Brian/Listers, Many thanks for your feedback on the National Broadband Strategy that was launched yesterday. The Commission does not disregard stakeholders’ input on the various regulatory issues that we subject to public and stakeholder comment and consultation. On the issue of the National Broadband Strategy, all submitted comments were analyzed by the Committee spearheading the process, and the analysis uploaded onto our website at http://www.cck.go.ke/links/consultations/published_responses/Analysis_of_Dra... The analysis shows the position that the Committee took in respect to each and every submitted input. The analysis was posted onto our website after conclusion of the consultations to apprise stakeholders on the decisions that the Committee took in respect to submitted comments/inputs. In light of the foregoing, comments to the effect that the CCK does not take on board stakeholders’ input have no basis whatsoever. Have a lovely day. Best regards, Christopher Wambua Manager – Communications Consumer and Public Affairs Department Communications Commission of Kenya P.O. Box 14448 NAIROBI 00800 Tel: +254 20 4242209 info@cck.go.ke<mailto:info@cck.go.ke> www.cck.go.ke<http://www.cck.go.ke> From: kictanet [mailto:kictanet-bounces+wambua=cck.go.ke@lists.kictanet.or.ke] On Behalf Of Brian Munyao Longwe Sent: Tuesday, July 23, 2013 2:46 PM To: Wambua, Christopher Cc: KICTAnet ICT Policy Discussions Subject: Re: [kictanet] Thoughts on Kenya's National Broadband Strategy Hi all, I have just gone through the recently launched National Broadband Strategy. Sadly, none of my submitted input (included below) was accomodated (even after confirmation from CCK that they had been received). I guess this is a sign of the times, because it seems that over recent years "public consultations" by CCK and Govt on ICT issues have been merely stage-managed exercises aimed at giving an appearance of inclusion, but in reality are merely rubber-stamping exercises which allow largely third party driven agendas (vendors, foreign govts) to take center stage and prioritization in our strategies, policies, laws etc... I guess I will just have to stop making the effort to "contribute" to these processes as it seems to be pointless and an exercise in futility. Hopefully others will have better luck? Have a good day, Brian On Sun, Jan 13, 2013 at 12:16 AM, Brian Munyao Longwe <blongwe@gmail.com<mailto:blongwe@gmail.com>> wrote: I had shared these thoughts in ISOC-KE and someone asked if I would mind sharing them with KICTANET. Well, here goes: ------------ Is it right to explicitly name a particular technology within the context of such a high level strategy? Pg 6 ¬† the immediate plan to further deploy broadband through a nationwide LTE system The language in principle 2 (pg 8) and principle 7 (pg 9) seem to be contradictory. While principle 2 emphasizes technology neutrality (a good thing), principle 7 in elaborating competitive use of technologies explicitly names fiber optic and wireless broadband. It is proposed that the language here be changed to distinguish between fixed and non-fixed media as alternatives for infrastructure Pg 21 - the relationship between a pacemaker (for heart conditions) and content & applications is not immediately obvious - could this be the wrong kind of example to use in this section? Pg 22 (Table 4) on the problem of an unstructured innovation chain; wouldn't it be better to aim at developing a National Innovation System - rather than simply seeking to "institutionalize the innovation value chain"? The current recommendations fall far short of *really* tackling the underlying issues and proposing sufficient interventions to address the problem in the medium to long term. Pg 23 the figures related to mobile penetration should be updated with latest market estimates and not figures from 2011. Current estimates are at 100% mobile penetration. Also the percentage of *youth* is questionable as it is based on a 2005 study. Should statistics that are 8 years old be used in such an important document? pg 26-32 Section 3.4 Policy, Legal & Regulatory Environment While CCK has over the past 13 years of it's existence facilitated massive transformation with the information and communication technology sector in the country and the region as a whole. It could be argued that the Commission's mandate has become bloated over the years, leading to a "too many eggs in one basket" problem. It could be recommended that specialized agencies be established to deal with essential issue that do not strictly fall under the regulatory mandate of CCK and may, in some cases create opportunity for conflict of interest. These include but are not limited to: Operation and Administration of the Universal Service Fund, Operation and Administration of cyber-security related units, consumer protection etc... While it is evident and obvious that CCK has served and may continue to serve as an ideal "incubator" for these types of services/agencies. It is true that they encompass a potentially vast amount of work, especially within a national context and could be better served by specialized agencies that can focus time and resources and deal with issues in a focused and timely manner. pg 33 Section 3.5.2 by specifically referring to a particular technology (in this case LTE) as a means to accomplishing the objectives of this strategy - it might appear that the strategy is biased towards particular vendors or operators and may not necessarily be taking the best interests of the marketplace and the greatest stakeholder - the citizen - into consideration. It is recommended that the language in this section be reworked to eliminate the mention of specific technologies. The section on Financing and Investment should include recommendations on various incentives to promote activity in the area. Tax breaks, concessions, PPP proposals, allocations from various existing (and new) funds etc... Section 4 Implementation once again, specific reference to LTE may not be in the best interests of leaving the strategy open enought to allow for competing and maybe more affordable technologies that can achieve stated objectives.