See my *responses *below On Fri, May 28, 2021 at 10:39 AM Mwendwa Kivuva <Kivuva@transworldafrica.com> wrote:

Thanks Twahir, see some of my follow-up inline.

On Thu, 27 May 2021 at 23:44, Twahir Hussein Kassim <twahir@hussein.me.ke> wrote:

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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.*

Why would for-profit organizations not go for the normal Tier 3 ISP license?

* Ideally, many who opt to setup CNs are small scale, going for the Tier 3 ISP license is definitely beyond their reach. Having said that, they do however add value to where traditional ISPs have shied away from; and this is the bottom line of this conversation - connecting the unconnected.*

Also, probably we need a better understanding of non-profit organizations. It does not mean the CN will not charge for services, but rather, the pricing will take into account community interests, public good, and any income will be used to grow the initiative further.

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*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

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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.*

Good feedback. Your suggestion is for CNs to recommend each other, instead of using community leaders as referees.

* Yes sir :-) *

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3. Geographical coverage of a CNSP will be a sub-county boundary

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*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.*

I have seen several calls for county-wide coverage. Well noted.

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4. License period of 10years with License Application fee Ksh1000,

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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.*

What do you mean by "annual fees should be set to 1000 per location?". In this case location means one CN license?

*Yes 1 CN license per location of operation; e.g. if Dunia Moja Network operates in Kilifi and Tana River County then each county location should be treated as a different CN i.e. DMN - Kilifi, DNM - Tana River etc.*

On license fee, you mean that annual operating license fee should be Ksh1000?

*Yes *

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6. Spectrum Fee: Fee waiver for non-protected access to lightly-licensed

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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.*

CN has intricate license categories for broadcast media. How would those licenses be woven into the CN license? CN also has a similar license for community broadcasters by the way.

" community broadcasting service as an entity which meets all the following requirements: a. is fully controlled by a non-profit entity and carried on for non-profitable purposes; b. serves a particular community; c. encourages members of the community served by it or persons associated with or promoting the interests of such community to participate in the selection and provision of programmes to be broadcast in the course of such broadcasting service; and d. may be funded by donations, grants, sponsorships or membership fees, or by any combination of the aforementioned

*The essence behind this suggestion is to empower CNs to be a 1 stop shop for all community communication needs. This will empower the communities PLUS also capture the LOCAL CONTENT problem that we are currently complaining about. Take a scenario of a school drama then can be broadcast to the community... local values taught, content created! *

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7. CNSPs would be exempt from USF contributions, while the USF

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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. *

This has been one of the recommendations of the licensing framework.

" Community networks require comparatively modest sums of money to get started and a small grants program initiated by the USF could kickstart new community networks. The authority will explore establishing a subsidy for start-up funds for community networks, under special projects, to help catalyse initiative from communities to develop locally-owned connectivity solutions "

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______________________ Mwendwa Kivuva, Nairobi, Kenya https://www.linkedin.com/in/mwendwa-kivuva

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