[kictanet] Fwd: [afnog] UCC Licensing Framework for IXPs

[Ali Hussein]

Barrack

'I'm surprised it has taken this long for governments to start thinking
about using IXPs for potential 'National Security' Chock points. This will
accelerate the Balkanization of the Internet in regions where we haven't
even heard the term before. Sad. Really sad.

Regards

*Ali Hussein*

*Principal*

*AHK & Associates*



Tel: +254 713 601113

Twitter: @AliHKassim

Skype: abu-jomo

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<http://ke.linkedin.com/in/alihkassim>


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On Thu, Jun 20, 2019 at 1:30 AM Barrack Otieno via kictanet <
kictanet at lists.kictanet.or.ke> wrote:

> I hope this doesn't become a Regional Trend.
>
> Regards
>
> ---------- Forwarded message ----------
> From: Mike Barnard <mike.barnardq at gmail.com>
> Date: Mon, 17 Jun 2019 17:09:10 +0300
> Subject: [afnog] UCC Licensing Framework for IXPs
> To: Afnog Mailing List <afnog at afnog.org>
>
> The Uganda IXP (https://uixp.co.ug) recently received a letter from the
> government (UCC) which announces that they intend to establish a licensing
> framework for IXPs. The letter includes a detailed draft of the proposed
> framework text (see attached).
>
> While we think it is wise for the government to continuously reconsider its
> role in this evolving industry in order to support its development, the
> UCC's proposed licensing framework would ironically prohibit further market
> development by effectively nationalizing the network interconnection
> service.
>
> As written, the framework:
>
> 1) Establishes a government controlled monopoly IXP called the “Designated
> National Internet Exchange Point” and requires all other IXPs to function
> as edge nodes for it. The framework accomplishes this by requiring all IXPs
> to connect to the DNIXP, and by giving government control over the
> contracts between IXPs and their members. See 7.4.b; 8.2.a; 9.e.iii; 9.j.
>
> 2) Includes vague language which could lead to problematic interpretations.
> For example: Clause 9.h could mean that the government intends for the
> DNIXP to establish itself by expropriating the UIXP’s infrastructure.
>
> 3) Allows the government to inspect, copy, or remove any data related to
> any IXP without a court order. This could include proprietary information.
> See 7.5.b.ii.
>
> 4) Turns IXPs into potential surveillance hubs by requiring them to report
> any unlawful activity observed in member networks to the government. See
> 7.3.e.iv.
>
> 5) Introduces other significant barriers to entry for new market entrants.
>
> Our view is that this licensing framework should either be (a) scrapped
> entirely, as it can be argued that it is counterproductive to license IXPs
> in the first place or (b) significantly revised such that it no longer
> includes any language which would create a monopoly or otherwise hinder the
> emergence of true competition in this industry.
>
> The UCC has called for written feedback to be submitted by July 5th, 2019
> and we need your help to avoid disaster. Please take a few minutes to
> review the attached document and submit your comments in writing before the
> deadline. If you cannot submit feedback to the UCC directly, please send it
> to us (board at uixp.co.ug) and we will ensure that it gets delivered to the
> UCC in writing.
>
> Thank you.
>
>
>
> --
> Barrack O. Otieno
> +254721325277
> +254733206359
> Skype: barrack.otieno
> PGP ID: 0x2611D86A
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