Universal access and service in South Africa:

policy success, policy failure and policy impact

Charley Lewis

Independent Consultant

+27 83 539-5242

Charley.A.Lewis@Gmail.com

orcid.org/0000-0002-6307-4520

Abstract
In 1994 South Africa’s new democratic government embraced universal access and service
(UAS) as the centrepiece of telecommunications policy. International best practice for
UAS had been developed and promoted under the growing hegemony of an international
telecommunications reform regime from the mid-1980s. Its implementation in South
Africa has been widely criticised. However, examining the track record through the
heuristic lens of McConnell’s policy success and failure framework provides a more
nuanced assessment of the relative effectiveness of this policy shift. The implementation
of the new UAS policies between 1994 and 2014 is documented, analysed and
interrogated, examining the effectiveness of the process, the success of the programmatic
implementation, and the political outcomes. Under each aspect the outcomes appear at
best mixed. Nevertheless, a long-term fundamental paradigm shift in the landscape of
telecommunications policy has resulted, suggesting that theoretical and practical questions
of policy success and failure may need further examination.

Keywords: Policy failure, policy success, universal access, universal service

1 Introduction
The advent of democracy in South Africa, the inception of telecommunications reform, and
the country’s prioritisation of the need to achieve universal access and service (UAS)1, form
a unique conjuncture of political change together with consequent policy reform and
implementation. But, twenty years later, as telephony gives way to broadband, the success

1
Universal service (providing telephony services to individual subscribers) was for many years the defined policy
objective. The concept of ‘universal access’ (shared public access to telephony services via payphones,
telecentres etc) was introduced much later as a policy objective appropriate for developing countries (ITU, 1998,
pp. 61-81).

Electronic copy available at: https://ssrn.com/abstract=2980803

of the UAS cluster of policy reforms, and the prospects for the future remain mired in doubt
and cynicism (Horwitz & Currie, 2007; Dagada, 2010; Hislop, 2015). Together, however,
these events and the drivers that animated them present a rich opportunity to interrogate
the criteria for policy success and policy failure.

Although South Africa’s then apartheid government had flirted with reform of its
telecommunications sector (de Villiers, 1989; Coopers & Lybrand, 1992) prior to the advent
of democracy in 1994, it was only under the incoming African National Congress (ANC)
government that ICT sector reform began in earnest. At the behest of the ANC (CDITP,
1995, p. 24), a multi-lateral, stakeholder-based negotiating structure, the National
Telecommunications Forum, had been launched several months prior to the country’s first
democratic elections (Khumalo, 2001). Following the victory of the ANC in that landmark
election, the newly appointed Minister of Posts and Telecommunications, Pallo Jordan,
moved to institute a complete review and overhaul of the telecommunications sector. The
ensuing process involved the development of a consultative Green Paper (RSA, 1995), the
adoption by the new government of a formal set of policy positions in a White Paper (RSA,
1996a), and their subsequent translation into legislation via the 1996 Telecommunications
Act (RSA, 1996b). It was a process that has been charted in fine detail in Horwitz’s seminal
work on the reforms in the communications sector (2001b, pp. 178-281). Horwitz
characterises the transition as one of ‘negotiated liberalisation’ (2001a) and charts its policy
outcomes as the structural product of a series interactions between contending stakeholder
groupings (including civil society, the trade union movement, business interests and the
new government), all beset by tensions between the ancien regime under the National
Party versus already conflicting sets of interests within the ANC itself as it solidified from a
liberation movement into a governing party (Horwitz, 2001b).

Confronted by the stark and staggering inequalities in access to telecommunications

services between the county’s ‘black’, often rural, majority and its hitherto-ruling ‘white’
minority (UNDP / ITU, 1995, p. 29), the resultant policy and legislation understandably
placed universal access and service at the forefront of its objectives (Lewis, 2013, p. 96).
This vision of the need to provide universal affordable access to telecommunications
services for the hitherto marginalised and excluded majority of its citizens has remained a
prominent plank of sector policy throughout the intervening years (Msimang, 2006; DTPS,
2015, pp. 37-45).

The policy prominence enjoyed by universal access and service has been matched over the
years by a number of policy implementation initiatives. These have been detailed at some
length by Lewis (2013), and have included:
• The imposition of a series of what are commonly known as universal service
obligations (USOs) on licensees, requiring them, inter alia, to roll out
telecommunications networks to under-serviced areas, to provide
telecommunications services to the poor and to schools and other priority
institutions, to install additional payphones or community service telephones in
under-serviced areas2;

2
Given the limited space available in this short paper, a number of the USOs will not be discussed in detail,
such as the provision of free SIM cards, connectivity to public schools, and the provision of access for
institutions catering for people with disabilities.

Electronic copy available at: https://ssrn.com/abstract=2980803

 • The creation of what is commonly referred to as a universal service fund (USF3),
sourced from a levy imposed upon licensees and used to finance a range of project
interventions designed to address UAS shortfalls;
• The establishment of a dedicated entity, the Universal Service and Access Agency of
South Africa (USAASA4), mandated to manage and implement the USF, and to keep
universal access and service prominent in policy and in the public mind;
• The introduction of a privileged class of telecommunications licensees (USALs5) with
the object of providing telephony and other services in under-serviced areas of the
country;
• The mandatory provision of discounted Internet access to public schools, through
what is usually referred to as the ‘e-rate’6.

Taken together, these interventions reflect an exceptional degree of policy priority accorded
to UAS over the last twenty years. Yet, despite such emphasis, these interventions are
widely regarded as having failed, either wholly or in part.

