pISSN: 2723 - 6609 e-ISSN: 2745-5254
Vol. 5, No. 11, November 2024 http://jist.publikasiindonesia.id/
Indonesian Journal of Social Technology, Vol. 5, No. 11, November 2024 5029
Analysis of Domestic Content Standards for 5G BTS
Infrastructure in Indonesia Using RIA Method
Insani Sekar Wangi1*, Ajib Setyo Arifin2
Universitas Indonesia, Indonesia
Email: [email protected]
*Correspondence
ABSTRACT
Keywords: DCL,
regulatory impact
analysis, base transceiver
station.
This research aims to analyze and develop the standards for
the Domestic Content Level (DCL) specifically for 5G Base
Transceiver Station (BTS) infrastructure in Indonesia using
the Regulatory Impact Analysis (RIA) method. The
Regulatory Impact Analysis (RIA) method is employed as
the primary approach in this research to evaluate various
policy options and potential DCL standards for
implementation. This approach allows for understanding the
policy implications on various stakeholders, including
regulators, vendors, and operators. A cost-benefit analysis
assessment was conducted using in-depth interview
methods, and the results indicate that the status quo
alternative, which is 40% DCL standards for goods and
services components, remains relevant for implementation
in Indonesia. On the other hand, regulators are evaluating
and reviewing this regulation to increase the DCL value and
foster the BTS industry in Indonesia. The challenges
currently faced by local producers also require stronger
government supervision and support for future technological
self-sufficiency in Indonesia.
Introduction
In the increasingly developing digital era, reliable and sophisticated
telecommunication connectivity is a necessity in supporting economic growth,
technological innovation, and public communication. One of the important elements in
the telecommunications ecosystem is the fifth-generation (5G) mobile network that
promises a level of speed and performance that has not been present in previous
technologies. To implement 5G technology in Indonesia, problems arise related to the
Domestic Content Level (TKDN) policy. Currently, there is no clear policy framework
that regulates TKDN in the 5G BTS industry in Indonesia (Putri & Kadewandana, 2018).
Regulation of the Minister of Communication and Informatics Number 13 of 2021
states that telecommunication equipment and/or telecommunication base station devices
based on Long Term Evolution technology standards must meet the minimum Domestic
Component Level of 40% (Blondel, Guillaume, Lambiotte, & Lefebvre, 2008). In the
Insani Sekar Wangi, Ajib Setyo Arifin
Indonesian Journal of Social Technology, Vol. 5, No. 11, November 2024 5030
context of 5G where technology continues to develop rapidly, it is important for Indonesia
to immediately formulate regulations and guidelines that are by local conditions and
needs. In this case, various tools or models of analysis of laws and regulations, such as
Regulatory Impact Analysis (RIA), Rule, Opportunity, Communication, Interest, Process,
and Ideology (ROCCIPI) models, Regulatory Mapping (RegMap) models, Legislation
Analysis Models (MAPP), and others, can be guidelines to ensure that the resulting
regulations are not only good but also effective. Although each regulatory analysis model
has certain advantages, it should be acknowledged that each also has weaknesses
(Hoesein, 2012). The RIA method has been widely used and reviewed by several authors.
In 2004, when Poland joined the European Union, the country had to adopt EU standards
related to Regulatory Impact Analysis (RIA). Therefore, in 2004, the Ministry of
Economy formulated new guidelines for the assessment of the impact of regulations
(Renda, 2015).
This guideline was adopted by the Council of Ministers on 10 October 2006 and is
still in force today. The 69-page document consists of the principles of the preparation of
the RIA before the formulation of the legislative project. This guideline introduces a new
element in RIAs, namely environmental impact aspects that expand the assessment of
costs and benefits. This is done as a form of implementation of the principles of
sustainable growth which is based on integration and equal efforts on three pillars:
economic, social, and environmental (Brzęk, 2014) References (Kurniawan, Muslim, &
Sakapurnama, 2018) in the results of his research show that several institutions that
consistently implement RIA produce the following benefits: First, instruments that apply
Regulatory Impact Analysis (RIA) provide detailed and systematically prepared policies.
