5.2.
Oral and Written Submissions
During the entire cycle of the review, stakeholders were given adequate
opportunity to make both oral and written submissions with respect to the study
methodology, the study assumptions, data collection and the proposed
interventions. The comments raised by industry stakeholders revolved around the
following thematic areas:
a)
Potential impact of low termination rates associated with pure LRIC on
rural coverage;
b)
Consideration for network externality surcharge to support mobile
penetration;
5.3.
c)
Merit of price cap of off-net tariffs to on-net tariffs;
d)
Modeling voice termination rates on the basis of 2G instead of 3G;
e)
SMS termination charges; and
f)
Correct glide path to attain pure LRIC cost for termination rates.
Consideration of Comments by Stakeholders
The Commission notes that the study has addressed all the above comments as
follows:
a)
Impact of pure LRIC Model: The low termination rates associated with
pure LRIC will improve the competitive landscape and provide operators
with greater retail tariff price flexibility, helping to support effective
competition. In addition, the pure LRIC model sets efficient termination
rates that are close to the opportunity costs of providing termination
service by operators;
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