ministry of information, communications technology
TRANSCRIPT
THE REPUBLIC OF UGANDA
MINISTRY OF INFORMATION,
COMMUNICATIONS TECHNOLOGY & NATIONAL
GUIDANCE (ICT & NG)
DRAFT POLICY FOR ICT INFRASTRUCTURE SHARING
(DRAFT VER 2.0)
JULY 2017
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FOREWORD
2
TABLE OF CONTENTS
FOREWORD................................................................................................ 1
ABBREVIATIONS ........................................................................................ 4
EXECUTIVE SUMMARY .............................................................................. 5
CHAPTER 1: INTRODUCTION ..................................................................... 6
1.0 BACKGROUND ................................................................................ 6
1.1 CURRENT STATE OF ICT INFRASTRUCTURE SHARING .................. 7
1.2 THE NEED FOR THE ICT INFRASTRUCTURE MANAGEMENT POLICY .................................................................................................. 12
1.3 TYPES OF SHARING of ICT INFRASTRUCTURE ............................. 19
1.2.1 Sector Strategic investment plan ................................................. 25
1.2.2 National ICT Policy ..................................................................... 25
1.2.3 National Development Plan (NDP II) ............................................ 25
1.2.4 National Broadband Strategy ...................................................... 26
1.2.5 Sustainable Development Goals (SDG) .......................................... 26
1.3 POLICY, LEGAL AND REGULATORY GAPS ....................................... 26
Licensing Issues..................................................................................... 26
CHAPTER 2: THE POLICY ......................................................................... 28
2.0 Introduction .................................................................................. 28
2.1.2 Principles and conditions for formulation of policies ...................... 28
Regulatory framework ............................................................................ 29
2.1 Policy Vision .................................................................................. 29
2.2 Policy Mission ................................................................................ 29
2.3 Guiding Principles .......................................................................... 29
2.4 Policy Objectives ............................................................................ 30
2.5 Policy Strategies ............................................................................ 30
2.6 POLICY TARGETS ....................................................................... 32
CHAPTER 3: IMPLEMENTATION FRAMEWORK ......................................... 34
3.0 Introduction ..................................................................................... 34
3.1 Institutional Framework ................................................................... 34
3.1.1 Ministry of Information and Communications Technology & National Guidance ............................................................................................... 34
3.1.2 Uganda Communications Commission .......................................... 34
3.1.3 National Information Technology Authority – Uganda .................... 35
3.1.4 National Environment Management Authority (NEMA) ................... 35
3.1.5 Parliament .................................................................................... 36
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3.1.6 Cabinet ......................................................................................... 36
3.1.7 Operators ...................................................................................... 37
3.1.8 The people .................................................................................... 37
3.2 Monitoring and evaluation ............................................................. 37
3.2.1 Introduction .................................................................................. 37
3.2.2 Methodology .................................................................................. 38
3.2.2.1 Assessment of impact ................................................................. 38
3.2.2.2 Monitoring and assessment of outputs ....................................... 38
3.2.2.3 Monitoring and assessment of Implementation ........................... 38
Annexure – A : Policy Development Roadmap ........................................... 0
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ABBREVIATIONS
ADSL
Asymmetric Digital Subscriber Line
BSC
Base Station Controller
BTS
Broadcast Technology Society
DAS
Distributed Antenna System
DWDM
Dense Wave Division Multiplexing
EASSy Eastern Africa Submarine Cable Systems
ETCL
Electricity Transmission Company Limited
GIS
Geographic Information System
GNI
Gross National Income
IBS In-Built Solutions
ICT
Information and Communications Technology
IP
Internet Protocol
ITU
International Telecommunication Union
ISP
Internet Service Providers
ISSP
Infrastructure sharing of service providers
MoICT&NG
Ministry of Information, Communications Technology and National Guidance
MVNO
Mobile Virtual Network Operator
NBI
National Backbone Infrastructure
NDPII
Second National Development Plan
NITA
National Information Technology Authority
ONU
Optical Network Unit
PoPs
Point of Presence
QoS
Quality of Service
RF
Radio Frequency
RAN
Radio Access network
SEACOM
Sea Cable System
SDGs
Sustainable Development Goals
SIP
Session Initiation Protocol
SPV
Special Purpose Vehicle
STM-1
Synchronous Transport Module level-1
TEAMS
The East Africa Marine System
UIXP
Uganda Internet eXchange Point
UCC
Uganda Communications Commission
USD
United States Dollars
WACS
West African Cable system
WiMAX
Worldwide Interoperability for Microwave
Access
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EXECUTIVE SUMMARY
Though there is reasonable growth in ICT sector in the last decade, still
large traits of the country do not have proper data coverage. Added to this,
the cost of internet bandwidth is also relatively high when compared to
neighbouring countries. Uganda has crossed 22 million subscribers in
mobile customers and 16 million subscribers in internet services. Unless the
internet penetration reaches at least 50% in the country, the fruits of the
ICT growth will not reach the citizens. But extending internet and telecom
services to all parts of country requires significant infrastructure costs. The
service providers’ business models may not always allow them to provide
carpet coverage across the country and they are usually reluctant to extend
to rural areas.
2. Ensuring country wide coverage and achieving the goal of reaching 90%
tele-density with 100% broadband penetration in urban and 50% in rural
areas requires huge infrastructure requiring significant investments. Also, in
order to achieve Broadband access speeds of 30Mbps per household in
urban areas (as envisaged in NDPII), extensive fibre network not only in the
backhaul but also in the last mile are required to be build. The biggest
challenge remains in how to optimally utilize the available resources while
also ensuring competition and ensuring services at affordable costs. Hence,
a cooperative approach amongst the service providers to optimize
investments and provide services efficiently is required. The infrastructure
sharing therefore is the need of the hour so as to ensure constant levels of
investment in the network. The advantage of such infrastructure sharing
will be passed on to subscribers also, in terms of faster roll-out and greater
affordability of services. While regulatory interventions are normally not the
norms in infrastructure sharing, in an eschewed market some levels of
interventions are required for a certain period of time to ensure uniform
growth of the sector.
3. This policy initiative is aimed to encourage competition, ensure level
playing field and maintain technology neutral stance in extending the
services across the country through effective infrastructure sharing.
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CHAPTER 1: INTRODUCTION
1.0 BACKGROUND
The ICT services have been recognised world over as an important tool for
socioeconomic development of a country. In addition to fulfilling the basic
need of communicating with each other, ICT is a prime support sector for
rapid growth and modernisation of various other sectors of the economy.
