Business and Technology

Every Organization Should Have an ICT Policy

An acquaintance of mine told me a story of how he continued to receive a salary from an employer 4 months after he left the organization complete with statutory deductions including HELB loan repayments. We have also heard of incidents where an employee is fired and he ends up ‘locking’ up ICT systems by changing passwords or refusing to share the passwords, sometimes leading to loss of business or information. Worse, some organizations have slowly bled to death due to frequent flouting of ICT policies leading to loss of money and customers. In fact, most fraud incidents today involve the improper use of ICT systems because of the lack of or poor policy implementation. Think IFMIS/NYS.

On the surface, these staff exit related examples might seem like the failure by the HR or IT department in ensuring proper exit of an employee or the proper use of ICT resources. But deeper, they point to a more critical and dangerous state of affairs: The lack of or the failure to adhere to ICT policy best practices.

What is an ICT Policy Document?

The Oxford English Dictionary defines policy as “A course of action, adopted and pursued by a government, party,ruler, statesman, etc.; any course of action adopted as advantageous or expedient.” Adding ICT to it, the definition can be thus: an ICT policy is a roadmap with specific actions and best practices towards the adoption, use, maintenance and value extraction at reasonable cost from ICT resources. Every action taken in the organization that uses or impacts ICTs must be guided by this policy.

As you can see above, without an ICT policy, there will be no roadmap on how and why an organization should adopt ICTs. At the bare minimum, an ICT policy document for an organization should include the below:

  1. Scope and objectives of the policy document: This defines the reason why the document exists, it’s target audience and what the document covers.
  2. Technology adoption roadmap: This gives a clear definition of where the organization is and where it wants to go in the short and long term as far as ICT is concerned. For example; is the organization moving from an in-house data center to the cloud? it must be in the ICT policy. Is the organization trying to change the ICT department from being a cost center into a revenue generator? It must be in the ICT policy.
  3. ICT best practices in relation to the organizations objectives: These define the do’s and don’t’s for the organization as a whole (and not the individual ICT user in that organization). For example; is the organization outsourcing its sensitive data analysis to a third party? This must be specified in the ICT policy. Is the organization allowing personal devices such as phones (BYOD) to connect to the office WiFi? This must be specified in the ICT policy.
  4. Precautions and disciplinary measures: This section details the rights and obligations of ICT users with punitive or damage preventive measures for failure to follow the laid down ICT policies by a member of staff. The severity of the punishment should commensurate with the risk or exposure the company suffers as a result of the failure to follow the laid down processes.

Checks and Balances

A policy document is just that; a document. It has to be operationalized through the implementation of systems, processes and a mindset change to ensure its success. Many organizations have well written but poorly implemented ICT policies. This poor implementation is often as a result of failure to interpret the policy into well understood rules and regulations. A policy begets regulation, which in turn begets directives. A directive like “No member of staff shall copy into a portable disk, any document, software or multimedia that belongs to the organization…” should have stemmed from a regulation that bans the use of portable drives in the work environment. This regulation should have stemmed from the policy that states “The organization, shall treat all the organization information with utmost care, protecting it from unauthorized access or modification both in storage and in transit”.
But what happens if all the above exist and members of staff still carry around USB drives containing the organization’s data? This is where checks and balances come in. the CIO can go a step further and disable all USB ports from accepting portable drives. He can also go ahead and have the system send an alert to the relevant IT team should anyone attempt to connect a portable drive to a company computing resource.

Future Proofing ICT Policies

A good ICT policy document should be future proof and technology or vendor agnostic. This is to say that it should desist from mentioning vendors or particular technologies. These details should be in the subsequent documents that emanate from the ICT policy document. These include but are not limited to:

  1. The ICT resources user guide. This is what many confuse for an ICT policy, Its more of regulations than policy. This gives details of how the organizations ICT resources are used with best practices. This is the document that entails regulations such as social media use in the office, BYOD rules, Email etiquette etc. It also specified specific do’s and don’t’s when using the organizations ICT resources.
  2. The Technology adoption plan: This is the short and long term plan of how various new technologies will be adopted and integrated into the existing systems. It gives solid reasons and timelines for this, showing the entire ICT use lifecycle. Technology adoption should not just be for the sake of it or because there is a newer, shinier technology in the market. Technology adoption should take into consideration the competitive advantage the organization is going to earn from the adoption and capex and opex availability.

