Critical Analysis of National Telecommunication Policy of Bangladesh (1998)

Tahmina Afroz

NORAD Scholar, MPPG Program, North South University, Dhaka

E-mail: silvia@bdosn.org

Abstract

This paper is a comprehensive evaluation of the National Telecommunication Policy of the

Government of Bangladesh. To the author's knowledge this study is first of its kind where the

evaluation has followed the proposition of a formal and concrete model. The evaluation model

comprises the technological landscape and the socio-eco-cultural fabric. The author also

dedicates a separate section to find out how much the policy is aligned with respect to other

public policies and regulations. With the appraisal of current achievements, the study proposes

categorical recommendations about the opportunities of improvement in the policy. Through this

paper, the author also proposes a blue print of standard evaluation of public policies which

involve modern technologies.

Key Words: Telecommunication Policy; Telecom Services

1. Introduction

The National Telecommunication Policy [6], 1998, is the Rosetta stone for regulating over all

telecommunication activities within the territory of Bangladesh. As the policy covers a number

of important issues to different levels, a comprehensive study from different perspective with

detailed analysis is required. Being a regulatory policy, in terms of specialization and

individualization, it is not as extensive as a distributive policy. As it is the first of its kind in

Bangladesh, it is not expected that the maturity and completeness will be same as the other

developed countries. This paper aims to discover the insight and motivation behind the policy

which will shape the future of the telecommunication in Bangladesh.

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2. History and Origin of the Policy

The Ministry of Post and Telecommunication (MoPT) bears the legacy of the Telegraph branch

of the Posts and Telegraph department started in 1853 in British India under the Telegraph Act,

1885 [7]. Bangladesh Telegraph and Telephone Board (BTTB) was responsible for both

regulating and serving the telecom sector. Eventually, the following governments started to think

to open the telecommunication market for private entrepreneurs. In 1998, the government

announced the first national telecommunication policy. Eventually, the Bangladesh

Telecommunication Act was promulgated in 1999 to open the market. Since then, the policy is

acting as the center piece of this grand game.

3. Brief Analysis of the Policy

Analyzing a national policy in a single report, covering a billion dollar sector, is a very difficult

task. In this section, a status snapshot of the narratives is given with the comparison between

background and impact of the policy.

Since mid-sixties the discourse on a public policy includes the following:

- Description of the content narratives.

- Analysis of how different forces (social, economic and political) have impact on the

policy.

- Description of how institutional structure and political ecosystem on the policy.

- Expected and unexpected consequence of the policy (Hewitt 2009) [5].

The author has tried to focus on these four aspects by using content analysis method.

3.1. Policy snapshot

The policy starts with the 'Preface' describing the vision. Eighteen objectives ranging from

regulation to market competition and universal services to local innovations are mentioned in

the third article. But few of them have appropriate level of tangibility.

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The fourth article, Strategy, is the largest article with six major sub-sections. The first sub-

section describes targets regarding teledensity, future services, information infrastructure,

international network and master plan. The second sub section suggests the details of

regulatory framework.

Third sub-section describes tariff design with direction on protection from malpractices. The

fourth sub-section elaborates ensuring fair competition. The fifth sub-section discusses how

BTTB should be restructured and the regulatory responsibilities to be transferred to

Bangladesh Telecommunication Regulatory Commission (BTRC). The last sub-section says

how the government should help the private entrepreneurs.

The fifth section is about institutional development suggesting establishing research institutes

and human resources development.

The sixth section discusses about local manufacturer of telecommunication components. The

author recommends that this section should have more details about supporting local

manufacturers and indigenous innovations.

The seventh section mentioned suggestions to establish consulting forums to increase

interaction among stakeholders.

The eighth section states that the services will be based on the need of the users and provided

at one stop.

The ninth section has mentioned the related laws being enforced at this moment.

3.2. Comparison Between Background and Impact of the Policy

In 1998, the telecommunication sector was linear and simple. There was analog transmission

equipment with costliest voice and data transmission in Asia. The teledensity was 0.4% [6],

and in rural areas less than 0.03% [11]. The traffic among the service providers used to go

through bilateral bridges rather than any common exchange. The only point to terminate

international calls was BTTB. There was no nationwide fiber backbone.

