Enabling a thriving and leading African digital, communications and telecommunications ecosystem.
Globally, the media landscape is becoming increasingly chaotic and fragmented, but South African telecommunications network operators within the ICT sector are able to speak with one voice thanks the Association of Comms and Technology (ACT). Founded by Cell C, Liquid Intelligent Technologies, MTN, Rain, Telkom, and Vodacom, ACT cuts through the noise to focus on ecosystem matters vital to the functioning of the ICT sector as a whole.
ICT sector advocate
ACT collaborates with stakeholders across the ICT ecosystem to advocate for a thriving communications and telecommunications sector while fostering and sustaining a culture of collaboration, education, research, development, innovation, and technology development. Key strategic objectives include furthering an enabling policy, legislative, and regulatory operating environment conducive to the sustainable development of a transformed, inclusive, and diverse telecommunication network ecosystem ready for the Fourth Industrial Revolution. ACT achieves its objectives by leveraging members’ combined capabilities and assets to expedite empirical research on national policy, strategy, socio-economic conditions, and broader imperatives for industry advancement. These research endeavours have enabled the organisation to provide authoritative and perceptive viewpoints through press briefings, policy submissions, and public participation in high-level forums.
Strategic focus areas
Founded in 2021, ACT spent its first year on raising its profile in the ICT sector. Since then, the organisation has focused on the following ten strategic priorities.
Economic sabotage of physical and digital infrastructure
Over the years, the economic sabotage of physical infrastructure by criminal elements has taken place to the detriment of the industry as a whole. As a result, ACT’s first task was to identify relevant industry research areas, including cybersecurity, where the industry could influence policy intervention.
Effective and capacitated regulatory environment
The objective has been to provide independent and neutral viewpoints on policy and the regulatory environment with a view to creating fit-for-purpose modern policies. ACT has succeeded in identifying and developing a memorandum of understanding framework for research partners. ACT has made contributions to a number of draft policy and legislations, such as the amendment of the Electronic Communication Act, of the Next Generation Radio Frequency Spectrum Draft Policy (“Spectrum draft policy”) and the regulatory changes based on the impact of loadshedding in the sector.
Universal access to future technologies
ACT is developing an ICT digital roadmap aligned with the overall digital roadmap and masterplan of the country’s policy direction. Considering the digital economy’s potential to act as a lever of economic growth, job creation, and poverty alleviation, ACT’s first step was to call for a transversal digital policy focused on critical policy, regulatory, and institutional bottlenecks that could undermine that potential.
Green economies and meeting the ESG demands on the sector
Anthropogenic climate change represents an urgent threat to human societies and the planet and requires an effective, progressive and incremental response. However, the adoption of green technologies to combat climate change has been slow, and a co-ordinated understanding of the sectors’ role in this challenge is lacking. ACT aims to be the sector’s voice and representative in policy discussions and ESG interventions. The association has engaged members on the potential to become a conduit to channel the sector’s commitment, opportunities, and challenges back to stakeholders. ACT has identified channels to conduct industry consolidated research, measuring the collective industry contribution to ESG and establish a framework to benefit the entire industry.
Practical, impactful and cost-effective energy solutions for the sector and country
At the peak of load-shedding, second half 2022 a large amount of capex had to be diverted to backup energy infrastructure. This impacted the industry’s ability to provide good quality services. ACT brought industry members together with stakeholders and agencies to develop energy solutions and determine the necessary interventions. The association successfully quantified expenditure on diesel, batteries, generators, and other alternative power solutions. Subsequently, ACT developed terms of reference for energy agreements in line with the Block Exemptions on energy user granted by DTIC, such as the joint procurement of backup or generation capacity between ICT sector energy users. The goal is to help members reduce costs and alleviate the effects of load shedding while complying with the competition law. Meanwhile, ACT members have been increasingly using diesel to alleviate the effect of load shedding. Consequently, ACT submitted an application for rebates on diesel levies and taxes for the telecommunication industry to the National Treasury.
