Monrovia - 'Imagine Life Without Being Able To Talk To Your Loved Ones'. This is what the Lonestarcell , CEO, Tebogo Mogapi appears to be saying to the Liberian Telecommunications Authority in a leaked document that is in possession of Front Page Africa.

The document was a submission made by the CEO of Lonestarcell to the LTA on why it will not be technically possible to implement the decision of the suspension as prescribed by the LTA on the 13th November 2012.

The document appears to have been submitted before the LTA came up with its decision Friday through a news conference to announce their final decision on the long awaited dispute relating to what the LTA refers to as '“Unilateral implementation of an unauthorized change in the status of its interconnection with Comium Liberia from 18 May 2012 to 21 May 2012.

In a statement read by the LTA chair Angelique Weeks, Friday, the board of the regulatory body noted:

Lonestarcell Cites ‘Technical design issues

“For purposes of this decision, suspension means that Lonestarcell/MTN customers will be able to receive calls but will not be able to make calls for the duration of the suspension period. To minimize the impact of this Decision on customers in those areas in which only Lonestarcell/ MTN provides service, said areas will be exempted from the suspension order such that those customers will be allowed to receive and make calls. However Lonestarcell/ MTN shall pay 25% of the revenues generated from such operations to the Government ofLiberia ". According to the LTA, the suspension is slated to commence at 12:01 am on the 3rd December 2012 and continue for three days until 12 Midnight on 5th December 2012.  “A major factor that influenced the BoC’s decision to reduce the duration of the suspension is Section 20(5) of the Telecommunications Act of 2007, which states that where a license is suspended, revoked or not renewed, the LTA shall take into account continuity of service to customers and include in its order such terms and conditions as it deems appropriate,”. Liberia'. In their submission which is contained in the document Lonestarcell is making it clear to the LTA that what they are prescribing cannot be implemented due to technical design of the network. And, if they have to implement it as is prescribed the risk of damaging and losing the whole network is much greater.”

Industry watchers say in order to achieve what the LTA is prescribing, LonestarcellMTN will have to keep all elements of the network operational in order for its customers to receive calls.

The leak document pointed out that past experiences have shown that whenever there are network downtimes or outages, the number of ‘failed – attempts’ by customers increase. This normally results in the abnormal increase of signal resources that leads to the instability of the “Core Network’. And, because of this, the Mobile Switching Centre (MSC) automatically goes into a ‘cycling restart’ preventing any inbound or outbound calls to terminate on the network".

The submission goes further to mention that besides the “Core Network” challenges, the signaling resources on all Base Transmission Stations (BTSs) will be fully ceased, denying the possibility of any incoming traffic to terminate.

“This will cause a double bottleneck layer effect on the “Core Network and Radio Access Network (RAN). This unfortunately, will create huge congestion that even the well-meaning customers from all other operators will not be able to get through to the LonestarcellMTN customers.”

With all these challenges, Lonestarcell MTN seems to be saying, you either leave the network on or you shut down.

According to the chairperson of the LTA Angelique Weeks, the suspension means that Lonestar Cell/MTN customer will not be able to make calls but will be able to receive calls for the duration of the suspension beginning December.

The LTA board also said it took the decision because Lonestar Cell/MTN failed to timely comply with the LTA’s directive to restore fully by 5:00 PM, Monday, 21 May 2012, the interconnection between Lonestarcell and Comium Liberia as it existed prior to Lonestarcell MTN’s 18 May 2012 unilateral implementation of the said unauthorized change; and recalcitrance considering Lonestarcell MTN’s previous unauthorized shutting down of its interconnection link with another operator in 2010.

The decision by the LTA has been greeted with mixed reviews with some suggesting why the LTA did not instead force Lonestar cell to turn over revenues generated for three days into government revenue or simply instill a hefty fine on the cellular giant.

“Shutting down a business in a struggling post-war nation like Liberia puts the consumers at a disadvantage,” says Gerald Williams, standing in a queue at the Lonestar cell main office in Congotown Saturday.

Minimizing impact

But despite the criticisms, the LTA says it has taken steps to minimize the impact of the decision on customers in those areas in which only Lonestar Cell/MTN provides service.

“Said areas will be exempted from the Suspension Order such that those customers will be allowed to receive and make calls. However, Lonestar Cell/MTN shall pay 25% of the revenues generated from such operations to the Government of Liberia(GOL),” the LTA said in a statement announcing the suspension last Friday.

According to the LTA, the suspension is slated to commence at 12:01 am on 3 December 2012 and continue for three days until 12 Midnight on 5 December 2012.

“A major factor that influenced the BoC’s decision to reduce the duration of the suspension is Section 20(5) of the Telecommunications Act of 2007, which states that where a license is suspended, revoked or not renewed, the LTA shall take into account continuity of service  to customers and include in its order such terms and conditions as it deems appropriate,” the regulators noted.

A senior executive of “LonestarcellMTN who spoke to FrontPageAfrica on condition of anonymity Sunday, because he was unauthorized to speak on behalf of the company, said the decision makes no business sense for the company.

“To achieve this, LonestarcellMTN will have to keep all elements of the network operational in order for its customers to receive calls,” the source noted.

“Our past experiences have shown that whenever there are network downtimes or outages, the number of ‘failed – attempts’ by customers increase. This normally results in the abnormal increase of signal resources that leads to the instability of the “Core Network’. And, because of this, the Mobile Switching Centre (MSC) automatically goes into a ‘cycling restart’ preventing any inbound or outbound calls to terminate on the network. This is the feature that is built into the MSC to protect itself.”

