Telecom policy review, finally!

The outdated 2003 telecom policy framework has been waiting a review since 2008. The Ministry of IT (MoIT) started the review process last year by hiring a British consulting firm. Now the new five-year policys draft has been released on its website. Sifting through the generic details, here are a few key observations BR Research has found worth sharing from that draft.
There is realisation that regulations and market forces have to find new ways to see the kind of growth previously seen in the 2000s. To achieve that, the policy draft maintains the open and competitive nature of the telecom market. However, existing licensing frameworks for LDI, landline, cellular mobile and class value-added services remain in place, till the MoIT review in July 2020.
Strong focus on consumer protection is refreshing. Draft notes that PTA will subject all telecom services to minimum quality of service (QoS) standards. QoS benchmarks will also be applied to "marketing, customer provisioning processes, billing processes, customer support processes, payment processes and repair associated with such services."
An affordable, entry-level tariff has been made mandatory for broadband services. Operators will now have to publish customer charters, provide standard contracts for customer use, and prevent unsolicited and fraudulent communications through their networks. All cellular operators will immediately become members of the global IMEI database to block stolen phones and equipment importing their way to Pakistan.
Encouragingly, the draft states that PTA and CCP will hash out their respective roles regarding market regulation of the sector, in light of the Telecoms Act and the Competition Act. Both will work together to develop a Competition Framework to put a curb on anti-competitive behaviour. Such framework will extend beyond retail services, to include upstream, wholesale services like interconnection and backhaul. PTCL will be monitored for fair behaviour in selling its backhaul and broadband services to other operators.
There is recognition that VoIP and over-the-top (OTT) services have to be accommodated. The draft recommends that broadband service providers should be free to enter into revenue agreements with OTT providers. Net neutrality also figures in the policy, whereby internet service providers are required to provide their users access to all services without discrimination or favour for their own services.
The policy also gives a nod to public Wi-Fi services. It notes that "Provision of Wi-Fi in-building, in-vehicle and external commercial hot spots based on IEEE802.11 standards shall be allowed. PTA will put in place any necessary licensing and other regulations... Facilities that enable broadband communications will be installed in new buildings built by state, municipalities and government enterprises."
The draft also discusses both soft and hard telecom infrastructure. Future spectrum allocations will continue to be technology-neutral but latest technologies will be preferred. Fiber optic is preferred over copper for wire line connectivity. PTA will consult the sector on cost and time needed for transition. Mobile broadbands role is rightly in the spotlight, but there will be challenges, as noted here:
"The growth of broadband, particularly mobile broadband, will require very rapid expansion in capacity of backhaul and transit networks, international capacity and the provision of spectrum for cellular networks. Meeting these two requirements, growth in network capacity and availability of scarce resources will be critical to the success of the sector in delivering economic benefit over the policy period."
To meet those issues, effective spectrum management has been emphasised. The draft states that a "spectrum strategy" will be published annually by the PTA to outline the next three-year plan. The strategy will update the stakeholders on matters like existing spectrum audit, spectrum re-farming for high-value use, new spectrum availability, future spectrum auction plan, and spectrum trading.
After amendments in the Telecom Act, the policy will empower PTA to monitor the sectors renewable energy footprint, carbon emissions, e-waste recycling, post-construction environmental restoration, etc. MoIT has signaled it may, after studying the feasibility, require operators to use alternate energy resources to power their networks, to comply with the 2005 Environmental Policy.
For all the good thing the draft did mention, a few other things also needed attention. Only the significant market powers in a given telecom segment are required to share infrastructure with others, the rest are not required. Similarly, there is no requirement for national roaming, only an encouragement.
There are no milestones to increase the currently-low fixed broadband tele-density of 1.7 percent. There is no strategy for implementing broadbands "useful connectivity" in health, education, governance, security, etc. The draft mentions the noble pursuit of e-governance, but a roadmap is lacking. In short, there are vague goals but no specific outcomes. Perhaps segment policies will address that.
Nonetheless, it is a first draft which commendably contains many positives. After feedback is received by the stakeholders till July 20, one hopes its quality and scope will further improve.