Shared Spectrum Framework for Community Networks for Kenya online discussion

Dear Adam,

Many thanks as always for stirring the conversation, i will attempt to give
some feedback on your feedback. I hope other colleagues can chime in.
Indeed Spectrum has been a very opaque subject and the silence is a
testament to this. Be that as it may , we are at an important phase of
history where we are attempting to move local stakeholders from the
spectrum menu onto the table. My responses are in line

On Fri, May 28, 2021 at 6:53 PM Adam Lane via kictanet <> wrote:

> Hi Mwendwa
> Everything has gone silent, even though this is a controversial topic!
> Maybe I can stir up some debate…
> Firstly, it would be helpful to clarify what the problem is before trying
> to identify the solution. For example, is it a lack of spectrum or is it
> the cost of spectrum or is it something else? Actually there is quite a lot
> of spectrum available in Kenya that is completely un-used (for example, in
> 700 Mhz band that is good for rural areas) and some that is so under-used
> (by some ISPs and some government users) that the best thing to do would be
> to return it to the CA and let the CA license it to someone else to use. *[In
> relation to the Spectrum Fees Topic] *
*BO*: In my humble opinion, the problem is lack of sufficient meaningful
and affordable access despite the efforts made by mainstream operators.
Some parts of the country are still unserved and others are underserved.
Community Networks are an attempt at local solutions to local connectivity
challenges. A good example that most of us relate to was shared by Michuki
Mwangi during the Webinar where we pool resources to sink boreholes and
build water networks in the rural areas with the goal of ensuring each
home/household has a decent water supply. Before we sink boherholes
permission is required from the relevant government authorities under the
ministry of water. In the same case, community members can come together
through CBOs or relevant special purpose vehicles and develop frameworks
for ensuring they get meaningful and affordable connectivity.
On the issue of Spectrum I agree with you that there is under-used spectrum
that can be returned to CA after which CA can license someone else to use.
I believe this is what this process is all about. A new license category is
in the office that can take advantage of this unused or underused spectrum.
I believe this is the way the likes of Kameme TV started which broke the
glass ceiling on who could own a TV.

> Certainly the cost of that spectrum is a challenge for many, and it is
> very commendable that the CA proposes to Review spectrum fee framework
> recognising the need for significantly reduced fees for underserved/rural
> areas. I fully support this and it should be applicable to ALL spectrum
> license holders to encourage as many as possible to connect more
> unconnected areas. Fees can help work out who to allocate spectrum to that
> is serious about using it, but it also adds major costs. There are multiple
> fees at the moment, not just for spectrum licenses but also per base
> station using it, and even for using spectrum for backhaul to base stations.
*BO: I agree with your observation on the need for an all encompassing
review of the spectrum framework. My humble opinion though is that we
should not mix the two and should give due attention to the later as you
propose since there might be many factors beyond the current issue premised
around developing a culture of local solutions to local problems. Community
Networks have the potential to spur local development of Network equipment.
Latvia has done well with Mikrotik, China has done well with the Huawei and
Ubiquiti products. I believe Kenya can come up with a local solution in
future using the dormant Gilgil Telecommunication Industries.*

> Secondly, it is important to understand that connectivity relies on
> infrastructure investments, the business case for which need some
> predictability. One cannot build a network (whether a community network or
> a “regular” ISP) without some guarantee that the infrastructure will still
> be usable for 5 years or 10 years etc.
*BO : This is true. A lot of peer support is taking place in the background
to make sure that Community Networks understand the fundamental issues of
connectivity. We are discussing meaningful and affordable connectivity.
Forums such as the Kenya Network Operators Group (
<>) have been very helpful on this front hosting panels
that reflect on Infrastructure investments and the business case for the

> Also, it is critical to avoid different providers using the same spectrum
> too close to each other that it causes interference. These kind of issues
> are what makes shared spectrum tricky. When does one decide the spectrum is
> not being used in a location and let someone else use it compared to
> recognizing the license holder just has not yet got around to building in
> that location but will do “soon”? Leasing spectrum from a license holder
> could be a viable option (i.e. that license holder agrees to let someone
> else the their spectrum in a particular location for a fee and for a
> determined time). *[In relation to IMT spectrum topic]*
*BO: Agreed. This is a factor of capacity building. The Communications
Authority has Regional Offices that I believe can assist in equipping
Community Network and other operators with ample knowledge on spectrum
utilization and management.*

> In relation to this a critical issue with investment in infrastructure and
> having predictability is the issue of wanting to change a spectrum usage
> after equipment has been invested in. Let me give 2 example:
> 1) TV White Space regulations have been available in some countries
> (e.g. US, UK) for many years but have had very little adoption. Meanwhile
> some of those frequencies have been used for regular mobile use, e.g. 600
> Mhz network in the US and achieved wide scale and are particularly useful
> for rural coverage. What if equipment is deployed to use TVWS in this
> frequency but gets little adoption so the CA wants to change to mobile use;
> what to do with the existing equipment? How to avoid interference with the
> new equipment? *[In relation to dynamic spectrum access topic].* Since
> there is plenty of spectrum available in Kenya, just some is not well used
> and could be taken back/re-distributed and some is too expensive, there may
> not be a huge need for TVWS, but if ISPs can get it to work with the
> geolocation databases, and if they can get good enough Quality and Speeds,
> they could try.
> 2) Use of equipment in unlicensed spectrum – once it is in use in
> the market then it cannot be taken out of the market and new equipment
> brought in. With licensed spectrum it is easier to manage. So for example
> as countries weight up spectrum for wi-fi vs 5G, if later there is more
> demand for 5G, it will not be possible to remove wi-fi equipment since
> there is no record of who owns it.
*BO : I agree with your observations. It would be good to have feedback
from the Communications Authority on the results of the trials that were
done ny Mawingu Networks and Strathmore University with respect to the use
of TV White Space.*