The USOs were ineffective and poorly implemented, widely circumvented by the licensees
and poorly monitored by the regulator, and ultimately sidelined by the march of technology,
as prepaid GSM telephony came to dominate the market (SATRA, 1998; Hodge, 2004; BMI-
T, 2010; Lewis, 2013). The USAF has been undermined by its inability to quantify, access
and spend the contributions of the licensees, as well as by repeated allegations of
corruption and mismanagement (Perry, 2010; Lewis, 2013; GSMA, 2014; Lewis, 2015).
USAASA itself has been bedevilled by mismanagement and leadership turnover, and beset
by allegations of corruption (Stavrou, Whitehead, Wilson, Seloane, & Benjamin, 2001; USA,
2005; Lewis, 2013; Holomisa, 2013). The USALs were of tenuous viability from the outset,
rapidly outflanked by the burgeoning of mobile telephony, and crippled by lack of funding
and poor management, with the result that only one is known to survive (Gillwald, 2005;
Thornton, 2006; Lewis, 2013). The e-rate has been widely criticised and being un-
implementable and ineffective (Vecchiatto, 2008; Vecchiatto, 2010; ISPA, 2015).

It is noteworthy that much of the criticism voiced in respect of universal access and service
is directed at the implementation of the policy interventions and at their outcomes, with
little criticism directed at the prioritisation of the policy goal itself, or at the chosen
interventions per se. This suggests that an examination of the broader questions of policy
success and policy failure may illuminate the sources of the problems identified by the
commentators above in the implementation track record. This in turn may assist in
clarifying the nature of policy success and failure, and lead to the development of a more
nuanced heuristic with which to gauge the critical implementation dimension of policy.

3
Originally dubbed the Universal Service Fund, it was rechristened then Universal Access and Service Fund in
2005.
4
USAASA, too, underwent a change of name and stationery with the passage of the 2005 Electronic
Communications Act.
5
Under-serviced Area Licensees.
6
The e-rate was not covered in Lewis (2013).
2 South Africa and the Emerging UAS Regime
Before we turn to the question of policy failure and policy success, it is important to chart
the rise of the precepts of universal access and service interventions, and to assess how
they came to find so central a place in South Africa’s ICT sector reform.

From the late 1970s, the global market for telecommunications experienced a series of
profound changes that were to have a lasting impact on the global face of ICT sector policy
and regulation, changes which continue to mould its features today. This series of changes
are best encapsulated within the phenomenon now known as ‘telecomm reform’ (Melody,
1997) and comprise three core features: privatisation of the incumbent operator; the
introduction of competition into the market; and the creation of an independent sector
regulator (cf (ITU, 2016)).

The nature and evolution of these changes have been dealt with by a number of
commentators, albeit from differing perspectives. The pressures driving the transformation,
however, despite differences of emphasis and inter-relationship, broadly include:
commercial and business imperatives (Zacher, 1996); technological change (Cowhey,
1990); and global power struggles (Hills, 2007).

The role of the International Telecommunication Union (ITU) and its relationship to the
General Agreement on Tariffs and Trade (GATT) and its successor, the World Trade
Organisation (WTO), have been examined from the perspective of regime theory by a
number of analysts (Aronson & Cowhey, 1988; Cowhey, 1990; Woodrow, 1991; Drake,
1994; Zacher, 1996; Levi-Faur, 1998; Zacher, 2002). The defining features of the
‘telecomm reform’ agenda - privatisation, competition and regulation - are best
understood within the context of the emergence of a global ‘regime’ centred around the
ITU, the WTO and ICANN and aligned to what is often referred to as the ‘Washington
consensus’ (Williamson, 1990). A ‘regime’, in turn, is best conceptualised as a structure
(such as the ITU or the WTO) around which contention between actors seeking to advance
economic and political agendas crystallises around a set of ‘implicit or explicit principles,
norms, rules, and decision-making procedures around which actors’ expectations converge’
(Krasner, 1982, p. 186).

UAS began to emerge as a key feature of ‘telecomms reform’ as countries sought to oppose
privatisation and the introduction of competition on the grounds that this would undermine
their ability to deliver ‘universal service’ to their populations. In response, proponents of
the emerging regime sought to demonstrate that universal service and sector reform were
indeed perfectly compatible (EC, 1987; OECD, 1991). By the mid-1990s the canon of
universal service policies had begun to solidify around two key policy interventions in
particular. The first of these comprised the imposition of USOs upon operators (EC, 1994;
OECD, 1995; ITU, 1998). The second strand of intervention involved the establishment of
a USF collected from levies imposed upon licensees and designated to support universal
service interventions. Although this part of the universal access and service policy arsenal
was only formulated rather later (ITU, 1998, p. 89; ITU, 2003, pp. 67-84), there appears to
have been thinking along related lines rather earlier (EC, 1994, pp. 56-57). Other, less
prominent, components of the policy toolbox came to include: the award of rural
franchises or licences, for which least subsidy auctions were usually considered best
practice (EC, 1994, pp. 61-62; ITU, 2003, pp. 85-94); the establishment of telecentres as
nodal points for the aggregation of access (EC, 1994, pp. 61-62; ITU, 2003, pp. 95-105).
When it was unbanned, as a liberation movement primarily focused on the overthrow of the
apartheid government, the African National Congress could hardly have been expected to
have a comprehensive policy on telecommunications and the ICT sector. It did, however,
have an able cadre in the shape of Andile Ngcaba, who had been appointed the ANC’s head
of IT on his return from exile in 1990 (interview, 28 January 2015). Ngcaba moved rapidly
to establish an ANC-aligned telecommunications policy think-tank, the Centre for the
Development of Information and Telecommunications Policy (CDITP) with a view to
building a cohort of researchers and policy-makers in order to develop ‘policy options’ for
the ICT sector (CDITP, 1995, pp. 2-3). Ngcaba also began to articulate policy positions on
behalf of the ANC, declaring, for example, the organisation’s opposition to the ‘principle of
privatisation’ of the state-owned incumbent operator, Telkom (Business Day, 1991), and
inveighing against the licensing of the first mobile operators, Vodacom and MTN (Sergeant,
1993)7.

