Improve participation, planning and allocation: APC's comments to the South African national broadband policy


In April 2013, the South African government published their proposal for a national broadband policy with the aim of ensuring “universal service and access to reliable, affordable and secure broadband services by all citizens prioritising, rural and under-serviced areas.” The document was open for comments and the Association for Progressive Communications, based on the experience of its South African members and its involvement in similar process throughout other countries of Africa and the rest of the world, has submitted observations on key aspects of the policy.

While the policy recognises the importance of access to affordable broadband and its role in the promotion of education, health services, job creation, building sustainable rural communities and reducing crime and corruption, there are pressing issues that the policy is not addressing in its current form, which could potentially become significant obstacles for its implementation. Here is a summary of APC’s main concerns:

Civil society participation
Although the policy mentions the private sector as a key actor to be included in the process, and more generally calls for a collaboration with all stakeholders, civil society is not specifically mentioned as an actor. APC believes, as it has been demonstrated in countries like Brazil, that civil society is a key actor, able to provide many valuable inputs to the process of developing an effective plan to address the needs of the general public as well as more marginalised groups, such as women and girls.

Decision-making processes
While the policy demonstrates its commitment to urgent adoption by instating the direct involvement of the head of state in decision-making, this mechanism should not overlap with other governmental bodies who are also working on broadband. It is necessary to ensure that such processes do not simply add another layer of bureaucracy and delays. In the case of the currently under-served rural areas, the policy should adopt a comprehensive strategy that synchronises the efforts of entities such as the Department of Rural Development and Land Reform.

Targets and timeframes
The proposed policy currently sets a fairly general target: “To ensure universal access to reliable, affordable and secure broadband infrastructure and services by 2020 and stimulate sustainable uptake and usage.” The policy should specify achievable and concrete target timeframes including intermediate milestones prior to 2020, and these should include more specific affordability and speed targets, such as those defined in the NDP 20301 and by SIP 152.

Backbone infrastructure
With regards to infrastructure, this is an issue that has not met expectations in the past and is key to achieving low cost access. The proposed policy sketches out general intentions in broad terms and advocates for a model of “wholesale regulations to support service-based competition.” This would likely be through a state-owned wholesale backbone network made up from Telkom’s fibre infrastructure, which could duplicate private backbones in many areas. This model has been implemented in some other countries, but its success has not yet been confirmed, and should be evaluated against other models, such as to subsidise the cost for private operators to extend their networks to more remote and less profitable areas, especially in the provision of shared passive infrastructure such as masts and ducts, especially in rural areas.

The policy should spell out in more detail what the fibre initiative means in terms of integration with the other state infrastructures (the assets of Sentech and Broadband Infraco), and the longer-term plan for public investment in infrastructure that could compete with the private sector in some areas.
The policy mentions the need for coordinated action at municipal, provincial and national levels in infrastructure development, including the participation of private actors. There is, however, a need for more explicit recognition of potential conflicts of interest between the state as both a player in the market and the body who sets the rules.

Connecting households and business
The connection from the carrier to the final consumer (also known as “local loop”) eventually defines the quality of the internet access that citizens and business can use. While this is recognised in the policy, it is surprising that it makes no mention of the importance of ensuring that multiple carriers can reach last mile users and thus improve fixed access, such as through the passive infrastructure mentioned above.

Spectrum allocation
An efficient allocation of spectrum is essential for citizens and business that rely on mobile and fixed wireless services, especially those in rural or remote areas. In this respect, the policy states that “all future allocation of the radio frequency spectrum for broadband shall be done in a manner that advances competition, black economic empowerment, quality of service, universal service and access principles.” Meeting all these needs together in a timely manner will be difficult without special efforts – an aspect that should be underlined in the policy.

Spectrum allocation is the most urgent task for the policy, as the damage caused by delays and changes in the spectrum allocation process means that there is less interest to invest in wireless markets with a process that does not appear trustworthy.

As the high-level justification for action, the proposed Broadband Policy must lay a strong foundation and the focus then needs to shift quickly to implementation. To carry all this out in South Africa’s complex ICT sector environment will require consistent visionary leadership to make the necessary policy changes, and take the tough decisions on how to address the infrastructure bottlenecks and accelerate investment in affordable broadband infrastructure.


1 The NDP’s target is: “A seamless information infrastructure will be universally available and accessible and will meet the needs of citizens, business and the public sector, providing access to the creation and consumption of a wide range of converged services required for effective economic and social participation – at a cost and quality at least equal to South Africa’s main peers and competitors.”

2 SIP 15 (Expanding Access to Communication Technology) aims to: “Provide for broadband coverage to all households by 2020 by establishing core Points of Presence (POPs) in district municipalities, extend new Infraco fibre networks across provinces linking districts, establish POPs and fibre connectivity at local level, and further penetrate the network into deep rural areas. The school roll-out focus is initially on the 125 Dinaledi (science and maths-focussed) schools and 1525 district schools.


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