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Community Networks 19 March 2018

Unleashing Community Networks: Innovative Licensing Approaches DRAFT

This document is a discussion draft for community input with partners. We welcome feedback and any case-studies that colleagues and Chapters would like to contribute to improve the document. Comments can be sent to Konstantinos Komaitis ( and Jane Coffin ( by 30 March 2000 UTC.


The Internet Society (ISOC) aims to make the Internet available for everyone, everywhere.i ISOC works with industry, government, academia, and other organizations worldwide to support innovation and growth of the open Internet. For over 25 years, ISOC has helped to connect individuals in virtually every country to the Internet.

After more than 25 years of Internet development, there still remains a profound connectivity “gap” in many parts of the world, particularly in developing nations, leaving over half the global population without Internet access.ii 3.58 billion people currently have Internet access—meaning that over half of the world’s population remains unconnected.iii This connectivity “gap” exists in urban, rural, and remote unserved and underserved areas of many countries, particularly developing and least-developed countries.iv

The consequences of being unconnected are well documented.v Internet access enables socioeconomic development, and those without access are left behind, facing tremendous competitive and economic disadvantage. Better connectivity and the exchange of information strengthens democratic processes, spurs economic growth, and enables sharing of culture and ideas in ways previously unimaginable. Accordingly, the United Nations seeks, as part of its sustainable development goals, to “significantly increase access to information and communications technology” and “strive to provide universal and affordable access to the Internet in least developed countries by 2020.”vi

To address this issue, some communities are building their own networks to connect to the Internet. These networks complement existing commercial infrastructure, providing additional access points that can help bridge connectivity gaps. Policymakers can assist these communities through innovative changes in licensing, permitting, tax and fee, compliance, universal service, and spectrum policies. By employing common sense regulatory and policy reforms, Government can unleash the potential of community networks and allow unserved and underserved areas to realize the transformative benefits of having access to affordable connectivity.

Key Considerations

What is a community network?

Community networks refer to telecommunications infrastructure deployed and operated by a local group to meet their own communication needs.vii They are the result of people working together, combining their resources, organizing their efforts, and connecting themselves to close connectivity and cultural gaps.

Unlike the traditional, “top-down” commercial approach, community networks originate from the ground up. Deployment starts from the end user or the “last mile” and builds out to connect with an Internet gateway. This “bottom-up” approach marks a key distinction between commercial and community networks. Commercial networks in no way replace commercial networks. Rather, they provide a complementary service by offering local access where commercial networks find it is not economically viable to operate.

Several hundred community networks exist in unserved and underserved areas worldwide.viii They may be built and managed by individuals, local nongovernmental organizations, private sector entities, and/or government bodies, and they usually operate on a cost-recovery basis. Community networks are often small in scope and typically serve communities of under 3,000 residents. However, some networks can serve multiple neighboring communities.ix

Unconnected areas or areas without access to affordable connectivity benefit most from community networks. Where commercial networks with limited services do reach such communities, community networks provide a complementary service. Community networks often emerge where the existing coverage is unaffordable or of low quality, or where there is no coverage at all.

Why Are Community Networks Important?

Economic and social benefits can be brought to communities worldwide to reduce the “digital divide.”x Internet access is a key factor driving opportunity and success in today’s global economy. Benefits include access to electronic commerce and telehealth services, distance learning, social and political engagement, government services and public safety information, and much more. Connectivity underpins contemporary societies, and community networks bring connectivity to those otherwise excluded because of geography, topography, size, or income level.

Community networks enable local development. They help keep profits local—generally reinvesting any proceeds in the local community and its network. Community networks also empower people and encourage civic participation.xi Giving people choice and control, they make the Internet user centric.xii

Challenges and Guiding Principles

Policymakers are urged to consider the benefits of community networks and reduce or eliminate barriers to community network development. Doing so may help Governments achieve important universal connectivity goals. Community networks face a myriad of challenges: lack of affordable access to backbone infrastructure, barriers to entry (e.g., business and/or service licensing, regulatory fees and taxes, spectrum access), high deployment costs, and limited funding, including difficulty in obtaining universal service funding, among others.

