ICT Unit, Department Of Education
Attention: Ms. Trudi van Wyk
Room 619, Sol Plaatje House, 123 Schoeman Street
Pretoria, 0001 SOUTH AFRICA

Dear Ms. van Wyk,

Bridges.org would like to take the opportunity afforded by the Information and Communications Technology (ICT) Unit of the Department of Education to make written representations on the Draft White Paper on e-education approved by Cabinet on 27 August 2003. The White Paper sets out Government's response to a new ICT environment in education. The overarching goal of the White Paper is to equip every basic and Further Education and Training (FET) learner with the knowledge and skills to use ICT confidently, creatively and responsibly by 2013.

Bridges.org: Who we are and why we care

Bridges.org is an international non-profit organisation based in South Africa that believes that the effective use of ICT offers huge potential to people in developing countries. ICT has the potential to empower people to overcome development obstacles, to address the most important social problems they face and to strengthen communities, democratic institutions, a free press and local economies. ICT provides tools to aid the management and administration of schools, as well as teaching and learning resources to ensure that learners are appropriately skilled to participate in the Information Society.

We have structured our written representation according to the headings set out in the Department's call for submissions and provided our analysis of the Draft White Paper's key strategic objectives in terms of our Real Access criteria.

Thank you for extending the deadline to allow us to submit our comments. I hope that you find our input useful and that it adds value to your discussion. Please do not hesitate to contact me if you require further clarification on any of these points.

Yours sincerely,

Leonie Vlachos
Senior policy associate
bridges.org

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1. Introduction

The Department of Education's (hereinafter "the Department") Draft White Paper begins by contextualising the use of ICT in society (and more specifically in education), within the broader realities of the digital divide. It provides a good introduction to the potential of ICT for development within Africa and identifies the current status quo of ICT in education and the initiatives underway to support the use of technology in education.

While reference is broadly made to existing legislation that impacts upon the provision of e-education, we believe there needs to be stronger emphasis on relevant existing legislation and regulation, including telecommunications policy and how the e-education draft Bill will ultimately feed into the national e-strategy. It is paramount that any further sectoral legislation fits into the national e-strategy to allow for an integrated ICT policy.

a) e-Education
We support the Department's broad definition of e-education, which includes the use of technology as a resource for reorganising schooling and a tool to assist whole-school development. We are particularly pleased to see the inclusion of technology use to provide learners with the necessary skills and computer literacy to be able to effectively participate as e-citizens in the Information Society.

Bridges.org has had first-hand experience with the difficulties faced in getting people comfortable and skilled with the basic technology and helping them become informed Internet and Information Society citizens. In order to address this challenge, we developed the "bridges.tech.guide", a unique learning tool that teaches students practical computer skills while educating them about the critical social issues related to computer use. The guide is free, and provides a flexible set of resources that can be adapted to specific classroom contexts. We recommend that the tech.guide or a similar tool be incorporated into the e-education curriculum to help students understand the underlying social issues that affect or are affected by technology use. See the techguide for further information.

There is a range of different kinds of literacy that would need to be addressed within an e-education system. The draft White Paper currently mentions "digital" and "information literacy", which might best be addressed under a broader banner of "e-literacy". But e-literacy should be further expanded to include "visual literacy" (the ability to understand the meaning and components of an image through the knowledge of basic visual elements), and "multimedia literacy" (the ability to decode, analyse, evaluate, and produce communication in a variety of forms).

These definitions are used in many of new models of ICTs in education that are radically changing the concept of education. Attention should be drawn to the fact that models of learning are implicitly part of the broader area of development, where the interplay of technology, human development and growth has a far-reaching effect. The Department bases its considerations on numerous internationally-developed models, and we would caution against the wholesale importation of an international model to a South African context. It would be useful to include a section on "the significance of e-education for South Africa" here, which would identify, amongst other things, the significance of e-education in a country with 11 official languages and the potential of translation and voice-recognition software for language learning.

b) e-Education policy goal
The Department has clearly set out an ambitious and necessary e-education policy goal, namely that every South African learner be ICT capable by 2013.

