Draft Policy Directions - Please provide your feedback (new deadline: 22 Feb)

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ellipsis

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This refers to the Draft Policy Directions on Radio Frequency Spectrum for Electronic Communications Services in High Demand Spectrum and on Exploiting the Digital Dividend, which you will find here.

Mybroadband will submit your comments to the DoC. Please post your comments on the Draft Policy Directions - you can do so until 20 January 2012, after which we will compile the submission and circulate it for your further input. Final date for submission is 31 January 2012.

EDIT:
New deadline for submissions is 29 February, so feel free to add your comments.
 
Last edited:
Note that you only need to read pages 4, 5, 8 and 9 of the document - that's where the content is.
To help you out a little, herewith a summary (there's not much to summarise, so some of it is a duplication...).

Draft Policy Directions for Electronic Communications Services in High Demand Spectrum

Background
Licensing of high-demand spectrum should achieve the following policy directives: the introduction of new national and rural providers of electronic communications; participating licensees contributing to BBBEE; imposition of universal service and access obligations.

A combinational licensing approach of 800MHz (790-862MHz) and 2.6GHz (2500-2690MHz) will achieve the Government objectives of delivering and efficient, competitive and responsive infrastructure network - 2.6GHz being suited to providing the high capacity to carry traffic in densely populated areas, and 800MHz being suited for achieving broadband nationwide coverage, in building penetration and indoor coverage (delivering mass market broadband at a lower cost due to fewer base stations being required).

Policy Directions
ICASA is directed to:
  1. Determine an appropriate licensing method to achieve objectives of universal access, introduction of new entrants and economic empowerment;
  2. Licence 800MHz based on a wholesale open access network, due to limited bandwidth in this band;
  3. Licence 2.6GHz to multiple operators, ensuring that a portion is set aside for new licensees;
  4. Consider an auction only as the last resort, where necessary;
  5. Where the demand exceeds available bandwidth, apply auctions for assignment of the spectrum;
  6. Establish obligations on priority stages for network roll-out on the basis of a number of inhabitants per area, thus ensuring availability of broadband in sparsely populated, rural and remote areas;
  7. Explore a combinational award of 800MHz and 2.6GHz for wireless broadband access applications, to ensure for efficient spectrum utilisation and to allow for the introduction of new entrants.


Draft Policy Directions on Exploiting the Digital Dividend

Background
The consideration of the scope of action to be taken at national level to promote efficient use and maximised benefits of the digital dividend spectrum while complying with the ITU Regional Agreement of the planning of digital terrestrial television broadcasting services in ITU Region 1.

Policy Directions
ICASA is directed to:
  1. Consider the declaration of 800MHz as the first phase of digital dividend;
  2. Conduct an inquiry into the rational and efficient exploitation of the remaining VHF (Very-High Frequency) and UHF (Ultra-High Frequency) spectrum for future digital dividends, and report to the Minister on:
  • Future spectrum requirements of the 3 spheres (public, community, commercial) of digital terrestrial television broadcasting in the next 10 years;
  • Future spectrum requirements for digital sound broadcasting after analogue switch-off;
  • Possible use of white-space technologies;
  • Implemenation of large and small multiplexes within the framework of the national digital broadcasting frequency plan;
  • Future spectrum requirements for mobile broadband application in digital dividend over the next 10 years;
  • Consideration of the possible impact of any recommendations made on the digital dividend on neighbouring countries that are also parties to the GE06 Agreement.
 
Oh god. Race coming into this too. Bloody BBBEE again.

When will this crap sunset and work be given to whoever is most capable and efficient regardless of what they look like?
 
If the goverment was serious about delivering mass market broadband, why not allow entrepreneurs to use TV white spaces! Equivalent of WiFi on steriods and already successfully trialled in the US.

White spaces are an enormous, underutilised resource that the general public could be using for the next-generation digital media and low-cost communications, or can even provide broadband connections between rural areas. Several hundred megahertz of sub-900MHz spectrum frequency ready to be put to good use by telecoms entrepreneurs, but this precious resource is currently being wasted by virtue of the fact that it is underutilised.
 
Just to add my bit:

This looks like a good, solid plan save for two weaknesses:
1) I believe "Where the demand exceeds available bandwidth, apply auctions for assignment of the spectrum;" may be easily exploitable by the big operators as they may simply exaggerate the demand they have for spectrum and as such force an auction where it is easily evident that only they may come out as the winners.

2) "Licence 800MHz based on a wholesale open access network, due to limited bandwidth in this band;" may be a very difficult thing to achieve as rolling out networks with almost no compensation would not entice any operators. Great compensation would be necessary and as such I think it would be better suited to have an open access network but with service fees which decline yearly such that after X amount of years the network may be paid off and would become free for true open access.