This policy paper explores these challenges in detail below and offers guidance and real-world solutions for addressing these barriers. This paper first discusses barriers that hinder efforts to begin constructing networks at the outset. Next, this paper highlights the importance of spectrum availability and suggests innovative policy solutions to ensure access for community networks. Policymakers should look to these examples when considering how community networks can allow the unconnected to connect.

Startup Barriers Can End Community Network Ventures Before They Begin

Common start-up and organization costs can be detrimental to community network ventures. Unlike for-profit, commercial entities, community networks often lack the resources and wherewithal to navigate complex legal requirements and associated costs.

  • Registration, Licensing, Permitting, and Compliance. Many countries require operators to register their business and subsequently apply for a license to provide service. Operators often must also obtain permits and other authorizations before constructing their network.

These often require operators to file applications (and pay application fees) with multiple agencies. The applications are often difficult for the layperson to complete. Furthermore, application requirements, though well-intentioned, may inadvertently disqualify community networks. For example, some jurisdictions require applicants to satisfy a minimum net worth requirement to demonstrate their ability to deploy the network. India, in some instances, has required applicants to demonstrate a net worth of at least Rs 100 crore ($15.4 million) to participate in spectrum auctions.xiii Others require collateral, which many community networks are not able to supply as they start-up.

Once completed, processing times can take months or even years—time these communities remain without service. Compliance requirements, including onerous reporting obligations, can further hinder community network initiatives. Complying with these requirements may detract from limited time and resources needed to get nascent community-built networks off the ground.

  • Taxes, Regulatory/Licensing, and Import Fees. Countries often lack access to telecommunications equipment and end-user devices, especially equipment and devices built to withstand extreme heat and cold, tropical and dust storms, and other weather conditions. Equipment is therefore often imported from abroad. This can be expensive and subject to high duties, taxes, and customs fees.

Regulators frequently assess application fees, entry fees, and licensing fees to spectrum holders. These fees often prevent communities—many serving fewer than 3,000 end users—from obtaining spectrum. Fixed fees, as opposed to variable, income-based fees, can be particularly costprohibitive for community network operators.

  • Financing. Deploying, maintaining, and operating a community network can be costly, especially for very poor and rural communities in developing nations. For some, it is a choice between investing in a community network or other necessities like food or healthcare.

Community network operators need initial capital to procure equipment and other resources to develop the underlying infrastructure. These communities often lack access to an electric grid or other reliable power source and must therefore invest in developing a power infrastructure.xiv Power costs can account for more than 70 percent of capital expenses.xv Backhaul costs—namely the costs of connecting the community network to the network core—are also high.xvi

Communities frequently depend upon universal service program funds, in addition to private grant programs, to help defray some of these costs. Yet many countries do not offer any financial support. Of those that do, universal service funds are often misspent or left unused. In African countries Benin, Kenya, Rwanda, Togo, and Uganda, for example, an estimated $59 billion remains unused or has been diverted for other purposes.xvii In South Africa, you must be licensed in order to eligible for Universal Service and Access Fund (USAF) funding.xviii India has only used 30 percent of fees collected for its universal service fund since establishing the fund in 2003.xix Without wellmanaged universal service or other financial support, many community networks never come to fruition.

Governments Can Ease or Eliminate These Barriers through Common Sense Reforms

Opportunities abound for policymakers and thought leaders to alleviate many of these burdens, which are often costly, unnecessary, and contrary to the public interest. Community networks are only successful if connectivity is not only available, but also affordable. Governments should therefore consider the following reforms:

  • Easing Regulatory Requirements. The existing regulatory landscape—developed for large, for-profit telecommunications companies—does not work well in the community network context. Governments should consider creating enabling regulations and polices to specifically address not-for-profit operators and small-scale operators.