In Summary

With ICT becoming an integral part of doing business today and the digital transformation that enables it, it’s very critical that CIOs are in control of the direction and pace of ICT adoption in the organization. This control cannot happen without a policy in place. The CIO can adopt the best ICT systems with good intentions to help the organization, but without an ICT policy, these systems will serve as a conduit for fraud, information assets and eventual revenue loss to the organization. If your organization does not have an ICT policy in place, Its time to have one.



Internet of things

The IoT is About to Take Off in Kenya

The recent news that Liquid Telecom has partnered with Sigfox Networks to to build and operate a nationwide Internet of Things (IoT) network should have received more prime time airplay than it deserved. The low cost, low energy consumption, long range IoT network will cover up to 85% of the Kenyan population. The introduction of a Sigfox “Low Power Wide Area Network” (LPWAN) is the first in the region, allowing users to use IoT technology wherever they are and positioning the country to apply cost-effective local solutions using IoT. This if you ask me, is a significant leapfrog opportunity for the country to show Africa and the world once more, who is the technology adoption leader.

The internet is full of articles of how the IoT adoption will be bigger than the mobile’s. The Internet is about to come out the screens we have used to interacting with, into the real world. The Internet is going to soon cease being virtual and become part of the world we live in. However, there has been little discussion of how the IoT will be adopted in Kenya.

Why “Low Power Wide Area Network” (LPWAN)?

The IoT will involve the connection of billions of sensors. These sensors will sense our surroundings, feed this data into computing systems that will most likely be in the cloud. I say most likely because IoT is bound to decentralize computing with what is known as fog computing. One of the shortcomings of the current mobile era is the high power consumption of mobile computing devices and networks. Their algorithms and architecture is optimized for speed and not power efficiency. If we were to embrace IoT and use the existing mobile networks, it would lead to sensors consuming a lot of power. This would limit applications, conditions and environments in which they can be deployed. With Low Power Wide Area Networks or LPWANs, the network is optimized for power efficiency and not speed. This means that IoT sensors that connect to LPWAN consumes much less power. To give an example, there now exist IoT sensors that can go for 10 years on a single battery charge thanks to their ability to use very low power in transmitting data. Industry estimates that there will be about 24 billion IoT devices on Earth by 2020. That’s approximately four devices for every human being on the planet.

The IoT Adoption Waves in Kenya?

The Liquid LPWAN presents an opportunity for Kenya to embrace the IoT. The question in everyone’s mind however is: What real life application for IoT is there in Kenya? Based on my prediction, there will be two adoption waves.
The IoT early adopters who make up the first wave, will be manufacturing and logistics companies who will have realized early enough the efficiencies the IoT will bring into their operations. For example, one of the biggest challenges faced by keg beer manufacturers is the loss of the aluminum kegs. It is estimated that over 15% of the kegs are lost and never return to the depot, with each keg costing about KES 30,000 to manufacture, they are losing money. With IoT sensors with GPS and tracking capabilities, the brewers can not only keep track of their kegs throughout the supply chain but also monitor the freshness of their contents.
Another low hanging fruit is in the logistics sector. App developers can come up with new applications that leverage IoT sensors and networks, for example, to track the delivery routes and frequency of various parcels and use this data to come up with better, more efficient routing, or efficiently track in real-time the movement of goods. Utility companies such as Kenya Power can add value to their customers by incorporating IoT smart meters that will enable consumers track power consumption in real-time and give them more control over their usage patterns.

The second wave of adoption will bring IoT into homes and personal spaces. This will see the rise in smart homes, embedded health devices and personal tracking systems. This is the wave that will cause an IoT adoption explosion whose outcome is mass adoption, massive drop in IoT device prices and unprecedented innovation around the IoT similar to what we witnessed in the mobile telephony adoption.

The benefits of the IoT adoption will be immense, consider the effect of connecting taxi cars to the internet via apps such as Uber, Taxify and Littlecab. This has had the effect of significantly lowering taxi fares and waiting times in ways we thought impossible just a few years back. This is just one example of how connecting previously unconnected everyday things to the Internet will change how we live and work.