The White Paper addresses the implications for the schooling environment, but we believe it does not go into sufficient detail on the integration of e-education in higher education levels and lifelong learning. Additional learning environments that should be covered include Adult Basic Education and Training (ABET) programmes, community/NGO-led skills development initiatives, research and development institutes, Small Medium and Micro Enterprise (SMME) staff development, and internship programmes in ICT companies.

Furthermore, it would be useful to make a brief mention in this section of what monitoring and evaluating programmes will be implemented to ensure that the policy goal is met by the target date of 2013, with further detail in the chapter on monitoring and evaluation.

c) The use of ICTs in education
We agree with the Department that enriching the learning environment through the effective use of technology is a continuum, ranging from improved learning methods, to improved school management and administration. The White Paper draws a distinction between learning about ICT, learning with ICT and learning through ICT which does not come across clearly as currently worded and requires additional explanation.

Mention is made in this section on the role of school libraries in e-education. We recommend that concepts here should be expanded to include municipal libraries. In 2002 bridges.org conducted a study on the status of the Digital Divide within Cape Town, and found that libraries (especially those participating in the Smart Cape Access Project) were making a positive education impact. See http://www.bridges.org/capetown/ for further information. Libraries can function as key resource nodes to serve schools in areas as the schools begin implementing e-education practises. We encourage the optimal use of existing resources (such as libraries) in addressing e-education requirements, and in extending the reach of these resources to the broader community (such as extending the operating hours of school computer laboratories to address the needs of the broader community).

The Department has correctly identified a lack of broader appreciation for the benefits of e-learning and potential benefit of ICT in education. This underlies the corresponding requirement of getting buy-in from stakeholders, educators and learners in the education system. One way to do this is to clearly demonstrate the value of e-learning by establishing a "model e-school" in each province for demonstration and learning purposes before expansive national roll-out in both rural and urban areas.

2. The policy framework

a) Elements of the policy framework
The White Paper highlights the following as key elements of the e-education policy framework: equity; access to ICT infrastructure; capacity building; norms and standards.

Bridges.org supports the view that there needs to be an equitable allocation of resources and that schools in rural and underserved communities should be prioritised to ensure that technology use in the education sector does not further exacerbate the digital divide within South Africa. In this respect, it would be worthwhile to consider alternative technological solutions, including the use of wireless and solar-powered technologies. These would help address the education needs of communities that do not have even the most basic of infrastructure, including electricity and landline telephony.

Once access to the ICT infrastructure is attained, regular, reliable and affordable access is required which is closely connected to the costs of basic telecommunication services as well as the cost of hardware and software ownership. This point once again relates to the intertwined nature of future e-education policy with telecommunications and trade policies.

With regard to capacity building, it should be noted that ICT can help empower existing teaching staff to deliver science and mathematics lessons at a time when the education sector has been hampered by the outflow from the country of experienced science and mathematics teachers. Capacity building in terms of technology support training should also be reflected in this section, to recognise the need for support of the technology end users (learners, teachers, managers and administrators).

The final element of the policy framework looks at norms and standards, following on current initiatives and donations of software and hardware. The example of Microsoft's donation of Windows XP to all of South Africa's 32,000 public schools underlines the relevance and complexity of the debate and shows the difficult decisions that need to be made. Critics argue that by accepting the Microsoft donation, the Government chose a short-term solution that has given away the South African market to Microsoft, instead of following a long-term strategy that may be better served by open source software alternatives. Others counter that Microsoft investments in South Africa will help tackle the digital divide and bring greater overall benefits to the country. For more information and our thoughts on this matter, see the Software Comparison Study.

Bridges.org recommends that Government legislation should remain technology-neutral. Further, technology donations should each be assessed on the merits, based on a clear analysis of the costs and benefits involved (including licensing, interoperability and the current availability of the support required to maintain the donation). Free or more advanced does not necessarily equate to better technology. It is imperative that more established technologies (such as mobile communications, and radio and television broadcasting) continue to be used in effective and innovative ways and do not fall by the wayside in preference to newer, flashier technologies.

b) Strategic objectives
The Department has considered many of the factors necessary to ensure that its ambitious e-education goal is attained, and has captured them within the following strategic objectives:
- ICT professional development for management, teaching and learning,
- electronic content resource development and distribution,
- access to ICT infrastructure,
- connectivity,
- community engagement, and
- research and development.