Infrastructure investments can affect growth, beyond adding to the capital
stock. Fortunately, Uganda is at a relatively early stage of infrastructure
development especially for broadband, and can gain the most from investing
in ICT networks to reach the critical mass for higher impact, before the
diminishing returns take effect. Therefore, development of an adequate ICT
infrastructure policy remains one of the Ministry’s major goals.
Advancement towards converged networks has seen the emergence of newer
technologies where certain elements of the network infrastructure can be
shared to bring down the cost and decrease the roll out time. Sharing could
be possible in both active and passive network elements. With huge
requirement of infrastructure to be created, there needs to be an active
involvement of Infrastructure Providers in meeting the infrastructure
requirement of the service providers. The infrastructure providers and the
various Service Providers should be able to share infrastructure with all
licenced service providers.
Infrastructure sharing in ICT is an important measure to reduce costs. The
penetration of mobile coverage and the fiber network in the country requires
significant investment and efforts are required to ensure that Capex and
Opex for the service providers are optimized. It is useful in start-up phase to
build coverage quickly and in long-term scenario to help build additional
cost-effective coverage in non-serviced areas. Although to some extent,
passive infrastructure sharing (e.g. masts, towers, antennas etc.) is taking
place amongst some of the service providers, it has slowed down in recent
years and hence there is a need to accelerate the pace of sharing especially
in fiber networks (where currently there is hardly any sharing).
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The existing licensing conditions enable passive infrastructure sharing
though much is still not being done in this area. But international practice
as well as technological necessity in the sector requires, expanding the
scope of infrastructure sharing into the active domain and in the backhaul
domain (the optical cable network). The key issue however is to determine
the nature of regulatory intervention that will be required for such
infrastructure sharing.
The issues centring infrastructure sharing could be addressed in three
parts - Passive infrastructure sharing, Active infrastructure sharing and
Financial and economic measures for infrastructure sharing. This ICT
infrastructure policy covers various elements of the infrastructure like
optical fibre network, towers, IP networks, evolving technologies like IBS,
DAS etc. amongst others.
The Permanent Secretary to the Ministry of ICT and National Guidance vide
letter dated 7th March 2017 had sought a detailed concept note and
contours of an infrastructure Management Policy for the country.
1.1 CURRENT STATE OF ICT INFRASTRUCTURE SHARING
Currently, Infrastructure sharing is predominant only in the mobile
network, involving sharing of towers. In the country, most of the mobile
operators have either sold or outsourced the management of towers to
independent tower firms. In the wireline network including fiber optic
network, no significant sharing is taking place. This remains a fact though
Google, through its Project Link and Liquid Telecom, subsidiary Infocom,
have invested in fibre networks to largely provide wholesale access on non-
discriminatory basis.
One of the mobile operators, MTN has reportedly laid 2800 km of fiber
networks in the country. The Government through National Information
Technology Authority (NITA), have also laid the National Backbone
Infrastructure (NBI) covering around 1,645km (as of April 2015), with
another 756km under construction.
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The mobile towers of some of the mobile service providers have been
acquired by Public Infrastructure Providers. M/s Eaton had acquired towers
from M/s Orange, M/s Warid and M/s Airtel while another infrastructure
service provider, M/s American Tower is also in the fray through acquisition
of Airtel towers and MTN towers.
The current ownership share of the around 3485 towers in the country is
shown in figure 1 below. It shows that around 1300 are each owned by the
infrastructure provider- Eaton towers and American towers. Figure 2 also
show the number of towers in certain selected countries of Africa.
Figure 1: No of towers
Figure 2: Tower counts in certain countries of Africa
But out of these 3,485 towers, it is estimated that there are only a little over
4,000 BTS with an average tenancy ratio of just under 1.14, which is very
low as per industry standards. Other than sharing of towers, other ICT
infrastructure sharing like in-building solutions (IBS) are relatively naive in
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the country. For example only around five buildings are covered by IBS
when compared to 100’s in neighbouring Kenya.
In the wired network especially in the fiber optic network, Uganda has
around 5,110 optic fiber kilometres (Table 1) laid by both the Government
and the private sector.
TABLE 1: Fiber Optic Cable routes
Company Route Length (km)
Uganda Telecom
Kampala – Entebbe 42.2
Kampala – Mukono 20
Kampala- Masaka 258
Mbarara- Katuna 220
MTN (U) Limited
Kampala – Busia 206
Kampala – Mbarara 289.8
Kampala - Masaka, 258
Mbarara – Katuna 220
Masindi- kiryandongo- Oyam- Kole –Lira-Soroti-Kumi.
Kumi- Mbale- Tororo
Airtel Around Kampala 82
Infocom
Kampala – Tororo 240
Kampala – Katuna 596
Roke Telekom Kampala Metropolitan 360
Masaka- Mutukula 88
Uganda Electricity Transmission Company Limited (UETCL)
Nalubale – Malaba, Masaka - Mbarara Nalubaale -TororoTororo –Malaba Bujagali-Kawanda-Mutundwe, Kampala-Namanve.
480.85
MoICTs -Government of Uganda.
(NBI Phase 1 & 11)
Kampala, Entebbe, Mukono, Jinja, BomboLuwero, Nakasongola, Masindi, Gulu, Lira, Soroti, Kumi, Mbale, Tororo, Busia, Kyenjojo, Fortportal, Kasese, Bushenyi, Mbarara, Ntugamo, Egelu, Iganga, Bugiri, Tororo, Busia, Malaba.
1,585
Total fiber 5,110.85
On the privately owned Fiber Optic infrastructure, during the last few years,
the main telecom operators in Uganda have rolled out fiber backbone
networks around the country to support the provision of their services.
Along with Uganda Electricity Transmission Company Limited (UETCL) who
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have rolled out fiber along their high transmission lines there is a sizeable
investment in backbone fiber along the commercial corridor cutting across
the country from East to West border points. This link is also used by a
number of ISPs. The fiber network route of some of the major service
providers are given in figure 3 below.
Figure 3: Map showing the fiber route of some service providers
Liquid telecom and Google’s Project link are poised to offer wholesale
backbone network. The network of liquid telecom and Google’s Project link
fiber network are depicted in figure 4 below.
