Hi Mwendwa,
This is a welcome step in the right direction y CA to address the
challenges of access such as affordability, limited digital literacy
skills, lack of local relevant content and platforms as stated by CA.
My comments on the Community Network Licensing proposals are as follows:
1. CNSP License created within the Unified Licensing Framework is an
acceptable action plan that should be embraced by the
industry stakeholders as this is inline with the existing regulations
2. The CNs should be fully controlled by a non-profit entity and carried
on for no-profitable purses, encouraging members of the community to
participate in the governance, design and the operationalisation as
stated by CA, however it is also important to seriously consider
long-term sustainability from the inception.
3. Having two letters of support for community leaders as part of the
application process for CNSP to ensure community ownership is appropriate.
However, this could also include community legally registered
organisations such as SACCOs or recommendation from local administrations.
4. Geographical coverage of CNSP will be a sub-county. This should apply
countrywide for both rural and urban areas, considering that within
counties such as Nairobi, Nakuru, Mombasa, Kisumu etc. pa, there are areas
or sub-counties which are currently unserved or underserved, though there
is coverage by MNOs, ISPs or Fixed Network operators. This is mainly due
to challenges of affordability or some other reasons. Therefore CNSPs
should not be restricted to rural areas.
4. License period of 10 years with License Application fee of Ksh 1000,
Initial Operating License Fee of Ksh 5000 and Annual Operating License of
Ksh 5000 looks reasonable. However CA could consideration reviewing fees
such as the Annual Operating fee downwards, based on the population of
subcounty or the area to be served.
5. Spectrum Fee: Fee waiver for non-protected access to light-licensed and
license-exempt frequency bands by wireless access system is a good practice
and welcome.
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 – This is quite in order.
Regards,
Vitalis
On Thu, May 27, 2021 at 5:45 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 coverageâ€. 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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