Submissions

The SACF welcomes the Policy for High Demand Spectrum and the Licensing of the WOAN, followed by the Information Memorandum as this the beginning of the process to licence critical spectrum to alleviate the spectrum crunch and introduce new players.

The SACF welcomes Treasury’s initiative to focus on ways in which a multitude of interested stakeholders can jointly contribute to moving the economy forward and supports the Discussion Document’s focus on economic transformation, inclusive growth, and competitiveness: Towards an Economic Strategy for South Africa (Economic Strategy document). While we support the intention, we have approached our commentary from the perspective of trying to highlight the key areas of growth as envisaged by the SACF. The SACF welcomes Treasury’s initiative to focus on ways in which a multitude of interested stakeholders can jointly contribute to moving the economy forward and supports the Discussion Document’s focus on economic transformation, inclusive growth, and competitiveness: Towards an Economic Strategy for South Africa (Economic Strategy document). While we support the intention, we have approached our commentary from the perspective of trying to highlight the key areas of growth as envisaged by the SACF.

The tariff structure for all input costs including that of wayleaves nationally across all municipalities are therefore of interest to the SACF and its members. We therefore, put forward our objections to the proposed tariffs included in the City of Tshwane’s Draft 2019/20 Medium-Term Revenue and Expenditure Framework (MTREF) (“the Draft 2019/20 MTREF”) for wayleave applications for electronic communication network (ECN).

We believe that transformation is imperative and acknowledge that it has been an iterative journey, from narrow based transformation to broad-based transformation. We are of the view that broad-based empowerment is central to the achievement of meaningful transformation across the economy as equity acquisitions in firms demands access to capital. Access to capital is a significant barrier for many, especially for Black people due to our historical past.

The SACF reiterates its position that HDI ought to be replaced by the recognition of Broad-Based Black Economic Empowerment (BBBEE) due to its wider application. In this regard, we propose that the Authority, make recommendations to the DTPS to substitute the recognition of BBBEE instead of HDI. Comments on conformity standards.

Persons with Disabilities are an identifiable market segment, which our members strive to better serve as they do all other market segments with a culture of inclusion and understanding the challenges and barriers faced by disabled consumers towards improving the consumer experience. Innovation is key to achieving this.

The SACF on behalf of its members would like to participate in any hearings or further engagements that the Authority may have in this regard. While, we acknowledge that as a country we still have a long way to go on our journey of transformation, our members have made and continue to make significant contributions to transformation and are committed to the goals of transformation.

The ICT ECSPs are concerned that the DoJ is in the process of finalising the Bill without clarifying government’s approach towards cybersecurity issues. This makes it difficult to contextualise the Bill against the challenges that it intends to address. In this regard, we request that the DoJ finalise the NCPF and advice on the extent to which it considered the draft NCPF when drafting the Bill.