Though I applaud the D.O.C. in their efforts in trying to help, this policy is flawed and tries to implement policy that hinders and contradicts it's own aims.
The policy specifies that the goal is : 2.1.1 - formation of a "people-centred, inclusive and development-oriented Information Society, where everyone can create, access, utilise and share information and knowledge, enabling individuals, communities and people to achieve their full potential in promoting their sustainable development and improving their quality of life."
Then, the policy proceeds to create divides between "everyone", and suggests that the only way forward is for government to monopolise everything. The policy also strictly specifies that ONLY marginal areas will receive government aid, whereas, the entire country should benefit from any aid that is available, which is what EVERYONE means. It IS NOT NECCESARY to differentiate between who gets aid. Stop this senseless discrimination. The aim is to grow all the services available, not just certain select services.
More specific details:
In (2.3), the policy decides that the only way to ensure that government can provide better service to it's citizens is for government to develop it's own local content. This decision contradicts the previous aim to provide opportunities to everyone to provide content. A better approach would be for government to provide the facilities, training and access to information that potential content creators would require to do that task. The government must not compete with the people it serves.
In (3.1), the policy implies that municipalities must sell broadband. Once again, the government is stealing opportunity from the people they are pretending to help, and at the same time eliminating any potential for competition. The government must not provide broadband, but instead provide opportunity, training and financial aid to anybody who is willing to try to provide the services within the communities. The provision of this helping hand must be structured in a staged manner so that cash is not squandered on applicants that do not achieve. The aim is to generate skills and competition and therefore a better service to the entire populance.
The entire section: 4.1 - Access; is moot. The opening statement says that every citizen has a right to access to basic broadband. There is no need to add anything to this statement. Further creating division by listing: needy people, government institutions and mentioning limited radio spectrum simply dissolves the point made in 4.1., creating confusion and blurry lines. We need crisp and clear policy, not blurry lines.
In (4.2) - Affordability; The policy assumes that more is equal to cheaper on the infrastructure side. However, this is like saying that more roads creates cheaper roads. Infrastructure costs money to maintain and fund. The correct approach is to force shared utilisation of infrastructure, and once infrastructure is fully utilised, to force the upgrade of that infrastructure. In addition, under-utilised infrastructure must be highlighted so that opportunities to utilise these can be recognised and taken advantage of. The last point completely contradicts the first point. The wishy-washy instructions of this section is confusing. The policy clearly admits that "sharing infrastructure" can significantly reduce costs, but fails miserably in that is does not specifiy the infrastructure must be shared, thereby contradicting itself and not actually creating policy.
In (4.3) - Uptake and usage; Once again governemnt has decided to be the only provider in urban and rural areas, and to only perform these steps within urban and rural areas. Change 4.3.1 to: All government departments will utilise ICT. Government will also actively encourage the formation of community based ICT services and tools that provide the community with direct access to governemnt facilties and services. These facilities/services must be actively created and run by the communities themselves, and the government is to provide the enablers for this to happen, whilst simultaneously stimulating competition and opportunities to compete.
Security will take care of itself, there is absolutely no need for government to pretend to be a security IT specialist, competitors providing a more secure service will be more succesful than those that do not if the market so desires. Regarding awareness, the government must identify and market specific opportunities directly to the correct audience. No more blanket marketing of vague opportunities to the country, the policy must specify direct and specific marketing of specific opportunities to specific audiences, while ensuring that the companies that provide this "awareness creation service" are competing for the priveladge. The policy must once again steer away from saying that goverment will do it.
4.4, Roles - Government must NOT decide that it must provide it's own broadband infrastructure. Government must instead provide opportunities for infrastructure to be provided. And it must encourage competition. Point 4.4.1.1 simultaneously says that government must provide all infrastructure to government while specifying that the private sector must be stimulated to build their own infrastructure. Surely the private sector could provide the infrastructure for the government, that way an opportunity is created by government, instead of monopolised by government. Once again, government wants to create it's own local content instead of encouraging and enabling the creation of local content. This section also creates an allowance for local government to hire skills to build their own networks, stating that it should be financially sustainable. This is a ridiculous situation, where the municipality can simply raise the rates and taxes to cover the costs. This situation is not only undesirable, but also severly detracts from good service delivery principals. State owned enterprises do not encourage competition, and should not be included in a competition encouraging policy.
4.5, Implementation - The steering comittee must make itself available to the communities they serve. Step number one should be the formation of this steering comittee's transparency using ICT. This comittee must lead by example, and be open to criticisim. Remember that the aim of this policy is to provide broadband to EVERYBODY, which means that everybody should have a say in what is happening as much as possible.
Using broadband penetration as a measurement of success is rediculous. 100% broadband penetration with monopolised services and infrastructure heavily funded by tax money is not success, it's complete and total failure. A better measure of success is to count the number of companies created that are part of the competitive environment, and to count the jobs created withing those self-sustaining companies, then to measure the comunities served and the types of services they get.
General:
The policy spends too much time mumbling about percieved benefits without bothering to consider practical implementation and the cost of such implementation. Once again, the policy completely forgets about creating a competitive environment and decides that government must provide a single solution, without competition, funded by taxpayers. The reality is that the beauty of ICT is the myriad of components that make up the whole can change and shift at any time, forming the perfect environment for a competition driven society, and policy MUST take advantage of that.
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I shall be mailing this off tomorrow once I have given my brain some time to think.