Licensing and Shared Spectrum Framework for Community Networks for Kenya online discussion

Good People

Great conversation. As we continue to discourse, a special thanks to the CA
and our other partners for making this a reality. This is true
*MultiStakeholderism* with one overarching objective – To make this country
a better place and leave NO ONE behind when it comes to connectivity.

Regards

*Ali Hussein*

Digital Transformation

Tel: +254 713 601113

Twitter: @AliHKassim

Skype: abu-jomo

LinkedIn: ke.linkedin.com/in/alihkassim
<ke.linkedin.com/in/alihkassim>

Any information of a personal nature expressed in this email are purely
mine and do not necessarily reflect the official positions of the
organizations that I work with.

On Fri, May 28, 2021 at 3:53 PM nzambi kakusu via kictanet <
[email protected]> wrote:

> Hello Mwendwa,
>
> Thank you for this discussion.
>
> The report is very commendable and will help people in understanding
> community networks and their deployment which will help in bridging the
> divide and inclusion.
>
> Coming from a village with poor network and limited or no connectivity,
> Encouraging CN deployments in rural areas would be a great plan for areas
> like ours.
>
>
>
>
> Warm regards,
> Nzambi Kakusu.
> On Fri, 28 May 2021 at 12:54, Barrack Otieno via kictanet <
> [email protected]> wrote:
>
>> Dear Adam,
>>
>> Many thanks for your detailed responses which are appreciated, I
>> understand your perspective. My thinking is if we bring more of the
>> unserved and underserved on board the cake will be bigger in addition to
>> the other benefits articulated in my previous email. Having said that, I
>> acknowledge the fact that those that go first always pay a hefty price but
>> equally benefit if they deploy the right strategies. I propose that we
>> start with an open mind as was the case when Prof Njuguna was faced with a
>> decision of allowing mpesa to operate and tighten the rope as we move along
>> depending on the ground we are able to cover.
>>
>> Best Regards
>>
>> On Fri, May 28, 2021 at 12:16 PM Adam Lane <[email protected]> wrote:
>>
>>> Hi Barrack
>>>
>>> So far I was just commenting on the licensing aspects, but will
>>> certainly also comment on the shared spectrum framework when that arises.
>>>
>>>
>>>
>>> I agree with your comments. Spectrum is priced too highly. It is priced
>>> out of reach for many who could provide telecoms services, and the price of
>>> spectrum is reflected in the cost that consumers pay directly (and
>>> indirectly, in that in some areas the telcos won’t invest in, having
>>> already invested so much in spectrum). Tier 1 licensees are making good use
>>> of their spectrum, but many tier 2 or tier 3 (or other spectrum holders
>>> such as in government) may not have many sites, so indeed, their spectrum
>>> is being under-used.
>>>
>>>
>>>
>>> I am not against community networks, but I am a realist in that they
>>> won’t make a massive difference since a) so many issues are demand-side,
>>> not supply-side, as my other emails explain; and b) there are so many costs
>>> to running a network; and c) existing providers are operating in a
>>> competitive market and most are not making excessive profits (or are
>>> actually loss-making) so it is hard to say the existing market has many
>>> problems that a community network could resolve. I am not saying they
>>> cannot try, they should be encouraged, but community networks in of
>>> themselves may not make a big difference to the digital divide. Other
>>> solutions, such as spectrum pricing, VAT etc etc could have a big
>>> difference.
>>>
>>>
>>>
>>> The reality is that the CA makes 8.5bn KES a year in license fees and
>>> remits 4.7bn KES to Treasury to be spent on whatever treasury wants. Let
>>> alone the money (tens of billions) that treasury collects in VAT on
>>> devices, excise duty on airtime and data and many other taxes.
>>>
>>>
>>>
>>> Adam
>>>
>>>
>>>
>>> *From:* Barrack Otieno [mailto:[email protected]]
>>> *Sent:* Friday, May 28, 2021 11:55 AM
>>> *To:* KICTAnet ICT Policy Discussions <[email protected]>
>>> *Cc:* Adam Lane <[email protected]>
>>> *Subject:* Re: [kictanet] Licensing and Shared Spectrum Framework for
>>> Community Networks for Kenya online discussion
>>>
>>>
>>>
>>> Hi Adam,
>>>
>>>
>>>
>>> I beg to respectfully differ with you on the purpose of the framework.
>>> This effort by the Communications Authority has broken the glass ceiling on