> Third, it is important to recognize the need and benefits from economies
> of scale. Nationwide providers get this from non-infrastructure based
> operations (e.g. creating an organization with administration functions,
> customer service functions, core network, billing systems etc) and they
> also get this from having common infrastructure. This is a challenge for
> localized spectrum access *[in regards the IMT spectrum topic]*.
*BO: Agreed. As a matter of fact, we have so many homegrown Customer
Relationship Management Solutions that have been developed to respond to
the needs of the Sambaza culture in our mtaas. This is the beauty of
Community Networks*

> *[on the license exempt spectrum]* It is clear that in Kenya the majority
> of people use mobile for their access (from a base station that is using
> either microwave or fiber) or they are using wi-fi for their access (from a
> mobile router or a home fiber router). Most ISPs that provide wi-fi
> networks also use fiber as their backhaul. In the future more and more
> people may be able to use both mobile routers (5G capacity) or home fiber
> routers (fiber). In fact there is need for more spectrum for mobile, as
> more and more people will use 4G and 5G mobile routers to give them wi-fi
> at home especially in rural or less dense places where fiber may be
> expensive. In these cases there is no need for more spectrum for wi-fi.
> Wi-fi provides only short-range internet and is easily blocked by walls,
> and with 7+ Gbps capacity that is more than enough for the small number of
> users for each access point (It can get 7Gbps because it already has 560
> Mhz of spectrum, way more than mobile) whereas each mobile base station
> will support thousands of users. Mobile base stations cannot work with
> unlicensed spectrum.
*BO : I agree there is need for more spectrum for mobile. I equally think
there is need for more spectrum for wi-fi since it the preferred mode of
access in the rural areas. I would prefer an evidence based approach to
this issue.*

> Also [*on license exempt spectrum]*, it is noted that in the CA document
> that there is frequent interference for those using it for backhaul. This
> is an inevitable problem with unlicensed spectrum which causes quality
> issues, making it unsuitable for large scale deployments of backhaul in
> dense populations (with other users of wi-fi for personal use as well as
> use for backhaul intefering).
*BO : Agreed. This issue has come up for discussion during the Community
Networks panel on the Kenya Network Operators Group. Community members are
already aware of the punitive steps that CA takes when there is
interference. I beleive there is need to create more awareness around this
issue to deter such occurrences.*

> I know this can get quite technical, but I hope that some of this
> information may be useful. Note some comments I have made are
> simplified/generalized to try to be brief and not too technical.
> Regards
> Adam
> *From:* kictanet [mailto:kictanet-bounces+adam.lane=
>] *On Behalf Of *Mwendwa Kivuva via
> kictanet
> *Sent:* Friday, May 28, 2021 12:20 PM
> *To:* Adam Lane <>
> *Cc:* Mwendwa Kivuva <>
> *Subject:* [kictanet] Shared Spectrum Framework for Community Networks
> for Kenya online discussion
> Dear Listers,
> The tread on Licensing framework is on fire and doing very well. Thank you
> all for the contributions, reading, learning, relearning … Please
> continue debating on that thread.
> We will start a new thread on the proposed \”Shared Spectrum Framework\”.
> 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
> <>
> .
> *License Exempt Spectrum *
> WiFi has emerged as a powerful technology for both access and backhaul
> around the world but regulation has not fully kept up with the backhaul
> developments.
> The draft framework recommends:
> · Review the Guidelines on the use of Radiofrequency Spectrum by
> Short Range Devices to amend EIRP limits for 2.4 GHz & 5 GHz Wi-Fi for
> Point-to-Point and Point-to-Multipoint use.
> · Review options for lowering the barrier to use of other
> license-exempt bands for PtP and PtMP use, including 24 GHz and 60 GHz.
> · Expand the range of frequencies available for license-exempt
> use, especially in the 5 & 6 GHz range
> · To strengthen collaborations with service providers to foster
> standards and regulatory inclusion.
> *Dynamic Spectrum Access *
> · To expedite the commercial availability of geolocation database
> service and implement required mechanisms to make the TVWS spectrum
> available immediately to operators.
> · To establish an incubatory period for TVWS technologies.
> · To evaluate with regional regulators the feasibility of a common
> approach implementation of geolocation databases
> *IMT Spectrum*
> · Establish a regulatory sandbox for localised spectrum access for
> small operators in an unassigned LTE band.
> · Conduct a review of international approaches to the creation of
> more localised access to spectrum to inform the establishment of a more
> permanent mechanism for local spectrum access that is well adapted to the
> Kenyan context.
> *Spectrum Fees*
> · Review spectrum fee framework recognising the need for
> significantly reduced fees for underserved/rural areas.
> · Consider a spectrum fee reduction scheme for non-profit
> community networks.
> *Questions:*
> · What are your comments on the proposed recommendations?
> · What in your opinion are the most important considerations the
> proposed shared spectrum framework should address?
> · Are there gaps you have identified in the existing licensing
> framework in respect to spectrum assignment and utilization?
> · How would you recommend CA to address the identified gaps?
> ______________________
> Mwendwa Kivuva, Nairobi, Kenya
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