Formal ANC policy in relation to telecommunications was, however, slow to crystallise, and
thin on specifics. For example, the organisation’s Ready to Govern declaration bundles
telecommunications together with other forms of infrastructure, and speaks in very general
terms about the need to ‘promote infrastructural development in the rural areas’ and to
provide ‘access to these essential services for all’, along with the ‘equitable allocation of
these resources between industry, agriculture and domestic consumers’ and the
‘democratisation of the control of utilities which provide these services’ (ANC, 1992).

But the apartheid-engineered gaps in access to telecommunications services were, as

alluded to earlier, stark and yawning. Universal access and service, therefore, rapidly
became the centrepiece of ANC policy in the sector - counter-balanced with a perhaps
grudging recognition of the role played by telecommunications infrastructure in economic
growth and social development. The seminal pre-election policy positions adopted by the
COSATU-inspired ANC (Lodge, 1999) Reconstruction and Development Programme (RDP)
committed the ANC to ‘provide universal affordable access for all as rapidly as possible’
while at the same time flagging the role of telecommunications as an ‘indispensable
backbone for the development of all other socio-economic sectors’ (ANC, 1994a). A
subsequent policy discussion paper, in which the hand of Ngcaba loomed large, sought the
same balance between ‘equity’ and ‘efficiency’, but declared its ‘overriding goal’ to be the
‘delivery of affordable universal access to the telecommunications network, irrespective of
race or location’ (ANC, 1994b, p. 4).

Both documents can be criticised as being long on principle and short on detail, but they
served to place universal access and service at the forefront of policy in the sector. It was,
however, to be through the National Telecommunications Policy Process centred around the
NTF that the broad policy commitments of the RDP would be given implementable,
programmatic substance by the incoming ANC government. The decision to run the
process under the stewardship of special adviser to the Minister, Willie Currie, and at arms’
length from the Department, was prompted in part by the still unreconstructed nature of
the old apartheid bureaucracy and its hostility to ANC positions, but also by the fractious
nature of the stakeholder terrain, marked by deep ‘dislocations’ in viewpoint, especially in
relation to ‘universal service’ and the ‘introduction of competition’ (Currie, 1996a, p. 1).
That disputatious process has been, as previously noted, ably charted by Horwitz (2001b),
and so will not be discussed here.

7
On the importance of prominent individuals and their influence on policy outcomes, albeit in a rather different
context, see (Brummer, 2016).
However, from the perspective of this analysis, it is important to note that the three central
pillars of the ITU’s sector reform agenda - viz, privatisation, regulation and competition -
were central to the debate (RSA, 1995). Indeed, the resultant legislation remained fully
compatible with the reform agenda, establishing a regulator8 and providing for the
introduction of competition9 (RSA, 1996b). The thorny issue of the privatisation of the
incumbent fixed-line operator, Telkom, and of its extent and timing, was deliberately
omitted from the legislation, but was subsequently railroaded through in the teeth of fierce
opposition from organised labour (Horwitz, 2001b, p. 226ff; Horwitz & Currie, 2007). A
similar level of adherence to these pillars underpinned South Africa’s GATS commitments
(WTO, 1994) upon its accession to the WTO.

With regards to the more specific set of good practices associated with universal access and
service, South Africa was largely in line with ITU prescription. The legislation provides for
the imposition of universal service obligations upon licensees (RSA, 1996b, p. Section 36
(2)), via operator licences, as was already the case in respect of Vodacom and MTN (since
1993). This was later extended to Telkom (1997), Cell-C (2001), Neotel (2005), as each
was licensed. Similarly, the Act provided for the establishment of a universal service fund,
sourced from a levy on operators, and designed to support ‘needy person’ and network
rollout (RSA, 1996b, p. Chapter VIII). In a key innovation and departure from the precepts
of the global universal access and service regime, control over the fund was vested in an
independent agency with a broader universal access and service mandate, the Universal
Service Agency rollout (RSA, 1996b, p. Chapter VII). Some years later, in 2001, a further
innovation in respect of international good practice was added, albeit one with roots in the
‘rural franchises’ alluded to above, with provision being made for the granting of a series of
Under-serviced Area Licences (RSA, 2001, p. Section 40A).

The close alignment of South Africa’s telecommunications reform process to the set of
international best practices preached by the ITU, reinforced by the WTO GATS
commitments, and backed by the precepts of the Washington consensus, is a perhaps
surprising, given the ANC’s initial hostility to the early tentative moves towards reform
embarked on by the then National Party apartheid government. Some will doubtless see
this as simply one more aspect of the ANC’s rightwards shift towards accommodation with
the globalised neo-liberal agenda. However, both the nature of the process adopted and
the key actors involved as it unfolded, ensured the direction that it would follow.

