No. A 2G Operator that is not providing 3G services cannot decline access to 3G-2G Inter-Operator Roaming Service on the ground that it is not providing the service to itself. The Access List Determination states that 3G-2G Domestic Inter-Operator
Roaming Service is a service that enables a customer of a 3G Operator or a 3G MVNO to initiate, receive or otherwise utilise applications on the 2G Mobile Network of a 2G Operator. The Access Provider in this case only needs to be a 2G Operator.