Kenyan consultation on TVWS regulation - response due 27 March 2020

You may have seen the CA announcement regarding a Public Consultation on the Draft Dynamic Spectrum Access Framework for Authorisation of the Use of TV White Spaces. The deadline is the Friday, the 27th of March or a little over two and half weeks from now. This conversation is being opened to discuss and hopefully develop a common position to be submitted to the regulator. Ideally it would be good to have a draft submission by Friday the 20th in order to be able to seek endorsements and to perhaps engage the press. The background document for the consultation can be found here.

I maintain a comparative spreadsheet of TVWS regulation around the world, which may be useful as a reference. I’ve added a row for Kenya but haven’t filled it in yet.

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“The initial studies of the DSA framework focusing on TVWS in the UHF band are set to be concluded by April 2020 and technical research and consultations will continue to expand the scope of DSA to other bands and radiocommunication services by 2023.” page 2

This is encouraging that CA see TVWS as a stepping stone to dynamic spectrum regulation in other bands. Also encouraging is this statement on page 4

d) Minimisation of regulatory hurdles. A level of regulation is necessary to permit access to white spaces while protecting primary users. The Authority has made this as versatile as possible, consistent with the need to prevent harmful interference and maintain flexibility for future applications of spectrum sharing.

As far as I have read, the proposed rules seem quite similar to the Dynamic Spectrum Alliance model rules. I think one possible area for deeper discussion is regarding the geolocation database, as referenced at the bottom of page 6.

“WSDs shall require registration authentication by a geolocation database before they operate. The qualified database shall provide device management functionality for the identification of non-conforming WSDs for their immediate deactivation. With time, the operation ofa large number of WSDs may require multiple geolocation databases with open standards to ensure interoperability so that network operators can select a qualified geolocation database of their preference.”

I believe that geo-location databases are the endgame for dynamic spectrum but to date they have proven a barrier to implementation of TVWS regulation due to the cost and complexity of setting them up operationally. Canada implemented TVWS regulation back in 2015 but still have yet to appoint an authorised geo-location database provider. Similarly in South Africa regulations were gazetted in 2018 but there is no commercially operational database yet, although maybe CSIR’s is?

The point here is that there are a lot of moving parts in setting up a geo location database. Whose software? Who will host it? How will it be paid for? Commercial or government operation? etc. Those are all worthwhile problems to sort out but ideally they are something that can be sorted out in parallel to allowing operators to get started with services. In rural areas, there is typically a lot of spectrum available and in many regions it should be possible to identify spectrum that can be used without risk and tracked in a spreadsheet.

This seems to be the approach that South Africa and Mozambique have taken in authorising service providers prior to the existence of a fully operational geo-location database. Worth checking this out in more detail.

Unlike other regulators who seem to have specified a fixed maximum antenna height for transmitters anywhere between 30 and 60m depending on the country (see the comparative spreadsheet), the proposed regulations appear to allow the antenna height to be defined in the database itself which, in theory, allows for a lot of flexibility for taller towers in more rural areas. Again, this needs to be verified. See Section 7.2 B.

“b. Height: defines the availability of TVWS ata given area in terms of the height of the TVWS transmission site and its antenna height, in relation to surrounding TV broadcasting coverage reception. Basically, the higher the TVWS transmission site/antenna, the higher the likelihood of interference toTV receivers.”

Yet another question is the requirement for professionally accredited installers. With WiFi gear, the equipment must meet type approval but there is no professional requirement for installing it. In South Africa, the equipment must be installed by a certified IEEE engineer. The draft regulations do not appear to have an opinion on this. This strikes me as somewhat analogous to the periodic debate about software developer certification. My own take is that making TVWS as similar to WiFi as possible with low barriers to deployment is desirable. Naturally, you would need an operator license but is more than that necessary?

Thanks for sharing Steve. I’m new to this platform. I do notice others haven’t commented. Wondering if the discussions on email could be migrated here with an alert back to the contributors?

Hi Eleanor,

People are signing up. @amunyua @Barrack and @carlos are here. Still waiting for a few others though. Happy to migrate email discussion here if that is preferable. I think the only email comment to date has been from @michuki who asked whether the Kenya draft regulations were similar to the Nigerian ones. I’ll try to get to that by tomorrow.

I see that the Nigerian regulator held a f2f consultation on their TVWS policy today. AFAIK, there was no public online opportunity to comment. I also know the Dynamic Spectrum Alliance has been involved behind the scenes.

In the context of the current pandemic crisis, should our strategy shift towards asking for an extension for the submission?