Shared Spectrum Framework for Community Networks for Kenya online discussion

Thanks for the update

On Mon, May 31, 2021, 16:33 Adam Lane via KICTANet <> wrote:

> Thanks Barrack and Mwendwa for your excellent comments.
> I believe extending power for Wi-Fi will lead to more interference, not
> less, and that the problem isn’t so much the lack of spectrum (Wi-Fi
> already has more than IMT yet IMT is fulfilling 90 or 95% of the internet
> currently I guess), but the way Wi-Fi works through using unlicensed
> spectrum. Letting the CNs use IMT would be better, whether they are
> licensed directly or lease from an existing licensee who’s not using their
> spectrum in that location.
> I believe the CA’s framework does suggest exploring that option and I’d
> recommend some pilots in these various options to see what’s technically
> feasible as well as whether existing licensees are willing to enter into
> these agreements for reasonable prices (if they’re not using/planning to
> use the spectrum in that area, then any revenue for them could be better
> than nothing, even if little, though CA could mandate it to be made
> available for a very small admin fee, I.e.g. Use-it-or-lose it concept) or
> make some specific spectrum available for CNs to use, e.g. 700MHz that
> would be really good for fixed wireless access in rural areas and for which
> there’s some unused spectrum currently but which currently requires 2.5bn
> to get…
> Out of interest I am not sure if Mawingu counts as a CN since its quite
> big now, but the friend I’m staying with at the moment pays them 5k a month
> and a 15k set-up fee for the router and installation for 5mbps, whereas
> Safaricom charges the same for same speed using 4G (basically unlimited
> data, though after 400GB they’ll reduce to 1mbps) with router about 10k
> according to their website. So in this case the pricing is basically the
> same (obviously depending on actual coverage being available or not).
> Interesting to note that Safaricom fiber is cheaper than 4G but of course
> availability is limited to some urban areas.
> Adam
> ————————————————–
> M: +254-790985886
> Deputy CEO, Government Affairs
> Huawei Kenya
> *From:*Mwendwa Kivuva <>
> *To:*Adam Lane <>
> *Cc:*KICTAnet ICT Policy Discussions <>;Heiko
> Rehm <>
> *Date:*2021-05-31 16:00:39
> *Subject:*Re: [kictanet] Shared Spectrum Framework for Community Networks
> for Kenya online discussion
> On Fri, 28 May 2021 at 18:52, Adam Lane <> wrote:
>> Hi Mwendwa
>> Everything has gone silent, even though this is a controversial topic!
> Probably it is a hard topic, and of course, it has a level of political
> weight behind it.
>> 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] *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.
> Since CA licensing is unified, from the webinar we had on this topic, they
> had indicated they would do a review as you have proposed for the entire
> sector.
> The challenges around spectrum are many, for example
> a) CA charges an annual registration fee for 5GHz Wifi for Point to Point
> connections. PtP/PtMP are important for community networks
> b) Current equipment used for WiFi has less range and strength because of
> the low permitted radiated power rating. Increasing this will make the WiFI
> equipment more reliable especially in rural areas.
> c) If the range of frequency in the license-exempt WiFi spectrum is
> extended, it would reduce the current congestion where communities are
> complaining that their connections are not reliable.
> d) We need to build the technical capacity of operators and businesses to
> enable them to conform to regulatory requirements. As Barrack has indicated
> in his reply, “Spectrum has been a very opaque subject to many.”
> e. As you have pointed out, there is a lot of allocated spectrum that is
> being hoarded. Spectrum refarming can be employed to govern the repurposing
> of spectrum bands to more efficient technologies, investments, or new
> services where the spectrum is needed most
>> 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.
> Probably this is where innovation and new ways of doing things should be
> allowed to thrive? There are many institutions ready to fund innovative
> connectivity solutions for the common good because it is in innovation,
> trial and error … where new things come into being. I wonder is community
> networks operators can tell us what is the minimum requirements to setup a
> small network for a typical Kenyan village.
>> 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”?
> One of the recommendations for the shared spectrum framework is to expand
> the frequency on license exempt spectrum, and also increase the power of
> equipment used. Does this sound as a viable solution?
> The two proposed solutions above are:
> a) Adjustment to PtP and PtMP EIRP levels could dramatically increase the
> potential of WiFi equipment in 2.4 GHz and 5 GHz to deliver access in rural
> areas. See Appendix 2 for specific recommendations.
> b) extending the range of frequencies available for license-exempt use.
> This would have the impact of reducing congestion in backhaul connections
> by increasing the range of license-exempt frequencies;
> 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]*
> Interesting solution. I am not sure what the rest feel. There is one
> school of thought that things this leads to hoarding a public utility with
> the expectation of exiting the investment at a profit.
>> 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.
> +1 on spectrum refarming.
> As you have indicated, if anyone wants to experiment in investing in TVWS,
> we should give them the opportunity.
> The Tier1 operators in Kenya are not deficient in spectrum. What the
> proposal is trying to do is give the small guy in the village access to
> usable spectrum to serve themselves, since the big boys are not serving
> them at the moment.
>> 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.
>> 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]*.
> There is a community network in Easter DRC – the Idjwi island, an
> underserved area with a population of three hundred thousand people on Lake
> Kivu – called Pamoja Net with IMT spectrum. There was a blog by Nzambi
> Kakusu on the KICTANet website
> <>
> This is a viable option especially in areas prone to terrorism – community
> control gives it so many advantages.
>> *[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.
> I think the bigger point is – how do we bring the guys doing KCPE and KCSE
> in year 2021 access to online learning tools? (usecase). How do we help the
> farmers tackle locusts in June 2021?
> What I am trying to say is, the bigger operators will one day take the
> internet to everybody. But if I am in the village, I also want the same
> opportunities for my child now, for my farm now, for my economic
> empowerment now. Life is for the moment.
> Do you think those people, no matter how few, may benefit from better
> WiFi? So that when they pull backhaul from their provider, it is less a
> hustle serving their communities leggaly through PtP/PtMP.
>> 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).
> True. The congestion is a major issue. You find a small area with hundreds
> of equipment. But then that shows there is a need. Hunger. Increasing the
> range and power may help those who can afford more powerful equipment serve
> their communities better.
>> 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.
> Thanks so much Adam for the healthy debate. I guess their are two side to
> this coin. And it is true that this topic is part of the deep end because
> it is very 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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