As a result, the resulting policies tend to be more accountable, transparent, consistent, and
able to support the achievement of economic and social welfare. Second, the use of
Regulatory Impact Analysis (RIA) by policymakers can contribute to formulating
efficient and effective policies. The efficiency aspect is seen through the benefits obtained
from the policy, considering that the main objective of the RIA is to ensure that the
resulting regulations will provide an improvement in the welfare of the community with
benefits that are proportional to the costs incurred.
The effectiveness aspect, which relies on the involvement of all stakeholders from
the outset to the stage of problem formulation and the formulation of available options,
can reduce the barriers that may arise from the outset. Third, instruments that apply
Regulatory Impact Analysis (RIA) can systematically evaluate the positive and negative
impacts of regulations that are being proposed or in force, involving an analysis of the
costs and benefits of the various options available (Widiantoro & Kusumadewi, 2011). In
other words, through the application of this method, it can be understood early whether
intervention from policymakers is appropriate and necessary, or vice versa. This
involvement is important because the policies formulated must provide maximum
benefits by considering the positive and negative implications.
Reference (Aquila et al., 2019) conducted a study of regulatory agencies in Brazil
to assess the complexity of the Regulatory Impact Analysis (RIA) conducted and identify
Analysis of Domestic Content Standards for 5G BTS Infrastructure in Indonesia Using RIA
Method
Indonesian Journal of Social Technology, Vol. 5, No. 11, November 2024 5031
the quantitative methods used by these agencies. In developing countries such as Brazil,
improvements in regulatory practices are becoming more relevant, and RIAs can
contribute to this. The activities of regulatory institutions in conducting discussions and
exchanging views on RIAs are very important for the advancement of regulatory quality,
so it is necessary to develop materials and hold discussions to build the acceptance and
use of RIAs. The implementation of RIA has become more relevant considering the goal
of making regulation a technical process rather than a political one. Shah, K. U. (2018) in
his research said that the RIA approach can provide evidence-based analysis to support
policy decision-making in the developing country of the small island of Antigua &
Barbuda. This approach can consider the potential technical performance of the option
combined with cost-effectiveness resulting in justifications that aid the decision-making
process.
This study provides hands-on experience in the implementation of RIA in the
Caribbean. The results of the observation raise several important things, RIA is useful not
only as an analysis tool but also as a coordination tool that can unite various diverse but
relevant community trends. RIA is also a rational-based and transparent tool that is easily
understood by policymakers and can be communicated to interested parties. Logic-based
results and calculations make them easier to understand than complex statistical modeling
or econometric approaches. RIA provides an analysis that allows decision-makers to
justify deciding on action. The quality of regulation contributes to good governance in
the public sector, which is increasingly recognized in the assessment of a country's
competitiveness and long-term sustainability. This study proves that RIA's efforts are
feasible and can provide critical results in the implementation of the SDGs for small
island developing countries towards sustainable development.
Method
The process or stages of a regulatory impact analysis (RIA) briefly involves several
stages. The level of deepening and complexity of this analysis will depend on how
important the impact of the policy will be. The process and stages can be seen in Figure
1.
Insani Sekar Wangi, Ajib Setyo Arifin
Indonesian Journal of Social Technology, Vol. 5, No. 11, November 2024 5032
Figure 1
Process of RIA
Definition
After running for approximately 8 years, the Domestic Component Level (TKDN)
regulation for Base Transceiver Stations (BTS) has not been able to encourage the
development of the 5G BTS industry in Indonesia. One of the main reasons is the BTS
TKDN policy which includes service elements, but this is not effective in encouraging
the growth of the BTS industry in the country. Currently, the calculation applied to
vendors still refers to the Regulation of the Minister of Industry Number 16 of 2011. This
is due to the provisions in the Regulation of the Ministry of Communication and
Information Technology (KOMINFO) which still includes base stations in the calculation
of TKDN Services. Although vendors submit TKDN for devices, the current regulations
still use the TKDN service rules[7].