The source noted that besides the “Core Network” challenges,  the signaling resources on all Base Transmission Stations (BTSs) will be fully ceased, denying the possibility of any incoming traffic to terminate. “This will cause a double bottleneck layer effect on the “Core Network and Radio Access Network (RAN). This unfortunately, will create huge congestion that even the well-meaning customers from all operators will not be able to get through to the LonestarcellMTN customers.”

Options for Lonestarcell/MTN Limited

It is unclear how the LTA intends to monitor or implement its decision and whether LonestarCell/MTN will obliged with the LTA to endure three days of disruptions. But appealing the process or seeking a legal remedy could prove difficult for LoneStar which recently dropped a planned lawsuit against the LTA.

The LTA had previously announced in June 2012 that Lonestar Cell/MTN had been informed of the BoC’s Initial Decision to suspend Lonestar Cell/MTN’s License for two(2) weeks because of the aforementioned reasons. However, before the LTA could implement further procedural steps including issuance of its order to that effect, Lonestar Cell/MTN filed a Court Petition seeking Judicial Review of the LTA’s decisions. This legal action by Lonestar Cell/MTN put a stay on further proceedings by the LTA, pending conclusion of the Court Action.

Lonestar Cell/MTN subsequently withdrew its petition, which freed the LTA to continue with the requisite procedural steps in furtherance of the BoC’s initial Decision to suspend Lonestar Cell/MTN’s two(2) Licenses.

The LTA says as required by the Telecommunications Act of 2007 and the LTA’s Licensing Regulations, the BoC by letter dated 17 July 2012 informed Lonestar Cell/MTN that the effective date of the proposed suspension would be determined after due consideration of inputs received during stakeholders consultations and that Lonestar Cell/MTN would have 30 days from the date of the receipt of the 17 July 2012 letter to prepare and provide to the LTA, comments on the proposed suspension. Lonestar Cell/MTN was also informed that the following procedures would be used in implementing the decision to suspend Lonestarcell MTN’s Licenses.

The LTA says in arriving to its decision, it considered several factors, including inputs from Lonestar Cell/MTN itself, other sector operators, a cross-section of the general public, as well as the BoC’s own research.

Lonestar Cell/MTN insists in the leaked document that the company is designed to operate at the Mobile Switching Centre (MSC) level, thus, switching controls of transmission (E1s) links to and from the BSC and BTS could be detrimental. Said a senior executive Sunday:

“In addition, it is important to note that our network is not configured to be controlled at the BTS level or individual mobile numbers. Therefore, if the Suspension Order is to block only outbound traffic to the network, then all network elements across the country will be blocked for outbound traffic, and unfortunately affect even the very customers that we are concerned about in the more than 18 areas where only LonestarcellMTN has presence.”

Lonestarcell/MTN says it has consulted with its Ericsson support team to look at alternatives, with no success or breakthrough. “Emergency numbers in use can be activated by customers, even though they are not otherwise able to call out”.

Decision poses challenges for Lonestarcell/MTN

The company says terminating “Emergency” traffic in light of the outbound restriction will complicate an already awkward provisioning mandate, especially in regards to availability of network elements and facilities.” Practically, customers will not be able to benefit as all other types of traffic will be affected.”

Industry watchers say the suspension as prescribed by the LTA presents numerous challenges for Lonestar/MTN.

“The impact financially and other wise is much greater than we can fathom as it is tantamount to closing the business, shut the network, and in two weeks reopen to pick up the pieces,” noted one observer Sunday.

Said the source, who preferred anonymity for this report, “the loss of revenue on outgoing calls locally and internationally should not be underestimated.

This will have such effect on the ultimate bottom line that it might affect the number of jobs in our employ, let alone the taxes due to the GoL. This loss could be in millions.

The impact that this will have on our distributors and airtime agents will be huge as they are not able to sell airtime during that period. And, the ripple effect when they are not an able to service their debts with the banks or with each other could create chaos for us. We have more than 300 sub - distributors that might want to bring stock back and to be refunded. This is disaster in our hands.”

Also problematic for the LTA decision is the fear that the decision is likely to have on the successful Mobile Money promotion as the regulations of the Central Bank clearly stipulates that the customer should get his or her money at the time they want it. This action could mean the customer funds trapped in their virtual purse.

Industry watchers say the suspension decision could also leave the company open to be sued by the likes of BICS - its international carrier, as they have other obligations and back – to - back contracts with other operators around the world, based on the traffic they carry to and from us.

With so much on the line, many are wondering how the LTA will implement such a complicated decision likely to draw controversy amid concerns from cell phone subscribers who are expected to be affected by a decision likely to disrupt the daily routine and business beyond the three days suspension announced by the regulators.

Mixed Reviews from Subscribers

Around Monrovia, subscribers and cellular users greeted the decision with mixed reviews.

Ralph Varmah a Lonestar subscriber says the LTA is the regulator of all service providers and if Lonestar violate they should be punish. Varmah explain that LonestarCell violated the LTA laws by disconnecting Comium so, they deserve to be punished.

“I think this decision will serve as a deterrent that other service provider will not do the same” he added. Varmah maintains, that laws should be respected whether LonestarCell/MTN has a million subscriber or not.

But Ambulai Kanneh, a resident of Saye Town disagrees describing the LTA decision as a untimely and done without the consideration of a huge number of subscribers under Lonestarcell/MTN’s wing. Kanneh explains that subscribers will be affected badly with festive season around that family need to connect with each other. “We do not have problem with LTA punishing LonestarCell but what we are saying this decision is not timely”.

Mitchell Kromah, a Cellcom subscriber says the decision of the LTA is to avoid the culture of impunity but added that he is in sympathy with Lonestar with customer. According to Kromah, what the Lonestarcell/MTN GSM Company did was a gross violation of the LTA Act so they need to punish.

“This decision has no political undertone as some people are trying to insinuate”. Kromah maintains that gone are the days where companies violated the laws and no action was taken.