>>> Spectrum licensing. Through this many more people will get to understand
>>> the value of spectrum which will in return encourage better usage and
>>> deployment which will be beneficial to the entire ICT ecosystem in the
>>> country. It is a fact that ICTs have widened the divide between the haves
>>> and have nots and community networks are one of the ways aimed at
>>> shortening this divide. Community Networks will definitely spur innovation
>>> at local community level. This may include ideas that will eventually lead
>>> to manufacture or assembly of local network equipment as we saw with the
>>> spread of TV where aerials would be manufactured locally which enabled many
>>> households to own television sets. By the way, I am sure majority of the
>>> senior listers here must have encountered their first TV sets when they
>>> were 10 years old, which is a testament of the havoc the digital divide can
>>> cause. Let us not view community networks purely from commercial lenses.
>>>
>>>
>>>
>>> Best Regards
>>>
>>>
>>>
>>> On Thu, May 27, 2021 at 5:44 PM Adam Lane via kictanet <
>>> [email protected]> wrote:
>>>
>>> Hi Mwendwa
>>>
>>>
>>>
>>> The framework is a positive step. Though Kenya has some of the best
>>> connectivity on the content, the CA has estimated that around 4% of the
>>> population do not have broadband network coverage and the business models
>>> of providing it in those areas are difficult (expensive to provide, few
>>> users, users have low incomes etc). Whether Community Networks are able to
>>> provide networks in those circumstances and at scale may be unclear but
>>> they should certainly be given a chance.
>>>
>>>
>>>
>>> I also want to commend the report for noting the critical issue of
>>> demand-side aspects of broadband usage (awareness, skills, access to
>>> devices, relevant local content etc). Addressing those issues are beyond
>>> the scope of the regulatory framework which is for licensing, but certainly
>>> it is good to note that Community Networks might be more willing to invest
>>> in those areas, and thus benefit from having more users.
>>>
>>>
>>>
>>> Since the stated purpose of the framework is to provide network coverage
>>> where it does not exist, my suggestion would be that Community Networks
>>> should certainly be given a chance in those un-served areas, and in those
>>> areas (88 sub-locations with 0 coverage, 239 sub-locations with <50%
>>> coverage for example) the CA needs to provide some efforts to reduce the
>>> costs of providing networks, including lower licensing fees, and lower
>>> spectrum costs. This should be for any operator, whether a community
>>> network, ISP or MNO. Since currently it is difficult for community networks
>>> to register, then certainly it is a good idea to make it easier for them to
>>> register and try to build a viable network.
>>>
>>>
>>>
>>> However it is strange that the suggested size is of “sub-county” rather
>>> than sub-location or ward; and strange that there is no limitation on
>>> location such as “no existing network coverage”. I would recommend a
>>> limitation on the size to be much smaller than sub-county, and more
>>> importantly, I would recommend a limitation on the community network to
>>> operate in areas that are un-served by other network providers (these areas
>>> are now well known following the Access Gaps Study this year).
>>>
>>>
>>>
>>> The way the current framework is written would allow community networks
>>> to operate in sub-counties of Nairobi or any other cities/towns, and be in
>>> direct competition to MNOs and ISPs, which I don’t believe is the purpose
>>> of the framework.
>>>
>>>
>>>
>>> Should the purpose of the framework be to address affordability issues
>>> of broadband (i.e. if affordability is one barrier of broadband usage along
>>> with devices access, skills, awareness, content, power etc), then I believe
>>> a different regulatory strategy could be developed to address this. This
>>> framework for community networks should be limited to areas that are
>>> un-served only.
>>>
>>>
>>>
>>> Regards
>>>
>>> Adam
>>>
>>>
>>>
>>> *From:* kictanet [mailto:kictanet-bounces+adam.lane=
>>> [email protected]] *On Behalf Of *Mwendwa Kivuva via
>>> kictanet
>>> *Sent:* Thursday, May 27, 2021 9:28 AM
>>> *To:* Adam Lane <[email protected]>
>>> *Cc:* Mwendwa Kivuva <[email protected]>