Identification
After obtaining the formulation of the problem, the next stage is to develop
regulatory options as an alternative to solving the problem. In this study, the author made
an alternative regulatory option based on the regulation of the Minister of Communication
and Information of the Republic of Indonesia Number 13 of 2021 which states that the
Long Term Evolution technology standard must meet the minimum Domestic Component
Level of 40%. From these rules, the author makes three options as follows:
1. Alternative 1: The 40% TKDN standard for goods components includes software and
software baseband details. Conditions where the TKDN standard of 40% is only
implemented for goods components.
2. Alternative 2: TKDN standard of 30% for goods components excluding software, and
10% for service components including software.
3. Alternative 3: 40% TKDN standard for combined components of goods and services
(status quo)
Analysis of Domestic Content Standards for 5G BTS Infrastructure in Indonesia Using RIA
Method
Indonesian Journal of Social Technology, Vol. 5, No. 11, November 2024 5033
Assessment
At this stage, an assessment of the impact of the proposed policy alternative options
is carried out, one of which is by analyzing costs and benefits. References (Jacobs, 2006)
show that there are several analysis methods that can be used according to the challenges
or problems that occur.
Table 1
Pressures on RIA Methods
Pressures on RIA Goals Analytical Method
Neoclassical
economics
Maximization of social
welfare among
multiple goods and
bads (Pareto optimum)
Benefit-cost analysis using
a common, monetary
metric
Better public policy,
integrating multiple
objectives and
interests
Weighing and
balancing many
positive and negative
impacts
Soft benefit-cost analysis,
integrated impact
assessment including
multiple policy objectives
New public
management
Cost and performance
disciplines
Cost-effectiveness analysis
of various options
Competitiveness,
microeconomic
policies
Minimizing business
costs
Business impact, SME
tests, administrative burden
tests
Social consensus,
interest group
pressures
High valuation of
impacts on selected
groups
Distributional analysis,
partial analysis
Table 1 shows that monetary cost-benefit analysis which requires all cost
components and benefits assessed in money is only one of the alternatives in analyzing
the choice of policy options, if using a different approach, you can use other analysis
methods or still use a more flexible cost-benefit analysis. For example, in the soft cost-
benefit analysis method, the most important thing is that all costs and benefits felt by
various stakeholders can be informed without any assessment in the form of money.
In the assessment stage of this study, two approach methods were used, namely
Multi Criteria Analysis and Minus Implication. Multi Criteria Analysis (MCA) focuses
on the preparation and determination of which decision is more appropriate to a condition
faced by the organization. The same decision under different conditions will produce
different results [13]. In this study, the author also uses the Plus Minus Implication
method as a combined method in cost-benefit analysis. The PMI method classifies aspects
of action/thought into three groups, namely the plus group in the form of positive aspects
of the action/thought. The minus group is in the form of negative aspects of the
Insani Sekar Wangi, Ajib Setyo Arifin
Indonesian Journal of Social Technology, Vol. 5, No. 11, November 2024 5034
action/thought, and the interesting group is in the form of implications or possibilities that
are still uncertain after the action (Alijoyo, Wijaya, & Jacob, 2021). The following stages
of data collection and calculation of value weights for the Plus Minus Implication and
Multi-Criteria Analysis methods carried out by the author are as follows:
1. Determine the scale for Plus Minus Implication with a range of 1 3. Where the
largest value shows the greatest profit/loss impact of the specified indicator.
2. the Multi Criteria Analysis method, is determined by a scale of 1 5 where later the
scale of 1 5 is converted into a value weight of 0 1 because the sum for all
indicators from all stakeholders must be worth 1. The higher the value/weight, the
more important and relevant the indicator is to the goals that have been set, and vice
versa. It was found that the indicators from the validation results were 15, so the
following is the value conversion determined:
Table 2
Conversion of Weighted Value of MCA Method
Nilai Konversi Pembobotan
1 0.02
2 0.04
3 0.06
4 0.08
5 0.13
3. After the value is obtained and converted, then the value is multiplied by the result
of the value contained in each alternative that has previously been obtained by the
Plus Minus Implication method so that the total value is obtained to assess each
alternative.