Since the policy, the scenario has been changed. More areas are now covered by the thriving

private sector. A tertiary service sector has emerged. By 2010, more than 60 millions of

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subscribers were enjoying services [4]. WiMAX and WiFi have started to be available at

selected locations. Most of the public universities are under Wi-Fi coverage. At least one

private service provider is listed in stock exchange. The Average Revenue per User has been

3.1 USD in 2010 which is between Pakistan (2.3 USD) and India (4.3 USD) [4]. More than

one public university has started m-payment to receive application fees. Compound Annual

Growth Rate (CAGR) reports that annual growth rate of the market is over 50%. In

summary, the telecommunication sector has undergone a complete change in all aspects.

A timeline of telecommunication industry [4] since the policy is given at Table 1.

4. Brief Critique

There is no specialized department in the ministry for maintaining the policy. So, some part

of it has become relatively obsolete or irrelevant over time.

The rationale behind not regulating directly by the Ministry of Science, Information and

Communication Technology (MoSICT) is not explained. Conflicts of scopes and

responsibilities at such a top level raise ambiguity.

Government agencies are major institutional clients of telecommunication services. As they

run under different policies, compliance with them should be elaborated in a policy. The

Right to Information (R2I) Act makes the public offices publish information to the citizen.

The Telecommunication Policy does not address the juridical framework on how the public

offices should deal with the telecommunication infrastructure to enforce the act.

The policy is more market driven instead of focusing on social disparity and increasing

ownership on the international body of knowledge.

While issues like 'Private Sector Operators' or 'Restructuring of BTTB' has got several pages,

'Promotion of Local Manufacturers' has not received due importance. It was described in

only two paragraphs with no specific guideline. The policy should address the needs of local

entrepreneurs with high priority.

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The policy is not written in Bangla, which could be understandable for all. A quick review

has discovered several typing error, indentation problem, repeating of one section twice, etc.

A national policy deserves more review before going public.

5. Categorical Analysis of the Policy

5.1. Impact on the Governance System of Telecommunication Sector

The telecommunication sector is under the MoPT instead of the MoSICT. Moreover,

transferring the regulatory role of the ministry to the newly established BTRC was never

been consulted publicly. When the government converted BTTB into Bangladesh

Telecommunications Company Ltd (BTCL), the regulatory role was expected to go back to

the ministry. But the government established an autonomous commission recurring overhead.

The policy does not specify how the commission remains responsible to the Ministry of

Commerce for consumer right and fair competition. There is no provision for BTRC to work

with the Ministry of Health to develop a standard of safe radiation.

5.2. Impact on the Social and Cultural System of Bangladesh

Telecommunication is an effective way of introducing new values. A cautious, yet generous,

control might be imposed on the information exchanged. The government can learn from the

experience of China and Iran to avoid the implication of over control. The services should be

designed so that it encourages the users to build healthy relationships among each other

without hampering positive evolution of the society.

The policy should address the necessity of commissioned research on the cultural and social

changes.

5.3. Impact of the Economy of Bangladesh

Recent expansion of telecommunication network has increased white collar jobs in

Bangladesh. But the major macro-economic contribution is connecting people. Lack of

enough micro-payment and information dissipation infrastructure has helped people innovate

a number of novel services. A good example is telepayment. People from one part of the

country come to the other part for work. They send money to their family using the top up

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services for cell phones. After charging commission, the top up service provider instructs his

counterpart on the other side to disburse the money. So, unrecognized but positive economic

practices are growing.

At micro level, it opens up the closed doors of creative lifestyle. Small and medium

enterprises are able to run PCOs making people's life better. As data service is also available,

people in every corner of the country can access internet. A variety of value added services

ranging from entertainment to personal vehicle tracking has emerged.

Only generalized statements are provided in the policy about helping the shadow tertiary

telecommunication services to integrate with the mainstream. The policy should be well

equipped to help them flourish.

5.4. Impact on the Political Culture of Bangladesh

In recent years, a number of financial scams have been uncovered in telecommunication

sector. Sometimes other governments try to influence the terms of the contract which may

put the country in a weaker position. This attracts the corrupt politicians to influence

government's decision. The policy should recommend commissioning a department under the

Auditor and Comptroller office to ensure transparency and accountability in incoming

Foreign Direct Investment (FDI)s.

