MANILA - Smart Communications Inc. is willing to shift its unit of billing on cellular voice calls to per-pulse from per-minute charging provided that this will reflect only after the first minute.

The cellular firm proposes that the retention of the international standard of billing for the first minute of a voice call and then shift to per-pulse charging in the succeeding duration instead of what is stated in the draft memorandum circular (MC) on billing of mobile voice service. “This will be more consistent with internationally accepted industry best practice,” said Smart, in its position paper dated July 6.

Under the draft guidelines issued by the National Telecommunications Commission (NTC), the unit of billing for the cellular mobile telephone service (CMTS)—whether postpaid or prepaid—will be reduced from one minute per pulse to three seconds per pulse.

“The authorized rates shall be reduced correspondingly. The rate for the first three pulses shall be higher than the succeeding pulses to recover the cost of the call setup,” said the NTC.

While Smart agreed on shifting to per pulse billing after the first minute of the call, it also suggested that instead of charging for every three seconds per pulse, regulators should change this to every six seconds per pulse.

The existing unit of billing for mobile voice service is based on a one-minute pulse where subscribers are billed on a per-minute basis. This, even if customers use the service for less than one minute. If the proposed circular is approved, a 30-second call will cost only P3.60, based on NTC’s computation.

The CMTS providers are asked to submit their respective proposed rates based on the prescribed unit of billing within 30 days from the effectivity of the circular. It reminded the cellular operators that proposed rates should not be higher than the prevailing rates.

This is the next new policy that regulators are going to implement after it issued on Friday MC 03-07-2009 as the new guidelines for prepaid loads. As provided in the curcular, the NTC extended the validity of the prepaid loads corresponding to the amount of load purchased. Prepaid loads with higher value will have longer validity periods.

Smart also told the NTC that consumers should be given a choice on whether they want to subscribe to either the per-pulse, per-minute or unlimited voice calling schemes as “this will not only encourage competition and spur innovation but will ultimately redound to the benefit of the consumer.”

Further, it asked the commission that it be given four months or at least 120 days from the day the proposed MC will take effect before it could implement the new adjustments in its network.

The NTC proposes that all CMTS providers and their interconnected network and service providers implement the necessary adjustments in their respective networks and systems to comply with the prescribed unit of billing not later than 60 days from the effectivity of the circular.

But Smart said a longer transition period should be given to carriers to make provisions in their systems, before the option of going into a per pulse billing takes effect. Smart believes that instead of 60 days, a minimum four-month period or at least 120 days be provided.

“Definitely a lot of technical modification, testing and adjustments will take place between carriers to ensure an error-free environment, as various hardware or software equipment may have to be purchased to accommodate the per pulse mode of billing,” said Roy Ibay of Smart’s legal and regulatory department.

To reflect the true costs, interconnection agreements between CMTS providers and between CMTS firms and other interconnecting network and service providers shall be amended to incorporate the prescribed unit of billing within 30 days from effectivity of the new rules.

Smart also commented on another proposed MC drafted by the NTC concerning the grouping of promotional pricing schemes.

The NTC wants all promos to be group into specific services being offered, be identified by specific registration codes, and be accessed by a single access code. Simply put, all text and voice call promos shall be separately identified with only one set of access codes per network operator.

The NTC was compelled to draft guidelines on promotions to avoid confusion. “Numerous promos are offered to attract consumers, increase traffic volume and improve efficiency. Some of the promos are similar causing confusion,” it said.

Applications for promos should be filed with the NTC at least seven working days prior to launch. If the agency fails to act on the application within two working days, the application is deemed approved. The promo must also be published in a newspaper of general circulation at least three days prior to start of the campaign.

Smart suggested that the period for promo applications be filed at least five working days due to the demands of the market instead of the seven-day prescribed period. Similarly, the publication requirement be adjusted to at least two days prior to start of the promo.

Promos cannot be discontinued or terminated during the said period, added the NTC.