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Figure 4: Liquid telecom fiber network & Google’s Project Link
network
Source: Liquid Telecommunications Holdings Limited / Project Link website
The government’s flagship National Backbone Infrastructure (NBI) also offers
wholesale fiber-network as shown in Figure 5 below. Phase I, II and III of the
project have been completed. Phase I had covered Kampala, Entebbe,
Bombo, Mukono and Jinja, whilst Phase II had covered Luwero,
Nakasongola, Masindi, Gulu, Elegu, Lira, Soroti, Kumi, Mbale, Malaba,
Tororo, Busia, Mbarara, Kasese, Fort Portal and Kyenjojo. Phase III had
extended the connectivity been Kampala-Masaka, Masaka-Mutukula,
Mbarara-Kabale Kabale-Katuna and Kyenjojo-Hoima.
Figure 5: NBI fiber network
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Source: NITA Uganda website
1.2 THE NEED FOR THE ICT INFRASTRUCTURE MANAGEMENT
POLICY
Uganda is largely a dichotomy economy; in urban areas, increasing
population density, construction and data usage is presenting mobile
operators with one set of challenges, whilst the need to meet coverage
requirements for a large underserved population in remote, rural areas
presents totally different set of issues and challenges. Today there are eight
mobile operators and 23 Infrastructure service providers who are active in
the country.
With the uptake of 3G/4G, sharing of towers is declining, as these require
fiber to be brought to these towers unlike microwave backhaul earlier. This
has also upset the existing business models resulting in reduction of
revenues in tower sharing, with the result sharing is not increasing amongst
the players. Also, out of the around 4000 base stations in the country, only
around 1,600 are 3G enabled. Out of the 612 sub counties having 3G
coverage, 384 do not have any fibre to support data backhaul, implying
limited access speeds.
The next challenge is the result of increasing number of high rise buildings
because of urbanisation. This necessitates increase in number of towers or
in building solutions (IBS), but the infrastructure providers are reluctant to
add sites because of rising costs resulting in selective coverage of these sites
by the mobile service operators. Unfortunately, there are also no guidelines
for building developers or owners for development of infrastructure – say
ensuring proper ducts lead-in for fibres or building common IBS. A common
infrastructure for such IBS- a platform over which different service providers
could ride over -will help in cost reduction and enhance coverage. In
countries like Nigeria and Rwanda, for example, the regulatory bodies have
defined guidelines for building owners.
The next challenge is developing similar common infrastructure in secured
areas – both residential and commercial - which do not have sufficient
coverage. A common infrastructure provider could install an outdoor
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Distributed Antenna systems (DAS) that could allow all operators to provide
coverage using the same infrastructure which also could include lead-in
fibre optic cables.
In the underserved rural areas, there are no proper infrastructures available
because of constraints in power availability, accessibility and no economic
business advantage. A common infra structure provider, even operating
regionally, such district level providers, could pave way for increased rural
coverage and fibre connectivity at sub county levels which could also be
used by various service providers. In countries like India, Zambia, such
technologies are common. Such common infrastructure will not only cover
masts, antennas and fiber, but also the active elements namely the
switches, OTN, BTS etc.
The penetration of fiber optic network is also relatively poor in rural areas.
Today, around 60 districts have no fibre on their land and more than 1030
sub counties have no fiber connectivity, while only Kampala’s metro fibre
network is around 282 km. Also, though there are around 5100 km of fiber
in the country, most of the routes are duplicated, effectively reducing the
fiber route to less than 2100 km.
Internet Bandwidth
Sharing of ICT infrastructure will help in reduction of internet bandwidth
costs. Currently, the costs of the bandwidth are very high in the country,
when compared to neighbouring countries. The table 2, below depicts the
costs for some of the African countries.
Table 2: Price Rankings by Country of Internet in Africa
(10 Mbps, Unlimited Data, Cable/ADSL) (Utilities (Monthly))1
S.No Country Cost
1. Ethiopia 189.76 $
2. Rwanda 175.17 $
3. Tanzania 120.31 $
4. Zambia 97.80 $
1https://www.numbeo.com/cost-of-living/country_price_rankings?displayCurrency
=USD&itemId=33®ion=002
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5. Zimbabwe 78.14 $
6. Uganda 68.73 $
7. South Africa 61.60 $
8. Namibia 56.43 $
9. Nigeria 56.07 $
10. Ghana 50.46 $
11. Kenya 46.79 $
12. Algeria 40.07 $
13. Mauritius 35.04 $
14. Libya 23.42 $
15. Morocco 22.73 $
16. Egypt 20.22 $
17. Tunisia 19.57 $
It could be seen from the table above, that in Kenya (a neighbouring
country) the cost of internet bandwidth is 45% cheaper than Uganda. If we
analyse the costs further, it is surprising to note that the cost to get to the
east coast of Africa from Uganda, is expensive than the cost to get to Europe
or USA from the African coast. There are millions of kilometres of fiber optic
infrastructure at the coast of Africa from various countries and these are
grossly underutilised. The African region is connected to rest of the world
through a number of cables embedded in the Indian ocean- some are the
5,000 kilometre TEAMS (The East Africa Marine System) cable; the 8,000
kilometre SEACOM cable (Sea Cable System) ; Eastern Africa Submarine
Cable Systems (EASSy) and WACS cable (West African Cable system). Figure
6 is a snapshot of some of the African undersea cables.
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Figure 6: African Undersea Cables
Though it could be argued that the price of 68$ per Mbps for the internet
bandwidth in the country, is cheaper than what it was, a year before, the
price could be significantly lower with proper infrastructure management.
For comparison, Globally, the price of a basic fixed-broadband connection
fell from around USD 80 per month in 2008 to USD 25 in 2015,
corresponding to a drop in the ratio of price to average GNI per capita from
over 90 per cent to 14 per cent. But in Uganda, a fiber based fixed-
broadband plan is sold at over USD 600 a month whilst ADSL based
broadband is sold at USD 300 making it very expensive and clearly
unaffordable.
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Unfortunately, the country could not capitalise on the WiMAX network it
developed as early as 2013. The local ISP, M/s Foris Telecom, had offered
WiMAX plans at 512kbit/s for USD 14 per month. And in 2015, the
cheapest fixed-broadband plan advertised (based on ADSL) costed USD 300
per month for a speed of 256kbit/s though it fell to USD 37 per month in
June 2016. As could be seen in the following Table-3, during 2015, Uganda
was the third highest amongst the list of countries offering fixed-broadband
network.
