Submission on proposed policy on licensing unassigned high-demand spectrum and deployment of the WOAN

In Notice 1003 published in Government Gazette No. 41935 dated 27 September 2018, the Department of Telecommunications and Postal Services (DTPS) invited the public to provide written comments on proposed policy and policy directions to the authority on licensing of unassigned high-demand spectrum.

Our submission is premised on the supply-side challenges identified in the White Paper to transform “South Africa into an inclusive, people-centred and developmental digital society.” As acknowledged, “multiple networks have been rolled out across the country, with deployment skewed towards urban areas,” yet the cost of communications, especially mobile broadband, is far from being affordable to many.

In particular, our submission provides complementary strategies aligned with the White Paper’s goals of defining and treating spectrum “as a public good used to meet public interest objectives” and of managing and using it “effectively and efficiently”. The two complementary strategies proposed are:

• 2x5 MHz of spectrum in the 800 MHz band should be set aside for non-profit, black-owned, small operators.

• Licensing of spectrum in the 800 MHz and 2.6 GHz bands should include Use It or Share It provisions allowing qualifying operators to access unused spectrum on a secondary basis.