LIRNEasia is a regional ICT policy and regulation think tank active across the Asia Pacific (About)


Rapid Response Program

Based on the idea of the teachable moment, LIRNEasia makes quick responses to specific requests for training/advice by governments/entities in the region. The response primarily takes the forms of (a) a written submission (e.g., to a public consultation or to media) or (b) a country visit that includes one or more presentations. In the case of a country visit, the following rules of engagement apply:

  1. The Requestor shall bear all local costs and will make best efforts to reimburse the receipted airfare of the LIRNEasia Consultant. LIRNEasia shall bear the professional fees of the consultant.
  2. The Requestor will ensure that a productive program with the participation of government, private sector and civil society representatives at a decision making level will be arranged. The Requestor will distribute and make available background documents provided by the Consultant and agreed to by the Requestor.
  3. The Consultant will provide mutually agreed upon deliverables.
  4. The Requestor will provide a report on the efficacy of the visit and any actions resulting from it to LIRNEasia within one month of its completion. LIRNEasia may post this information on its website and otherwise use it in its work.

2011

  • India is without question one of the most important economies.  Telecom plays a critical role within the Indian economy.  Therefore, when the Government of India requested comments on a draft National Telecommunications Policy (NTP 2011), there was no question we would respond.  More could have been said, but we chose to focus on a few areas where we figured the impact would be the greatest and LIRNEasia had a comparative advantage.    The LIRNEasia comments are here.
  • When LIRNEasia was told that the Bhutan Info Comm and Media Authority (BICMA) was considering a new building, the first question that came up was whether an organizational overhaul that would contribute to a new design. The end result was that LIRNEasia Research Fellow and Knowledge Management Specialist Dilini Wijeweera (who is also an architect) went to Bhutan for three weeks to recommend organizational changes and related design parameters for the building.This was brand new territory for LIRNEasia and for BICMA.  But Dilini Wijeweera did a great job.  The design parameters recently issued by BICMA were qualitatively improved as a result: the office space will be conducive to cross-divisional collaboration.  Most importantly, a conversation has been initiated within BICMA on organizational changes driven by commonly held values. Instead of the conventional approach of recommending the emulation of best practices or the acceptance of principles developed by others, she worked from the inside out, identifying the core values of the staff and suggesting organizational design principles based on those values and how they are operationalized in daily practice.  In this assignment, Dilini synthesized knowledge from architecture, knowledge management and organizational theory, as well as telecom policy and regulation.

  Most national regulatory agencies were established in the late 1990s.  They are now 10+ years old.  They were not perfect when they started, but at least they were malleable.  By now, many are sclerotic.  The reboot option tempts, but is not realistic.  The solution appears to be something on the lines of what was initiated in Bhutan.  Of course it is still too early to see if the redesign process catches, but from what we saw during the dissemination visit in May 2011, the chances are good.

Downloads: LIRNEasia response

  • Harsha de Silva, LIRNEasia’s Consultant Lead Economist, made a submission in response to BTRC’s Call for Comments on a draft regulatory and licensing guidelines on renewal of mobile telecommunication services in Bangladesh. The submission focused on a few important issues, relating to economic efficiency, transparency and good governance. The guidelines proposed a license renewal fee of BDT 10 crore from each operator. An additional fee of BDT 150 crore per MHz of GSM  1800MHz band and CDMA frequency; and/or BDT 300 crore per MHz of GSM 900MHz band from each operator for the initial assignment of spectrum, and a subsequent annual fee is also proposed. LIRNEasia questioned the seemingly arbitrary justification used to set the upfront lump-sum license renewal fees. Furthermore, given the substantial sums involved, the basis on which the additional annual spectrum fees had been proposed (currently based on subscriber numbers) was also questioned. Click here to read the full blog post or here to read the full document submitted. Click here to read a follow-up op-ed piece written by Harsha for the Daily Star, Bangladesh.  Another oped in the Daily Star published at toward the end of the process by Rohan Samarajiva is here.