The Department's understanding of the complexities surrounding e-education is shown in the White Paper's comprehensive approach to a range of issues beyond physical access to technology and cost. However, we believe that additional factors need to be considered over and above the mentioned strategic objectives, which will help enhance the e-education policy's efficacy and likelihood of success.

Bridges.org has developed a planning and evaluation tool that helps frame a holistic approach to ICT strategies. Our Real Access criteria set out the key factors that determine whether people can truly access and use ICT in their daily lives, and in the way the initiative or legislation envisages. We believe that it would be useful for the Department to adopt this model to analyse its approach to e-education as it continues deliberations and sets out its policies in this area.

What can the Department of Education do to ensure Real Access to ICT for South Africa's learners?

There is no single answer that will guarantee success. However, Department of Education decision-makers can approach the problem by using the following Real Access questions as guideposts to help them determine what needs to done and how to plan an effective strategy:

• Physical access. What can we do to make technology available and physically accessible to teachers, administrators and learners in their education environments?
• Appropriate technology. What can we do to ensure that the technology that is available is appropriate to how our teachers, administrators and learners need and want to put technology to use, and that it fits within the reality of their educational environment?
• Affordability. What can we do to make technology access and use affordable for our education institutions?
• Capacity. What can we do to help our teachers, administrators and learners understand the potential ways that they could use technology for e-education, and what can we do to ensure they receive the training they need?
• Relevant content. What can we do to ensure that content is developed which is locally relevant to our teachers, administrators and learners, especially in terms of language?
• Integration. What can we do to ensure that technology is not just a further burden to the lives of our teachers, administrators and learners, and how can we help them integrate technology into their daily education routines?
• Socio-cultural factors. What can we do to ensure that our teachers, administrators and learners are not discouraged from using technology or limited in their use because of their gender, race, or other socio-cultural factors?
• Trust. What can we do to help our teachers, administrators and learners trust technology and how can we help them understand what happens "behind the screen" so that they will feel confident and be informed about things like electronic privacy, data security, and cybercrime?
• Legal and regulatory framework. What can we do to determine how laws and regulations affect technology use and what can we do to drive change toward a legal and regulatory environment that fosters its use it the education environment?
• Local economic environment. What can we do to foster local economic development that can and will sustain technology use in our education institutions and beyond?
• Macro-economic environment. What can we do to determine whether national economic policies are conducive to technology use for education, for example, in terms of transparency, deregulation, investment, and labour issues, and what can we do to drive change toward a more conducive environment?
• Political will. What can we do to gain public support for our e-strategies, to fortify our government's political will so that we can make tough decisions and drive the change needed for our country to achieve its education goals?

Looking at the White Paper through the lens of Real Access effectively highlights those areas that need further consideration. Although each criterion is not always as relevant as others in each sectoral application, it is essential that they are born in mind and addressed to ensure thorough and holistic policy formulation.

The White Paper currently identifies some of the Real Access criteria in its introduction (sections 1.7 and 1.17) with the strategic objectives directly addressing additional Real Access criteria. We have applied the Real Access criteria to the strategic objectives and have made additional section references where necessary.

· Physical access
The White Paper considers infrastructure and connectivity in section 1.22, and provides an overview of some the initiatives various parties have begun to address the physical access criteria. The disparities in computer access are reflected through the statistics for schools per province. Section 5.32 is concerned with the provision of electricity and physical infrastructure. We support the Department in its collaboration with the Department of Minerals and Energy to prioritise the electrification programme for general and further education and training while also noting that there are ICT applications that use alternative sources of energy.

Section 5.37 mentions that "the education network will provide high-speed access for learning, teaching and administration." There is no mention of South Africa's bandwidth problem, which is linked to the issue of affordability. It is important to think realistically about the bandwidth constraints that the country faces due to the current telecommunications environment, and what the related policy implications would be, before raising expectations of such connectivity levels.

· Appropriate technology
Section 1.16 states, "through appropriate technologies, it is hoped that South Africa will leapfrog into the new century, bypassing the unnecessary adoption cycle, and implement a solution that works now, and has the capacity to handle further developments." This shows the Department's awareness of the exciting opportunities offered by cutting edge technologies, but does not acknowledge that the current legislative environment prohibits the use of some of those technologies, for example Voice over Internet Protocol (VoIP), as a means to circumvent excessive landline telephony costs.

