Dear Portfolio Committee on Communications and Digital Technologies,

Minister Malatsi appeared before the Portfolio Committee to justify his directive, which seeks to “align” the Electronic Communications Act and the ICT Sector Code.
This “alignment” would allow foreign entities to operate without complying with the 30% local ownership requirement mandated by law for previously disadvantaged groups.
In what can only be described as an unlawful attempt at subverting the powers of the Parliament of South Africa by using a Ministerial Policy Directive, Minister Malatsi characterises the amendments he wants to make to two Acts of Parliament as regulatory alignment."
Minister Malatsi admitted that the Independent Communications Authority of South Africa (ICASA) advised him that the correct path would be to amend the Electronic Communications Act itself, not circumvent it via policy alignment.
Elon Musk, who owns Starlink, has previously peddled disinformation about South Africa, expressed disdain for transformation, and proposed to operate without guarantees for local jobs in the telecommunications industry.
The above spurred me to conduct more research about the risks associated with having Starlink operating in RSA. Find attached some industry-researched articles.
Please note that ICASA is currently investigating alleged unlawful use and provision of Starlink Services in South Africa, indicating that Mr Musk has already disregarded and undermined RSA laws and sovereignty.

Please find some articles expressing the dangers of Starlink to our national security below.

"While offering revolutionary global internet access, Starlink also presents several national
defence concerns. These risks stem from its capabilities, ownership, and geopolitical
implications. Here are the key dangers:
1. Dual-Use Technology (Civilian + Military Use)
•Military Applications: Starlink provides high-bandwidth, low-latency communication globally,
which can be used for:
o Real-time battlefield coordination
o Drone and UAV control
o Secure military communication networks
National Security Risks
•Starlink is a US-based company, and SpaceX has contractual ties with the Pentagon. This raises
concerns over surveillance and data access, and interference by US agencies.
•Critical Infrastructure Dependence: Reliance on a foreign-controlled communications network
could expose the country to geopolitical leverage, especially during conflicts or sanctions.
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2. Private Control of Strategic Infrastructure
•Owned by a Private Company: SpaceX, a U.S. private firm, controls Starlink. This raises
concerns for national sovereignty because:
o A private individual (Elon Musk) can potentially unilaterally disrupt or deny service for
geopolitical or business reasons.
o Lack of governmental oversight in foreign nations where Starlink operates could leave
countries vulnerable to coercion or service withdrawal.
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3. Reduced Sovereign Control Over Communications
•Bypassing National Infrastructure: Starlink can offer internet access directly to users,
circumventing national telecoms and security agencies.
o Governments may lose the ability to monitor or regulate data traffic.
o Censorship-resistant communications can aid both democracy movements and
extremist or criminal networks.

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4. Cybersecurity Risks
•Hacking or Sabotage: A successful cyberattack on Starlink satellites or ground stations could
disrupt internet access in multiple countries, potentially including military systems relying on
the network.
•Dependency Risk: Military forces becoming reliant on Starlink for secure comms may face
disruption if the system is compromised or withdrawn.
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5. Space-Based Surveillance or ISR Capabilities
•While not its primary function, a dense constellation like Starlink could be repurposed or
augmented with sensors or cameras for intelligence, surveillance, and reconnaissance (ISR)
purposes.
•This poses a strategic surveillance risk at the behest of foreign countries.
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Spectrum & Licensing Conflicts
•Starlink operates in unlicensed spectrum bands, potentially causing interference with local
services.

•Starlink’s user terminals (dishes) connect directly to satellites, bypassing local ISPs. This could
undermine South Africa’s Universal Service Obligations, where telecom providers are required
to expand services to
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7. Legal and Regulatory Grey Areas
•Jurisdiction issues: Starlink operates across borders, often without clear regulatory approval or legal frameworks in many nations.
•This creates ambiguities in accountability, especially during a conflict or cyber incident.


Regards,