2009

  • Helani Galpaya of LIRNEasia with Alison Gillwald of RIA!, South Africa, responded to the Bangladesh Telecommunication Regulatory Commission (BTRC) on the public consultation paper on proposed Significant Market Power (SMP) regulation. Using the recent experience of South Africa in using SMP in regulation (and contrasting with Namibia and Botswana which do not use SMP), we pointed out that implementing complicated market definitions or SMP determinations was often difficult, even within the sophistcated and progressive structures found in developed countries. Furthermore, implementing them in South Asia, given our levels of development, would be (at best) complicated and (at worst) unfeasible. Hence, it was recommended that BTRC view with caution solutions that are taken “as-is” from developed countries and recommended without recognizing the ground-level realities of Bangladesh.  The full response can be downloaded from HERE
  • LIRNEasia facilitated the publication of an article in one of Sri Lanka’s leading English newspapers by Muhammed Aslam Hayat on regional experiences and concerns with mobile payments. Hayat is a legal expert currently based in Bangladesh but with extensive regional experience. The article was aimed at raising interest around mobile payments, in light of the Central Bank of Sri Lanka’s indication at the start of 2009 that it will be making policies for mobile payments. Not having seen much activity on this front, LIRNEasia facilitated a contribution from Hayat, which was published in the Financial Times, 12 July 2009. The full article can be read HERE.
    • Chanuka Wattegama responded to Bangladesh Telecommunication Regulatory Commission’s (BTRC) Consultation Paper ‘Standardization of Quality of Service Parameters for Broadband Internet Services’ based on the broadband research and testing done in Dhaka, New Delhi, Chennai and Colombo. We said (a) broadband is above 256 kbps, not 128 kbps; (b) minimum bandwidth requirements should be valid beyond the ISP domain; (c) operators should maintain predetermined contention ratios; (d) bandwidth ultilisation should be above 75% on average; (e) latency < 85 ms for local and <300 ms for international and (f) user surveys are important but should be supplemented by user testing which gives a more objective measure. LIRNEasia also offered assistance if BTRC plans user testing.

Downloads: Consultation Paper and LIRNEasia’s Response .

Implementing complicated market definitions or SMP determinations is often difficult, even within the
sophisticated and progressive governance structures found in developed countries. Implementing them in
South Asia, given our levels of development, would be (at best) complicated and (at worst) unfeasible.
We urge the BTRC to view with caution solutions that are taken “as‐is” from developed countries and
recommended without recognizing the ground level realities of Bangladesh.
  • Chanuka Wattegama of LIRNEasia with Timothy Gonsalves PhD and R. Tirumurty of TeNet Group, IIT Madras responded to Telecommunication Regulatory Authority of India (TRAI) on the consultation paper ‘Bandwidth required for ISPs for better connectivity and improved quality of service’. We recommended the use of contention ratios between 1:20 and 1:50 and complement it with user-end testing. We also introduced our own methodology and test application AT-Tester. The recommendations were largely based on our own research in broadband Quality of Service Experience testing. The full response can be downloaded from HERE.

