Thanks @Mwendwa Kivuva <[email protected]> and the entire who is who in
KICTANET and her partners for bringing this on, I must say that it
couldn’t have come at a better time.
My *responses* below
On Thu, May 27, 2021, 5:21 PM Mwendwa Kivuva via kictanet <
[email protected]> wrote:
> 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.
>
*This is a welcomed move, late in the day as it may be but we are here, we
intend to make the most of it.*
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.
>
*Forcing this to be solely for nonprofits is skewed on unfairness.
Community Networks many a time have been looked upon ONLY as organisations
that serve with no profits, however, I must say that this is what has been
a cause for CNs not picking up as they fail to be sustainable. Additionally
attaching it to community ownership especially in areas where the value of
the net is yet to be appreciated might be a tall order.*
*Suggestions:-*
*a) should be open to both for profit and nonprofit. However, there should
be attached the need to serve the community. Market forces will determine
pricing.*
*b) There are many individuals who set out to serve communities. At onset
forcing that registration is only for community run projects might lead
some areas to remain in net-darkness. We are talking rural folks in most of
these cases, many such setups are started by individuals and as kids
benefit the adults start taking notice and interest comes on. Let this not
be a blanket rule, let it be on a case basis.*
3. Two letters of support from Community Leaders as part of the application
> process for CNSP to ensure community ownership
>
*Unfortunately here we shall be killing a heifer before it grows into a cow
to be milked. The sorry state of nepotism and corruption that exists within
our borders will see a new avenue to make a quick buck. Let this be a peer
review process, where CNs vouch for others; the CN space is a small
community that can assist CA is vetting these.*
3. Geographical coverage of a CNSP will be a sub-county boundary
>
*This is welcomed though county wide coverage would be make more sense. The
reality is TELCOs only focus on areas where it makes financial sense which
has seen town centres being the focus, moving out of CBDs in most “rural”
counties would reveal no coverage beyond a 5-10km in many cases. I would
suggest countywide coverage.*
4. License period of 10years with License Application fee Ksh1000, Initial
> Operating License Fee Ksh 5000, and Annual Operating Fee Ksh5000.
>
*Application fees of 1000 is very welcomed, however this should cover the
initial operating license too. The annual fee should be set to 1000 per
location. What we need to realise is that the CNs are basically trying to
cover what USF SHOULD have covered by now. Most of these CNs would
basically be serving Wanjiku and barely sustainable if we are to take
example of many CNs which are mostly donor supported.*
6. Spectrum Fee: Fee waiver for non-protected access to lightly-licensed
> and license-exempt frequency bands by wireless access systems
>
*The CNs should be allowed to operate Radio, TV and ISP services within
their jurisdiction areas.*
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
>
*Not only should CNs be exempted from USF Contributions; they should be
funded by USF as essentially what CNs have setup to do is step in where USF
is yet to reach. *
>
> 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?
>
*I believe I have handled the above questions within my responses above.*
*CNs are most probably the silver bullet we need to bring down the Digital
Divide Ogre that continues to roam our rural villages.*
> ______________________
> Mwendwa Kivuva, Nairobi, Kenya
> www.linkedin.com/in/mwendwa-kivuva
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