5.5. Impact on the Government System of Bangladesh

Telecommunication infrastructure provides an economic way to exchange information

strengthening democracy. Since R2I Act, it is the responsibility of the public offices to

inform citizens about services. The offices cannot deploy a whole department with specialists

quickly. A pragmatic solution is to take the advantage of growing nationwide

telecommunication infrastructure.

For example, the cabinet division is a top level unit taking policy decisions. It may start

Push-Pull service where interested persons can know about the latest cabinet decisions via

SMS. A mobile newsletter is also an easy way to allow people follow the government.

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To encourage this, the telecommunication policy should concretely explain how the public

offices should develop their own tele-information contents and services. The policy may

commission BSTI to develop interoperable standards for digital public services.

5.6. Impact on Citizen Services

In recent years e-governance is being discussed as the next generation paradigm for public

services. Telecommunication infrastructure may play a versatile role here. Provisions should

be made so that the agencies become responsible to innovate telecommunication based public

services. Incentives should be proposed for the agent of these activities.

5.7. Impact on Local Government

According to the constitution, the local governments should be given full autonomy doing

business. To know people’s opinion, it is necessary to connect the government to them

effectively. Local governments should use telecommunication infrastructure for public

consultation. For example, the local government can maintain an inventory of fertilizer and

inform the farmers through Short Message Service (SMS) when new supplies arrive. The

policy should suggest legislative framework so that the local governments remain committed

to do this.

5.8. Impact on Small and Medium Enterprises (SME) Fabric

Since 2000, there was a boom in terminating overseas calls which was more popularly

dubbed as Voice over Internet Protocol (VOIP) business. Thousands of tech-savvy young

enterprisers were earning foreign exchanges under the shadow economy. But thousands of

terminating setups gone idles when the entrepreneurs were arrested. Such stern action caused

the sector collapse suddenly. Later the government decided to issue the call termination

license to a handful large companies creating oligopoly. Finally, different sources indicated

that the licenses are going to be given back to the VOIP entrepreneurs. Such U-turns harms

investors' plan and confidence.

The author recommends that the national policy should be equipped to protect the

entrepreneurs who innovate new businesses yet unrecognized by any specific law. The

enterprises should be given a transition time to regularize gracefully.

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5.9. Compliance with Competition Policy and Law

To ensure consumers’ right, the policy emphasized on ensuring rapid development in

telecommunication field as well as developing quality services. It has mentioned the

Government’s role to control the market oriented regime. The Government also needs to

create competitive market for the users to have choices. If there are vertical or horizontal

agreements to favor some particular entity to create monopoly the citizens will get low

quality service. The policy should address this issue to ensure a competitive market for the

consumers.

5.10. Compliance with other National Polices and Telecommunication Acts

A policy should not conflict with other national policies. In recent years, there have been

allegations against [8] several telecommunication companies of indulging child labor in risky

projects. The policy should instruct the related laws to have provision for auditing

compliance with National Environment Policy, National Labour Policy and National

Children Policy etc.

A recently proposed amendment in Bangladesh Telecommunication Act, 2001 allows a

person to be punished if his action harms the national interest. Drawing the line between

actions against the state and protection of the whistle blowers requires serious judgment call.

The telecommunication policy and the acts should not constraint the opportunity of

flourishing a free and open society.

5.11. Compliance with the International Telecommunication Union (ITU) Policy

In international community, every year, new standards are adopted while old standards

become obsolete. To ensure global interoperability, all nations are encouraged to get their

policies compliant with ITU standards. It is important for the policy to ensure alignment with

ITU-T [2], the Internet of Things Global Standards Initiative [3] and the Next Generation

Networks Global Standards Initiative.

The author also suggests that the policy commission BSTI to establish a sub-unit to work on

ITU standards.

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6. Recommendation

Although the policy has covered several importance issues, it could have address national

and social interest in a more coherent way. The author recommends putting more emphasis

on decreasing social disparity and increasing ownership of knowledge. The author

recommends an immediate review of the policy and publishing a proof read version. Later a

permanent committee should be created to revise the policy and update it regularly. This

committee should also remain responsible to make this policy available to the citizens in all

means.