I do however believe that the directions lack a major consideration which is the emergence of new technologies. It would be most beneficial to add a clause allowing for shared spectrum access (more correctly Dynamic Spectrum Access) by technologies such as cognitive radios and future implementations of IEEE 802.22 and IEEE 1900. This may be easily added as a license exemption for standard-compliant devices as these standards themselves are designed for optimal operation without any interference to current, licensed users. This would also allow much increased innovation and effectively level the playing field for newcomers as they would be able to provide operations without the huge capital expenditure necessary to just obtain spectrum alone.
 
The big concern for me is that the intentions of the policy directive may be noble, but that the execution and the result may well be that spectrum is once again wasted, like in the case of Sentech.

I would like to see that most of the LTE spectrum must become available to operators which are certain to use it – hence Vodacom and MTN, and to a lesser degree Telkom and Cell C.

Whatever needs to be done to ensure that South Africa sees LTE quickly.
 
Emergency and Disaster Management

There was a very interesting woman at iWeek 2010 - an Amercian called Karen something - she spoke to the ISPA guys and had some very sane and simple solutions to spectrum allocation and management that she's helped implement in many 1st world auctions/allocations around the world... as there was both an ICASA and DoC rep there I wonder if they every talked. Would be annoying to think that another strategy has been put in place without much global input.

BBBEE and rural roll-out for the corporates is all well and good but this approach only ensures that the people profit from the economically viable areas and systems. There definitely needs to be something in there for cooperatives to allow rural groups to setup and connect their owns systems where it's not financially viable or are only long-term planned for 2020. It's simple to impose professional standards but they must be allowed to use this bandwidth and also to purchase network access at reasonable rates.

On a side note to the money-making practice of spectrum allocation:
I would also like to see standard spectrum reserved for the Emergency Services, Utilities and Disaster Management & Emergency broadcast to stream live video from emergency/failed areas.. Also for police in-car video, databasing etc. etc...

Of course I am not suggesting that we replace the much needed emergency FM, analogue TV and digital TV broadcast frequencies.

Database centralisation, improved monitoring for policing & emergency services and a national disaster management network infrastructure are the fundamentals to a well run country. It would be nice to think that people are thinking of the future as well as the desire for more income in to central government coffers.
 
Note that TV white spaces are specifically mentioned in the draft direction on exploiting the digital dividend. Personally i think it is nothing short of staggering that a document from the SA Minister of Communications specifically takes cognisance of a technology and directs ICASA to investigate it (I can think of no other occasion where this has occured). That this has happened is in no small part due to lobbying from the Wireless Access Providers' Association (WAPA) and others directed at the previous Minister.

There are plans for two TVWS pilots in SA in 2012...

execMobile said:
If the goverment was serious about delivering mass market broadband, why not allow entrepreneurs to use TV white spaces! Equivalent of WiFi on steriods and already successfully trialled in the US.

White spaces are an enormous, underutilised resource that the general public could be using for the next-generation digital media and low-cost communications, or can even provide broadband connections between rural areas. Several hundred megahertz of sub-900MHz spectrum frequency ready to be put to good use by telecoms entrepreneurs, but this precious resource is currently being wasted by virtue of the fact that it is underutilised.
Click to expand...
 
Excellent...

I don't have an issue with the demand exceeds supply bit being exploited. Seems to be clear that this is already the situation for all frequencies currently allocated to access services.

It will be very interesting to see the detail (lot of detail, lot of devil) of the wholesale network option but for now I just like it as progressive thinking and something different from the exclusive use model....

See previous post re TVWS & could not agree with you more. Ideal would be to open up 470-792MHz for secondary use on a licence-exempt basis (but hear the distant whining of the broadcasters)

UnUnOctium said:
Just to add my bit:

I do however believe that the directions lack a major consideration which is the emergence of new technologies. It would be most beneficial to add a clause allowing for shared spectrum access (more correctly Dynamic Spectrum Access) by technologies such as cognitive radios and future implementations of IEEE 802.22 and IEEE 1900. This may be easily added as a license exemption for standard-compliant devices as these standards themselves are designed for optimal operation without any interference to current, licensed users. This would also allow much increased innovation and effectively level the playing field for newcomers as they would be able to provide operations without the huge capital expenditure necessary to just obtain spectrum alone.
Click to expand...
 
rpm said:
The big concern for me is that the intentions of the policy directive may be noble, but that the execution and the result may well be that spectrum is once again wasted, like in the case of Sentech.

I would like to see that most of the LTE spectrum must become available to operators which are certain to use it – hence Vodacom and MTN, and to a lesser degree Telkom and Cell C.