Table 3: Countries with highest fixed broadband prices, 2015 2
It is unfortunate that though some ISPs, like M/s Gilat; M/s SEACOM have
ownership of a dedicated fibre cable from Kampala to the African coast (PoPs
connected directly through backhaul links to Nairobi - Mombasa and then to
the international subsea cable network) apart from stakes in the
international fiber, they are reluctant to reduce the bandwidth prices. This
is largely because of insufficient competition and no sharing guidelines
amongst players.
The lowering of backhaul costs could also trigger a number of regional
district level new Internet service providers to enter the market through
sharing of the backbone infrastructure. This will ensure that broadband
reaches to the sub-counties and rural areas. Importantly, in order to ensure
that the goals of SIP are achieved, there is a need for a strong fiber optic
backhaul.
Hence, deploying much denser coverage of terrestrial fibre networks are
crucial for improving access to the international bandwidth which will bring
down the cost of data services.
2 Source: ITU Facts, 2016
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Economic Case
The country’s National fibre backhaul could play a vital role in bridging this
gap. Unless the prices in the backhaul are lowered, the internet costs will
not become economically attractive. The pricing strategy on the existing NBI
network is based on ‘market’ forces and surprising in a number of cases
they remain more expensive than the backhauls offered by some private
providers like M/s Gilat. The reason could be that the operation of NBI is
outsourced to a private firm (M/s Soliton Telmec) while the pricing and
access are governed by the NITA and there are no synergies.
The cost per month per Mbps for a STM-1 (155 Mbps connection), is around
100 dollars in the country. In contrast such backhaul costs in Europe/
USA, costs less than a $ per Mbps per month, though the cost of building
such networks in these countries are several times expensive than building
in Uganda.
But even in the existing network, by maximizing the usage of fibers, the
costs could be significantly brought down. For example, the cost of building
the NBI network was $106M. This backbone is served through a 24 core
fiber cable. Each pair of fibre strands can be broken down to serve multiple
wavelengths (through Dense Wave Division Multiplexing (DWDM)
technology). Depending on the sophistication of the technology used to light
the fibre, one can obtain different wavelengths over the same fiber.
Assuming 64 wavelengths for each pair of fiber, each delivering at least
10Gbps (64 STM-1), the NBI network could carry at least 64 x 64 x 12
STMs. The total cost per STM-1 will be around 2150$. Hence if the costs per
operator for lifetime rights for one STM-1 is brought down to 2150$ plus
annual maintenance cost, it will help in stimulating the market. But this
however requires a proper infrastructure policy to be in place.
Moreover, the service providers utilise only a fraction of their installed
capacity just enough to match the demand, to control capital outlay
resulting in artificial scarcity which are pushing the prices higher. When
building national fibre backbones, they tend to treat it as a competitive
advantage and allow access to it by other new players at a premium. Apart
from this, the infrastructure providers are also continuing to lay new fibers.
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The treatment of all fiber optics backbone as common infrastructure could
thus reduce costs and help in penetration of broadband in remote areas.
Hence with no policy on infrastructure sharing, they can set whatever price
they choose to the extent the market can bear.
Ineffectiveness of the Uganda Internet eXchange Point (UIXP)
The Uganda Internet eXchange Point (UIXP) is a framework for Internet
Service Providers (ISPs) to Peer and Exchange IP traffic with each other. It
allows networks to directly interconnect and freely exchange data traffic at a
common point, thereby reducing the traffic that is delivered via
intermediaries.
UIXP’s infrastructure has not been utilized optimally as many networks and
ISPs have not joined. The total numbers of connections to UIXP from these
ISPs are only 24. A lot of domestic traffic is still not routed through UIXP,
defying the very purpose of setting up UIXP. Hence these functional weak
links need to be addressed to improve the effectiveness of UIXP through an
appropriate policy.
Effective functioning of UIXP can reduce the carriage cost for domestic
Internet traffic to great extent which will facilitate cheaper content download
and encourage local web hosting services apart from stimulating local
content generation.
This will enable domestic bandwidth utilization for routing of domestic
traffic resulting in significant reduction in bandwidth utilization costs apart
from improvement in Quality of Services (in terms of lower latency and
number of hops). This will also enable effective utilization of the
International Internet bandwidth.
Apart from these, the following are some of the effects of an infrastructure
sharing policy:
The Policy could enable infrastructure sharing amongst service
providers for quick enhancement of the service capacity;
The Policy could enable competition as it can stimulate regional
district level players to offer services;
The Policy can help in quick and easy improvement of the network
coverage especially in rural areas;
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The Policy can exert influence on CAPEX and OPEX of service
providers. Service providers can reduce their capital expenditures.
Instead of each service provider constructing their own infrastructure,
service providers could reduce their cost by either jointly constructing
the infrastructure or leasing their existing infrastructure;
Through lowering of infrastructure costs, the policy can help reduce
the usage charges for consumers;
The policy can help reduce the costs on the network construction and
maintenance of ICT service providers;
The policy can help in accelerating the entry of various new service
providers into market;
The policy can help in simplification of the selection process of site
locations and quicken the pace of network construction. The
integration the policy brings amongst service providers will greatly
increase the speed of the network construction and help in putting the
network into operation within the shortest time possible;
The policy can also improve the service level (Quality of service offered)
of service providers;
Because of shared infrastructure, the policy can help in protection of
the environment (because of reduction in consumption of land, energy
and raw materials) and avoid wastage of resources;
The policy can help in enhancing the broadband access level thus
reducing the digital divide;
The policy will enable the service providers to be more focused on
End- User Services and Customer Care, as the coverage area; access
to fiber etc. will become similar for different service providers.
Thus, the infrastructure sharing policy can have a number of benefits for
all stakeholders and for the national economy as a whole.
1.3 TYPES OF SHARING of ICT INFRASTRUCTURE
Infrastructure sharing refers to sharing of all or part of elements of ICT
networks among service providers. Such elements may include ducts,
trenches, towers, pole lines, fiber networks, ONU/ONT, access node
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switches, spectrum, equipment rooms and related power supplies etc.
According to the report of “Six Degrees of Sharing”, ITU, 2008, there are
primarily two types of sharing – passive and active. The policy will enable
both the types of sharing; making the passive infrastructure sharing
mandatory while the active infrastructure sharing is optional left to needs of
the service providers on mutual agreement.
Passive Infrastructure Sharing
Sharing of passive infrastructure means sharing of physical sites, buildings,
shelters, towers/masts, fiber optic cables, power supply, battery backup,
etc. The service providers while sharing sites may share all site related
infrastructure which includes ownership rights or right to-use the site.