It is important that technology use is needs-driven rather than technology-driven. For e-education to reach all South Africans, technologies must be appropriate to the goals, local conditions, and how people want and are able to use them. For example better utilisation of radio and television broadcasting technologies and alternative software applications need to be considered.

· Affordability
The Department acknowledges that "any solution that South Africa adopts has to be cost-effective if we are to meet our developmental demands and reach the most remote parts of our country."

It is important that interventions are affordable for all stakeholders - there is no point in connecting schools that are unable to afford their monthly telephone bills. The e-rate for all schools, depending on how cost-effective it proves to be in reality, could do much to address this concern. It should be extended to all higher and further education and training institutions, as well as research institutions.

The Department has looked at the issues of investment for e-education and the proposed strategies to be followed to meet the strategic objectives as currently outlined. Clearer mention should be made of the role of schools and parents in funding these projects, and what the potential is for involving local business.

· Capacity
In the context of e-education, this element of Real Access includes consideration of teacher training, technical support and related high-level ICT skills capacities, as well as teaching methods that embrace e-literacy and skills development.

It is very encouraging to note that the Department will bring researchers, teachers and members of the ICT industry (Chapter 5, Research and Development) to collaborate in forming programmes. Many similar projects have not succeeded because those using the programmes have not been involved in the planning and design stages. The establishment of the Advanced Institute for Information and Communication Technology (AIICT) is a positive development in addressing human resource capacity building. This should however be done in partnership with existing research institutes, higher education academic departments, and the Centres of Excellence (established by the National Research Foundation and the telecommunications operator, Telkom).

In section 5.46 dealing with community access, the paper indicates the Department's hope that the local community "will be involved in the maintenance and security of e-school ICT infrastructure, as well as supporting e-schools by availing ICT experts, specialists and champions in the community who are willing to volunteer their skills and expertise." Effective volunteerism requires major organisation, administration and infrastructure. While volunteerism can be an effective mode for knowledge and information transfer, mechanisms are required for it to be coordinated and sustainable.

· Relevant content
It is important that initiatives for generating and accessing high quality content that is relevant to the South African education system are initiated and supported.

There is not sufficient detail on the specifics of content development in the White Paper. The bulk of existing ICT-based educational material is likely to be in English or of little relevance to education in developing countries (especially at the primary and secondary levels). There is a need to develop original educational content (including radio programs, interactive multimedia learning materials on CD-ROM or DVD, Web-based courses), to adapt and also convert existing print-based content to digital media. These are tasks for which content development specialists such as instructional designers, scriptwriters, audio and video production specialists, programmers, multimedia course authors, and web developers are needed. There should be an authority that evaluates the electronic content material for relevancy and effectiveness.

Translation of educational material from predominantly English into indigenous languages can greatly assist learners for whom English is a second language. Translation software should be introduced at e-schools for this purpose.

· Integration
The use of ICT needs to be incorporated as much as possible into the already existing curriculum, allowing for students to assimilate ICT skills while learning all other subjects. If the use of ICT is seen as an add-on, then teachers and school systems will feel further burdened. ICT should be implemented in school systems in order to bolster and augment existing learning frameworks; paying attention to how technology can make teaching tasks easier -- increasing efficiency and accuracy -- will ensure teacher buy-in.

A multi-pronged approach for the integration of ICT is mentioned in the White Paper, and we support this proposal to ensure easier integration of technology into the education system.

· Socio-cultural factors
Section 3.9 lauds the applicability of e-education within the South African context, whereby it can be adopted by learners "who represent a wide array of cultures, languages and social backgrounds." However, the paper should ensure that e-education opportunities encompass the needs of all, especially those who may be marginalised owing to gender, race, economic circumstance, or being special needs users.

· Trust
Mistrust of technologies can be a major barrier to the effective use of ICT. It is important that initiatives work towards gaining the trust of teachers, learners, administration staff, management and the wider community during training and awareness raising programmes. This criterion will also be successfully addressed by including elements of the bridges.tech.guide training which helps ensure a socially aware and informed user of technology. It is important that appropriate technologies are used and that support systems are in place to address the resulting loss of trust in technologies should a technical system go down.

