TENET’s behind-the-scenes work helps shape public policy

TENET is working to help shape public policy by making four important regulatory submissions on behalf of the SA university community.
TENET’s behind-the-scenes work helps shape public policy
South African Parliament: momo, CC BY 2.0, via Wikimedia Commons

The first half of 2021 has proven to be another challenging year, with South Africans waiting to be vaccinated against COVID-19 amid second and third waves of infection, and universities trying to adjust to a hybrid approach of on-and-off-campus teaching, learning and research.

While providing high-speed Internet connectivity to South Africa’s 26 public universities and expanding the footprint of the global Wi-Fi roaming service eduroam in South Africa, TENET has also been working quietly in the background to help shape public policy by making four important regulatory submissions on behalf of the SA university community.

Here is what has been happening behind the scenes:

ICT COVID-19 National Disaster Regulations

In May 2021, TENET made two important submissions. The first was to the Independent Communications Authority of South Africa (ICASA) in respect of the ICT COVID-19 National Disaster Regulations, and more specifically, addressing aspects of zero-rating.

As SANReN’s operating partner, servicing some 350 separate sites of 85 institutions of higher learning and research, TENET acts on behalf of the Department of Higher Education and Training to approve zero-rating for public universities and AC.ZA domain holders, and is represented on the ministerial task team convened to advise the minister on zero-rating.

According to Guy Halse, who has been leading TENET’s zero-rating response, the network’s submission to ICASA received input from, and is supported by, both Universities South Africa (USAf) and Higher Education Information Technology South Africa (HEITSA).

“The COVID-19 pandemic has fundamentally and permanently transformed the education landscape. Globally, the educational sector expects to retain the current hybrid or blended model of teaching for the foreseeable future. As a result, the need for remote access to educational content will not fall away when the COVID-19 pandemic subsides or when the national state of disaster is lifted,” he says.

In its submission, TENET warns that the normalisation of blended learning will continue to exacerbate the existing digital divide, given South Africa’s spatial and socio-economic challenges, unless meaningful steps can be taken to ensure equitable access to educational resources.

“Such steps will, by necessity, include the continued provision of relevant and affordable access to educational content. It is for this reason that we are requesting a long-term, permanent ‘zero-rating’ regulation to ensure that all students and learners have free or low-cost access to the learning resources they need to succeed.”

National Data and Cloud Policy

TENET’s second submission in May was to the Department of Communications and Digital Technologies (DCDT) in relation to the draft National Data and Cloud Policy, which proposes moving most of the government’s services and data online.

According to the draft policy, a new entity, the State Digital Infrastructure Company (SDIC), will have access to the excess capacity of government-funded ICT infrastructures, including that of SANReN.

“This policy proposal gravely misunderstands the role of ‘excess capacity’ in the design of a national research and education network,” says TENET CEO, Duncan Greaves. “On behalf of the South African research and education community, we respectfully requested that this element of the policy be abandoned.”

In its submission, TENET explains that, unlike the circuits of commercial Internet service providers (ISPs), NREN circuits are always designed with much more capacity than the average load they are expected to bear. The ‘surplus’ is, more accurately, standby capacity, as the network must always be able to carry a large data transfer on demand from researchers. This design principle is broadly characteristic of NRENs worldwide. Without such capacity NRENs would be limited in their ability to respond rapidly to demand, to pivot in the face of emerging circumstances, and to meet unusual research requirements.

TENET also endorsed a submission by the South African Internet Service Providers' Association (ISPA) to the department as broadly representative of the industry, as TENET only addressed this one specific aspect of the draft policy.

Draft Official Identity Management Policy

In February 2021, TENET answered the Department of Home Affairs' (DHA) call for public comment on the draft Official Identity Management Policy (IdMP).

As the operator of the South African Identity Federation, an academic identity federation that facilitates identity interchange amongst higher educational and research institutions on a global scale, TENET is in the unique position to provide invaluable insights gained from first-hand experience of some similar challenges.

"While the first draft is overall an excellent document, we made a number of recommendations, including the need for a national 'levels of assurance' framework for identity proofing which provides an indication of the veracity and trustworthiness of such information," says Halse.

Draft Educational Network Concept Document

In January 2021, TENET provided input to the Department of Higher Education and Training’s (DHET) draft Educational Network Concept Document.

A key concern was that the concept document made numerous mentions of establishing an educational network without recognising that South Africa already has an established and fairly mature national research and education network.

While TENET’s current focus is largely on the university sector and to a lesser extent the Technical and Vocational Education and Training (TVET) colleges, there are many NRENs throughout the world that support the entire post-school sector, and sometimes even basic education. Therefore, TENET proposed that the focus should be on identifying the shortcomings of the existing SANReN, and putting in place specific, targeted interventions, rather than building an entirely new network.