Market Analysis 01 Intercfonnection Part 1

Market Analysis of Wholesale Call and SMS Termination on Individual Fixed and Mobile Networks
 
Consultation Part 1
 
1 Executive Summary
1.1The purpose of this market analysis is to define the markets for wholesale call and SMS
termination on individual fixed and mobile networks and to assess the extent of dominance in
those markets and apply remedies if appropriate. The Telecommunications Regulatory
Commission, (the “TRC”) is consulting stakeholders and the public on these key areas:
 
 

On behalf of CCT, please, see below our responses to the Interconnection Consultation:

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Summary

Digicel is grateful for the opportunity to respond to the Commission's consultation on a market analysis of wholesale call and SMS termination on mobile and fixed networks.

We believe that the Commission should avoid going down a market analysis and assessment of dominance route.  If the analysis and assessment was carried out in what we would consider to be a fashion that could provide a dependable result, it would be very different from what has been suggested by the Commission.  In fact, in our respectful opinion, and considering the way that consultation has been drafted, the Commission is attempting to take a short cut.

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RESPONSE
TO
CONSULTATION
on
THE MARKET ANALYSIS OF WHOLESALE CALL AND SMS
TERMINATION ON INDIVIDUAL FIXED AND MOBILE
NETWORKS
and
DETERMINATION OF DOMINANCE FOR TERMINATION
SERVICES ON INDIVIDUAL FIXED AND MOBILE NETWORKS
(draft) 2011
and
TELECOMMUNICATIONS CODE (INTERCONNECTION AND
ACCESS TO FACILITIES AND UTILITY INSTALLATIONS)
REQUIREMENTS, 2011

CWI Caribbean Limited, on behalf of its affiliate Cable and Wireless (BVI) Limited, trading as LIME (“LIME”), is pleased to provide the following response to the Commission’s Public Notice in the matters of ‘Consultation on the Market Analysis of Wholesale call and SMS Termination on Individual Fixed and Mobile Networks’ (the consultation document) and the draft ‘Determination of Dominance for termination Services on Individual Fixed and Mobile Networks 2011 ’ (the draft determination) and ’Telecommunications Code (Interconnection and Access to Facilities and Utility Installations) Requirements, 2011’ (the Code), all published 01 June 2011. Together called the consultative documents.

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SHORT REPORT ON THE CONSULTATION ON THE MARKET ANALYSIS OF
WHOLESALE CALL AND SMS TERMINATION ON INDIVIDUAL FIXED AND
MOBILE NETWORKS: DETERMINATION OF DOMINANCE AND
INTERCONNECTION REQUIREMENTS
 
This short report collates the operators’comments in response to the Consultation on the Market Analysis of Wholesale Call and SMS Termination on Individual Fixed and Mobile Networks, specifically
with regard to:
 
  • Determination of Dominance
  • Interconnection Requirements

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DETERMINATION OF DOMINANCE FOR TERMINATION SERVICES ON
INDIVIDUAL
FIXED AND MOBILE NETWORKS 2011
 
The Telecommunications Regulatory Commission, in the exercise of the power conferred by
Section 26 (3) of the Telecommunications Act, 2006 (No. 10 of 2006), issues this Determination.

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PART I

PRELIMINARY

Citation and scope of application

(1) These Requirements apply to the interconnection of public telecommunications networks and public telecommunications services as well as access to facilities and utility installations.

(2)  These Requirements apply to all public suppliers.  Requirements related to access to facilities and utility installations also apply to public utilities.

(3) These Requirements may be cited as the Telecommunications Code (Part 4) (Interconnection and Access to Facilities Requirements) and shall come into force on the date of publication in the
Gazette.

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CONSULTATION ON THE MARKET ANALYSIS OF WHOLESALE CALL AND
SMS TERMINATION ON INDIVIDUAL FIXED AND MOBILE NETWORKS:
PART II: ASSESSMENTOF REGULATORY REMEDIES
 
Market Analysis of Wholesale Call and SMS Termination on Individual Fixed and Mobile Networks
Consultation Part 2–Assessment of Regulatory Remedies
 
Executive Summary
 
In line with the Determination of Dominance2, the TRC proposes to regulate the wholesale price of call
termination on fixed networks, the fixed termination rate “FTR” and the wholesale price of call
termination on mobile networks, the mobile termination rate “MTR”. The TRC hasconsidered the range
of regulatory remedies toaddressthe call termination bottleneck which include:
  • No regulation
  • Bill and Keep
  • Application of Long-run Incremental Cost(“LRIC”) models to calculate the termination rate
  • Benchmarking

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Find attached below CCT’s responses to the document “Consultation on the Market Analysis of Wholesale Call and SMS Termination on Individual Fixed and Mobile Networks, Part II”:

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RESPONSE
TO
CONSULTATION ON THE MARKET ANALYSIS OF WHOLESALE
CALL AND SMS TERMINATION ON INDIVIDUAL FIXED AND
MOBILE NETWORKS:
PART II: ASSESSMENT OF REGULATORY REMEDIES
 
Cable and Wireless (BVI) Limited,trading as LIME BVI, is pleased to provide the following response to the Commission’s Public Notice in the matter of ‘Consultation on the Market Analysis of Wholesale
Call and SMS Termination on Individual Fixed and Mobile Networks:
Part II: Assessment of Regulatory Remedies’ (the consultation document) published 30 September 2011.

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Short Report on the Consultation on the Market Analysis of Wholesale call and SMS Termination on Individual Fixed and Mobile Networks: Part II: Assessment of Regulatory Remedies

This short report collates the operators' comments in response to the second phase Consultation on the Market Anyalysis of Wholesale Call and SMS Termination on Individual Fixed and Mobile Networks: Part II: Assessment of Regulatory Remedies dated September 30, 2011 "the Consultation Document: PartII", whch outlined the TRC's proposals in relation to:

  • The proposed methodology for determining the call termination charge controls
  • The proposed termination rates
  • The process of consultation and licence amendment.

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With the effect from August1,2012, the Licences of the following Licensees of public telecommunications networks in the Virgin Islands:

 

  • Cable and Wireless (BVI) Ltd (“LIME”)
  • Caribbean Cellular Telephone Ltd (“CCT”)
  • Digicel (BVI) Ltd (“Digicel”)

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Report on the Directive on Call Termination Rates in the Virgin Islands

On June 1,2011, the Telecommunications Regulatory Commission (“the TRC”) launched a consultation on the Market Analysis of Wholesale Call and SMS Termination on Individual Fixed and Mobile Networks (“the First Market Analysis”). The purpose of this consultation had been to review the market for call and SMS termination in the Virgin Islands and to assess if any operators were dominant in that market and, if appropriate, to apply regulation under Section 26 of the Telecommunications Act , 2006 (“the Act”) .  The TRC noted, however, that it did not propose to regulate wholesale rates for SMS termination at that time.

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