1. Maltacom is delighted to note that finally the ISPs have come out and openly declared that they are providers of voice telephony.

Quote: “VOIP operators have once again given the consumers the best possible deal. Calls are now available at less than two cents per minute to most of Europe.”

To be able to provide this service, Maltacom pays an annual licence fee to the Maltese government of Lm150,000, plus one per cent of total gross revenue, for an aggregate total, in 2003, of Lm546,424. ISPs pay a (modest) licence to carry “data” traffic, and are (mis)using it to carry voice traffic.

At this point, the MCA might decide to take note of the anomaly, and realise why we feel discriminated against.

2. The ISPs then keep wondering why none of the free pulses are available to users of their service.

The Maltese public ought to be aware that in addition to the licensing fees referred to above, Maltacom provides these free pulses for use by domestic subscribers, to cover emergency and/or other socially related traffic. Incidentally, this social service that Maltacom will very happily continue to provide is additional to the subsidised tariffs to 5,000 socially disadvantaged Maltacom subscribers (who will actually benefit from an even less onerous tariff once the rebalancing exercise becomes effective). It will be interesting to learn about the social contributions being made by the ISPs.

3. Another gratuitous allegation by the ISPs:

“Clearly, therefore, much of the traffic being carried by the VOIP providers is not traffic that was lost by Maltacom, but traffic that was gained by Malta. Most of this traffic would never have been carried by Maltacom because at their prices, it just would not have been generated.”

Conversely, our auditors have confirmed that during the last 15 months we have lost 27 per cent of our revenue from international traffic. We, and our shareholders, will therefore be grateful to the ISP Trade Section of the Chamber of Commerce for enlightenment about the whereabouts of the “black hole” that has swallowed up this substantial part of our revenue.

At the same point, may we draw the MCA’s attention (once again) to the continued focus of the ISPs on the marketing and propagation of their voice telephony service?

4. And now we come to our assertion that ISPs are enjoying, and benefiting from, a free ride at Maltacom’s expense.

First of all let us reiterate our statement: ISPs are not contributing anything to Maltacom for the use of its infrastructure. We stand by this statement.

ISPs have no telephony subscribers and/or network, despite their dreams. If they did they would have to publish a directory (as we have just done, at a very substantial expense), they would have to provide a help desk for their clients; 24 hours a day, seven days a week, for 52 weeks of the year, just as we do (at great expense). They do nothing of this despite their assertion that they “give their clients the best possible deals”. They would also have invested in the capital cost, and the ongoing maintenance of a national copper and fibre network to carry their voice traffic, just as we did, and will continue to do, etc, etc, etc.

They have done none of this, and they contribute nothing towards these services (as the mobile services operators do, just as an example). We repeat, they contribute nothing towards these services, despite insisting on their supposed God-given right to use them free of charge. Hence our conclusion that these ladies and gentlemen are on a free ride.

5. We can go on and on rebutting their remarks, such as their allegation that Maltacom was (supposedly) given a “free fibre optic cable over which they carried their voice and data traffic”. Obviously they must know something that none of our accountants, auditors, and shareholders know about.

6. Other allegations in the ISPs Trade Section’s statement to the press: “ISPs pay (to Maltacom presumably) every single cent of these applicable tariffs.” We will refrain from commenting on the amount of time and effort we put in to recover those amounts.

7. The ISPs Trade Section concludes its statement to the press by stating that Malta now forms part of the European Union. Maltacom too is aware, and proud, of this reality, and consequently is comforted by the fact that “recent developments at EU level, and globally, are leading National Regulatory Authorities and the European Commission to consider whether certain categories of VOIP services should be declared voice telephony”.

When that distinction is made, and the consequent regulatory obligations introduced, we will be the first to declare that the playing field has been truly levelled, and we will then be delighted to compete (robustly), with the members of the ISP Trade Section of the Chamber of Commerce, as we are doing, very successfully, in the field of mobile telephony.

8. In the meantime, we will continue to insist that ISPs are on a “free ride”, and competing unfairly, and consequently we will continue to be relentless in our insistence that this situation must be redressed.