"Interconnection rights are key for fair competition - otherwise it isn`t really a Convergence Bill," the Internet Service Providers Association (ISPA) said in its submission on the Convergence Bill.
ISPA, represented by joint-chairman Masedi Molosiwa and its regulatory chairman Ant Brookes, presented its response to the Parliamentary Portfolio Committee on Communications yesterday.
Other presenters were the SA Post Office and free-to-air broadcaster e-TV.
According to the ISPA submission, another critical issue facing the drafting of the bill is that the licensing process needs to be as simple as possible, and that categories and definitions need to be very clear.
ISPA does not want to see any licensing requirements for applications and content, and it believes reseller conditions should form part of other licences and not be licensed separately.
The association also said it is critical that communications services licensees be given the right to interconnect, and not only the network services licensees.
Marcel Golding, chairman of HCI, e-TV`s holding company, criticised the lack of an overall government policy document concerning convergence.
"We recognise that convergence is critical and we are not hostile to it. However, we have to be sensible about it. It would be sensible to be cautious," he said.
Golding said the problem is that the entire Independent Broadcasting Act will be repealed and replaced by the Convergence Bill and that means one regulator, the Independent Communications Authority of SA (ICASA), "will be swamped by work".
In its submission, the SA Post Office asked for a "licence-exempt" category of application services to be created to enable the rapid deployment of services that would allow viewing of content and access to messaging services.
"For example, the SAPO`s packet-tracking service may in the future be classed as an applications service," it said.
SAPO and ISPA called for Section 19 to be repealed, as it is superfluous as it is covered in Section 14. This section requires that class licence-holders must inform ICASA of "any material changes to the communications service provided".
Joe Majwara, Department of Communications deputy director general, agreed with this suggestion.
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