 10,37 19 7,62 26,5%Côte d’Ivoire 28 10,41 36 10,41 Dominant is cheapestCameroon 29 10,44 35 10,28 1,5%South Africa 30 11,07 32 9,83 11,2%Togo 31 11,18 38 11,18 Dominant is cheapestZambia 32 12,05 26 8,22 31,8%Niger 33 12,30 31 9,77 20,6%Central African Republic 34 12,33 39 12,33 Dominant is cheapestAngola 35 12,50 41 12,50 Dominant is cheapestSwaziland 36 12,87 44 12,87 naMalawi 37 13,01 45 13,01 Dominant is cheapestZimbabwe 38 13,48 43 12,67 6,0%Morocco 39 13,56 42 12,53 7,6%Gabon 40 16,11 30 9,09 43,5%Lesotho 41 16,51 40 12,43 24,7%Cape Verde 42 18,15 46 18,15 Dominant is cheapestGambia 43 na 15 4,33 naMauritania 44 na 21 7,77 naLiberia 45 na 23 8,09 naSeychelles 46 na 37 11,04 naSource: Research ICT Africa Mobile Pricing Report 2012Source: Research ICT Africa Mobile Pricing Report 2012Source: Research ICT Africa Mobile Pricing Report 2012Source: Research ICT Africa Mobile Pricing Report 2012Source: Research ICT Africa Mobile Pricing Report 2012Source: Research ICT Africa Mobile Pricing Report 2012

40

55

70

85

100

Jan 11 Mar 11 May 11 Jul 11 Sept 11 Nov 11 Jan 12 Mar 12 May 12

8ta Cell CMTN South Africa Vodacom South AfricaVirgin Mobile

January 2012 May 2012

2732

2430

Cheapest prepaid product from Dominant OperatorCheapest prepaid product in country

Ranking of South Africa among 46 African countries - prepaid mobile for OECD low user basket

8ta

Cell C

MTN South Africa

Virgin Mobile

Vodacom South Africa

MTC Namibia

Telecom Namibia 6,8

7,8

10,7

8,2

13,6

13,5

13,6

Price per MB in US cents for SA and Namibia

MTC has already 4G - LTE is 100 Mbps compared to max of 21 Mbps in SA

MTN Ghana

MTN Cameroon

MTN Rwanda (RwandaCell)

MTN Uganda

MTN Benin

MTN South Africa

MTN Swaziland

MTN Zambia

MTN Nigeria 33,5

20,5

15,3

13,6

9,9

9,3

5,1

4,0

2,1

Price per MB in US cents for MTN - June 2012

59

Telkom Fixed-line operating revenues and expenses in ZAR million (Telkom 2011, Telkom 2012, FY ending March)





2011 2012 Change

Interconnection Revenues

Total Revenues 1 679 1 757 78


Mobile Domestic 498 375 -123Interconnection Revenues Mobile International 186 630 444Interconnection Revenues

Fixed 328 262 -66


International 667 490 -177

Interconnection Expenses

Total Expenditure 5 193 4 839 -354

Interconnection Expenses

Mobile network operators 3 704 3 218 -486Interconnection

Expenses Fixed 404 306 -98Interconnection Expenses

International network operators 792 1 029 237

Interconnection Loss TotalInterconnection Loss Total -3 514 -3 082 432Interconnection Loss Mobile onlyInterconnection Loss Mobile only -3 206 -2 843 363

Interconnect revenue up, expenses down, net improved by ZAR432 million

Telkom past on MTR cuts 100% to customers

Revenue up 7.8%, profits up 27.9%

Interconnect revenue down 10.3%, expenses down 13.4%, net interconnect profit up 6.2% in South

Africa, additional ZAR 66 million

10.2% increase in traffic from Telkom due to

pass through of MTR cuts

MTN South Africa

Revenue up 7.7%

EBITDA

margin up by 1.2%

CAPEX up 5%

MTN South Africa: ZAR million

2010 2011 change

Revenue

Expense: interconnection and roaming

Net Interconnect

6!568 5!924 -644

5!483 5!183 -300

1!085 741 -344

‣ Still a net receiver of ZAR 741 million net‣ Overall higher profits in 2011 compared to

64

MTN and Vodacom: profits upVodacom: R66 million more after cuts

Vodacom: net profit from termination R1.14 billionMTN: net profit from termination: R741 million

Increase prices? Invest less?

Retrench staff?

65

Integrated perspective of markets, networks, services, services, applications and content and determining governance, legal and regulatory frameworks

ICT Ecosystem

66

Services

Networks

Apps Content

Policy & Legal Framework

Institutional Arrangem

ents(NRA, CC, USF)

Mar

ket S

truct

ure

(com

petit

ivene

ss)

Global/regional GovernanceITU, ICANN, WTO

StateConstitution

Glo

bal p

laye

rs a

nd a

ssoc

iatio

nsG

oogl

e, F

aceb

ook,

GSM

AM

ultilateral Agencies (W

B, AfDB, International Donors

Innov

ation

Inves

tmen

t

UsersConsumers

Citizens

Affordability

Access

Employment

Human Development

(e-skills)

National/industry formations(unions, industry associations, NGOs)

!"#$%&"'()*+',-../#."'012314

CLOUD

What does this mean for interconnection going forward?Interconnection‣ Diversity of interconnection contracts

significant as affects allocation of costs and revenues across the Internet value chain impacts on profitability of industry

‣ Challenge of recovering fixed and usage sensitive costs of network transport resulted in more complex settlement mechanisms than original simple dichotomised model of Internet

‣ Balance often conflicting incentives for investment in networks and innovation of services and applictions

67


68


69


70

What does this mean for interconnection going forward?

Interconnection

71

‣ differences between switched networks and NGN

‣ Separation of networks from service ‣ Inherent cost structure‣ Number of points of interconnection‣ Growing heterogeneity and size of Internet

Regulating in the transition?Interconnection

72

InterconnectionIP/NGN

Interconnection

‣ Regulated (ex ante)

‣ Transit (Partial)

‣ Competition (SMP)

‣ Reasonable network management vs. discrimination

‣ Right charging principle - cost of efficient operator

‣ Quality of service

‣ Disincentivise to migrate to IP-based interconnection

‣ Asymmetric termination

‣ Bargaining between autonomous systems

‣ Peering (paid)

‣ Consumer rights ( access to content) symmetrically?

‣ Zero based rating (B&K)

‣ Low price but reward innovation

‣ Quality of service (Best effort)

‣ Symmetric termination

‣ Content network & eyeball networks


73


74

Regulatory directions?

75

‣ Interconnection collusion?‣ Right charging principle ‣ Wholesale/retail?

- CPNP on wholesale services + Internet data?

- Bill & keep for everything including voice?

‣ Quality safeguard?‣ Ensuring investments in innovative networks‣ Focus on bargaining power/abuse‣ Cross border interconnection/harmonisation of

Parallel systems will convergeConclusion‣ Traffic flows are complex and who benefits from

termination rate cuts depends on business strategies and the competitive interactions of all operators

‣ Cost based termination rates lead to more and fairer competition an thus more subscriber, traffic, investment and a bigger pie of revenues to be shared among operators

‣ Quick and steep glide path to lower MTRs to cost of an efficient operator

‣ Net neutrality policy emphasising symmetric regulation protecting consumers, some tolerance of network discrimination that is proportionate, transparent .

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