Sunsetting legacy networks
Globally, mobile network operators (MNOs) are decommissioning legacy 2G and 3G networks, but South African MNOs still have to allocate limited spectrum to keep legacy networks running in parallel with more efficient 4G and 5G infrastructure. Sunsetting these legacy network technologies will open up the spectrum for 4G and 5G networks, making for improved performance and faster data rates, to the benefit of all citizens. To this end, on 8 September 2022, Minister of Communications and Digital Technologies Ms Khumbudzo Ntshavheni published the Next Generation Radio Frequency Spectrum Draft Policy (“Spectrum draft policy”) stipulating the shutdown of 2G and 3G networks by specified dates. However, the Spectrum draft policy did not consider the supporting data on end user impact. Abrupt sunsetting could leave communities stranded without access to potentially unaffordable modern devices capable of operating on 4G and 5G networks.
Reciprocity implementation in international termination rates
The Independent Communications Authority of South Africa (ICASA) is seeking to amend the Call Termination Regulations of 2014 specific to the markets for wholesale voice call termination, in terms of section 67(8) of the Electronic Communications Act of 2005. ACT has engaged ICASA on the regulations and their implications on an ongoing basis. ACT support bilateral agreements in order to facilitate the reduction in roaming fees given that such can only be enforceable in the event that all SADC Countries have similar provisions.
Spectrum-related social obligations
The terms of the International Mobile Telecommunications (IMT) spectrum licence awarded by ICASA as a result of the Invitation to Apply (ITA) auction on 8 March 2022 impose social obligations on licensees to connect the following public service institutions (PSI): 18500 Public schools, 3967 government clinics, 1764 government hospitals, and 8241 traditional authority offices. ACT has been engaging relevant stakeholders and seeking coordination to ensure that social obligations can be implemented and that past lessons are heeded. ACT has proposed the establishment of a Project Management Office (PMO) to assist members to implement their respective social obligations by facilitating, coordinating, and enabling decision-making among stakeholders, especially with regard to supporting stakeholders and proactively resolving implementation bottlenecks.
National relay system implementation
In 2021 ICASA published the Code for People with Disabilities Regulations. In terms of the Code, all ECS licensees must provide for a National Relay Service (“NRS”) which translates voice to text and vice-versa, provides captioned telephony, and – in what has proven to be a complex and costly requirement – provides video relay services with interpreters. The purpose is to assist persons who are deaf or have a hearing or speech impairment to communicate in a manner functionally equivalent to persons without such impairments. ACT has aimed to explore collective efforts, comply with the requirements, and ultimately benefit the end user given that the area in question has no competitive implications. Members have developed an information-sharing agreement on technology, compatability and standarisation for the initiative in line with the Competition Act, and ACT keeps the Competition Commission updated on a regular basis. Going forward into 2024, this subject has assumed a lower strategic priority, as members are piloting their own innovations to meet requirements.
Analogue switch-off
The migration to digital television broadcasting will free up spectrum from broadcasting services to mobile connectivity usage. Some of the spectrum has been auctioned to ACT members. The association’s role has been to monitor and engage relevant government agencies on analogue switch-off. As an indication of progress, on 31 July, the Minister of Communications and Digital Technologies did a ceremonial switch-off of analogue transmitters above 694 MHz in Western Cape.
Focus areas in 2024 and beyond
Policy formation continues to be ACT’s primary concern, particularly in light of the Electronic Communications Amendment (ECA) Bill being introduced for the year 2024 and beyond. The association advocates for the implementation of a comprehensive digital policy to address significant policy, regulatory, and institutional obstacles that could impede the nation’s ability to harness its full potential. This policy should encompass over-the-top (OTT) activities in which participation and local economic impact are accompanied by equitable obligations and responsibilities, namely fairshare. It has been recognised that the effective operation of ACT’s strategic subcommittees is critical to achieving the organisation’s goals of addressing critical issues and advocating for member interests. The subcommittees have demonstrated expertise in submitting developing technical work essential for gaining industry-wide insight into policy and regulatory approaches.