The pre-eminent role of Andile Ngcaba as the ANC’s eminence grise for policy in the sector
has already been noted. By his own account, he was heavily embedded in ITU structures
and closely involved in ITU work: he describes himself as ‘very busy with ITU work,
running the ANC department, and commuting back and forth between Johannesburg and
Geneva’ (interview, 28 January 2015). He also knew and admired ITU General Secretary
Richard Butler. In addition, many of the international experts he brought out to work with
his fledging policy cadre at the CDITP (such as the ITU’s Tim Kelly), were imbued with the
ITU’s policy prescriptions, albeit in many cases from a left-wing pro-developing country
perspective. In addition, the task team working on the Green and White papers drew in a
range of international expertise from Canada’s International Development Research Centre

8
Then called the South African Telecommunications Regulatory Authority (SATRA). It was later merged with
the Independent Broadcasting Authority (IBA) to become the Independent Communications Authority of South
Africa (ICASA).
9
The process was later to be described as one of ‘managed liberalisation’ (Ngcaba, 2001). Telkom’s monopoly
over most aspects of infrastructure and service provision (with ‘mobile cellular’ being the stand-out exception)
was protected in the medium term, in the famous phrase, ‘until a date to be fixed by the Minister’ (which appears
no fewer than 8 times in the Act)
(IDRC), which provided logistical and financial support to the process10. Keeping the
process at arm’s length from the apartheid-tainted Department, and ensuring exposure to
international experience, along with input from stakeholder interest groups, likely had the
effect of enabling a policy model both profoundly aware of and deeply influenced by
international best practice.

3 The Policy Continuum: Betwixt Success and

Failure
As noted earlier, the overall policy thrust for the ICT sector, along with that in respect of
universal access and service, has been the subject of a great deal of criticism at the hands
of both academic analysts (Horwitz & Currie, 2007; Gillwald, Moyo, & Stork, Understanding
what is happening in ICT in South Africa: A supply- and demand-side analysis of the ICT
sector, 2012; Hawthorne, 2014) and the commentaries of the trade press (Vegter, 2001;
McLeod, 2015; Hislop, 2015). We also noted that the same holds true in respect of
universal access and service (Hodge, 2004; Lewis, 2013; Dagada, 2013; BusTech, 2013).

To date, however, most analysis has been piecemeal in its evaluation and assessment.
None have attempted the kind of systematic analysis, both detailed and nuanced, of the
kind offered by heuristic tools such as the framework proposed by McConnell (McConnell,
2010). It is to an application of such a framework that this paper now turns, applying its
analytical tools in order assess their effectiveness and applicability, and in order to gain
some insight in respect of their value or shortcomings.

McConnell’s framework (initially proposed in collaboration with Marsh (Marsh & McConnell,
2010)) has its roots in the analytical framework developed a good few years earlier by
Bovens and his collaborators (Bovens & ‘t Hart, 1995)11 as a tool to define and discuss
specific instances of failure in government policy implementation. Drawing on the analytical
categories of the ‘programmatic’ and the ‘political’, in respect of which ‘asymmetric’ policy
evaluations are possible (a policy can, for example, be a political success but a
programmatic failure), which was the basis for a two-dimensional analytical framework
(Bovens, ’t Hart, & Peters, 2001), Marsh and McConnell add a third dimension, that of
policy as ‘process’ (Marsh & McConnell, 2010). Despite ongoing contestation from Bovens
as to whether or not the ‘process’ dimension is indeed conceptually distinct and at the same
level of abstraction (Bovens, 2010; Bovens & ‘t Hart, 2016, p. 659), McConnell has since
gone on to elaborate his proposed categorisation into a comprehensive heuristic tool
(McConnell, 2010; McConnell, 2016, p. 671ff). He does this by introducing a five point
Likert-type scale, measuring degrees of ‘success’, from complete, through ‘resilient’,
‘conflicted’ and ‘precarious’ success, down to outright ‘failure’. He also adds a series of
‘objective’ and ‘subjective’ criteria to each of his ‘process’, ‘programmatic’ and ‘political’
categories. The resultant series of matrices requires 14 points to be plotted in order to
evaluate the degree of success versus failure for any policy (McConnell, 2010). Howlett has
since gone on the defend and extend McConnell’s three dimensional framework (Howlett,
2012). His insights into McConnell’s ‘process’ dimension are particularly useful: he links
‘process’ failure to errors at the various stages of the standard policy cycle (Howlett, 2012,

10
This included: Dr T Chowdary, an academic and consultant who had overseen the implementation of
telecommunications reform in India; and left-wing academic Prof R Horwitz, whose first book had examined
telecommunications reform in the USA, amongst a range of others.
11
Their work in turn has its roots in a long tradition of policy evaluation stretching all the way back to the
utilitarian calculus of Jeremy Bentham.
pp. 545-547), thereby giving rather more substance to McConnell’s somewhat flimsy
original characterisation of the issue.

Whilst the McConnell framework provides a useful looking glass through which to view
South Africa’s universal access and service policy, it must be noted that the debates in the
field are far from settled, with many aspects of the conceptualisation yet to cohere into an
integrated and consistent framework. In part this is due to the very complexity of the
study of policy itself: it is a field of study beset by complex interaction between agents and
institutions, agendas and outcomes, causes and consequences. It is also a field beset by
subjective verdicts and adversarial assessments, ‘permeated’, in the words of Bovens and ‘t
hart, ‘with prosecutorial narratives, blame games and a search for culprits’ (2016, p. 653).
The value, therefore, that Bowens, McConnell, Howlett and others bring to its analysis is an
approach that is systematic and structured, one that moves away from ‘relativistic’
judgements towards ‘objectively assessable outcomes’ (Howlett, 2012, p. 542).