Whatever needs to be done to ensure that South Africa sees LTE quickly.
Click to expand...

Nobody likes a cynic in early January ;). But, well, yes...
 
ppedrick said:
There was a very interesting woman at iWeek 2010 - an Amercian called Karen something - she spoke to the ISPA guys and had some very sane and simple solutions to spectrum allocation and management that she's helped implement in many 1st world auctions/allocations around the world... as there was both an ICASA and DoC rep there I wonder if they every talked. Would be annoying to think that another strategy has been put in place without much global input.
Click to expand...

http://www.iweek.org.za/karen-wrege-founder-wrege-associates/
she did have some interaction with ICASA iirc
 
Reminder to interested parties to give us your comments by 20 Jan...
 
There have not been many posts in this thread. Are you still open to comments on the Draft Policy Directions before 31 Jan?
 
WireFree said:
There have not been many posts in this thread. Are you still open to comments on the Draft Policy Directions before 31 Jan?
Click to expand...

Yes, we are. Please post your comments. I'll have something up by Monday, and will add any other comments you may have. We will submit to the DoC on Tuesday.
 
My zwei-cents on the wholesale open-access network.
I don't think it is true that wholesale means no, or even necessarily "low" profits in the traditional view of what that would entail (eg a stagnating and or struggling business). "Wholesale" in this context needs to mean (if it does not already, then this must be addressed) that the entity operating such a network makes at the very least a normal profit, if not a super-normal profit.
In the material world, we have wholesalers, for eg the base material to make LCDs. They sell these to say Sony, Toshiba, Samsung and the like who add value to these materials, and use proprietary technology to differentiate their products. The wholesaler, is by no means struggling. If Toshiba steals Samsung's market share the wholesaler will not be affected. The pie's been cut up a different way, sure - but the wholesaler is still getting to sell the entire pie anyway.
If Sony through innovation manages to increase the size of the market (maybe through lowering their own costs, and thus stoking greater demand) - the wholesaler benefits too.
it is thus not a given that wholesale means poor or low profits - it all depends on our assumptions of the pricing model adopted by the operator will be. If they shoot themselves in the foot by not assessing their costs correctly, then this is merely a question of poor business decision making or risk assessment, rather than a question of retail vs wholesale as competing models.
I support the wholesale concept as long as it is implemented in such a way that this wholesale operator (let's call it Optimus MegaCom) is sufficiently bound by a competent regulator to oblige by evidence and policy based roll-out targets and objectives. (e.g
1) Use it or lose it.
2) Transparent and clear open reporting at regular intervals
3) Regular accountability tribunal meetings where the public get to ask/question/complain direct to management)
 
ellipsis said:
Have a read: http://dl.dropbox.com/u/24829246/MyBB_Submission_Draft_Policy_Directions_310112.docx

Comments, criticisms, suggestions, edits, etc all welcomed.

I'll check back in at 15h00, make any changes required and submit by 16h00.
Click to expand...

Looks good.

In my opinion spectrum is a national resource. Assignment of high demand spectrum should not be monopolised by a few entities. The spectrum assignment process should also aim to increase competition in the supply of wireless services as competition will help to drive down prices.

The currently assigned GSM and UMTS spectrum is assigned to a few entities who do not provide wholesale access to their radio network to entities who do not have spectrum in these bands. ICASA should be required to investigate other avenues where licensed operators can access spectrum held by the incumbents, at a wholesale level. One example would be MVNO Regulations similar to those in
- Brazil (http://www.internationallawoffice.com/newsletters/detail.aspx?g=bffed9bb-67b7-46ce-85ee-6c14d779828f) and
- India (http://www.ictregulationtoolkit.org/en/Publication.3636.html and http://www.ictregulationtoolkit.org/en/Document.3636.pdf)

WireFree
 
hi WireFree

one of the outcomes of the LLU "process" is that ICASA will be looking directly at how to introduce competition in services over the MNO networks and MVNOs are obviously one of the prime options. Have no idea when this will be done though...

pricing of wholesale products by the MNOs is currently a massive problem waiting for someone with big enough testicles to take it to the Comp Comm (who i think were looking at this towards the end of last year of their own volition but not sure of the outcome)
 
dominic said:
one of the outcomes of the LLU "process" is that ICASA will be looking directly at how to introduce competition in services over the MNO networks and MVNOs are obviously one of the prime options. Have no idea when this will be done though...
Click to expand...

But I am sure the Minister can still include this in her Policy Directions as the currently assigned GSM and UMTS Spectrum is also "High Demand Spectrum". ;) Then at least this task would get her Stamp of Approval.

WireFree
 
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