Passive infrastructure sharing though simplest still requires consideration of
load bearing capacity of the tower, azimuth angle of different service
providers, tilt of the antenna, height of the antennae, before executing any
agreement.
Active infrastructure sharing:
The active infrastructure sharing can broadly be defined as sharing of active
elements in the network amongst service providers. Active infrastructure
sharing includes sharing of antenna, feeder cables, node B’s, Optical
network unit, transmission equipment and can ultimately include sharing of
spectrums allocated to service providers individually. Common back-haul
sharing also will be useful in rural environment where traffic from BTS to
BSC is very low. A common RF or Optical fiber medium can be utilized. This
will reduce cost and maintenance efforts.
Various approaches to ICT Infrastructure sharing
There could be different approaches towards an effective infrastructure
sharing. In case of fiber networks, optical fibre connectivity is largely
available up to major headquarters and it does not cover all the districts.
The NBI has about 2,324 kms route kilometres of optical fiber covering
around 50 Districts. Hence there is hardly any coverage at the level of many
districts or sub counties. If broadband as envisaged in the SIP is to be
implemented, then arrangements need to be made to aggregate village traffic
and backhaul it to the backbone at the earliest. Once the backbone is ready
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regional district players will pitch for delivery of broadband to villages. The
problem of availability of high bandwidth fibre optic network is not limited to
rural areas. Even in towns and cities, the growth of broadband is also
limited by non-availability of fibre in the aggregation and the access
networks. In these areas, there is a need to deploy various configurations to
take fiber near households; corporate establishments; buildings or units or
to the kerb where a number of discreet houses or customers can be served.
Some of the options for infrastructure sharing are discussed below:
A. Mutual Sharing among Service Providers.
In this type of sharing the service providers are encouraged to voluntarily
share their infrastructure with little or no intervention from either Regulator
or the Ministry.
In urban areas, the government can initiate a programme- Infrastructure
sharing of service providers (ISSP), where all the service providers are
encouraged to mutually negotiate and agree to share the networks. All major
service providers including the infrastructure providers should be members
of this ‘Project ISSP’ This initiative will first concentrate on metros and
subsequently move to smaller cities, towns and villages.
A target needs to be fixed for this programme, monitored by the Ministry,
where it is expected that 20% of the sites of 3G/4G and around 500 km of
fibers are shared by December 2018.
B. Mandatory Sharing among Service Providers
While infrastructure sharing in urban areas is important to control the
mushrooming growth of towers and prevent underutilisation of fibers,
infrastructure sharing in rural area is important to reduce the roll-out cost
and increase expected rate of return on investment. This could be achieved
through mandatory regulatory or policy intervention and with suitable
amendment of the license condition. But such an intervention may retard
the growth of infrastructure and perhaps may be inadequate to address all
the technological and level playing issues.
C. Financial Incentives
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The other option is to encourage infrastructure sharing through a
mechanism of financial incentives. This could be through various modes of
incentives particularly financial to motivate the service provider for sharing
of infrastructure. The existing tower data and fiber optic network of all
service providers are to be plotted on a geographic information system (GIS)
map and the uncovered areas identified. The exact number of towers to be
located in the uncovered area should also be calculated through RF
planning tools after taking into consideration the terrain, topography etc.
The extent of fiber reach in the country should also be mapped and the
uncovered areas located and marked. The extant of common infrastructure
required for tower and fiber network should be identified and could be
funded appropriately. The provision of reliable power supply in rural areas is
another challenge. The operational cost becomes very high to provide
backup power supply in case regular electric supply is erratic. So the policy
should also enable installations of renewable energy technologies.
Based on the above mentioned options, the model envisaged for the current
ICT infrastructure policy is to form an SPV for this purpose.
Special Purpose Vehicle for Infra-sharing
A special purpose vehicle (SPV) to be formed to acquire and pick up strategic
stakes in infrastructure companies, being hived off by service providers and
other independent companies. This SPV will cater only for the fixed wireline
network. 35% of the fibers laid by the service providers in the country to be
mandatorily be provided to the SPV. The SPV will also have the service
providers who have shared the infrastructure as stakeholders with
propionate equity. The SPV will do mapping of the current infrastructure
network including mobile towers and fiber optic cable and calculate the
estimated cost for providing coverage and connectivity across the country
and built such networks. The SPV will have the option of raising fund from
public. The SPV will be run as a separate company. This will ensure proper
funding to fund all infra projects thus ensuring all the uncovered areas are
covered both in terms of coverage and in terms of fiber optic back haul
connectivity. No service provider will be allowed to build their own network
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– either in the back haul or in the last mile unless a certificate of ‘No
Objection’ is provided by the SPV.
In the mobile segment, however the existing passive mobile infrastructure
has to be shared mandatorily amongst the service providers; whilst the
active sharing of the mobile infrastructure will be on mutual basis. Also all
existing 3G carriers will make available an aggregate of at least 30% of their
network capacity for infrastructure sharing through MVNOs.
Common Steps to be adopted
I. The process of sharing infrastructure should be transparent and non-
discriminatory. The SPV and the mobile service providers must
announce on their web site the details regarding the existing and
future infrastructure installations available for sharing. The criterion
for negotiation should be specifically provided in the license
conditions. All licensees should not construct their own infrastructure
till they explore the opportunities for sharing.
II. The licence conditions of service providers should be suitably
amended to allow active infrastructure sharing limited to antenna,
feeder cable, Node B, Radio Access network (RAN) , transmission
system and other active elements. In case of mobile networks, there
will be no major technological issues in active infrastructure sharing
and could carry the combined traffic from BTS to BSC using the
common backhaul or a common OTN/ONU, while still maintaining
individually allocated spectrums or last mile connectivity for access
purpose separately. The active infrastructure sharing arrangements
may be left to service providers based on mutual agreements. The
service provider should indicate the intention of active infrastructure
sharing in transparent and predictable manner.
III. Fibre Optic Backhaul of all service providers including NBI to be
treated as Infrastructure and seamless sharing be allowed. These
networks should be built to ensure that :
a. They should be open access optical fibre network, with long
term plan to connect all district headquarters.
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b. The optical fibre network would sufficiently support backhaul
bandwidth requirement for provision of broadband and facilitate
broadband growth. (the number of cores of fibers and capacity)
c. It should be an enabler to provide fibre to home or kerb in at
least 4 major cities.