We shall now turn to an application of the approach advocated by McConnell to attempt to

assess and quantify the relative degree of success and failure of the important cluster of
universal access and service policy interventions put in place in South Africa over the period
since 1994.

4 Process Effectiveness
When viewed through the lens of McConnell’s criteria for ‘process effectiveness’ - viz,
‘preserving government policy goals and instruments’; ‘conferring legitimacy on the policy’;
‘building a sustainable coalition’; ‘symbolizing innovation and influence’; level of ‘opposition’
or ‘support’ for the policy (McConnell, 2010, p. 352) - the development of universal access
and service policy appears to be a relative success.

The three main features of universal access and service policy - universal service
obligations, the establishment of the universal service fund, and the creation of the
dedicated universal service agency - all coalesced in the formal passage of the 1996
Telecommunications Act, and hence are substantially influenced by the degree of process
success associated with that entire legislative process. It is true that universal service
obligations had already been included in the mobile licences of Vodacom and MTN, in an
agreement brokered by the ANC’s Cyril Ramaphosa that ended the standoff between the
ANC and then National Party government over the licensing of the two new entrants (Cape
Times, 1993; Horwitz, 2001b, p. 200ff). But this was carried forward into the Act without
controversy.

If it is agreed, as suggested earlier, that the overall policy goal was to enshrine within a
legislated outcome a balanced set of measures designed to reform the sector and to
achieve a balance between providing telecommunications services to the deprived majority
of the country’s population while simultaneously providing an environment beneficial to the
needs of the economy and the society at large, then the 1996 Telecommunications Act was
surely a successful policy process. The creation of the universal service fund and the
imposition of universal service obligations enjoyed both the imprimatur of ITU endorsement
as international best practice and the support of both the ANC and other stakeholders, and
hence enjoyed process legitimacy. The establishment of the universal service agency,
although it was a global policy innovation, likewise seems to have enjoyed legitimacy. The
idea came after the Green Paper, likely from Andile Ngcaba himself, and was introduced at
the policy colloquium that preceded the White Paper (DPTB, 1995, p. 19), where it was
thoroughly debated, with some measure of agreement on its value (DPTB, 1995, p. 19).

It is in relation to stakeholder coalitions that the 1996 Telecommunications Act process

became profoundly fraught, following the sacking of Minister Pallo Jordan and his
replacement with former COSATU General Secretary Jay Naidoo (Horwitz, 2001b, pp. 264-
270). This in turn led to substantial changes in the notorious 14th draft of the Bill and the
resignation of Willie Currie, who felt his stewardship of the process had been betrayed and
undermined (Currie, 1996b). While it must be noted that the legitimacy of the universal
access and service provisions of the Act were not affected by the changes, the sense of
betrayal and acrimony was to colour the attitude of the private sector towards government
and the Minister for years to come.

A further marker of the relative degree of process success enjoyed by South Africa in
relation to universal access and service at the time can be seen by the repeated
presentation of South Africa as an exemplar or in a positive light in the first, landmark ITU
report to deal with the full set of issues (ITU, 1998). Indeed, Tina James, closely involved
in the policy process from the side of the IDRC, recalls how much South Africa’s universal
access and service interventions were ‘looked up to’ on the rest of the continent (interview,
27 November 2014). Opposition to the universal access and service measures and their
formulation within the policy remained very limited.

By the time of the 2001 review of the policy and legislation, at which point rural franchises
in the form of under-serviced area licences and the e-rate were added to the policy
armoury, disillusionment with the legitimacy and meaningfulness of the process had begun
to show through the cracks (Vegter, 2001). One commentator was even more sceptical,
wondering if the ‘colloquium was merely a facade for a participatory policy process’ and if
the Minister had not merely ‘ignored [its] feedback’ (Bridges, 2001). A bizarre series of
often contradictory policy directions (DoC, 2001a; DoC, 2001b; DoC, 2001c) emanated from
the Minister in the following months, before amendments to the Act were finally passed in
November of that year. Whilst the policy vacillation did not directly affect universal access
and service12, it did have the effect of making the process somewhat less than successful.

If we take Howlett’s suggestion and examine the universal access and service set of policy
interventions in relation to the policy cycle (2012, p. 547), a different set of process failures
manifest themselves, those related to ‘policy implementation’ and ‘policy evaluation’.

The Universal Service and Access Fund (USAF), in particular, has been plagued by a series
of implementation failures. The problems alluded to earlier in relation to tracking,
accessing and spending funds effectively (Perry, 2010; Lewis, 2013; GSMA, 2014; Lewis,
2015) all suggest a failure of implementation. The Universal Service and Access Agency
itself has been shown to be the cause of much of the problem, with lack of capacity, along
with poor quality and high turnover of leadership13, being an ongoing set of issues
undermining policy implementation (USA, 2005). Similarly the inability of ICASA, within the
limitations of the law, to implement a workable set of e-rate regulations, again alluded to
above, suggests a further example of policy implementation failure. The implementation of
the under-serviced area licensing policy intervention post 2001 likewise was accompanied
by widespread concerns and caveats (Gillwald A. , 2002; AVP, 2002; van der Merwe, 2002;
Gillwald A. , 2005).

