From: Brian Longwe [mailto:[log in to unmask]]
Sent: 14 December 2000 16:43
To: [log in to unmask]; [log in to unmask] Eaia. Org; [log in to unmask]
Eaia. Org; [log in to unmask]
Subject: [eaia] KIXP - revised statement - the real thing
The second time the attachment was there, I promise... maybe it got stripped
of by Telkom as it flew past the satellite at Longonot on it's way to the
US, Singapore and back! :-)
Anyway, I've pasted the text below. You should get it now.
Thanks and sorry for the wasted bandwidth :-(
Statement by TESPOK on the Kenya Internet Exchange Point
Certain sections of the press have quoted CCK officials and, more
specifically, the Director General of the CCK in regard to the
Telecommunications Service Providers of Kenya (TESPOK) and the recently
closed Kenya Internet Exchange Point (KIXP). This statement hopes to make
the facts surrounding KIXP known and chart a way forward for the development
of the Internet in Kenya.
TESPOK was launched 12 months ago as a non-profit association to represent
the interests of ISPs and other value added telecommunications services.
Our aim was to further the growth of Kenya’s Internet society. During that
time there have been many changes in the industry, not least of which has
been the increase in licensed ISPs from 8 to 47.
Necessity for a Local Traffic Exchange
One of the key items on TESPOK's agenda has been an effort to address the
long standing problem of e-mail and web traffic from one ISP to another
going out over international links and being exchanged overseas, sometimes
traversing two or more continents to get to a correspondent across the
street. The solution to this problem came in the form of a proposal to
establish a Kenyan Internet Exchange Point (KIXP).
Currently all traffic, local and international has to be routed over
Jambonet circuits. The cost of a Jambonet Internet circuit is vastly higher
than that of a local Kenstreams digital link, ISPs are paying dearly for
local traffic that is using their international links (between 200-400
Megabits a day).
Bandwidth Jambonet Kenstreams
64K US$ 3,375 US$ 200
256K US$ 6,750 US$ 375
512K US$ 9,546 US$ 650
Efforts made by TESPOK
1) 3-12-1999: TESPOK wrote to the Manager, Data Services, Telkom Kenya
informing him of the plans for KIXP and requesting Telkom Kenya to host
KIXP. There was no response to this communication.
2) TESPOK's Chairman then sought an audience with Telkom Kenya's General
Manager for Operations & Maintenance during which the request was repeated.
TESPOK's request was denied.
3) TESPOK held consultations (among the ISPs) and decided to identify a
suitable, neutral location to host the KIXP. Failing to locate an ideal
location TESPOK rented offices in Bruce House, Nairobi for this purpose.
4) 19-7-2000: TESPOK wrote a letter to the Director General, CCK, to confirm
verbal discussions concerning KIXP.
5) CCK wrote back to TESPOK on July 31st, 2000 requesting a meeting with
TESPOK officials for "further consultations".
6) TESPOK's Chairman met with CCK's General Manager, Telecoms Development
and went into the details of the KIXP proposal. CCK gave every assurance
that KIXP did not require a license and did not in any way infringe upon
Telkom Kenya's monopoly.
7) There was a second meeting between TESPOK's Chairman, Cisco Systems, and
CCK's General Manager, Telecoms Development on November 24th in which the
CCK General Manager affirmed the approval of KIXP. Cisco Systems would not
have initiated work nor proceeded work on the KIXP unless there was local
regulatory approval. The meeting on the 24th was held to answer any further
questions or concerns CCK held on the IXP. None were given.
8) TESPOK proceeded to implement KIXP which went live with four ISPs
exchanging traffic. TESPOK Announces the KIXP launch.
9) TESPOK's chairman received a call from Telkom Kenya's GM Operations and
Maintenance during which he threatens to to shut down KIXP.
10) 24-11-2000: TESPOK's Chairman wrote to the CCK to confirm the previous
discussions, and notify the Director General that KIXP was now operational.
11) 30-11-2000 & 4-12-2000: CCK officials visit the KIXP. On the second
visit speaking with the Chairman of TESPOK, who explains the functionality
of KIXP. The officials seem satisfied with the fact that KIXP is not
violating any laws or monopolies.
12) 7-12-2000: CCK writes to TESPOK demanding the immediate closure of KIXP
and by copy of the same letter instructing Telkom Kenya to disconnect all
ISP lines to the KIXP and to "provide all the internet backbone services
including local e-mail and other similar services for which KIXP was
intended to provide".
Interpretation of the Kenya Communication Act, 1998
An Internet Exchange Point (IXP) is a "meeting place" for ISPs where they
can exchange local traffic without having to pass this traffic over costly,
slower international links. Each ISP pays for their circuit and router into
the IXP datacenter. Local Area Network (LAN) technology is used to
interconnect each ISP's router. Since an IXP is in one way a Local Area
Network (LAN) and another way a 'closed user group,' readings of the Kenya
Communications Act indicated that the KIXP did not need a license. To affirm
this reading, TESPOK held several meetings with CCK during which there was a
confirmation that the KIXP did not need a license. If indeed ethernet LANs
need a licence then by extension every corporate, government office, and
educational institute are breaking the law by operating LAN's without a
Proposed way forward
In acting in this manner, CCK has clearly placed Telkom Kenya's interests
before those of the consumer (the public), the service providers (ISPs) and
the Government, (as there are many Government agencies that are serviced by
local ISPs). All of these stakeholders are missing out on the benefits
associated with local traffic exchange. There is a need for greater dialogue
on KIXP and other concerns that TESPOK have brought before the CCK such as
limitations of Telkom’s access network, unreliable Jambonet, delays in
leased line connections among others.
The recent occurrences have raised much alarm both in local as well as
international circles as they are indicative of "heavy-handed" regulation
where expert opinion is not sought, vested private interests are preferred
over public interests and power is misused.
Telecommunications Service Providers of Kenya
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