>>> *Subject:* [kictanet] Licensing and Shared Spectrum Framework for
>>> Community Networks for Kenya online discussion
>>>
>>>
>>>
>>> Dear Listers,
>>>
>>>
>>>
>>> As we had indicated, today we will have a discussion on the Licensing
>>> and Shared Spectrum Framework for Community Networks for Kenya that was
>>> issued by the Communications Authority of Kenya, available for direct
>>> download here
>>> <ca.go.ke/wp-content/uploads/2021/05/Licensing-and-Shared-Spectrum-Framework-for-Community-Networks-May-2021.docx.pdf>
>>> .
>>>
>>>
>>>
>>> Today, we will discuss the licensing aspect of the community networks.
>>> and tomorrow about the shared spectrum framework.
>>>
>>>
>>>
>>> The Community Network Licensing framework proposes;
>>>
>>> 1. Community Network Service Provider (CNSP) License to be created
>>> within the Unified Licensing Framework.
>>>
>>> 2. The community network should be fully controlled by a non-profit
>>> entity and carried on for non-profitable purposes, encouraging members of
>>> the community to participate in the governance, design, and
>>> operationalisation.
>>>
>>> 3. Two letters of support from Community Leaders as part of the
>>> application process for CNSP to ensure community ownership
>>>
>>> 3. Geographical coverage of a CNSP will be a sub-county boundary
>>>
>>> 4. License period of 10years with License Application fee Ksh1000,
>>> Initial Operating License Fee Ksh 5000, and Annual Operating Fee Ksh5000.
>>>
>>> 6. Spectrum Fee: Fee waiver for non-protected access to lightly-licensed
>>> and license-exempt frequency bands by wireless access systems
>>>
>>> 7. CNSPs would be exempt from USF contributions, while the USF
>>> implementation framework may include a community ICT development and/or
>>> capacity building component. The authority shall further examine ways to
>>> ensure that community networks receive consideration under the future
>>> framework for the Universal Service Fund
>>>
>>>
>>>
>>> Questions:
>>>
>>> =========
>>>
>>> – What are your comments on the proposed licensing framework?
>>> – What gaps have you identified in the proposed licensing framework?
>>> – How would you recommend addressing the identified gaps?
>>> – What recommendations do you have for CA to improve entry into the
>>> telecommunications market in Kenya?
>>>
>>>
>>>
>>> Looking forward to an engaging discussion.
>>>
>>>
>>>
>>> ______________________
>>> Mwendwa Kivuva, Nairobi, Kenya
>>> www.linkedin.com/in/mwendwa-kivuva
>>>
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>>> Unsubscribe or change your options at
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>>>
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>>>
>>>
>>> —
>>>
>>> Barrack O. Otieno
>>> +254721325277
>>> +254733206359
>>> Skype: barrack.otieno
>>> PGP ID: 0x2611D86A
>>>
>>>
>>>
>>>
>>
>> —
>> Barrack O. Otieno
>> +254721325277
>> +254733206359
>> Skype: barrack.otieno
>> PGP ID: 0x2611D86A
>>
>>
>>
>>
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>> Unsubscribe or change your options at
>> lists.kictanet.or.ke/mailman/options/kictanet/kakusuj7%40gmail.com
>>
>> The Kenya ICT Action Network (KICTANet) is a multi-stakeholder platform
>> for people and institutions interested and involved in ICT policy and
>> regulation. The network aims to act as a catalyst for reform in the ICT
>> sector in support of the national aim of ICT enabled growth and development.
>>
>> KICTANetiquette : Adhere to the same standards of acceptable behaviors
>> online that you follow in real life: respect people\’s times and bandwidth,
>> share knowledge, don\’t flame or abuse or personalize, respect privacy, do
>> not spam, do not market your wares or qualifications.
>>
> —
> *jNzambiKakusu*
>
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>
> The Kenya ICT Action Network (KICTANet) is a multi-stakeholder platform
> for people and institutions interested and involved in ICT policy and
> regulation. The network aims to act as a catalyst for reform in the ICT
> sector in support of the national aim of ICT enabled growth and development.
>
> KICTANetiquette : Adhere to the same standards of acceptable behaviors
> online that you follow in real life: respect people\’s times and bandwidth,
> share knowledge, don\’t flame or abuse or personalize, respect privacy, do
> not spam, do not market your wares or qualifications.
>

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