Countries should streamline onerous regulatory requirements, such as annual reporting requirements and other unduly burdensome requirements designed to address market dominance by larger, commercial providers.

Governments should promote infrastructure sharing and access to rights of way policies that allow smaller networks to share infrastructure and build out infrastructure in a more cost-effective manner.

  • Tax and Fee Exemptions. Governments should similarly exempt community networks from various tax, regulatory and licensing, and import fee requirements. Such fees are difficult for small, non-profit community network operators to afford and can delay or prevent their development.
  • Enhanced Transparency. Regulators can greatly assist community networks by providing clear guidance on the specific policies and regulatory requirements (and exemptions) for community networks. This information is often not easily accessible, especially for communities without Internet access, or not widely known.
  • Expanding Universal Service and Other Public Funding Opportunities. Countries without a universal service program should establish a fund, and those with an existing fund should expand the program to include additional funding for community networks. Universal service programs—when properly funded and employed—have proven to be tremendously successful. For example, even though underutilized, India’s universal service program has helped provide more than 2.6 million broadband connections in rural and remote areas. In Malaysia, the universal service program has helped to raise the broadband penetration rate from 20% to over 53% in three years.xx

In addition to universal service, governments should also consider identifying additional funding opportunities specifically for community networks. This could entail a separate grant program, support for public-private partnerships, or low-interest loan opportunities.

For example, the United States Community Connect Program provides grants to help fund community broadband deployment in rural areas where it is not yet economically viable for private sector providers to deliver service. Rural areas lacking access to broadband speeds of at least 4 Mbps downstream and 1 Mbps upstream are eligible to apply.xxi

As another example, the European Union (EU) has set aside €120 million to provide free wireless Internet connections by 2020 to up to 8,000 municipalities in the EU in areas with no Internet coverage.xxii And Canada’s “Connect to Innovate” program will invest $500 million to connect 300 rural and remote communities by 2021.xxiii

Access to Spectrum is Another Challenge for Community Networks

In addition to the general entry barriers identified above, communities often face difficulties identifying and accessing spectrum necessary to support their networks. Common barriers include spectrum scarcity, inefficient use of spectrum, and expense of spectrum access.

  • Spectrum Scarcity. The scarcity—or perceived scarcity—of spectrum and highdemand can deter policymakers from allocating spectrum for community networks. Although spectrum is a finite resource, technologies have evolved that make previously unusable spectrum attractive to operators. Many experts would encourage policymakers to focus on efficiently managing this public resource, rather than on its limits.
  • Inefficient Use of Spectrum. The traditional regulatory approach to spectrum licensing has been to authorize broad licenses on an exclusive basis. Exclusive-use, as opposed to shared-use, licenses vest one licensee with exclusive access to an assigned swath of spectrum. Many licenses cover broad geographic areas, even if the service provider lacks the economic incentive to deploy its network throughout the entire licensed area. This inefficient use can result in lack of coverage in some areas and decreased competition in others.xxiv
  • Expense of Spectrum Access. Spectrum access can come at a high cost, especially where regulators auction spectrum rights to the highest bidder or impose high license fees. These are forms of market gatekeeping. Because of the sizable investments commercial operators make, they frequently demand exclusive use of the spectrum. Although it can be tempting to view spectrum auctions as an opportunity to generate revenue, Governments should focus on putting spectrum to its highest and best use. Doing so ensures long-term benefits for end users and serves the public interest.
Innovative licensing models can help community networks access spectrum

Spectrum access is essential for the success of any community network. The types of networks and technologies employed vary. Some networks are Wi-Fi, Global System for Mobile Communications (GSM) 2G networks or based on Television White Space (TVWS) technologies. They can connect to the Internet core using a variety of backhaul technologies, including wireless, satellite, or fiber.

Community networks require access to spectrum to operate. Ensuring adequate spectrum enables communities to reap the social and economic benefits of information and communications technologies.