IV. The Infrastructure sharing is implemented in accordance with the
following procedure:
a. The first step is voluntary negotiation.
b. The second step is dispute resolution and mandatory.
c. The third step is sharing compensation mechanism;
V. No government body or agency to charge for fiber cable laying or tower
erection; except for the actual cost of reinstatement charges.
VI. For rural and far flung areas, the regulator may through a bidding
process support subsidy for setting the network for three years
through the SPV. Other service providers using the infrastructure
shall pay rentals to the SPV.
VII. Domestic traffic shall either be routed through UIXP or through
dedicated domestic peering of ISPs with International Internet
Bandwidth providers. All ISPs or their upstream providers should
either be connected at UIXP nodes or to International internet
bandwidth provider through separate domestic peering link.
VIII. In case of multi-homing ISP, such ISP will decide one of the upstream
providers to carry domestic traffic to UIXP or to ISP providing
International Internet bandwidth through domestic peering link.
IX. Provision of stringent penalties in the licensing conditions to curb the
tendencies of misuse at any interconnection points by ISPs.
X. The routes declared and accepted by various ISPs be intimated in
advance to UIXP and put on its website under protected folders so
that same can be viewed by UIXP members only. This will help to curb
the possibilities of misuse of UIXP connectivity.
XI. All the ISPs who are providing International Internet IP port in Uganda
shall be permitted to have peering for exchange of domestic traffic
with other ISPs provided such integrated ISPs segregate domestic and
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International traffic using any technique/ technology suitable to them.
This will enable alternate domestic peering points and will bring
competition ultimately benefiting the subscribers.
XII. All data centers to be connected to the UIXP.
XIII. Define QoS Parameters for UIXP.
XIV. UIXP to be reorganized and strengthened with the Government
becoming a member.
1.2.1 Sector Strategic investment plan
The MoICT & NG has also had its Sector Strategic and Investment Plan
2015/16-2019/20 approved by Cabinet. Key among the action areas and
strategic interventions is the ICT Infrastructure development and
management whose objective is to ensure efficiency in coordination,
planning, investment, implementation and utilization of end-to-end ICT
infrastructure.
1.2.2 National ICT Policy
The ICT policy, 2014, under its priority area of Policy and regulatory
frameworks also caters for activities such as expanding ICT infrastructure
and its integration throughout the country. It also has its policy objective
towards establishment of a centralized mechanism to plan, build and
manage all the public communications Infrastructure in a coordinated
manner.
1.2.3 National Development Plan (NDP II)
In second National development Plan (NDP II) 2015/16-2019/20 under the
objective “Improve the legal and regulatory frameworks to respond to the
industry needs”, one of the action areas is to review and develop appropriate
policies, strategies and regulations to keep the sector abreast with
technology developments and market forces/industry demands.
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1.2.4 National Broadband Strategy
MoICT & NG spearheaded the development of the National Broadband
Strategy. The vision for Uganda’s Broadband Strategy is a transformed
middle income economy driven by affordable high quality broadband
connectivity. The overall objective of the strategy is to facilitate uptake of
broadband for socio-economic transformation of the country. Under the
objective of “Guide broadband infrastructure planning, investment and
development”, all the strategies is towards development of a robust
infrastructure.
1.2.5 Sustainable Development Goals (SDG)
All the 17 SDGs are connected to the various focus areas viz sustainable
development, Democratic governance & peace building and climate &
disaster resilience. Clearly a robust ICT infrastructure policy will go a long
way to enable the Country realise equitable development.
It is against this background that the Ministry has developed the National
ICT Infrastructure Policy.
1.3 POLICY, LEGAL AND REGULATORY GAPS
As the network infrastructure, may lead to the reduction of the service
providers’ network construction costs and can also relieve the new entrants
of discrimination because of infrastructure bottle, there are three criteria
based on which the policy could evolve - “Cost-based prices” and “Non-
discriminatory terms and conditions”; and “technical conditions to provide
services”. As infrastructure sharing, can increase the coverage of the
broadband network and the economy, resulting in narrowing the digital
divide, this requires relevant stimulus policies.
Licensing Issues
There is a need to recognize sharing of infrastructure as one such effective
measure for reducing Capex and Opex. …… (License conditions)
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As per the terms and conditions of the licence, the service providers were
initially permitted sharing of “passive” infrastructure viz., building, tower,
dark fibre etc. only, among themselves. In order to reduce input capital cost
of service providers towards fixed infrastructure, thereby facilitating further
reduction in tariff and to enhance the tele density in the rural areas.
Though there is a robust backbone in the form of NBI and also supportive
licensing provisions available to encourage infrastructure sharing, even
passive infrastructure sharing is not widely practised by service providers.
The tower sharing tenancy ratio is 1:1.14 only and in the fiber network there
is no large scale sharing.
The current licensing do not allow active infra sharing, this requires suitable
modifications in the license conditions. If any incentives are proposed those
are required to be made in the licensing terms. To ensure transparent and
non-discriminatory infrastructure sharing changes in license conditions to
be made. Other terms like displaying details of infrastructure, time lines for
infra sharing etc. should also be suitably incorporated in the license terms
and conditions. Provision of stringent penalties to curb the tendencies of
misuse at any interconnection points by ISPs should be part of the license
conditions.
Regulatory
There are currently no guidelines or regulation on infrastructure sharing,
this needs to be developed by the regulator within three months under the
overall policy objectives.
Also, the regulator needs to evolve a mechanism to check the likelihood of
reduction in tariffs as a result of infrastructure sharing and ensure
compliance at regular intervals. Such advantages are generally retained by
service providers unless there is tough competition. The monitoring and
regulating such costs becomes almost impossible since the sharing pattern
is not uniform across the country and between service providers. Hence it is
important to ensure how the substantial advantages to service providers out
of Infrastructure sharing are passed on to subscribers.
Legal
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Infrastructure sharing arrangements may affect the competitive
independence of service providers in the market as a result of the network
integration through such cooperation. The legal position should ensure that
any derived efficiencies do not result in tainting the competitive
environment.
It also has to be ensured that the savings in infrastructure sharing, be
passed on to subscriber. Another legal issue is to ensure that commercial
agreements for the sharing of the site are regulated.
The current law, the Uganda Communications Act of 2013 under section 5
(y) has also vested UCC to encourage and promote infrastructure sharing
amongst licensees and to provide regulatory guidelines under the overall
policy guidelines of the Ministry. Through this section necessary regulations
covering all aspects to be put in place by the regulator within three months.