7. Conclusion

Telecommunication infrastructure is extremely important for a society. On one side it can

control how people will communicate each other. At the same time it can also pave the way

for generating revenue. In some countries, properly planned telecommunication policy has

increased Gross Domestic Product (GDP) even by upto 1% [9]. It is also very crucial for

national security and sovereignty. So, strong and foresighted comprehensive policy is

necessary for the development of the sector. In this study the author has tried to point out the

existing issues with the policy. She also suggested some remedies for them. She believes that

with proper and flexible policy, Bangladesh can become a strong and vibrant

telecommunication market powered with fair competition, local innovation and highest

customer satisfaction.

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References:

1. Aminuzzaman, S. 2002. Public Policy Making in Bangladesh: An Overview. Public

Money and Management. Vol.2, June 2002.

2. International Telecommunication Union. General Tariff Principle.

<http://www.itu.int/itu-t/recommendations/index.aspx?ser=D> [Accessed: 08th June,

2011].

3. International Telecommunication Union. Internet of Things Global Standards

Initiative.

<http://www.itu.int/en/ITU-T/gsi/iot/Pages/default.aspx> [Accessed: 08th June, 2011].

4. Islam, Ifty. 2010. Bangladesh Telecoms Sector: Challenges & Opportunities. AT Capital

Research. Dhaka.

5. Hewitt, Sally. 2009. Discourse Analysis and Public Policy Research. Centre for Rural

Economy Discussion Paper Series No. 24. Center for Rural Economy, Newcastle

University.

6. Ministry of Post and Telecommunications, Dhaka. 1998. National Telecommunication

Policy. Government of the People’s Republic of Bangladesh.

7. Rahman, Fazlur. 2004. Telecommunications in Bangladesh. Bangladesh Strategic and

Development Forum. Dhaka.

<http://www.bdsdf.org/forum/index.php?showtopic=2907> [Accessed: 08th June, 2011].

8. Stoltz, Aasa C. and Paul, Ruma. 2008. UPDATE-1-Telenor Backs CEO in Bangladeshi

Child Labour Row. Reuters.

<http://www.reuters.com/article/2008/05/20/telenor-bangladesh-

idUSL2016577720080520> [Accessed: 08th June, 2011].

9. Waverman, Leonard, Meloria, Meschi and Melvyn, Fuss. 2005. The Impact of

Telecoms on Economic Growth in Developing Countries. The Vodafone Policy Paper

Series 2005.

10. Website of Laws of Bangladesh.

<http://bdlaws.minlaw.gov.bd/> [Accessed: 08th June, 2011].

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11. Zita, Ken. 2004. Bangladesh Telecom, USTDA South Asia Communications

Infrastructure Conference. New Delhi, India.

Appendix 1:

Table 1: Timeline of Telecommunication Industry since the Policy has been Announced [4]:

Year Milestones

1998 • National Telecommunication Policy announced

1999 • CityCell converts from AMPS to CDMA

2001 • BTRC launched

• Bangladesh Telecom Act promulgated

2002 • ICT Policy announced

• BTRC started working from January 31, 2002

2004 • Orascom buys out Sheba Telecom

• SE-ME-WE-4 contract signed by the government

2005 • TeleTalk starts its operation

• Warid gets license to provide wireless service

• 7 PSTN licenses distributed among local enterprises

• First mobile internet service launched by GrameenPhone

2006 • Information Technology Act promulgated

• Broadband Policy announced

2007 • Warid starts operations

• ILDTS policy proposed

• Interim Tariff Regulation declared

• Spectrum redistributed

• National Numbering Plan proposed

• BTRC revises licensing regulation

• MTR revised again

• 4 national PSTN licenses issued to local companies

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2008 • NTTDoCoMo buys out 30% of AkTel's stakes

• BTTB becomes BTCL

• GrameenPhone lists in the stock exchanges

• WiMax licenses issued to two private and one government companies

• 3 ICX, 4 IGW and 2 IIG licenses were issued to streamline

infrastructure

• Infrastructure sharing guidelines published

• More than 300 call center licenses issued

2009 • IP telephony licenses issued to local companies

• ICT policy revised

• VTS licenses issued

• Review of ILTDS policy

• Submarine cable framework proposed

• ULR consultancy

• Review of NFAP

• M-payments guidelines proposed

• 2 NTTN licenses issued

• GP completes listing

2010 • Airtel buys out Warid Telecom

• Allegations of scam regarding AirTel's deal

• ILTDS policy revised

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