Policymakers can facilitate community access to spectrum through innovative licensing solutions, such as social-purpose licensing, license exemptions, unlicensed or “license free” use, secondary use and dynamic spectrum sharing, and secondary market transactions. In each approach, regulators should pursue technology neutral policies to provide communities ample flexibility to develop networks tailored to serve their unique needs.

Licensing Approaches

  • Social Purpose Licensing

One example of innovative licensing is a “social purpose” license. This is a license granted in rural unserved or underserved areas to non-traditional network operators, such as community network operators. By setting aside spectrum for non-traditional operators, regulators can remove the competitive barriers to spectrum access and prioritize spectrum for social-use purposes. Although a relatively new form of spectrum management, social purpose licensing has proven to be tremendously successful in launching community networks.

Mexico is at the forefront of innovative, social purpose licensing. In 2015, the Mexican communications regulator, Instituto Federal de Telecomunicaciones (IFETEL), amended its frequency plan to set aside 2 x 5 megahertz of spectrum in the 800 MHz band for “social” use.xxv To qualify for a social use license, applicants must demonstrate that the spectrum would be used to service communities of 2,500 people or less, or communities located in a designated indigenous region or priority zone.

IFETEL’s bold reforms have already resulted in dozens of new community networks. Non-profit organization Rhizomatica, for example, relies on social purpose licensing to develop community networks in indigenous regions around Oaxaca, Mexico—areas that have typically garnered little interest from incumbent operators.xxvi

  • Experimental Licensing

Experimental licenses are another way provide communities direct access to spectrum. Experimental licenses authorize the licensee to test and develop new technologies and services, while protecting incumbent services against harmful interference. Before setting aside spectrum for social use, Mexico’s IFETEL awarded experimental licenses to organizations like Rhizomatica for community networks.xxvii

India has also issued experimental licenses for community network projects. In 2016, for example, the Indian government issued eight experimental licenses in the 470-582 MHz band to carry out experiments of Television White Space-type rules and regulations.xxviii These licenses enabled the Dynamic Spectrum Alliance (DSA) to study whether spectrum below 1 GHz could be authorized on an unlicensed or lightly-licensed framework in India, as it is in Malawi, Ghana, Singapore, the Philippines, the United Kingdom, and elsewhere. DSA Executive Director Professor H Sama Nwana observed that “[t]he 470-582 MHz band will be key to bridging the digital divide in India, a country with more than 800 million people who are not connected to the Internet, 68% of which are living in rural areas.”xxix

Although experimental licenses may be a good entry point, they are not a permanent solution. Experimental licenses are generally temporary, lasting often for a period of months of years. Governments that employ experimental licenses for community network initiatives should therefore develop avenues to transition experimental licenses to a permanent licensing framework. This would provide important guarantees necessary to encourage long-term investment in the network.

  • Spectrum Auction Credits

Governments may also adopt reforms that reduce or eliminate barriers to communities seeking access to licensed spectrum. For countries that license spectrum via auction, policymakers should consider providing auction bidding credits for community networks with adequate safeguards to prevent abuse.

To encourage marketplace competition, for example, the United States routinely awards bidding credits to small businesses, rural telephone companies, and businesses owned by members of minority groups and women to participate in spectrum auctions.xxxIn the 2017 600 MHz Broadcast Incentive Auction, for example, the U.S. Federal Communications Commission provided a 15% bidding credit to rural service providers. Over 50 rural carriers participated in the auction and, saving nearly $18 million in credits, secured low-band spectrum for rural networks.xxxi Without these credits, these businesses would find it much harder—if not impossible—to compete for spectrum with commercial operators.

License Exemptions and Unlicensed Use Approaches

As an alternative to social purpose licensing, regulators can exempt social purpose users from licensing requirements or permit social purpose services in designated unlicensed spectrum.

