1. Broadband Proliferation PTA Hearing Presentation by ISPAK 12 July 2007

2. Critical Issues 1. PTCL’s DSL Services 2. Anti-Competitive Clauses of PTCL-DSL Agreements 3. Un-bundling of OFAN 4. Local Loop Sharing Charges 5. DSL Provisioning SOPs 6. Inter-Exchange charging by PTCL in Karachi

3. PTCL’s DSL Services PTCL has reduced its bandwidth prices – appreciable step PTCL has committed to withdraw promos after 3 months ISPAK therefore don’t want to pursue further against PTCL’s own DSL services

4. Anti-Competitive Clauses of PTCL-DSL Agreements ISPs are restricted to procure IP bandwidth and leased lines for DSL from PTCL only No third party interconnects are allowed in PTCL colocations VPNs and video conferencing services are not permitted Clear abuse of SMP status Clear infringements of licensed rights of ISPs as well as private LDIs. Discriminatory and restrictive clauses need to be removed.

5. Un-bundling of OFAN PTCL has 0.3 m OFAN lines mostly in commercial areas of major cities ISPs don’t have access to this network Customers have no choice but to go for PTCL’s DSL services – unfair advantage PTCL should provide OFAN DSLAM ports to ISPs using ATM PVCs and backhauling to exchange on E1s. Monthly rental should not exceed Rs. 217 per customer per month inclusive of loop charges and DSLAM port

6. Local Loop Sharing Charges PTCL argued to PTA that it wasn’t providing its own DSL services, hence not over recovering the cost (Determination of 6 March 07). PTCL was charging ~Rs. 50 under O&M Agreements Rs. 150 is ~15% of gross revenue These charges need to be reduced to 5% of revenue, i.e., Rs. 50 Or PTCL should sign SLA with ISPs for 99.5% uptime of copper loop

7. DSL Provisioning SOPs PTCL’s own DSL service provisioning is very quick – phone and web orders accepted. ISPs go through lengthy cycle of 6-7 days, advice notes, jumpering slips, etc. PTCL’s own SOPs for DSL provisioning need to be adopted for ISPs

8. Inter-Exchange charging by PTCL in Karachi PTCL’s charges full ring distance for local inter-exchange leased lines in Karachi. This practice needs to be abolished and made on crow flying distance.