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

Another example of a CN just across the border is Bosco Uganda, it covers
almost the whole of Northern Uganda
boscouganda.com/connectivity/

Coverage map –
www.google.com/maps/d/u/0/viewer?mid=1kufmf0mqiOEb5mJiuPt2X-joSSO6PEul&hl=en&ll=3.0014236517916895%2C32.17317130000001&z=7

Kenya has always led in matters innovation, let not this framework be a
limiting factor rather let it widen our horizons.

On Fri, May 28, 2021, 12:23 AM Twahir Hussein Kassim <twahir@hussein.me.ke>
wrote:

> Adam,
>
> Some info that CA gives is not in tandem with what KNBS states. See my
> *comments* below
>
> On Thu, May 27, 2021, 5:45 PM Adam Lane via kictanet <
> kictanet@lists.kictanet.or.ke> 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.
>>
> *Kenya has a youthful rural population; the latest data from the census
> 2019 by the Kenya National Bureau of Statistics (KNBS) reveals. In this
> case, 35.7 million Kenyans (75.1%) are below 35 years, while 32.73 million
> (68.9%) live in rural areas.*
>
> *Source:
> kenyanwallstreet.com/census-2019-datashows-kenya-has-a-youthful-rural-population/
> <kenyanwallstreet.com/census-2019-datashows-kenya-has-a-youthful-rural-population/> *
>
> *Given these details, I wonder how we can reconcile the figure to 4% not
> covered by broadband.*
>
> *The framework is definitely a step in the right direction.*
>
>> 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.
>>
> *The aim of the framework while stated is for licensing however, the
> licensing is focused on addressing a bigger issue – The Digital Divide. *
>
> *If the license were not to focus on matters digit literacy, availability
> of digital devices, power then it will simply be putting regulation over
> nothing. The Digital Divide is very real and it cannot be addressed piece
> meal.*
>
>> 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.
>>
> *Unserved areas exist within cities. Take an example of Nairobi; we have
> Poa Internet, Tunapanda serving the masses where major telcos have failed.
> The question is not only about coverage but also about affordability.*
>
> *Mombasa has Muoroto, Bangladesh, Kisumu Ndogo… all remain unserved. Yet
> the town is teaming with all ISPs fighting for businesses within CBD and
> industrial areas of Shimanzi.*
>
>> 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).
>>
> *Limiting areas for CNs to the neighborhood would make no sense in as far
> as CNs normally operate. Take examples of CNs in Africa…*
> *Zenzeleni – **https://zenzeleni.net/our-journey/
> <zenzeleni.net/our-journey/> it covers at least a span of 60km if
> not more by now. This is equivalent to the distance between Mombasa and
> Kilifi, Mombasa and Kwale, etc. CNs should not be restricted within
> locations.*
>
> *The last ACCESS GAPS Study am aware of was done in 2016, as per CA’s
> website an EOI is dated to begin and end on 27/05/2021 – **https://ca.go.ke/document/expression-of-interest-eoi-for-consultancy-services-to-undertake-ict-access-gaps-study-in-kenya
> <ca.go.ke/document/expression-of-interest-eoi-for-consultancy-services-to-undertake-ict-access-gaps-study-in-kenya>*
> /
>
>
>>
>> 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=
>> huawei.com@lists.kictanet.or.ke] *On Behalf Of *Mwendwa Kivuva via
>> kictanet
>> *Sent:* Thursday, May 27, 2021 9:28 AM
>> *To:* Adam Lane <adam.lane@huawei.com>
>> *Cc:* Mwendwa Kivuva <Kivuva@transworldafrica.com>
>> *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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>

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