  • License Exemptions

Brazil has eliminated licensing requirements for providers with fewer than 5,000 users.xxxii Eligible “Private Limited Service” providers must notify the government of their intent to provide service and comply with certain equipment authorization rules. However, they are not required to obtain a service license. In Nigeria, private use of Wi-Fi spectrum is exempt from licensing fees and requirements, but commercial use is not.xxxiii In South Africa, operations in the 5725-5875 MHz Industrial, Scientific and Medical Apparatus band are exempted for all uses.xxxiv These and similar approaches could work in other countries as well—freeing small community networks to operate on a largely unrestricted basis subject to reasonable protections for incumbent operators.

  • Unlicensed Spectrum

Separate from license exemptions, which release specific operators or services from otherwise applicable licensing rules, unlicensed spectrum is spectrum available for use without a license or license exemption. Users may operate in this spectrum with minimal regulatory requirements and without the need to pay the high costs of obtaining a spectrum license, subject to power limits and other conditions intended to mitigate interference to other services. Unlicensed users generally lack exclusive use of the spectrum and may be subject to interference from other users of the spectrum.

Countries across the globe are continuing to examine appropriate use cases for license exemptions and unlicensed use. Spectrum in the 5-6 GHz range was allocated for unlicensed use during the 2003 International Telecommunication Union World Radio-Communication Conference.xxxv The United States, United Kingdom, and Canada, among others, have since taken steps to authorize these frequencies on an unlicensed basis.xxxvi

The European Commission has also proposed that its member states identify spectrum in the 2.4 GHz and 5 GHz bands for unlicensed use, which resulted in an increase of Wi-Fi spectrum in most EU-member states.xxxvii The European Commission further recommended allocating the 433-434 MHz band for unlicensed use, as did Australia, Malaysia, New Zealand, and Singapore. xxxviii China has expanded unlicensed use to include the 5150-5250 GHz and 5250-5350 GHz bands.xxxix

In India, the Supreme Court held that spectrum could be allocated on a license-exempt or unlicensed basis as long as the policy is “backed by a social or welfare purpose,” such as using connectivity to increase social and economic inclusion.xl Organizations like the Digital Empowerment Foundation (DEF) have since established wireless community networks using unlicensed spectrum in the 2.4 GHz and 5.8 GHz bands in remote areas in the Indian states of Madhya Pradesh, Meghalaya, Assam, Rajasthan and Uttarakhand.xli DEF’s Wireless for Communities (W4C) program has helped to build over 100 wireless mesh networks in rural and remote communities across India, connecting more than 4,000 people.xlii

Wi-Fi access technologies in unlicensed spectrum bands have also helped to connect communities in other parts of the world. In South Africa, for example, non-profit initiatives Zenzeleni and Project Isizwe use Wi-Fi to deliver affordable broadband access in unserved and underserved areas.xliii The world’s largest community network, Spain-based, serves more than 50,000 users using predominately Wi-Fi service.xliv

Unlicensed spectrum can also be used to support non-Wi-Fi-based technologies. In 2013, the Netherlands allocated 5 megahertz of spectrum in the 1800 MHz band for unlicensed GSM operations using low-power, femtocell base stations. Within three years, over 3,000 organizations established their own private GSM networks, and the government freed up additional spectrum for such use.xlv

To provide maximum flexibility for community network operators, unlicensed spectrum opportunities must be technology neutral. Unlicensed spectrum is often synonymous with Wi-Fi spectrum, but it can also be used with GSM, TVWS, and other technologies and services. Policymakers should therefore pursue a technology neutral approach to unlicensed spectrum.

Secondary Use and Dynamic Spectrum Sharing Approaches

  • Secondary Use

Advancements in spectrum sharing allow for more efficient use of spectrum and create greater opportunities for community access networks, which could operate on a secondary basis in already-licensed spectrum to connect unserved or underserved areas.

In 2002, the United States initiated a proceeding to permit unlicensed devices to operate in unused spectrum between television channels—known as television white spaces (TVWS)—on a secondary basis. xlvi In addition to providing separation needed to prevent interference between co-frequency or adjacent television channel operations, this ultra-high frequency spectrum can simultaneously support certain broadband operations. TVWS initiatives have started to appear around the world.