· Legal and regulatory framework
It is imperative that the Department of Education continues collaborating with, among others, the Departments of Communications, Minerals and Energy, Trade and Industry and the Independent Communications Authority of South Africa (ICASA) to ensure that the legal and regulatory framework cross-links and builds toward realising an Information Society. This will include collaboration on the implementation of e-rate telecommunication charges, increased electrification, reduced telecommunications costs and access to additional bandwidth.

· Local economic environment
Technology programmes and donations are meaningless if the local economy cannot sustain technology use. School's financial situations need to be considered and, where necessary, assisted, for the continued use of technologies to become a reality. Those schools that have more resources will always have an edge over those schools that are less well equipped and the risk remains that the digital divide will be exacerbated. Schools located in disadvantaged areas usually have a poor local economic environment and require particular consideration. The Department has addressed this problem through their equity principle in Chapter 4.

The only mention of engaging with SMMEs is in the context of providing technology repair services. A clearer strategy on how local businesses will be involved is required, with specific considerations around capacity development to be considered in collaboration with the Department of Trade and Industry.

The White Paper indicates the intention for community members to utilise the e-schools facilities after hours and services for SMMEs should be included in this. However, it is important that the telecentre model is not adopted with the assumption that this will promote sustainability. We support the idea that needs assessments and evaluations be conducted in each community to ensure that the services offered by the e-schools are relevant and useful.

· Macro-economic environment
It is important that national economic policy is conducive to widespread technology use in education. Furthermore, the White Paper does not make mention of the project impact of e-education on the macro-economic environment due to the increased pool of human resources, and vice versa.

· Political will
The paper sufficiently addresses the question of political will at the highest political levels as seen in the references to the New Partnership for African Development (NEPAD), the Presidential National Commission on Information Society and Development, and Government departments (sections 1.9 - 1.14). The paper asserts, "The Department of Education will invest in national initiatives to increase access, boost the capacity of managers, teachers and learners, and provide electronic resources of the highest quality."

The Department is therefore to be commended on its display of political will, and proposed engagement with the community on the e-schools initiative. The intention for e-schools to benefit the community is important and could be supported by identifying local community and school champions who will rally people around the use of technology and address their personal concerns. The establishment of a national champion would add further value to this process, and this person could also act as a troubleshooter when initiatives are hampered by inter-departmental disputes and differing priorities. (See also the reference in paragraph 4 below).

3. Funding and resourcing
The Department has a realistic appreciation of the fiscal constraints affecting the Government, the vast upfront investment required for e-education and the need for ongoing and predictable funding sources for the longer term.

While the Department has identified a comprehensive source of funding (including license revenues, private sector donations and partnerships), we recommend that it would be worth considering that all resources to supporting e-education in South Africa, need not be financial. Curriculum planners and multi-media corporations might consider donating their time, expertise and resources in this regard (considerations might include broadcasting slots on the national broadcasters, consulting and advice).

4. Implementation strategies
Implementation strategies are essential in making the ideals expressed in legislation real for the citizens of South Africa. We support the manner in which the Department is staggering its implementation throughout the three implementation phases outlined in the White Paper to achieve the e-education goals. We further support the consideration that that has been given to allow for feedback gained through monitoring and evaluation of the implementation phases, to be reflected in subsequent implementation phases.

In the section "Co-ordination and collaboration", the Department mentions the establishment of a Ministerial e-Education Advisory Council consisting of ICT champions from the public sector, academia, and private and civil society. This is a shift in the right direction in that such a body will serve to streamline the process. Bridges.org would recommend that this suggestion be taken one step further and that the Department collaborates with other Government departments to form an e-Ministry, or at the very least have the e-Education Advisory Council reporting to an appointed e-Minister that would be tasked with ensuring the implementation of the national e-strategy. Such a strategy would demonstrate South Africa's complete commitment to the role ICT for addressing socio-economic development challenges. We see the appointment of an e-Ministry or an e-Minister to which the Advisory Council would report, as essential in ensuring an integrated national ICT policy environment.

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