Thank you Adam. See responses inline. On Thu, May 27, 2021, 5:44 PM Adam Lane <adam.lane@huawei.com> 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
Some questions always asked in the access debate are; is coverage equal to affordability, accessibility, or usability? Can you have broadband coverage and yet not be able to use it? What other models can help bring more internet users onboard? 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 Can local ingenuity help Community Network thrive where other operators have failed? One inexpensive way I have seen CNs thrive is through sharing the cost of backhaul while using inexpensive solutions to distribute the last mile to all community members where traditional operators will not venture. but they should certainly be given a chance. Certainly community networks should 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.
Great points. I guess this was one of the key functions of USF, that the fund will also be used to subsidize setting up and operationalizing the hard-to-reach areas. 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.
This is a good point. The framework tries to simplify the application process by using a tried and tested template, that for community broadcasters. Probably that process will need to go through a "road test."
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).
Interestingly, Community Networks feel they should not be constrained in such a small area. This is the interesting push and pull of different stakeholders. My question is, why do you want the CNs to be constrained to regions where commercial operators who can afford (beyond providing shareholder value) don't want to venture? If a community feels they can provide internet cheaply than traditional operators, should they have that self-determinism to chat a path for cheaper access? An example is how KENET provides internet at cost to their community of colleges and schools, while commercial operators still thrive in those areas.
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.
Also, community networks rely on traditional ISPs for backhaul. Probably we can say CNs complement and extend ISPs? It would be great to hear what the few CNs in Kenya and other stakeholders think about competition with ISPs. My take would be CNs serve users who the ISPs have not reached either in cost or availability. It is still a competitive environment. 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.
Very useful to have different tools to solve the access gap. This framework for community networks should be limited to areas that are
un-served only.
Regards
Adam