12
It was more to do with how many new fixed line entrants would be licensed. In the event, only one was.
13
By the author’s count, the Agency has had no fewer than 17 CEOs, a number of them in acting capacity, in
less than 20 years of its existence.
Even more glaring failures emerge when we consider monitoring and evaluation as a
component of the process dimension of policy. The universal service obligations imposed
on the mobile licensees, for example, were the subject of two reportedly damning audits, in
1996 and 1998, by the Department and the regulator respectively (Rosenthal & Volschenk,
1996; SATRA, 1998), both of which were blocked from seeing the light of public day by the
licensees concerned. Further, there seems to have been no attempt on the part of the
regulator to ever audit the compliance reporting of Telkom (2002) in respect of its universal
service obligations: compliance reports were submitted, but were never audited, or
evaluated for creative compliance (Hodge, 2004, p. 218), and were never even mentioned
in ICASA’s annual reports. No evaluation of the universal service fund appears ever to have
been carried out by USAASA as the oversight entity: we have only those by external
commentators (Perry, 2010; Lewis, 2013; GSMA, 2014; Lewis, 2015). Evaluation of the
Universal Service Agency was undertaken as part of the 2001 policy review (Stavrou,
Whitehead, Wilson, Seloane, & Benjamin, 2001), but no formal report was ever published
or substantive corrective action undertaken. A later internally-commissioned impact study
was briefly available on the website of the Agency (USA, 2005), but led to equally little by
way of substance. No evaluation of the e-rate appears ever to have been undertaken.
Taken together, this suggests that, although implementation evaluation appears to have
been conducted, albeit sporadically, as part of the policy cycle, it has not been tightly
integrated into the policy cycle. Nor, more importantly, have there been structures and
mechanisms in place to ensure that policy learning takes place or that corrective measures
can be instituted.

This discussion of failures in respect of the implementation and evaluation components of

the process dimension of policy success and failure, as argued for by Howlett (2012, p.
547), begs the question as to whether these aspects do not belong more appropriately
under the analysis of the programmatic aspects of policy success and failure. From a
‘process’ point of view, it is surely the establishment and institutionalisation of feedback
loops and mechanisms for policy adjustment that constitutes process success rather than
the content of either feedback or adjustment. Process success thus depends or structure
far more than content, which is a programmatic issue.

In the case under consideration, it is also important to note that many of the ‘process’ issues
relate to the overall, larger policy process of telecommunications reform within which
universal access and service formed much smaller subset, even if a tightly integrated one.
It therefore seems likely that process success may depend rather more on what transpires
at a more macro policy level, rather than at the more micro programmatic level.

5 Programmatic Implementation
It is the programmatic dimension of policy success and failure that appears to have
received the greatest attention from commentators and analysts (Howlett, 2012, p. 545),
particularly those focused on sector-specific approaches rather than attempting more meta-
theoretical analysis, perhaps because its consequences are most readily visible and its
causes easier to track (Gillwald, 2005; Horwitz & Currie, 2007; Gillwald, Moyo, & Stork,
2012; Lewis, 2013; Hawthorne, 2014). It is this attention to the quantifiable and verifiable
aspects that shines through the criteria in McConnell’s elaboration of this aspect of policy
success versus failure - whether ‘implementation [aligns] with objectives’; whether
‘desired outcomes’ are achieved; whether ‘target group[s]’ benefit; whether ‘policy domain
criteria’ are met; the degree of ‘opposition’ to or ‘support’ for the programme (McConnell,
2010, p. 354).

In many cases the programmatic dimension of policy implementation is assessed in relation

to international best practice and judged accordingly (Gillwald, 2005; Lewis, 2013) in an
approach that is essentially the obverse of policy transfer (Stone, 2004). It is also an
approach that serves as the impetus for much of the literature concerned with ensuring
regulatory effectiveness (NERA, 2004; Brown, 2006; ECTA, 2010; Waverman &
Koutroumpis, 2011), and provides a springboard for the rise of regulatory impact
assessment as a policy tool (Radaelli, 2009; Sutherland, 2010; Renda, 2014).

Examining South Africa’s universal access and service policy interventions in the light of
McConnell’s programme success criteria reveals a picture that is gloomy to say the least.

The universal service obligations met with mixed success at best (Lewis, 2013, pp. 99-101).
While the fixed line incumbent rolled out its required 2,69 million lines, Telkom exploited a
loophole in its licence to disconnect almost all within a few years because of unpaid bills
(Hodge, 2004, p. 209), with Telkom’s voice telephony network now comprising fewer
subscribers than it had in 1994. The mobile obligations in the early years appear to have
been marked by widespread failure as the licensees struggled to find viable rollout models
and engaged in cavalier misreporting, according to the only recorded attempt at a
statistically accurate audit (SATRA, 1998). Latterly, Cell C and Vodacom in particular,
appear to have exceeded their original targets substantially (BMI-T, 2010), likely because of
the opportunities for commercial arbitrage afforded by the tariff differential (Jones, 2008).

The possible exception to this litany of failure is the network rollout obligations imposed on
the mobile operators, which have ensured almost complete national coverage, and allowed
a massive uptake of relatively cheap prepaid mobile, with household penetration of mobile
telephony now reported to exceed 96% (Stats SA, 2016).

As noted previously, the universal service fund was unable to access and spend more than
a fraction of the contributions levied on licensees (Perry, 2010; Lewis, 2013; GSMA, 2014;
Lewis, 2015), and has been bedevilled by repeated allegations of mismanagement,
corruption and misappropriation of funds, leading to at least one forensic audit, an official
anti-corruption probe, and the sudden resignations of a number of senior officials
(Holomisa, 2013; Lewis, 2015).