CHAPTER 2: THE POLICY
2.0 Introduction
The mission, vision and guiding principles of the ICT infrastructure
Management Policy are laid in this chapter. The chapter also lays out the
Policy objectives, Strategies and specific policy action areas.
2.1.2 Principles and conditions for formulation of policies
Infrastructure sharing is crucial for the cost-effective development of ICT
markets - where low urbanisation rates, low consumer spending power and
very limited existing infrastructure make it unaffordable for every service
provider to build their own network. The cost benefit of tower sharing, and
in turn more competitive end-user tariffs for mobile services, has yet to
translate into strong take-up of 3G mobile data services. This is primarily
because of limited backhaul infrastructure, limited 3G/4G coverage outside
major urban centres, and Uganda's landlocked position - which limits
access to international bandwidth capacity. For comparison, Kenya's total
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international bandwidth capacity at the end of June 2015 was
1,663,561Mbps whilst Uganda's was 31,223Mbps.
Analysis of benefits (including social benefits and economic benefits) from
sharing of network infrastructure has always been a major concern of the
industry. As the infrastructure sharing varies in frame mode, shared items
and operation modes, it is very difficult to obtain the same result in the
analysis of benefits from sharing of network infrastructure. Infrastructure
sharing can have a positive impact on universal service, environmental
protection, reduction of network construction costs, as well as acceleration
of new entrants’ entry into the market and preparation time.
Regulatory framework
2.1 Policy Vision
The Vision of the Policy is
“A Digitally Empowered and informed society through Efficient Use
of ICT infrastructure”
2.2 Policy Mission
The Mission of the Policy is
“To ensure that ICT infrastructure is built efficiently, economically, rationally
and utilised optimally and non-discriminatorily”
2.3 Guiding Principles
To enhance socio-economic growth and transformation and increase the
affordable broadband penetration in the country, the National ICT
Infrastructure Management Policy shall be guided by the following
principles:
a) Treat ICT infrastructure as National Asset;
b) Ensure that the ICT infrastructure is shared transparently without
any discrimination and on cost based sharing;
c) Treat all fiber backhaul of the service providers as infrastructure and
ensure efficient and rational use of the network;
d) Ensure efficient and optimal use of UIXP nodes;
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e) Stimulate growth of full MVNOs in the network;
f) Ensure digital documentation of the ICT infrastructure.
2.4 Policy Objectives
The objectives of this Policy are to:--
2.5 Policy Strategies
Policy objective 1: Building efficient, economic and rational ICT
Infrastructure across the country. (Fiber infra; tower infra; active infra)
Strategies:
I. Ensure that sharing of passive infrastructure amongst service
providers are mandatory; whilst the sharing of active infrastructure is
on mutual basis amongst the service providers;
II. Ensure that fibre Optic Backhaul of all service providers including NBI
to be treated as Infrastructure and be treated as a national asset; A
SPV with stakeholders from service providers be established, with
35% of all fibers laid by service providers to be mandatorily
transferred.;
III. Ensure through a bidding process subsidy support for setting up the
network in unviable areas, to be used by all service providers;
IV. Establish national roaming framework amongst all service providers;
V. Ensure that all infrastructure sectors develop suitable guidelines for
installation of common ICT infrastructure like :-
a. Road / Rail construction authorities/agencies/funded Projects
must include, in their construction design policy, a provision for
a ICT utility duct;
b. City developers and builders should include demarcated
sections in their building design for ICT infrastructure
(including lead-in ducts);
c. Government bodies or agencies to charge only mandatory
license fees and/or actual cost of reinstatement charges for
developing ICT infrastructure.
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Policy objective 2: Non-discriminatory and optimal use of ICT
infrastructure.
Strategies:
I. Establish a sharing infrastructure framework that is transparent,
non-discriminatory; includes dispute settlement mechanism and an
assessment mechanism;
II. Ensure that the regulator, acting as coordinating agency issues
suitable directions timely for infrastructure sharing amongst service
providers taking the following facts into consideration: -
a. whether the facility is a bottleneck facility;
b. whether the facility can be reasonably duplicated or substituted;
c. whether the facility is critical to the supply of service by the
licensees;
d. whether the facility has available capacity having regard to the
current and reasonable future needs of the licensee or person to
whom the facility belongs;
e. whether joint use of the facility encourages the effective and
efficient use of telecommunications infrastructure;
f. the costs, time, penalties and inconvenience to the licensees
and the public of the alternatives to shared provision and use of
the facility;
III. Ensure that all stakeholders, periodically, announce on their web site
details of their existing and future infrastructure installations
available for sharing;
IV. Ensure that licensees do not construct their own infrastructure till
they explore the opportunities for sharing;
V. Develop a price determination principle for infrastructure sharing;
Policy Objective 3: Digital transformation of the ICT infrastructure
records.
Strategies:
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I. Establish and maintain a Geo-mapped database of all ICT
infrastructure in the country (Fiber optic cables; towers etc.); A portal
linked to this database be developed, within three months, portraying
the ICT infrastructure of the country.
II. Establish a framework for updating the Geo-mapped database when
new infrastructure is added or modified by stakeholders;
III. Establish an open source real time sharing of infrastructure datasets
to facilitate sharing between the service providers;
Policy Objective 4: Establishing an efficient UIXP.
Strategies:
I. Reorganize and strengthen UIXP with Government as a member;
II. Ensure that all ISPs or their upstream providers be either connected
at UIXP nodes or to International internet bandwidth provider through
separate domestic peering link for routing domestic traffic;
III. Ensure that all ISPs providing International Internet IP port in Uganda
shall be permitted to have peering for exchange of domestic traffic
with other ISPs provided such integrated ISPs segregate domestic and
International traffic using any technique/ technology suitable to them;
IV. Ensure that all data centers are connected to the UIXP.
2.6 POLICY TARGETS
a) Set up the SPV by 2018;
b) Establish the framework for national roaming on common
infrastructure by 2018;
c) Establish mandatory guidelines for establishing infrastructure in
establishments, buildings, overhead cables, construction of
towers/masts and right-of- way issues by 2018 ;
d) Create an working group for network sharing to guide and coordinate
the ICT infrastructure sharing and decide the relevant major issues
sharing guidance within three months;
e) Create suitable dispute settlement mechanism and price
determination principles within six months;
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f) Create a geo-mapped database of all ICT infrastructure and
transparently share the details within six months.
g) Establish the sharing infrastructure framework within six months.
h) Ensure that the ISPs connect to the UIXPs or the international
bandwidth provider within the framework defined within six months.
