The Second National Operator (SNO) has voiced its views on the ADSL Draft Regulations in a seven page submission to ICASA.

While the SNO supports ICASA’s regulations for the provisioning of ADSL, it asks for caution when it comes to controlling the structure of a specific retail product, in this case ADSL.

“The SNO strongly supports ICASA’s intention to apply targeted regulations to the provision of broadband services such as ADSL, for the benefit of the consumer and in the interests of fair competition.” “However, applying controls to the structure of a specific retail product is not the most effective way of achieving this in the long-term,” the SNO stated in their submission.

The SNO asked the Regulator to focus its attention on the ADSL wholesale segment, where Telkom currently has a monopoly, to ensure fair competition.

It argued that the real costs involved in ADSL provisioning are not clear since fair competition is not present in this sector.

“In the absence of true wholesale broadband in South Africa, we have yet to see the real underlying costs directly influencing pricing in the retail market,” they said.

The SNO pointed out that there are various wholesale broadband models apart from full Local Loop Unbundling to achieve a more competitive ADSL environment.

These include Bitstream Access to the ADSL circuit via a Virtual Circuit, Access to the DSLAM, where a portion of the DSLAM may be leased, Shared Access to the local loop and Facilities Leasing.

The SNO further supports the disclosure of contention ratios and static IP addresses (no periodic resets of the ADSL service) ‘in the interests of good practice in the market’.

The SNO has requested an opportunity to make an oral submission at the ADSL hearings, which will most likely take place in the first half of 2006.