Consultation
To obtain data, the authors conducted in-depth interviews with stakeholders related
to 3 resource persons which can be seen in the following table 3.
Table 3
List of In-Depth Interview Participants
No Name Job Position Institution
1 Cendrawasih PIC Domestic Industry
Strengthening Program
Communication
and Informatics
2 Juan Andreas Procurement Analytics and
Reporting
Telkomsel
Analysis of Domestic Content Standards for 5G BTS Infrastructure in Indonesia Using RIA
Method
Indonesian Journal of Social Technology, Vol. 5, No. 11, November 2024 5035
3 Muhammad
Avenzoor
Procurement Specialist Huawei
Design
The last stage is design. At this stage, the agency that conducts the Regulatory
Impact Analysis (RIA) process determines the final design to find out an overview of how
the selected regulatory options can be implemented in accordance with existing
conditions. This stage will also formulate how the form of monitoring/supervision can be
carried out.
Results and Discussion
At this stage, an assessment of the three proposed alternatives was carried out, the
results of in-depth interviews with stakeholders, and the weighting of the Plus Minus
Implication and Multi-Criteria Analysis methods can be seen in the following sub.
Regulator
Table 4
Results of Plus Minus Implication and Multi-Criteria Analysis from Regulators
No Indikator Bobot 0
s/d 1
Alternatif
1
Alternatif
2
Alternatif
3Regulator
1 Peningkatan Nilai Ekonomi 0,06 3 2 1
2 Kemampuan Produksi Lokal 0,13 3 2 1
3 Kesesuaian dengan Rencana
Pembangunan Nasional
0,08 1 2 3
4 Biaya Perubahan Regulasi 0,02 1 1 1
5 Biaya Sosialisasi 0,04 1 1 1
TOTAL 0,71 0,6 0,49
In Table 4 above, it can be seen that from the regulator's side, it is produced that the
highest score is obtained for alternative 1. Local production capabilities will result in a
high level of importance if alternative 1 is applied when compared to other alternatives.
The production cost indicator does not have a significant effect because currently,
Kominfo is also evaluating the current TKDN policy for BTS devices in the hope of
growing the local producer industry in Indonesia.
Operator
Table 5
Results of Plus Minus Implication and Multi-Criteria Analysis from Operators
No Indicator Bobot 0 s/d
1
Alternative
1
Alternative
2
Alternative
3Regulator
1 Initial Investment Cost 0,08 2 1 2
2 Operational Costs 0,13 3 3 3
3 Network Quality 0,04 1 1 1
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Indonesian Journal of Social Technology, Vol. 5, No. 11, November 2024 5036
4 Product Availability and
Selection 0,06 2 2 2
5 Increased Local Industry
Participation 0,02 1 2 2
TOTAL 0,73 0,67 0,75
In Table 5 above, it can be seen that from the operator's side, it is produced that the
highest value is obtained for alternative 3. In the table above, it can be seen that the highest
value is obtained by the Operating Costs indicator. According to the source, operational
costs will always be high because the need for BTS maintenance operations is quite high.
Network quality does not have a significant impact because network quality is influenced
by investment costs for the purchase of equipment as well as operational costs for daily
BTS maintenance needs.
Vendors
Table 6
Results of Plus Minus Implication and Multi-Criteria Analysis from Vendors
N
o
Indicator Bobot 0
s/d 1
Alternativ
e 1
Alternativ
e 2
Alternativ
e 3Regulator
1 Partnerships with local
suppliers 0,04 2 1 3
2 Compliance with
government regulations 0,08 2 1 3
3 Decline in dependence on
imports 0,06 2 1 3
4 Innovation Development 0,02 1 3 2
5 Intervention with local
suppliers 0,13 1 2 2
TOTAL 0,51 0,5 0,84
In Table 6 above, it can be seen that from the vendor side, it is produced that the
highest value is obtained by alternative 3. This is because to maintain the stability of the
current BTS industry which is controlled by PT Huawei at almost 65%, the
implementation of alternative 3 or the status quo is better to implement. The government's
intervention in local suppliers has an impact on the difficulty of developing local
producers. On the other hand, the Kominfo scheme requires PT Huawei to hire Indonesian
human resources but this scheme is not applied to other manufacturers, making it difficult
for the BTS industry to grow in Indonesia due to the dominance of the BTS market share
dominated by PT Huawei.
