The Independent Communications Authority of SA (ICASA) has responded to recent criticism of its International Mobile Telephony (IMT) roadmap, saying due consideration has not been taken of events leading up to the publication of the document.
This comes after BMI-TechKnowledge director Tim Parle last week outlined what he said were "several important oversights" within the regulator's plan. The final IMT roadmap was published in mid-November, after what ICASA said was weeks of "extensive public consultation with relevant stakeholders".
While the roadmap was on one hand welcomed and praised for its thoroughness, Parle said critique of the roadmap revealed several notable faults in the plan and its structure.
ICASA has responded to the five points of dispute raised by Parle as follows:
1. "The time for the interested parties to provide responses to this hefty document and complex topic was short." ICASA says it made it clear with an indication in the draft roadmap, published on 27 August, that there would also be publication of the Radio Frequency Spectrum Assignment (RFSAP) for IMT.
2. "The relevance to other studies by ICASA is not clear." The regulator says the consultation documents are clear and specific on IMT systems and the roadmap for IMT 2014. "Studies referred to in the consultation document were made to ensure the deployment of IMT systems in SA conform and meet the requirements as defined by international bodies as in International Telecommunication Union Radiocommunication (ITU-R) reports and recommendations on technical rules on IMT systems and future requirements.
"Obviously, South Africa as a signatory to the ITU Convention has to comply with international rules set out in reports, recommendations and resolutions of the ITU-R."
3. "The overall process of spectrum allocation and assignment remains unclear." It is important to understand the context and the meaning of words used in spectrum management to ensure proper interpretation and use thereof, says ICASA. "The overall spectrum allocation is clearly spelt out in the National Radio Frequency Plan published by the authority in 2013.
"The allocation of a frequency band means an entry in the Table of Frequency Allocations of a given frequency band for the purpose of its use by one or more terrestrial or space radio communication services or the radio astronomy service under specified conditions. This term is also to be applied to the frequency bands concerned.
"The assignment of a radio frequency or radio frequency channel means authorisation given by an administration for a radio station to use a radio frequency or radio frequency channel under specified conditions. The process and procedure is clearly spelt out in the Radio Frequency Spectrum Regulation of 2011. Furthermore, the Radio Frequency Spectrum Migration Regulations, referred to earlier, specify the procedure and process to be followed when effecting assignment of spectrum when migrating users and uses in the identified bands."
4. "The roadmap is incomplete in the sense that it does not cover other important spectrum bands such as TV white space, and industrial, scientific and medical radio bands." ICASA differs, saying the roadmap is complete in that it deals with all services and applications that meet the criterion and definition of IMT systems. "The final IMT roadmap defines IMT as named in ITU-R Resolution 56-1, which is the root name and encompasses IMT 2000 (including enhancement) and IMT Advanced (including enhancement).
"Although TV white spaces, and industrial, scientific and medical radio bands are important for other applications, they, however, fall outside of the definition of IMT and do not meet the criterion and framework of IMT systems."
5. "It cannot take into consideration what the incoming ICASA councillors will think." Councillors come and go at ICASA and things cannot be left unattended because we have to consider their views, says the regulator. "ICASA does not appoint councillors; that is the minister and Parliament's duties and - as things stand - ICASA does not even know who the next councillor will be.
"The IMT roadmap is a long-term plan approved by the council of the authority, having applied their collective minds and taking into consideration the primary objectives of ensuring spectrum efficiency, universal availability of broadband services as well as a vibrant and competitive telecommunications industry that promote investments."
ICASA concludes by saying the IMT roadmap has taken the Radio Frequency Migration Plan 2013 process one step further by assessing the overall demand for mobile broadband and assessing how the identified IMT bands could be cleared for IMT; and how they might be used.
"This includes the development of an IMT roadmap to holistically analyse and plan all suitable IMT bands. The current step in the process from the technical point of view has been to develop a consultation document for RFSAPs for the IMT bands currently under consideration by stakeholders. This includes the development of nine RFSAPs setting the rules for the use of IMT bands."
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