2008

  • Chanuka Wattegama responded to Bangladesh Telecommunication Regulatory Commission’s (BTRC) Draft Regulatory and Licensing guidelines for invitation of proposals/offers for issuing license for establishing, operating and maintaining Broadband wireless access services in Bangladesh. LIRNEasia pointed out that Broadband prices in Bangladesh was one of the highest in the region. Therefore, an increase in supply is necessary. However, LIRNEasia disagreed with the rational of preventing existing operators from offering wireless broadband services. Furthermore, the response stressed that the minimum bandwidth should reflect future consumer requirements and the operators should ensure minimum bandwidths at least upto the first international entry point. The response document can be downloaded HERE
  • Harsha de Silva and Chanuka Wattegama responded to Telecommunication Regulatory Commission, Sri Lanka’s Public Consultation on Planning and Implementing of a National Backbone Network (NBN). LIRNEasia argued that proposal had failed to take into consideration the prospective growth in demand for broadband and that the existing infrastructure was able to cater to the projected demand. The findings of LIRNEasia’s Broadband QoS Benchmarking study were used to show that a NBN would not necessarily bring about the proposed improvements in broadband quality. The full response can be downloaded HERE
  • Harsha de Silva made a response to the Telecom Regulatory Authority of India’s consultation paper no. 2/2008 dated 21st January 2008 on the Access Deficit Charge (ADC) . LIRNEasia was the only non-Indian entity to send in a response.   LIRNEasia agreed with the phasing out of the ADC, taking the stance that the ADC was merely ‘a politically motivated tax on private operators to protect the incumbent, its employees and its copper-wire access network during a very long transition to competition.’ In today’s context   the need for the phasing out the ADC is much greater as there is no need for every new mobile customer getting connected to a network; who is more rural and less affluent, subsidizing a legacy wire line customer; who by virtue of having got connected early on is less rural and more affluent. Subsequently, on 27 March 2008 TRAI announced that the ADC will be completely removed from April 1 2008.

2007

  • A rapid response intervention was made by Harsha de Silva on 8 October 2007 in Sri Lanka on the proposed plans to roll out backbone by the government of Sri Lanka.   Part of this plan included the laying of fibre optic cables along the rail tracks of Sri Lanka Railway. An argument was made that although this is not uncommon in other countries, in a country like Sri Lanka where the regulatory regime is not up to scratch, illustrating a potentially disastrous outcome  using the case of Nepal’s failed smart subsidy program . Moreover, in a country where much backbone already exists in the incumbent possession, focus should be on how to ensure successful infrastructure sharing, whereby exclusivities enjoyed by the incumbent are cut, and a non-discriminatory, cost-based access regime is established.
  • Rohan Samarajiva and Harsha de Silva made a policy intervention on a proposed tax on mobile users in Sri Lanka in August and September 2007.  Whilst conceding the need for taxes as a source of government revenue, LIRNEasia used the findings of the Teleuse@BOP research to illustrate why the Sri Lankan government’s proposed plan to levy a flat monthly tax of LKR 50 per SIM card plus a 7.5 percent mobile levy would disproportionately affect bottom of the pyramid (BOP) mobile users. The outcome was a floor amendment eliminated the regressive fixed tax though the levy percentage was increased.  The change reduced the tax burden on all customers paying less than LKR 2000 (or approx USD 20) per month.  The resulting tax structure no longer unjustly targets users at the BOP.

2006

  • Helani Galpaya provided comments and input on Sri Lanka’s Department of Census and Statistics questionnaire design, for the household computer literacy survey in August 2006; the survey was implemented in October 2006.
  • Helani Galpaya visited the Bhutan Telecom Authority (BTA) from 1-2 September 2006; given the entry of two new private sector newspapers into the market and the upcoming democratic elections (and related campaigning through the media), the BTA was faced with having to decide what type of media regulation it would undertake. LIRNEasia made recommendations in this regard, proposing a workshop with the participation of all players to discuss their options; self-regulation by the participants was also discussed.
  • Rohan Samarajiva and Divakar Goswami were invited to make presentation son what shapers investment decisions in the telecom sector and on current policy and regulatory challenges facing the Indonesian ICT sector at the Seminar HariBhakti Postel 20-06 in Jakarta on 21 September 2006. The seminar was organised by MASTEL , representing a wide spectrum ICT industry representatives and by BRTI, the Indonesian regulatory authority. The audience consisted of commissioners from BRTI, policymakers from the Ministry of Communication and Information, representatives from the operators, industry associations and civil society groups.

2004 – 05 All rapid response actions during this year were undertaken by Rohan Samarajiva:

See detailed Rapid Response Report (2005)

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