Presentation to the Portfolio Committee on Science and Technology

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Presentation to the Portfolio Committee on
Science and Technology

• By Vodacom (Pty) Ltd
• 1 August 2007

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Introduction

• Vodacom thanks the Portfolio Committee on Science
  and Technology for the opportunity to make oral
  presentations on the Bill
• Vodacom welcomes and supports the noble
  objectives of the Bill, including the development
  of skills, capabilities and expertise of those
  engaged in Radio Astronomy in Southern Africa.

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Agenda

• Introductory remarks
• Consultation with stakeholders
• SKA Preliminary Design
• Mitigation Techniques
• Consultation with communities
• Potential Impacts on Vodacom
• Comments/Recommendations on provisions in the
  Bill
• Closure

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Consultation with stakeholders

• Although the Memorandum on the Objects of the
  Bill does not mention the Mobile Operators
  (MOs), consultations with the Square Kilometer
  Array (SKA) team are taking place.
• The SKA team and the MOs have discussed technical
  issues on protecting the core and central
  Astronomy Advantage Areas (AAA)

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SKA Preliminary Design

• The core AAA is deemed to be 5-10 km in diameter
  and contains 50 of the collection area.
• The central AAA is a buffer zone around the core,
  with more relaxed thresholds
• Mitigating strategies focus on maintaining
  partial operation of RF devices with no or
  limited operation in the direction of the SKA
  core.

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Map provided by SKA Team
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(No Transcript)
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Mitigation Techniques

• SKA will operate from 100 MHz to 25 GHz and the
  Karoo Array Telescope (KAT) from 700 MHz to 1750
  MHz
• SKA and cellular frequencies overlap
• Vodacom will attempt to provide as much
  protection as possible to the core and central
  buffer zones in the direction of the core zone
• At sites outside this area, current proposed
  threshold levels will be impractical to attain,
  especially in respect of the SKA remote stations.
• There is no consensus on the actual threshold
  levels to adhere to in the non-astronomy bands

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Current Vodacom Site 1
65 km
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Site 1 with Mitigation Techniques
65 km
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Current Vodacom Site 2
68 km
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Site 2 with Mitigation Techniques
68 km
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Consultation with communities

• We are not aware of consultations on the impact
  on affected parties such as communities,
  industry, farming and underserved areas.
• The Minister should investigate impacts on, and
  sacrifices by, communities resident in Astronomy
  Advantage Areas (AAA) should restrictions be
  placed on mobile cellular services.
• Alternative communications methods should be
  provided where mobile cellular service is
  restricted.

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Potential Impacts on Vodacom

• Vodacom has major communications infrastructure
  investments in SA to bring communication services
  to the public and to bridge the digital divide.
• Where the network infrastructure within the AAAs
  causes interference to radio astronomy
  activities, the infrastructure may have to be
  dismantled, which would result in heavy losses.
• The MOs have national roll out, Universal Service
  and Community Service Obligations, apart from
  commercial and spectrum interests, and may be
  negatively affected by some provisions in the
  Bill.
• Vodacom welcomes the provision in the Bill which
  provides for compensation to be paid

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Comments/Recommendations on provisions in the
Bill
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Register of Interested and Affected Parties

• Section 7(3)(a) provides that a declaration under
  subsection (1)(a) may be issued only if the
  Minister has beforehand conducted a section 42
  public participation process and has compiled a
  permanent register of interested and affected
  parties for the core AAA.
• Vodacom is a licensed mobile cellular operator
  providing communications on a national basis and
  should be registered as an interested and
  affected party on the Ministers permanent
  register of interested and affected parties.
• This comment also applies to the provisions of
  section 9(3)(a) and mention of register in
  sections 11, 16, 21, 22, 23, 24, 27 and 25.

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Withdrawal of declaration or exclusion of part of
Core, Central, or Coordinated AAAs

• Sections 8, 10 and 12 provide that the Minister
  may withdraw the declaration of an area as a
  core/central/coordinated astronomy advantage area
  or as part of such existing astronomy advantage
  area or exclude any part of an existing
  astronomy advantage area from such area.
• The Bill should specify under which conditions
  such withdrawal of the declarations may be made.

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Restrictions within core and central astronomy
advantage areas

• Section 20(1)(c) provides to the effect that no
  person may, without the written permission of the
  management authority, have in their possession
  within a core astronomy advantage area any radio
  interference source, unless the source is turned
  off and is incapable of causing any form of radio
  frequency interference
• These provisions imply restrictions on general
  access to the core/central areas.
• Vodacom submits that its personnel might need
  access to these areas where co-ordination areas
  have been agreed between parties.

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Declared activities in core or central astronomy
advantage area

• Section 23(3) provides that the Minister may
• a) in relation to activities contemplated in
  subsections (1) and (2), require that any
  activity cease subject to payment of
  compensation, if required by section 25 of the
  Constitution or
• (b) prescribe conditions under which any activity
  may continue in order to reduce or eliminate the
  impact of the activity on astronomy advantage in
  the relevant area.
• Vodacom submits that this provision may be used
  to request compensation in the case where current
  Vodacom base stations are prohibited to operate.
• Customers in these areas (business, farming,
  communities etc) may require dedicated low power
  highly directional point to point links or fixed
  line operations to continue services.

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Authorization to undertake identified activities

• Section 25(6)(a)(ii) provides that the competent
  authority must specify the information to be
  provided in a report required in terms of
  subsection (4)(a), provided that such report must
  include alternatives to an identified activity if
  it is likely to cause RF interference
• If Vodacom needs to adhere to Radio Astronomy
  threshold levels in spectrum bands allocated to
  Mobile or Fixed services, the impact on customers
  in the core/central zones will be major.
• Alternatives to the identified activities will
  have to take into consideration service, quality,
  coverage, cost, financial and social implications
  on the affected parties.

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Consultation between the Minister and the
minister of communications

• Whereas Section 22 of the Bill provides for
  consultation between the Minister and the
  minister of communications. Section 37(1)
  provides that the Minister may prescribe
  regulations impacting on the RF spectrum, but
  does not mention consulting with the minister of
  communications and ICASA.
• The current mechanism provided for in the
  Electronic Communications Act for managing the
  spectrum resource is adequate to ensure proper
  coordination.
• Consultation between the Minister and the
  minister of communications, combined with
  policy by the latter and policy directions to
  ICASA should avoid un-coordinated impacts on the
  RF spectrum.
• Vodacom recommends that the Minister of
  Communications retains total responsibility for
  the RF spectrum and that protection of astronomy
  advantage be facilitated by consultation between
  the Minister and the Minister of Communications.

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Regulation by the Minister

• Section 50(c)(v) provides for the Minister to
  make regulations on the use of the frequency
  spectrum in astronomy advantage areas
• Section 50(d)(ii) provides for the prohibition or
  restriction of the use of any interference
  source, mobile and portable radio frequency
  interference source or equipment which may
  cause , radio frequency interference within
  an astronomy advantage area
• Regulations pertaining to the use of sources
  interfering with the RF spectrum should be dealt
  with in terms of existing legislative instruments
  i.e. ECA refer to the previous slide.

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CONCLUSION

• Vodacom thanks the Portfolio Committee for the
  opportunity to give this presentation
• We welcome any questions