The performance and effectiveness of USAASA itself as a structural entity tasked with
championing universal access and service and with managing the universal service fund,
can best be described as dismal (Lewis, 2013, p. 101), even by its own admission (USA,
2005), so much so that the recent ICT Policy Review Panel recommended the dissolution of
the institution (DTPS, 2015, pp. 167-168).

The under-serviced area licensees, with one possible exception14, appear to have vanished
without trace, overtaken by market forces, regulatory changes and lack of support on
almost all levels (Thornton, 2006; Lewis, 2013, pp. 102-103), with the failure of the
intervention finally acknowledged some years later by the Minister (Vecchiatto, 2009).

As noted previously, the e-rate appears to have been a complete failure. Although some
ISPs may be offering the required 50% discount to some schools, the proposed 2010

14
Amatole Communications, now trading as Easttel, and offering telephony and Internet services in East
London.
revision to the first set of regulations remains stalled 6 years on, with Internet Service
Providers’ Association pointing out that there is no functional ‘regulatory framework’ in
place (ISPA, 2015).

From the point of view of implementation of each of these interventions being aligned with
the envisaged objectives, almost every one, with the exception of the mobile coverage
obligations, appears largely to have failed. Whilst it is true that South Africa now enjoys
almost universal access to mobile telephony, this has come about through market forces,
and was not an envisaged outcome of any of the armoury of interventions described above.
And, while it is true that envisaged target group, the country’s impoverished ‘black’ majority
have benefitted extensively from access to mobile telephony, it has come about as a result
of factors other than the policy itself.

Perhaps because of this, the affordability aspect of access to telecommunications began to

emerge as a major issue in recent years, both for business customers and in respect of the
poor and the needy. In arguably one of its major regulatory successes, ICASA succeeded
in driving termination rates down dramatically, leading to substantial drops in retail pricing,
with likely consequent spin-offs in respect of access to and uptake of telephony services
(Hawthorne, 2014; RIA, 2015).

The failure of the specifically universal access and service cluster of policy interventions,
therefore, to meet its own domain criteria is thus perhaps only apparent to expert
commentators and industry analysts.

6 Political Outcomes
For both McConnell and Howlett, coming as they do from multi-party electoral systems
where can and do get voted out of office at least partly as a consequence of policy failure,
the political dimension of the degree of failure or success is closely related to the
reputational impact of policy implementation, and its consequences for government’s overall
agenda and ultimately at the ballot box. McConnell grounds this dimension in the
‘consequences [of the policy] for the reputation and electoral prospects of politicians and
their capacity to manage political agendas’ (McConnell, 2010, p. 350). This leads him to
judge ‘political’ success or failure against criteria such as: ‘electoral... reputation’; ‘capacity
to govern’; the ‘direction of government’; the level of ‘opposition to political benefits’
(McConnell, 2010, p. 356). Rooting himself firmly in the literature of ‘blame avoidance’ as a
motivator for policy decision-makers, Howlett too sees the ‘political’ assessment of policy
success as ‘rife with actual and potential negative political consequences for political
executives and legislatures’ (Howlett, 2012, p. 548).

While that may be true for countries with extensive democratic traditions, it is surely a less
significant factor in a country like South Africa where the governing party enjoys a very
substantial margin of electoral support and where much of that support is based on visceral
support for the party of national liberation. Under such circumstances the ‘political’
consequences of policy failure are like to be that much more forgiving. For example, it can
hardly be said that the manifest policy fiasco that was the under-serviced area licences had
any impact on the ANC’s support at the polls - in fact, as recent events in Tshwane have
demonstrated, political opposition to the ANC is likely to be vented at the barricades, not the
ballot box. Neither did the policy failure of the USALs appear to have any consequences for
either the Minister concerned nor indeed for any of the senior civil servants involved.

It is also worth noting that the ‘political’ consequences of policy failure are likely, in a way
not dissimilar to that of ‘process’ success or failure, to operate more at a macro level.
Except perhaps in cases of policy disaster, where either or both the ‘salience (intensity and
visibility)’ or the ‘magnitude (extent and duration)’ (Howlett, 2012, p. 544) of the policy
failure are high, the ‘political’ impacts of policy failure are likely to be more diffuse and at
more of an overall level.

Considering the manifest ‘programme’ failures of South Africa’s universal access and service
policy outlined in the preceding section, it is perhaps surprising that the ‘political’
assessments of the policy appear to be so lenient. This may in part be because the manifest
and stark nature of South Africa’s digital divide remains obvious to all, notwithstanding that
it is now a divide that has shifted away from telephony towards access to broadband
Internet. This means that today, as in 1994, there is no serious or substantial opposition to
the political imperative of achieving universal access and service. Further, given the fact
that the two major planks of policy intervention in respect of universal access and service
(universal service obligations, and the universal service fund) still remain part of the
accepted canon of policy precepts (ITU, 2013), there is no contending vision of international
best practice in this policy area vying for hegemony. Coupled with the fact, as we saw
above, that the majority of the country’s households and citizens now have access to mobile
telephony - albeit not as a consequence of the policy - this means that political
judgement of the policy is muted.

7 Conclusion
As we have seen, South Africa adopted a number of UAS policy interventions (universal
service obligations and the establishment of a universal service fund, in particular), largely
influenced by an international best practice regime centred on the International
Telecommunication Union, but influenced also by policy inputs from the European
Commission, the OECD and the WTO. Driven by the imperative to provide universal
affordable access to telecommunications networks and services to the hitherto
disenfranchised majority of the country’s population, often poor and in rural areas, the
country also dallied with a number of policy innovations, not inconsistent with international
best practice (the creation of a dedicated universal service agency, and the granting of
licences specific to under-serviced areas in particular).