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CHAPTER 3: IMPLEMENTATION FRAMEWORK
3.0 Introduction
The successful achievement of the National ICT Infrastructure Policy will
depend on an integrated approach during implementation supported by
developing strategic synergies and partnerships. This implies that clear
definition of the roles, responsibilities and functions of all the stakeholders
must be made.
3.1 Institutional Framework
The following institutions are important in creating a favourable and
enabling institutional framework that will drive the coordination and
implementation of the Policy.
3.1.1 Ministry of Information and Communications Technology &
National Guidance
The Ministry of ICT shall be responsible for the overall oversight and
coordination of implementation of the Policy. Specifically, the Ministry shall:
a. Where necessary, coordinate the review, development and
implementation of relevant laws relating to infrastructure and ensure
that they are in tandem with regional and international best practices;
b. Provide guidance on good leadership and direction to the Regulator in
execution of its mandate;
c. Undertake public awareness at all levels through expos, forums,
conferences and other forms of stakeholder consultations;
d. Ensure that the policy is implemented within the time frame;
e. Ensure the setup of SPV.
3.1.2 Uganda Communications Commission
The Uganda Communications Commission (UCC) is an independent
Regulator, first established under the Communications Act of 1997. It is
mandated with the responsibility of promoting and regulating
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communications services in the country under the policy guidelines of the
Ministry. In implementation of this policy, UCC shall be responsible for the
following:
a. Provision of an enabling regulatory framework for all stakeholders;
b. Ensure the effects of infrastructure sharing is passed on to the
subscribers;
c. Act as a coordinating agency amongst service providers for
infrastructure sharing;
d. Ensure proper pricing strategy and dispute resolution mechanism to
be in place; and
e. Ensure that the there is adequate information available to
Government, operators and consumers on all matters relating to
infrastructure in Uganda transparently.
3.1.3 National Information Technology Authority – Uganda
The National IT Authority (NITA-U) is Government body established under
the NITA-U Act 2009 to coordinate, promote, regulate and monitor the
development of Information Technology (IT) in the context of social and
economic development of Uganda. In implementation of this policy, NITA-U
shall be responsible for the following:
a. Provision of an enabling regulatory framework to create standards and
guidelines for infrastructure layouts;
b. Become an active partner in the SPV;
c. Provision of an enabling regulatory framework for updating the Geo-
mapped database in digital records;
d. Provision of an regulatory framework for open source real time sharing
of infrastructure datasets between stakeholders;
e. Provision of suitable framework for efficient working of UIXP.
3.1.4 National Environment Management Authority (NEMA)
The National Environment Management Authority (NEMA) is a semi-
autonomous institution, established in May 1995 as the principal agency in
Uganda, charged with the responsibility of coordinating, monitoring,
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regulating and supervising environmental management in the country. In
implementation of this policy, NEMA shall be responsible for the following:
a. Provision of suitable guidelines for shared infrastructure.
3.1.5 Parliament
The role of Parliament in the effective implementation of this policy shall
include among others:
a. Where necessary, enacting appropriate and effective legislations that
will create a flexible, dynamic and responsive legal and regulatory
environment to support the implementation of the Policy;
b. Facilitate the allocation and approval of financial resources for
implementation of the Policy;
c. Monitor the effective utilization of financial resources allocated to
public sector institutions for the implementation of the Policy; and
d. Ensuring that good governance principles are applied and adhered to
in the implementation of the Policy by public sector institutions.
3.1.6 Cabinet
Cabinet is the highest policy making organ of the Government and is
therefore responsible for determining, formulating and implementing the
policy of Government. Cabinet collectively, and Ministers individually, have
a primary duty to ensure that Government policy best serves the public
interest.
In this regard, Government shall:
a. Provide visionary and catalysing leadership at the highest level of
Government to Support the implementation of the Policy
b. Ensure development and implementation of sector-based
Implementation/Action Plans to mainstream the provisions of the
policy in National Development Plans and other strategic frameworks;
c. Mobilise resources especially for programmes targeted to implement
this Policy.
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3.1.7 Operators
Operators include both Government and private users of the infrastructure,
including all license service providers. The users are generally expected to
cooperate with the Regulator and the Ministry in all aspects during
implementation of this policy.
Specifically, their envisaged roles are as follows:
a. Participate and support Government in local, regional and
international forums where matters related to infrastructure are being
discussed;
b. Take advantage of business opportunities resulting from the
implementation of this policy;
c. Ensure timely updates of their existing infrastructure on their web
sites and
d. Support development of human resources to be compliant with the
new Policy and regulatory framework.
3.1.8 The people
Uganda is a country with a population with diverse incomes, education,
races and cultures. The people of Uganda shall be responsible for the areas
below during the implementation of the Policy:
a. Fair use of ICT infrastructure.
3.2 Monitoring and evaluation
3.2.1 Introduction
This Policy has been designed to meet all its objectives in five years. As
such, a monitoring and evaluation framework has been developed to guide
in monitoring and evaluation of the Policy. The Policy shall be subjected to
short term annual reviews and a long-term review at the end of the five-year
period. A detailed implementation plan is placed at Annexure- A.
The MoICT & NG shall monitor and evaluate the Policy together with other
relevant stakeholders as mentioned in the implementation framework of the
Policy. The Office of the Prime Minister shall also play its Constitutional role
of monitoring and evaluation of the implementation of this Policy.
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3.2.2 Methodology
The following three methodologies shall be used to monitor and evaluate
implementation of the Policy.
3.2.2.1 Assessment of impact
Assessment at the impact level should be able to assess the extent to which
the Policy has contributed to the social transformation of Ugandans. And
also ensure that the policy targets are achieved.
3.2.2.2 Monitoring and assessment of outputs
The monitoring and evaluation framework will track and assess the
effectiveness of the Policy by monitoring the progress towards achieving the
desired objectives.
3.2.2.3 Monitoring and assessment of Implementation
The monitoring and evaluation framework will assess the efficiency of
implementation of the Policy by checking the following:
i) Whether there are sufficient human, financial and institutional
resources to implement the policy;
ii) Whether the implementation is according to plan; and
iii) Whether the overall objectives of the policy have been achieved.
Annexure – A : Policy Development Roadmap
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2