IoT Security and Regulation

The IoT is coming, whether we are ready or not. However, lessons from the mobile telephony adoption wave can be adopted to avoid similar mistakes that arose during the mobile era. These mistakes in the IoT include:
1. Failure to secure user data in transit or in storage collected by the IoT sensors.
2. Failure to regulate the quality of both the IoT software and hardware components imported into the country.
3. Lack of public awareness on the good use of the IoT and best practices when using or interacting with the IoT.
4. Failure to ensure privacy of people or entities the IoT sensors collect data about whether deliberately collected or not.

The above can be remedied by putting in place laws and regulations on the IoT use in Kenya and creating public awareness early enough for the IoT users.

ICT and Telecoms, Mobile Telephony, Regulation and Law

The Dominance Debate Should Be About The Consumer’s Welfare, Not Operators

Communication TowerDuring the last Safaricom AGM, the dominance debate came up and all contributors to the discussion at the meeting seemed to agree on one  thing: That the regulator is punishing Safaricom for being successful and that it was not their fault that their competitors have refused to invest and innovate. The recent calls by their competitors to the regulator to have them declared dominant and abusing their dominance are based on a market study report released last year by a consultant. This report found Safaricom to be dominant in both the mobile communication and mobile money markets. The report went further to suggest remedies that include infrastructure sharing, retail tariff controls and the splitting of the company into several independently run companies for mobile money and mobile communications.

In July this year, the parliamentary committee on ICT’s met sector players on the issue of dominance and what came out was other operators still strongly feel that they cannot be able to compete with Safaricom on equal footing. On the other hand the committee members felt that the operators are not doing enough to pry off Safaricom’s grip on the sector. Recent reports also indicate that the regulator is also under pressure to declare Safaricom dominant and in abuse of its dominance. By going ahead and doing so, the operator will not have a free hand in the determination and introduction of new products and services in the market without the regulators direct approval. Another recommendation that is being pushed is the sharing of both active and passive infrastructure by Safaricom with its direct competitors.

A point to note on the above is in all this discussion, no one is looking at the possible effects the implementation of these recommendations will have on the most important person in this debate; the consumer. The focus is mostly on the operators commercial welfare. Also, should the regulator decide to go ahead and implement the recommendations, what laws or framework will be applied? Are the laws also relevant to the current technological and market realities?

The Kenya Communication Act of 1998 and its subsequent amendments (Kenya Information and Communication amendment act of 2013) specify that the regulator shall from time to time develop and publish, in the Kenya Gazette, guidelines to be followed when determining whether a licensee in a dominant market position in a specific communications market. The Act also specifies that for the regulator to determine if a player is dominant, it shall prepare a dominant market power report to determine whether a licensee is dominant in a service or geographic communications markets. This is the report that was released in February this year. Based on the reports findings, the Act specifies that the regulator can declare a licensee dominant by considering the gazetted criteria, One of the critical criteria is if the operator possesses Significant Market Power (SMP).

Upon declaring an operator as dominant, the regulator will also need to show that the dominance is being abused to edge out competition from the market or to generate more profits or even offer inferior quality of service with no consequences. The criteria that can be used to check if there is abuse of dominance are as below. It’s worth noting that Safaricom meets none of the criteria below for abuse of dominance.

  1. Refusal to deal with competitors on the essential facilities doctrine: essential facility is facility supplied on a monopoly basis but is required by competitors but they cannot be reasonable duplicated by competitors for either economic or technical reasons. With new approaches or alternatives to essential facilities sharing such as VNOs and national roaming, and the fact that all mobile networks now have  a packet switched core as opposed to circuit switched, this doctrine cannot be used as a measure of dominance abuse because already Safaricom is sharing and leasing out unbundled services.
  2. Cross subsidization: This is where the dominant firm uses revenues from a market in which it is dominant to cross-subsidize the price of a service or product it provides in other markets. For example, there would be suspicion of cross-subsidization if Safaricom, when recently entering the home internet market (which Zuku was the de-facto player), offered much lower pricing than them by subsidizing home internet user pricing with revenues from their voice business. Entry prices for most markets Safaricom ventures into are often higher than competitors.
  3. Predatory pricing: This is where the dominant operator charges prices below a normal cost standard. At the moment, Safaricom prices are not the cheapest in the market so this also does not apply too. This debate would have made more sense if Safaricom was dominant through the offering of prices well below their competitors price points.
  4. Bundling of services: This is where the operator sells a product at a fairer price on condition that you also buy other services from them. For example, a user who simply wants airtime should be able to buy only airtime and not be forced to buy airtime and data though an offer despite them not having an immediate or future need for the data. If anything, its Safaricom’s competitors who are bundling services leading to wasteful accumulation of unnecessary services such as hundreds of unused SMS’s and talk time minutes that accumulate as subscribers purchase bundled data for internet access.

Innovation and Operations

There is this notion that the mobile sector is vendor driven, that the telecom equipment vendors often dictate the pace of innovation in the market. This is partly true and therefore also means that competitors in the sector have access to similar technology because the vendors in the sector supply all operators. Nokia, Huawei, Cisco, Ericsson all supply to the operators the same products. The difference however comes in on how these products are monetized. The dominance report recommends that Safaricom, upon being declared dominant should not sell services that are not replicable by the competition. This is to say, they cannot come up with a product that their competition, using their resources and infrastructure cannot come up with easily. The Kenyan ICT talent pool is very large and any operator worth their license can afford to hire the best brains in the country. The fact that all operators have equal access to technology and talent means that its not hard to replicate competitors products. But why then isn’t this happening? The answer lies in company culture. Safaricom cannot be punished for cultivating a culture of innovation as their competitors sit and wait for the regulator to give them a piece of the innovation pie. All operators have the necessary ingredients to succeed.

One business model that has been adopted by Safaricom’s competitors is outsourcing of functions. Ideally, firms are supposed to outsource their non-core functions so as to enable them focus on their core function. If its a hospital for example, it can outsource its transportation, cleaning, etc but isn’t expected to outsource core functions like diagnostics and patient care. However, many firms that adopt the outsourcing path end up over outsourcing even core functions. The reason is purely to make the financial statements look better because most of the costs will be classified as variable and not fixed costs. When a firm outsources both core and non-core functions to third parties, it loses control over quality of service and also fails to clearly see any inefficiencies in the operations.  The result is outsourcing will make the books look good but affect customer experience through inefficient service delivery.

What are the alternatives?

With telecommunication services now permeating all sectors of our lives, it has become a critical catalyst for socioeconomic development. drastic actions such as declaration of dominance and splitting up Safaricom will have far reaching effects on the Kenyan economy all in the name of giving it’s competitors an equal footing. So far, several regulatory actions aimed at leveling the playing field have not yielded much. First it was Mobile Number Portability (MNP) which according to analysts didn’t work well because subscribers were afraid to change operators due to M-pesa. For MNP to work, many felt that Mobile Money Interoperability (MMI) had to be in place. The regulator managed to bring all operators on the table and effect mobile money interoperability. So far since implementation, there has been no effect on the market dynamics. There are also a raft of measures put in place by the regulator to create a level playing field. Many of these measures have actually helped Safaricom’s competitors make slight gains in their market share. I believe these gains could have been more if these operators improved their operational efficiencies first.  Splitting Safaricom when the competitors operations are inefficient as they are will only do more harm to the sector as the supposed benefits will not be realized at that level of efficiency. The regulator in addition to playing its current role, should also demand accountability from operators on actions it takes to enable them gain market share but the operators fail to take up these opportunities. A good example is there was a very big push to effect mobile money interoperability, but when it was done, there was very little in terms of marketing this development bu those who were asking for it. At the very least there should have been a major marketing campaign that coupled MNP and MMI.

Another approach would be to offer tax breaks to Safaricom’s competitors on investment in network and services. This would lower their CAPEX on network roll out and services. Tax breaks can also be applied as a motivating factor when these operators reach certain predetermined targets. For example, if an operators revenues or market share hits a target, the government gives them a tax break. This will push them to be innovative in revenue generation and market share gaining activities.

The consumer

All the discussion around dominance has been mostly about operators gaining market share. There seems to be very little concern on the most important stakeholder: the consumer. At the end of the day the consumer should be able to make the decision on which provider to subscribe to based on the value they get. There is a general assumption that the consumer is always price driven. That all his decisions are based on price. This assumption is what has led to the many price wars we have witnessed in the market which have yielded little in terms of market share gains. Consumers buy convenience and experiences. operators who want to be successful must start looking at the consumer experience and convenience when they are on their network.

The focus of this debate should be the improvement of consumer welfare. All actions by the regulator should take into consideration the consumer, consumer welfare is the regulators biggest mandate. The best approach would be for the regulator to look at how best citizens will be served telecom services. The recommendation for Safaricom to share its infrastructure with competition can be shelved in favor of the Universal Service Fund. The USF can be used to lower the cost of rolling out services by operators in under served areas. This approach has worked very well in Latin America.

According to an analysis by the Institute of Economic Affairs (IEA), should the regulator implement the dominance report  recommendations, consumer prices for services would actually rise and not fall. This will hurt the consumer despite the fact that the leveling of the playing field for all operators is supposed to lead to lower prices. The declaration will serve the operators but not the consumer. So in the interest of the consumer, I believe other approaches listed above can be implemented, splitting Safaricom is not one of them.

Mobile Telephony, Regulation and Law

My Thoughts on the Proposed Retail Tariff Controls in Kenya

telecoms-13The Communication Authority of Kenya is mulling on introducing retail tariff controls in the Kenyan mobile telephony sector. As you would imagine, this has elicited mixed reactions depending on who you ask. This move it is said is part of a raft of recommendations by the recently released report that studied the Kenyan telecommunication competitive landscape. The introduction, according to the regulator is aimed at correcting market failures that are as a result of one operator being dominant over the rest. The proposed retail price controls aim at limiting Safaricom’s freehand in determination of loyalty schemes and promotions, prohibition of on-net discounts, mobile money fees charged to unregistered and cross-platform money transfers. Tariff  control is a regulatory mechanism that can be employed to correct market failures in a market. The main motivation for price control is to protect consumers’ rights and interests in circumstances where market forces alone have been unable to do so.

The competitive landscape report implies that Safaricom’s price differentiation between on-net and off-net calls leads to tariff-mediated network effects. By this I mean that subscribers on a network find it cheaper to call others who are on the same network than calling people on a different network, the effect of this the emergence of the ‘club’ effect where subscribers decide which network to join based on which network the people they call mostly are on. If most of my family and friends subscribe to a network X, I am more likely to subscribe to network X because by being on network X and not on network Y, my overall calling costs will be lower due to cheaper on-net pricing. This it is argued is abuse of its dominance. But this is only true if the interconnection rates are high between Y and X meaning it will cost me more if I chose network Y where none of my relatives and friends subscribe to. As we speak, interconnection rates are already regulated by CA. This fact alone means that the regulator found and enforced an interconnection rate that was cost based and reflected the market realities. The Safaricom on-net call rates are above the regulator-set interconnection rates  and are similar to the rates its competition provides its customers to call into the Safaricom network, in short, Safaricom’s subscribers pay the same rate as competitors subscribers when both call another Safaricom subscriber. CA would be justified in imposing tariff controls if indeed Safaricom’s subscribers paid less to call their counterpart than when competition subscriber calls. The fact that the report found that each operator was dominant on its own network also means that the club effect can easily be replicated by competition through aggressive marketing and innovation.

Individually tailored tariffs

Another proposal by the regulator is the prohibition of individually tailored loyalty schemes and promotions. The CA 2010 Tariff regulations specify that all promotions or loyalty schemes must be approved by the regulator prior to commencement. Any promotion, offer or scheme currently in operation has the direct approval of the regulator, the details of each promotion or loyalty scheme structure were available to CA before approval and these include individually tailored schemes and promotions. When an operators behaviour due to regulation causes it to become successful, it cannot be punished for successes it encountered while operating within the laid down regulatory framework. If there is any discriminatory behaviour, then CA failed in detecting and stopping this even with the existence of regulations. When that happens, it is clear that regulation is not the solution to the perceived market failures and the only remedy is let competitive forces determine customer choice.

What would happen if call tariffs are regulated?

Most people assume tariff regulation leads to the lowering of retail rates. This would only be true if CA had a way of accurately measuring the costs involved to provide service to additional customers on their network. At the moment, due to the fact that Safaricom has invested more in network infrastructures geographical and population reach, it costs them less to bring in a new customer and provide service to them than its competitors. The proposal to use Long Run Incremental Costs (LRIC) method would mean that because of the massive economies of scale enjoyed by Safaricom owning a large network and technology convergence, the cost of offering an extra minute of termination on the network is virtually zero in the short-term and LRIC is applied to give a realistic cost over the long term. How long is ‘long term’ will determine the price point.
A regulated tariff price should imitate the prices that would have arisen in a market with effective competition, both because this provides incentives to produce the requested service at the lowest possible cost and because the operators requesting the service have the incentive to optimize their own investment decisions. In this way price controls can contribute to efficient utilization of social resources. The problem however is that LRIC works very well in legacy circuit switched networks where it was easy to link network utilization with the provision of a service (if a switched circuit is in use, it is providing a directly attributable service), in a converged environment, the relationship between network resource utilization and provision of services is not that straightforward and an LRIC model applied to it would fail to efficiently allocate costs. As networks evolve into Next Generation Networks (NGNs), LRIC approach to service cost allocation becomes inefficient and LRIC starts to resemble the Full Allocated Costing (FAC) model. The result? higher prices to the consumer.

Replicable retail tariffs

One of the recommendations by the study is that Safaricom’s Tariff must pass the ‘replicability test’.  In order for a product or service to be considered replicable, it must be commercially and technically capable of being replicated by Safaricom’s competitors. By this we mean that any new tariffs that Safaricom comes up with should take into consideration the capability or state of competitors infrastructure and services especially at the wholesale level. If for example, Safaricom comes up with a tariff that takes advantage of a new innovation they developed, then competition should have similar innovations on their networks or should be allowed by Safaricom to access this new innovation at wholesales prices to enable them offer similar tariffs. In order for competitors to be able to compete with Safaricom in retail markets, it is necessary for them to have access, either via their own networks or through access to Safaricom’s network, to the wholesale components that enable those retail prices to be offered. This as you can imagine will slow down the pace of innovation by Safaricom or change the main focus of innovation from the customer to competition, anytime Safaricom wants to innovate, they will think of ways through which competition will not benefit much from it as opposed to spending their time and knowledge on how the innovation will first benefit the customer.

Tower sharing

The report found that Safaricom is dominant in the tower market owning about 65% of telecommunication towers in Kenya and recommends that it shares it towers with competition. To do this effectively, Safaricom has to let a 3rd party manage the towers on its behalf. Safaricom owns its towers while competition has a mix of owned and outsourced/leased towers. With rapid advancement in technology, there is a saying in the industry that it is always cheaper to build a network tomorrow. Any new entrant or existing operator rolling out new retail services and infrastructure such as towers will do it cheaper today than those who did it in the past. See how easy it was for Finserve Africa (Equitel) to get market reach by the flick of a switch riding on an MVNO license? Older operators didn’t get to enjoy these benefits and had to put in sweat and blood to get where they are.
In the Safaricom 2017 sustainability report, the operator spent close to 10 million litres of fuel and about KES 48,000 per month per tower location on energy costs. The report also shows that fuel and power costs are coming down and that Safaricom has also embraced green energy initiatives to power the active components at the tower stations, it is becoming cheaper by the day to setup and manage tower locations but the increase in the number of towers makes the management of the same a challenge.  Outsourcing of tower management is used by some operators to shift a large element of their fixed costs to the variable costs column of their financial books, in doing so the operators financial health improves. Tower outsourcing has little to do with improved efficiency in actual operations and management of these towers but more to do with improving the books. Due to this, the global trend in the telecom sector is the outsourcing of tower management to independent 3rd parties, something Safaricom should consider for its own benefit and not due to regulatory requirement. Safaricom should then decide to lease its towers to competition on a purely commercial basis.

Conclusion

Although well meaning, the CA needs to explore non-tariff based remedies to the perceived dominance of Safaricom. Tariff control is a very intrusive approach to handling abuse of dominance whether real or perceived. As markets evolve to become competitive, ex ante regulation should reduce as the regulator forebears regulation in favour of competitive forces. The challenge however is that customer inertia can mask the existence of competition in the market leading to the regulator applying regulatory tools to correct this perceived market failure. Market forces should be let to dictate the market tariffs.
The tariff control ocean floor is littered with shipwrecks of tariff control attempts by various countries that  tried to correct market failures by  employing it. One of these countries is Mexico who in 2012 introduced tariff controls by baring America Movil from charging interconnection fees to its competitors. Movil controls 70% of Mexico mobile market. As of 2015, mobile call charges had dropped by about 17% but investment in the sector dropped 30% during the same period, for a developing country like Kenya, a drop in ICT investments will have far reaching effects across multiple sectors of the economy. Whereas the intended outcome of tariff control is to  protect the consumer from a dominant operators actions, the question that remains is whether tariff control is the only viable market correction tool available.