We have seen that each of these policy interventions is widely, if loosely, considered to have
failed in one or more respects. Drawing on the three category heuristic developed by
McConnell, we have been able to elaborate and assess each of the components of this UAS
policy cluster in relation to the ‘process’ adopted, the ‘programmatic’ outcomes, and the
‘political’ impacts. It seems clear from the analysis above, that, while it assists to frame and
structure the discussion, the McConnell framework is not without its problems.

Firstly, it seems clear that there is some merit to the contention of Bovens and ‘t Hart that
McCionnell’s ‘process’ dimension operates at a level qualitatively somewhat distinct from that
of the ‘programmatic’ dimension. As we saw above, programme failures can be discerned
and analysed at the very detailed micro level of each of the specific policy components,
whereas ‘process’ assessment seems to operate at a much more overall level, that of the
entire cluster of policies within the policy cycle. Moreover, much the same seems true of
the ‘political’ dimension of policy, where assessment, except in cases of particular and
discrete policy, also tends to cohere around the policy cluster as a whole.

The attempt by Howlett to introduce the policy cycle framework into the analysis is an
interesting and useful one, but the question needs to be asked as to whether or not some of
the components of the policy cycle (‘implementation’ and ‘evaluation’ in particular) do not
more naturally align with McConnell’s ‘programmatic’ dimension. Perhaps we need to
distinguish between the adoption of a policy cycle approach as part of ‘process’, and the
assessment of concrete ‘implementation’ as part of ‘programme’.

What the introduction of the policy cycle into the debate does suggest is that there may be
a temporal sequence to McConnell’s framework. Whilst the causal concatenation is not
necessarily simplistic or unilateral, policy process does tend to precede and shape
programmatic implementation, which in turn influences political impact. Thus, the features
of policy as ‘process’ tend to be more pertinent in relation to the framing and formulation of
a policy or cluster of policies, whereas policy as ‘programme’ provides an analytical tool to
assess the implementation of the policy, and policy as ‘politics’ offers insights into the long-
term impact of the policy. And failure in any one of the three conceptual areas tends to
have a knock-on effect further down the chain15, mitigating against the likelihood of success
in consequent stages. This, in turn, opens up the possibility of developing a best practice
framework drawing on these insights.

Recent literature has introduced a number of additional concepts into the debate as to what
constitutes policy failure. With the debate about the analytical status of policy as ‘process’
yet unresolved (Bovens & ‘t Hart, 2016), and with the introduction of new concepts to the
debate such as the ‘policy cycle’ and the questions of ‘salience’ and ‘magnitude’ (Howlett,
2012), much remains to be settled if a fully coherent theory of policy failure and success is
to be constructed. Insights that come from differing planes of analysis are not always
readily integrated.

Further, new issues may well need to be introduced, considered and debated. For example,
to what extent and in what ways is policy failure path dependent? In South Africa, it was
apparent within its first five years that the universal service agency was an ineffectual
institution at best (Stavrou, Whitehead, Wilson, Seloane, & Benjamin, 2001), but nearly 20
years after its establishment we still await the necessary policy learning and corrective
action from the decision-makers, despite the recommendations of the ICT Policy Review
Panel (DTPS, 2015). The question of the degree to which analytical frameworks for policy
failure and success may be context specific, as suggested above, may also need further
investigation. We are therefore some way off an analytical framework that possesses
predictive power at anything but the most general of levels, as well as providing a narrative
framework. For the present, however, the frameworks offered by Bovens and t Hart,
McConnell, Howlett and others, nevertheless provide valuable lenses through which to
structure the narratives of policy failure and policy success, and from which an explication

15
Whilst is is possible to have ‘programme’ success in the absence of a high quality ‘process’, ‘process’ failure is
likely to spark problems at the ‘programme’ level.
and analysis of the possible causes of policy failure, along with the potential policy learnings
can be attempted. We should perhaps recognise, however, as van der Heijden has pointed
out in his plea for a ‘pluralist approach’, that competing lenses produce competing
interpretations (2012).

It appears, therefore, that the cluster of policy interventions adopted and adapted by South
Africa from the global international best practice regime, and implemented in the twenty or
so years since the advent of democracy, can largely be assessed to have failed in their own
terms. As ‘process’ they may have started well, but came largely unstuck as the process
moved towards implementation. As ‘programme’ they were almost without mitigation policy
fiascos. As ‘politics’, because of their relatively micro level and because of the nature of
South Africa’s body politic, the jury remains rather more out.

What is of interest, however, is the fact that, although the universal access and service
‘programme’ has largely proven a failure, the policy paradigm that animated this cluster of
interventions remains largely intact and continues to enjoy political legitimacy. Few today
would gainsay the need to extend access and promote universal service to the full range of
ICT services and content

But access to the Internet and to broadband is already firmly on the agenda. And, with a
number of companies rolling out fibre to the home in affluent households in the major cities
of South Africa (Sidler, 2016), a new digital divide looms. A new set of policy interventions
- hopefully evidence-based and informed by policy learning derived from analysing the
degrees of policy success and policy failure from the past - will be required to ensure that
interventions designed to ensure universal access to the full range of high-bandwidth
services, applications and content emerge as policy success rather than policy failure.
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