There is a maxim in the start-up business that if a venture attracts no criticism at all, it should not go ahead.
Since the announcement of the formation of a new government agency, the Info-communications Media Development Authority (IMDA), through the merger of the Infocomm Development Authority (IDA) and the Media Development Authority (MDA), I have heard only compliments and favourable comments of what a great idea it is.
In the spirit of wanting to send the new body off to an auspicious start, let me, therefore, offer a few discouraging words so that it will be at home on the range.
Some of the criticism of a regulatory body that combines both regulation and promotion of an industry are already known.
In fact, I had co-authored a paper a dozen years ago now in response to a study by the ITU of the advantages of the IDA model for telecommunications regulation.
ITU is the United Nations' specialised agency for information and communication technologies.
Chief among the reasons is the tension between regulation and promotion, which is known.
That the two agencies have been able to manage this tension speaks well of the capability of the regulators but also of the motivation of industry. That is, the system also depends on an industry motivated to strike the balance between regulation and promotion.
Looking ahead, the tension will be heightened.
Probably the best way to appreciate this tension is to think of the new agency as having four storeys, one each for regulation and promotion of the different industry sectors. (And the word "storey" is apt because the origin of that word is that every tier of windows was painted with a "story".)
The tension will also be between the promotion of the IT sector and media. Take something like Netflix, which is an IT play. Promoting it may take away even more from our existing media players. I just cut my HBO subscription.
And there is also the difference in culture between IT - which was open by default and perhaps neglect - and media, which in many countries has had a long history of regulation.
Singapore's Personal Data Protection Act under the IDA, for example, is probably one of the best such Acts in the region and perhaps even in Asia. There is certainty and it does not add substantially to business cost. The secret: It was open to a few rounds of public consultation.
In contrast, media rules have sprung up to the surprise of industry players. And one can think of instances where media outlets have closed because of some of those rules.
How should these tensions be managed?
The first step is to recognise that these tensions are inevitable, particularly as Singapore wants to be at the forefront of technology development. Singapore has no models to follow because it is leading. The safest course of action in the face of such uncertainty is to admit to uncertainty, and to discuss and debate the issues.
A converged regulator is no guarantee of policy planning success.
Friends who have worked in senior positions in such converged environments in Taiwan and Malaysia, for example, tell me so.
Also, consider - if one has a problem in answering how a new technology is to be regulated, does one say, "Let's look at the policies of this country because its regulator uses a convergent model"? Or does one say, "How do other countries do it and what is the best practice?"
The answer must be the latter.
Public consultation is even more critical. And some of this will have discouraging words.
But just as no venture capitalist will invest in a venture that has only green lights, so discouraging words should not be taken as words from an enemy. Sometimes, they may be just the word of caution needed to move forward.
The writer is a professor at the Wee Kim Wee School of Communication and Information, Nanyang Technological University, researching Internet law and policy. He is also founding president of the Internet Society (Singapore Chapter). The views expressed are his own.
This article was first published on Feb 10, 2016.
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