NAB Submission to the DoC on the Draft Convergence Bill

03 February 2004
Convergence means different things to different people and in different contexts. This, however, should not serve as an excuse not to define the concept in the context convergence legislation. Indeed, because of the inherent ambiguity of the convergence concept, there is an immense need to explore and articulate the policy objectives of regulating for convergence. However, apart from the recognition of convergence as inevitable in various policy documents (White Paper on Telecommunications Policy para 2.5, White Paper on Broadcasting Policy chapter 7 and para 11.3, and Green Paper on E-Commerce chapter 9), there has been no specific policy articulated as to the appropriate regulatory response to the inevitable process of convergence.

A more considered and comprehensive approach to the development of appropriate convergence policy for South Africa will help to set the stage for legislative and other interventions to effectively promote and facilitate convergence. The NAB therefore suggests that a green paper / white paper process be immediately initiated, in which all of the issues of convergence should be explored in a holistic and comprehensive manner.

At the same time, the required investigations that need to be carried out by ICASA, the Minister and other bodies should proceed with all deliberate speed to address individual issues. Those proceedings should feed into the convergence policy process and vice verse. As it is now, they are proceeding at their own speed and in some instances without regard to convergence. On the other hand, convergence policy seems to have proceeded without regard to the relevant issues.
  • Submitting organisation: ICASA
  • Submitted to: Department of Communications
  • File: Download
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