[kictanet] Thoughts on Kenya's National Broadband Strategy

[Brian Munyao Longwe]

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.
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.kictanet.or.ke/pipermail/kictanet/attachments/20130113/b09c18b1/attachment.htm>