Implementation Strategy
Although the results of the in-depth analysis that has been conducted on
stakeholders, vendors, operators, and regulators resulted in an alternative status quo (no
regulatory changes), the strategy for the implementation of the BTS TKDN policy that is
in line with the expectations of regulators, in this case, Kominfo, still needs to propose a
framework and action plan that needs to be carried out. The following is a table of the
Analysis of Domestic Content Standards for 5G BTS Infrastructure in Indonesia Using RIA
Method
Indonesian Journal of Social Technology, Vol. 5, No. 11, November 2024 5037
proposed regulatory framework based on the results of the in-depth interview as well as
a comparison of current conditions and expected conditions to see an overview of how
the new policy can be implemented.
Table 7
Regulatory Proposal Framework
Subject Current Conditions Expected
conditions
Action Plan
Formulation of
TKDN Policy
There is no
minimum TKDN
value rule for goods
or service
components
Determination
of TKDN value
rules for goods
and services
components
Changes in TKDN
formulation
Local
Manufacturing
Industry
The import of BTS
device components
is still being carried
out to obtain the
required device
standards.
BTS component
devices are
manufactured by
Indonesian
manufacturers
Incentive support from
the government to
local industries is
needed equally for the
development of BTS
infrastructure.
Innovation and
Technology
Do not have a
patent/intellectual
property of
technology
The existence of
an ecosystem
that supports
innovation and
development of
domestic
technology
Providing fiscal and
non-fiscal incentives
for research and
development of BTS
technology.
Growth of Local
Industries
There is no local
manufacturer that
can produce BTS
devices according to
the standards/quality
desired by the
operator.
The growth of
the local
manufacturing
industry that can
create devices
with the required
quality/standards
Monitoring and
evaluation of foreign
investors' compliance
in carrying out
technology transfer
and human resource
capability
development, based on
regulations that have
Insani Sekar Wangi, Ajib Setyo Arifin
Indonesian Journal of Social Technology, Vol. 5, No. 11, November 2024 5038
been determined, one
of which is the
Ciptaker Law No. 11
of 2020
From the table above, it can be seen that to implement the new regulatory policy, it
is necessary to change the applicable laws, especially in formulating the formulation of
the BTS TKDN that can grow the local industry. In addition, there is a need for
government support in terms of R&D development incentives and supervision related to
policies currently in place to improve local capabilities and foster technology knowledge
transfer.
Conclusion
The Indonesian government's preference for PT Huawei as a dominant player in the
Base Transceiver Station (BTS) market has various implications for other similar
companies. On the one hand, this decision can be seen as an effort to develop
telecommunications infrastructure by utilizing technology and resources owned by PT
Huawei. However, PT Huawei's dominance also poses challenges for other
telecommunications companies operating in Indonesia. Similar local and international
companies may face difficulties in competing head-on, especially in terms of price and
technology. Currently, the government through the Ministry of Communication and
Informatics is conducting an evaluation and assessment related to the applicable BTS
TKDN rules in Indonesia. Support from local producers is also needed so that if one day
the formulation of this regulation has been determined, its implementation can run well.
Kominfo also hopes that the telecommunications industry can grow from the side of local
producers so that this has an impact on increasing the TKDN of BTS devices in Indonesia.
Analysis of Domestic Content Standards for 5G BTS Infrastructure in Indonesia Using RIA
Method
Indonesian Journal of Social Technology, Vol. 5, No. 11, November 2024 5039
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