Microsoft has backed numerous TVWS initiatives, including Citizen Connect in Namibiaxlvii and Project Kgolagano,xlviii which have successfully connected large portions of northern Namibia and Botswana respectively. Similarly, Google supported the Cape Town TVWS Trial in South Africa in 2013, which utilized a database that calculated channel availability to avoid harmful interference.xlix

In Malawi, the regulator partnered with a university to conduct a TVWS trial, connecting hospitals and schools in rural areas where there is limited or no broadband service available through commercial operators.l And in Mesetas, Colombia, TVWS technology has helped to connect five farms and two educational

  • Database-Driven, Dynamic Spectrum Sharing

Some countries are exploring increasingly innovative ways to share spectrum, known as “dynamic spectrum sharing.” In the 3550-3650 MHz band, the United States has adopted a new Citizens Band Radio Service (CBRS), in which 150 megahertz of spectrum currently occupied by incumbent users— in this case the U.S. Department of Defense and commercial Fixed Satellite Service—is shared on a secondary and tertiary basis with priority access and general access users through a Spectrum Access System.lii Using automated techniques, the Spectrum Access System will facilitate the coexistence of disparate systems that would otherwise require separate bands to avoid interference. The European Union is examining a similar proposal for licensed, shared access in the 2.3 GHz band.liii

Modern technologies, such as orthogonal frequency-division multiple access, spread spectrum, frequency hopping, beam division multiple access, fixed-mobile convergence, ultra-wide band, and software-defined radio technologies further facilitate spectrum sharing. But, complex spectrum access systems are not necessary to leverage the benefits of dynamic spectrum sharing. Mobile handsets exist today that can identify spectrum activity and automatically select unused spectrum.liv

Policy makers should allow and create incentives for spectrum sharing by supporting spectrum sharing research and testing of new devices and services. Regulators should also ensure that each spectrum user’s rights and obligations are clearly defined, and that multiple uses of the spectrum are compatible.

Secondary Markets

Policymakers, in addition to providing direct access to spectrum for community networks, should facilitate indirect access through secondary market transactions. Secondary market transactions increase the efficiency of spectrum usage, and by adopting policies that support secondary market transactions, governments can enable spectrum leases and other arrangements that place spectrum in the hands of communities.

Incumbent service providers often lack the economic incentive to build out their networks in rural communities and those located in mountainous and other geographically challenging regions. These communities are therefore often left unserved. Network operators, however, might be willing to share their licensed spectrum with community networks through a lease or other secondary market agreement. In Rwanda, for example, wholesale service provider Vanu Rwanda sells spectrum access to companies like Airtel Rwanda, which are committed to serving rural areas. Vanu Rwanda intends to establish a total of 376 sites, reaching approximately one million unserved Rwandans.ll

Flexible licensing policies can also allow for community-based networks to partner with incumbent operators to provide service for profit. Open Cellular, which is controlled by Facebook, is partnering with existing operators to develop community cellular networks in Pakistan, Indonesia, Iraq, and the Philippines. lvi Many incumbent service providers, despite investing heavily in network deployment, find it challenging to build out last mile connections in certain rural and low-density communities. By working in partnership, community networks and service providers together can bridge the digital divide. Regulators should consider developing incentives to encourage incumbent licensees to allow lowcost, secondary market access to community operators.

Regulators could, for example, credit licensees for the deployment of the lessees. In other words, if the regulator imposes geographic or population coverage milestones on the incumbent licensee, it could credit the licensee for the community network coverage enabled by the sharing of spectrum.


Policymakers and regulators can help reach the next 1 billion unconnected people through innovative changes and through community network initiatives, helping to close the digital divide. To unleash the full potential community networks, policymakers should consider innovative ways to license community networks and provide meaningful access to spectrum. This includes:

  • Streamline or Eliminate Onerous Regulatory Requirements, especially those that are not applicable to small, community-based networks.
  • Provide Tax, Customs, