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LINK Centre Policy Research Paper
No 4: Preparing South Africa for Next Generation Networks, Services and Regulation
LINK Centre Policy Research Papers 1. Introduction
2.2 Telecommunications 2.2.2 Competition and innovation in services sector 2.2.3 Independent Regulation 3.2 Market convergence 3.3 Policy and regulatory convergence 3.4 Convergence or divergence? 5. Arising policy considerations for South Africa 5.2 Socio-cultural outcomes 5.3 Employment and human capacity outcomes 5.4 Research and innovation outcomes 5.5 Governance and Institutional outcomes 5.5.2 Changing role of regulation and regulatory principles 5.5.3 Institutional design 5.5.4 Global e-governance 5.5.5 Regional harmonisation
Governments across the world are grappling with appropriate policies to optimise the benefits associated with converging technologies and markets and to ameliorate potentially negative outcomes. Convergence has emerged as a global phenomenon as a result of digitisation which has allowed traditionally distinct services to be offered across interchangeable platforms. These technological trends have been accelerated by the liberalisation of markets allowing for the development of global digital communication networks offering multiple services across national borders. While converging technologies have changed the face of global communications and will continue to do so in future, the take up of converged technologies and services has been much slower than suggested by the hype even five years ago. The reasons for this are multifarious. At the global level the burst of the dot.com bubble, compounded by the global recession has slowed down investments both in the research and development and investment in infrastructures and services but the way convergence will play out at the national level will differ according to the market, governance and cultural arrangements of individual countries.
What is evident at this stage however is that it is these technological developments, together with the liberalisation of markets, that have been harnessed by those countries that are building national information infrastructures, critical to the development of effective modern economies. These are characterised by integrated broadband networks offering high speed access to a multitude of customised services and content to meet a variety of needs across the economy and society from finance to education. These national 'infostructures' serve as nodes in a global high speed communication network allowing the economies of those countries to engage in the global economy. While public and private business is transacted within these nodes and across the globe, two thirds of the world's population are marginalised from these information and decision-making networks, undermining their rights to equality as citizens and consumers. This increasing gap between those with access to these global information networks and those without access has been labelled the digital divide and represents one of the major challenges for policy makers across the world. For nearly a decade South Africa has articulated a vision for itself of an information society inclusive of all its citizens, participating in the network economy with the associated developmental dividends. This remains the challenge South Africa faces as it forges a forwarding-looking and enabling convergence framework. Existing Information and Communication Technology (ICT) policies have tended to move from an industrial economy base addressing as they do their various sectors as distinct silos of activity. For the potential of convergence to be realised and the backbone of an effective digital economy to be developed an entirely new approach will need to be adopted - one that is more reflective of the information era and which will enable the development of the information infrastructure needed to underpin a modern, network economy. This will require a change in the current market structure with its emphasis on vertically integrated network operations, distinctly regulated along technological lines, toward a more horizontal market design. This will allow for the most efficient delivery of digital services seamlessly across a variety of networks to fulfil an increasingly diverse range of communications needs. A new licensing regime that reflects this new horizontal market structure will need to be devised through the introduction of separate network, applications and services and content licences, some of which may require nothing more than a registration. In the longer term this will move the regulatory regime from the traditional economic regulation of the sector to a potentially less regulatory-resource intensive competition regime. While the regulatory burden associated with a vertically integrated market of the kind that has tied up ICASA, the Competition Commission and the Courts for the last five years, will be reduced, several new regulatory challenges will emerge requiring a highly skilled regulator. Convergence trends, unaided by the enabling licensing regimes or ownership rules, are likely to result in concentration of ownership and market dominance. Effective regulation will continue to be the lynchpin in the creation of a fair competitive environment, in which the excesses of the market do not impact negatively on public interest considerations of cultural diversity, equitable access and political plurality. This regulated competitive environment should make services more affordable and allow more citizens to be mainstreamed into the sector. There is no doubt however that there will be significant numbers of people that will need state assistance to access communications services for a long time to come and strategies to achieve this in a multimedia environment will need continually to be reviewed, explored and implemented. However, pursuing strategies of price reduction in the market - not an easy task at the time that one is simultaneously demanding high cost network expansion - would allow more people to meet their specific needs and access subsidies funding could be target at the people who most need it.
All of this is dependent on a highly integrated national plan that will include strategies to attract, develop and retain the necessary human, financial and intellectual capital needed to operate the information infrastructure. The need for the high level of policy co-ordination results from the role of the communications sector in the network economy both as a services sector in itself and as the underpinning of the other major service sectors in the economy. So, while the focus of this paper is on the convergence taking place in the communications sector, it should be noted that convergence in this sector allows for convergence of all knowledge and transaction based service industries, including finance, education and health. It is this cross-cutting impact of convergence that demands high levels of policy integration or at the very least co-ordination between different government ministries including finance, trade and industry, state enterprises, science and technology, education, arts and culture, health and so on. The opportunity costs of not developing an appropriate policy and regulatory framework are high and are globally evidenced in what has been coined the digital divide. Countries that are unable to take up the challenges posed by global technological and economic trends are increasingly marginalised, not only from the global network economy, but in their ability to deliver on their own developmental objectives.
The proposed telecom and broadcasting policy review process arises from the inability of existing policies to deliver on anticipated outcomes. Already the drag on the national economy of outmoded policies and legislation formulated not even 10 years ago are evident in the retarded growth in certain ICT market segments and diffusion of ICTs and even negative growth of certain market segments. Ensuring that South Africa's participation in the global economy is not simply the inclusion of another metropole surrounded by the unconnected periphery, will be a major policy challenge but clearly current strategies are not delivering affordable universal access. As the policy shifts required for South Africa to achieve desired outcomes are likely to be dramatic, they are likely to require longer timeframes to implement. In this regard prioritising and sequencing policy and regulatory issues is essential. Equally important will be the development of strategies to bridge the transition and also to ensure that the current failures that have prompted a policy review are not exacerbated during the transitional period. Current policy and regulatory constraints inhibiting ICT penetration and sector and national growth that can be eliminated within the existing law should be effected. This would include current artificial distinctions between voice and data in a digital environment and limitations on self provision, resale and direct connect. While existing licensees rights cannot simply be waived, the implementation of such provisions were anticipated from 2000 in the liberalisation time-table of the South African Telecommunications Policy White Paper. Several of these obstacles could be dealt with by the Minister of Communications simply setting dates for such activities as contained in the Telecommunications Act as amended. Despite the Second Network Operator (SNO) licence not having been finalised, such activities should not be made the subject of any further restrictive practices or licensee rights. Short-term financial gains for the state should not be achieved at the expense of longer terms losses arising from the stifled development of this critical sector of the economy. In fact, opening up these activities are likely to create clients for all network operators. Allowing all of them, those traditionally broadcasting and those traditionally telecommunications to compete equally, is also more likely to induce allocative efficiency in the market with the associated benefits for users and consumers.
The aim of such a policy intervention should be to create a more appropriate and efficient market structure, requiring less negative regulation, better and simpler licensing procedures and ultimately a technology-neutral policy environment that lowers costs to service providers and consumers. Indeed, in a converging environment there are no economic or policy reasons to differentiate among services on the fixed network and less and less reason to distinguish between fixed and mobile, where there is already a high level of substitutability and which is likely to increase as mobile moves increasingly into data services. These quite modest changes to the law or setting of dates to allow for resale and self-provision will increase competition, providing more choice to users and consumers, lower prices and relieve ICASA from regulating what have been some of the most unproductively contested areas within the sector. It is against this backdrop that this policy research paper reviews how the benefits associated with convergence can be optimised by a developing country such as South Africa in order to meet national development objectives while at the same time participate effectively at the global level. The paper is not definitive or conclusive but seeks rather to create a framework for understanding convergence, highlighting critical issues and proposing a number of policy success factors. 1. Introduction Convergence is driven by the technological and economic drivers of digitisation and liberalisation. Digitisation is what makes possible the convergence of the historically separate platforms for broadcasting and telecommunication. The liberalisation of markets is what has driven the development of global digital communication networks offering multiple services across national borders. This has undermined traditional modes of communication and their associated economies of scale and scope offering a communications environment that is more international on the one hand and more fragmented, niched and competitive on the other.
While convergence most commonly refers to the integration of the previously distinct industries of broadcasting, telecommunications and IT, it is also evident within industries themselves such as the convergence between mobile and fixed telecommunication services which historically have been treated as discrete market segments. In fact, although this paper will focus on convergence in the communication sector, convergence in this sector allows for convergence of all knowledge and transaction based service industries, including finance, education and health. This is an important consideration in ensuring the policy integration needed to order to optimise the benefits associated with converged services and infrastructures. Traditionally, communications markets have been characterised by mass production for domestic markets, usually by vertically and horizontally integrated operations. Arising from these market structures has been a highly regulated environment both for content and carriage. The rationale for regulating content has been largely been socio-cultural. On the one hand, because of the freely available nature of radio and television, control has been exerted over content in the name of consumer protection on the grounds of decency, obscenity or appropriateness particularly to child audiences. The other thrust of content regulation has been to ensure the development and airing of local content through quotas or incentives. The major rationale for the regulation of signal distribution (broadcasting) and telecommunications infrastructures on the other hand has been the utilisation of scarce resources, particularly spectrum. With the introduction of network competition other resources not originally thought valuable such as rights of way and numbers have gained competitive value. So while the monopoly on broadcasting was for decades justified on political grounds in most jurisdictions, the rationale for a monopoly in telecommunications has been underpinned by economic justifications. Public utilities such as telecommunications and electricity were 'natural monopolies' in that services could not be economically duplicated due to the scale and scope of infrastructures networks.
The new digitised and global environment has eroded such rationales. Low cost wireless technologies have made possible the far more rapid deployment of cheaper networks to compete with or complement existing fixed networks. The emergence of the Internet with its global and digitised nature has eroded traditional mechanisms of controlling content, making enforcement near impossible. The resulting global communications infrastructure, underpinning the global economy, is highly uneven. Concentrations of infrastructure, and financial and intellectual capital in major centres, particularly various parts of the United States and Europe, allow these centres to dominate the global landscape. While national goals associated with domestic markets remain policy priorities, the positioning of developing economies such as South Africa in the inevitably and increasing global economy is of critical policy importance. Policies that divert global financial and intellectual capital to national or regional markets and retain that which has been locally formed are needed in order to improve the global competitiveness of the country. Doing this while trying to redress national imbalances presents a particular policy challenge for developing countries and managing the tensions created by this will be part of any successful strategy. Arising from the development of global markets has been the emergence of multilateral institutions that have taken on the functions of global governance. Institutions such as the World Trade Organisation (WTO), the reforming International Telecommunications Union (ITU) and the International Commission on Names and Numbers (ICANN) are determining, with different degrees of formality, the rules for global participation (1). While the biases and agendas of various organisations have been identified and the factors contributing to the lack of effectual participation by developing countries acknowledged, the fact remains that, with the globalisation of communications, such global entities will increasingly determine the frameworks for effective participation. It will become increasing important to divert resources towards influencing these agendas and their outcomes in ways that represent the interests of the developing countries and emerging economies. As a result, national policy frameworks should correspond in so far as is feasible with global trends and developments, while meeting domestic objectives. These are increasingly characterised by converging markets, offering a multitude of services across numerous platforms, characterised by internationalisation on the one hand and customisation on the other.
While such developments are inevitable it should be noted that convergence has not progressed at the speed at which was previously thought, largely due to a number of technological, market, regulatory and consumer barriers. In this regard many developing countries trying to develop appropriate policy and regulatory regimes for this environment are not very far behind more mature economies which continue to wrestle with these issues. While the problems associated with developing an enabling environment for converged services are similar for developed and developing countries, developing countries do of course face particular developmental challenges. It is here that the potential not only of technological 'leap-frogging' but abandonment of linear development approaches to market structures and their associated regulatory regimes, need to be courageously considered. The needs in Africa are so great and the backlogs so immense that only a fundamental paradigm shift in approaches to communication will provide the necessary solutions. South Africa's market and governance arrangements for telecommunications and broadcasting have been subject to vast changes in the last decade. These changes reflect enormous political and social transformation at the national level, and are also in line with rapid changes in the global communications market. The Independent Broadcasting Act of 1993 together with the Broadcasting Act of 1999 have ushered in changes that have seen the public broadcaster transformed from a state broadcaster into a public broadcaster and the public broadcaster further corporatised and its commercial and public components distinguished. While the South African Broadcasting Corporation continues to dominate the television and radio market, the introduction of a free-to-air private broadcasting station, E-TV, in 1998 has provided another voice in the market and is the fast growing TV station. More by default than design, from a policy point of view, the country also has one of the most sophisticated digital satellite subscription services in the world, DSTV, which emerged from the long standing analogue terrestrial service MNet, owned by the countries major newspaper countries. The face of radio has also changed dramatically since 1994 with the licensing of hundreds of community radio stations, the privatising of all SABC regional radio services, and the granting of greenfield licences in the major metropolitan centres. The developments reflect some successful policy outcomes to the major objectives of the broadcasting policy and legislation:
The production and airing of local content has been promoted through the setting of quotas for different categories of television programming together with independent production quotas. Music radio stations are also required to conform with quotas for South African music that are believed to have impacted positively on local music production. Although not unflawed, the Independent Broadcasting Authority forged this new environment, without the benefit of a guiding policy process or framework until the White Paper on Broadcasting was produced in resulting in the Broadcasting Act of 1998. The Act, which sought to provide policy direction to the Authority and deal with the omissions of the IBA Act and the rapidly changing technological environment, was however poorly conceptualised and crafted, resulting in legislation that was at least in parts, difficult to implement effectively or without being taken on review. Some efforts were made during the merger of the IBA and SATRA through the Independent Communications Authority Act of 2000 to resolve some of these failings but the inability of the legislation within a few years of its promulgation to deal with the rapidly changing environment are evident and acknowledged by the need for another policy review. Some of the fundamental aspects of content regulation such as restrictions on content are almost impossible to deal with in a converged environment and ownership limitations may have the effect of restricting investment in network development or prevent network efficiencies that may benefit consumers. These factors will all require review in the new policy process.
A similar pattern developed in the telecommunications sector with the Amendment Act (2001) which sought to deal with the omissions and limitations of the 1996 Telecommunications Act. Although the Telecommunications Act arose from a widely consultative process, much of the consensus brokered to deliver the policy White Paper was not translated into the Act, and even the highly respected White Paper, failed to anticipate the speed with which the telecommunications environment was changing. In seeking to deal with the omissions of the earlier acts, both the Broadcasting Act and the Telecommunications Amendment Act overreacted by placing far too much detail in the legislation, including several specificities which would have best been contained in regulation and which would have left the Acts more flexible and focused on principles and mechanisms. The reason for this most likely lies either in a distrust of the regulator to effect the political mandate of Government or in a lack of confidence of its capacity to do so (2). Either way, the effect has been to restrict the independence of the regulator which has impacted on its legitimacy within the sector. This is particularly so in the telecommunications sector where the co-jurisdiction of licensing and regulation by the Minister of Communications and the regulator have not served South Africa well and resulted in regulatory bottlenecks and a litany of legal challenges. Broadcasting has had its fair share of licensing controversies and regulatory disputes with industry. These appear to have been managed more effectively however, within the existing regulatory arrangements and without recourse to the courts. While there are several factors that distinguish the broadcasting and telecommunications industries in South Africa, an obvious difference is the fundamental difference in their governance arrangements. The independence of the broadcasting authority continues to have the protection of the constitution, while telecommunications regulation does not. This may well account for the perception that broadcasting has been able to deliver more effectively on its mandate and that the broadcasting industry have not been able to play off different decision-makers on licensing and other regulatory issues. As the first phase of post-apartheid telecommunications policy - which focused on the partial privatisation of Telkom and an extension of its monopoly on basic telecommunication services - has ended, a new phase - characterised by a policy of 'managed liberalisation' - has commenced. Although a number of important economic and social goals crystallised from the policy into the objects of the Telecommunications Act (No. 103 of 1996), the primary objective of this initial period was to increase affordable access to communications through gradual liberalisation of the market - specifically:
Other policy goals also include the promotion of an innovative and responsive sector through the development of broad and diverse service offerings; a competitive manufacturing and supply sector; the promotion of competition; investment and stability in the sector, as well as encouraging a diverse shareholder base through the promotion of SMMEs and historically disadvantaged groups and individuals; and developing a strong consumer focus also taking into account the needs of local communities and disabled users, as well as ensuring technical compliance and efficiency and facilitating the development of human resources within the sector. In an attempt to deal with the legislative lacunas that emerge as soon as previous ones appear to have been addressed in this rapidly evolving sector, the government has also introduced various pieces of disparate legislation. The Electronic Communications and Transactions Act was passed to facilitate e-commerce and create the legal environment to enable online transacting, and the Regulation of Interception of Communications and Provision of Communication-Related Information Act (2002) was recently promulgated in an attempt to reduce the use of ICT in criminal activities with the use of intelligent systems within the communications networks. There is little doubt that the sector has been dramatically transformed from what it was even six years before. This has been brought about by the partial privatisation of the incumbent operator Telkom in 1997, then the initial public offering earlier this year and the introduction of a third cellular licence and the opening up of the VANS market for competition. Arising from the Amendment Act we have further seen the granting of carrier of carrier and multimedia licence to the broadcasting signal distributor, Sentech and the intention to licence a Second PSTN Operator and an initial 10 under-serviced area operators.
The outcomes of these policy reforms have however been mixed. There are some indications that policy restrictions have retarded areas of organic growth in the market such as in the areas of VANS and Internet. In fact, the segment of the market protected in order to deliver on universal service, fixed line, has over the last two years had a declining number of subscribers on its network. On the other hand mobile cellular services, which were introduced as essentially for corporate and high-end residential users, have become the major source of connectivity for South Africans, with mobile subscribers having outstripped the number of fixed line subscribers over two years ago. However, despite the achievements of mobile, it is also clear that fixed lines will continue to be an important developmental measure. This is especially true in terms of access to the Internet. It is possible that as mobile helps to combat the voice access portion of the digital divide, a new gap in terms of access to the Internet, both in terms of cost and quality of Internet connections, will grow unless further fixed line rollout and upgrades occur. The central strategy for achieving universal service, in line with multilateral agencies' models at the time, was that of the partial privatisation of the fixed line incumbent in order to capitalise the extension and modernisation of the network. The Ministry oversaw this privatisation process. The arising responsibilities of the Regulator were to monitor the terms of the licence, with regard to rollout and quality of services targets, and the Ministerial imposed price cap on tariffs. It was also required to prescribe regulations to facilitate interconnection and access to Telkom facilities. Acknowledging that this on its own would not meet the needs of the poor, the policy and legislation allowed for the establishment of a Universal Service Fund from a levy on operators' turnover that could be used to subsidise the extension of networks in uneconomic areas and usage by 'needy people'. This Fund was to be administered by the Universal Service Agency (USA). While the purpose of this approach was to establish a dedicated agency that would focus on achieving universality in telecommunications, the effect of this was to remove the universal access mandate from the core function of the regulator, although it continued to have some enforcement functions in that regard. From the perspective of promoting universality, the results of Telkom's exclusivity period together with the leadership and capacity problems that have wracked the Universal Service Agency, have been disappointing. While fixed line communications has slowed down all over the world, South Africa is one of the few countries in the world with a declining number of subscribers on the network. While it has successfully grown the lucrative corporate market during the period of the exclusivity, it may well be that there are fewer residential subscribers on the fixed network today than in 1996, with over 600,000 disconnections in the last 30 months.
Source: 2002 Telkom Annual Report From: Gillwald, A and Kane, S: (2003) LINK Sector Performance Review
In South Africa and other developing countries, universality will only be achieved by a combination of increased access to telephone services and equally importantly by ensuring that those services are affordable to the general population. Following its Rate Review, the regulations prescribed by ICASA were delayed by the Ministry, allowing Telkom to go ahead with increases out of line both with inflation and its own claimed productivity gains, with the net effect of prices on basic services have increased by over 250% in Rand terms over the last six years. Figure 1 - Telkom Tariffs, 1997 - 2003 (Nominal) 
Cost of a Local 3 Minute Call (Peak Rate) 
Cost of Monthly Subscription / Connection Charge Source: 1997 - 2000 from ITU World Telecommunications Indicators Database (2002), 1998 - 2003 from Telkom Press Releases Gillwald, A and Kane, S (2003) LINK Centre Sector Performance Review The saving grace with regards to contributing to the achievement of universal service, has been the exponential growth of mobile which in the policy process of the mid 1990s had been viewed as an elite service for the business market and certainly not the intended vehicle of universal service. Around the world the performance of mobile over the past six years has been nothing short of extraordinary with many countries achieving subscriber increases in excess of 100%. While South Africa's growth rate is lower than this it is nonetheless impressive given the relatively large initial base of 2.35 million subscribers off which it was achieved. In Africa the figures tell a similar story, with the majority of cases of universal service growth achieved during the latter half of the 1990s coming as a result of the growth in mobile penetration. Morocco provides a particularly interesting parallel, where clearly the exponential growth of mobile of 150% from 1996 to 2001 is resulting in mobile substitution of fixed services, as must be happening to at least some degree in South Africa. It is likely that the rapid increase in Telkom's prices is, in combination with the growth in mobile, the cause of the high number of people coming off the fixed line network in South Africa in the past three to four years. This reinforces the point that it is both increased access (seen in the more than two million new lines installed by Telkom) and increased affordability (not yet seen in South Africa) that is necessary to achieve universal access. 2.2.2 Competition and innovation in services sector
This outcome is arguably the least successful aspect of the first phase of managed liberalisation. While mobile services have become increasingly competitive with anticipated innovation in services offerings both technically and from a marketing and billing point of view, there has not been the kind of growth and innovation anticipated in the value added network services and Internet service providers market. The VANS and ISPs attribute this primarily to the anti-competitive behaviour of Telkom. The blame for this inhibiting effect on this critical information economy sector has often been placed at the door of the regulator, the Independent Communications Authority of South Africa, ICASA, as the party responsible for reigning in the incumbents alleged anti-competitive behaviour. While it is true that the regulator has suffered a capacity deficit and has not always acted as swiftly and procedurally as desired, the real cause of this inherent tendency towards anti-competitiveness lies in the market structure and resulting resource intensive regulatory regime required to regulate it. The market is structured around a vertically integrated national operator from whom rival firms (with whom the integrated company competes downstream) are required to acquire their non-competitive facilities in order to operate and with whom other networks have to interconnect in order for their customers to access the historically larger number of subscribers on the incumbent's network. This structure creates anti-competitive incentives for the incumbent to deny access to its network to rival firms, whether through delays or pricing strategies. Traditionally, the regulatory response to this market structure, which tends to arise wherever a former public utility enters into a competitive market, is access regulation. Together with the delays around establishing a clear and timely interconnection regime, which has come close to bringing smaller empowerment entrants to their knees, the absence of this cornerstone regulation essential to enabling fair competition, has reduced investor confidence. These effects have been especially prominent in the VANS and ISP segments of the market where Telkom's rights and behaviour have had a chilling effect on the market's growth. This has been one of the major sources of tension in the sector and the source of numerous disputes between the independent VANS, who claim that Telkom is leveraging its market power with anti-competitive effect in the VANS market, and Telkom, which complains that the VANS are infringing on its exclusivity rights. While the failure to regulate the privatised monopoly effectively has been placed at the door of the ICASA and before it SATRA, it is important to understand the structural conditions established by the policy and laws under which regulation takes place. The notion of independence relates to autonomy both from government (which may include the incumbent if it is not privatised) and the industry (3). The concept has been explored in the literature in regulatory capture theory, which examines the potential of regulators, even those that appear statutorily independent, to be systematically influenced by one party or the other. In broadcasting, independence has particular overtones relating to political independence due to the content aspects of regulation and the needs to ensure public as opposed to state broadcasting on the one hand and to ensure a space for public interest broadcasting in an increasingly commercial global environment. For this reason the independence of the regulation of broadcasting is enshrined in the Constitution of South Africa.
The importance of this policy outcome in telecommunications relates to the centrality of independent regulation to the structural reform of the telecommunications sector from a public utility to a diversified range of competitive networks and services. The legitimacy of the regulator will directly affect the quality and speed of that reform. The potential for market foreclosure, particularly by dominant incumbents, underlies the requirement for an effective independent regulator to be established if liberalisation policies are to be effective. In addition to ensuring affordable tariffs and adequate service levels for consumers receiving services from the non-competitive components where consumers have no choice but to obtain service from that one provider, regulators are responsible for ensuring access to the network and facilities of monopoly or dominant operators if the benefits of competition in liberalised sectors are to be realised. Due to the hybrid, partially monopolistic, partially liberalised nature of the telecommunications market in South Africa the regulatory approach included both access and accounting separation regulation. However, access regulation, including tariff regulation, whether price cap or rate of return regulation, interconnection and facilities regulation all depend on complex costing models and assume a high level understanding of the market if they are not to result in regulatory failure.
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