Analysis of the broadband policy of South Africa
, October 2010
A. The final draft of the South African Broadband Policy
There are a number of differences between the draft South African Broadband Policy published for
comment in September 2009 and the final policy released in June 2010:
1. The long term goal of the policy is to achieve universal access to broadband services by 2019.
This is defined in three ways, first, as access “to a public ICT access point within a two kilometre radius of any person in a sparsely populated area”(220.127.116.11.1), second, “household broadband penetration should be at least 15% by 2019” (18.104.22.168.20 and third, “ECN connectivity should be available to all municipal areas by 2019” (22.214.171.124.3). As speed is defined as “a download speed of at least 256 kbps” (1.3.3), achieving this goal will be the equivalent of achieving universal access to dial-up internet by 2019. At present to download reasonable quality video content online requires at least 4 Mbps download speeds. The goal of the US broadband plan released in March 2010 is “to achieve affordable access to actual download speeds of 100 megabits per second and actual upload speeds of 50 megabits per second.
2. The implementation of the Broadband Policy is to be undertaken by a Broadband Inter-Governmental Implementation Committee, which will draw up and coordinate an implementation plan.
The establishment of this mechanism suggests that the government sees the development of broadband as a governmental matter to be coordinated between national, provincial and local spheres of government. In the policy, the private sector is assigned certain roles (5.1.5) such as partnering “with Government on specific developmental initiatives” (126.96.36.199), being “utilised to achieve Government’s developmental agenda and to contribute towards bridging the digital divide through their license obligations” (188.8.131.52). However, the private sector is not included in the Implementation Committee, so it is hard to see how the Implementation Committee will do its work effectively or efficiently, given that it is the private sector that will be doing much of the rollout of broadband infrastructure and services.
In a recent statement the Minister of Communications, Siphiwe Nyanda, identified the role of the private sector as follows:
The greatest challenge is on how to approach infrastructure development in rural areas where it is clear that the private sector does not show interest to invest in infrastructure capability for internet connections and high-speed access to data. The issue we would discuss includes options for ICT infrastructure development in rural and semi-rural areas across the country. And the question we need to ask ourselves is “has our State-Owned Enterprises delivered the requirements for an integrated infrastructure in the rural areas inter-connected with existing ones.” In this instance, we also need the private sector to play a key developmental role in partnership with government for the benefit of all our people.
In analyzing the scenarios in ICT infrastructure spending in the recent past, we recognize that provinces and municipalities with smaller local economies are not be able to make the kinds of investments for the construction of ICT backbone networks similar to large regional economies like Gauteng and KwaZulu Natal. The Gauteng Province for instance had planned an investment of up to R700 Billion in ICT infrastructure by 2008 within its Blue-IQ project (B-Link) whilst projecting an improved economic growth of up to 15 percent increase in GDP by 2015.
These investments funded through a public private partnership model can be replicated in other provinces as part of the long-term strategic partnership for delivery within the context of our comprehensive rural development agenda. In other words, with government providing leadership and part of funding for infrastructure development, more private investment will accrue to partner on our transformation of rural areas into centres of economic and social livelihood.3
It is unlikely that the private sector will play this role if they are excluded from the implementation mechanism.
B. What is missing from the final draft of the Broadband Policy
The broadband policy is an extremely weak statement of policy. It does not fulfil the basic requirements of a policy document, which usually include the following steps:
1. State the problem/challenge/opportunity which requires a policy intervention, and relate this to wider national policy objectives.
2. Establish the present position in relation to that problem (through e.g. statistical summary, technological and market analysis, research into user behaviour).
3. Consider international and national trends relevant to the policy area concerned.
4. Establish objectives for national broadband policy.
5. Set out alternative approaches which could be taken by government (and other actors), and consider the pros and cons of these different alternatives in light of objectives and resources.
6. In a consultation process, identify choices and questions which need to be addressed and on which opinion is consulted (but may indicate an initial policy preference)
7. In a final policy document, choose a particular policy approach and give reasons why this particular approach has been chosen.
8. Address questions of resourcing, including both finance and human resources.
9. Identify and consider other policy areas, outside the policy area in question, in which action or interventions are required (e.g. In supply-side areas such as capacity-building, in demand-side areas such as enabling legislation for e-commerce).
10. Establish a plan of action with clear goals, allocation of responsibilities and timetable.
Given that this is the first policy document to be released by the Department of Communications (DoC) since the Broadcasting White Paper of 1998, it is clear that the capacity to formulate policy in the DoC has atrophied in the last twelve years. This is cause for concern.
1. Set clear policy targets such as: by 2014, South Africa will:
2. Have broadband access in every town and village;
3. Have the cheapest fastest broadband access on the continent; and,
4. Be number one in terms of broadband penetration on the continent.
5. Invite private sector and civil society participation on the Broadband Implementation Committee
6. Draft an implementation plan based on the ten steps for sound policy development, as outlined in section B. above.
The logic of a developmental state suggests that the state should play a leading role in development. When elements of the state are too weak to do so – as the evidence of the disappointing Broadband Policy process suggests about the Department of Communications – it is wise for the state to engage other sectors of society to build a common approach. When it comes to broadband policy, OECD evidence indicates that states that develop solid broadband policy strategies, increase both their broadband penetration, GDP and boost the performance of their economies4. South Africa can not afford to miss the opportunity that a sound broadband policy can bring to socio-economic development. The current broadband policy is not up to the task.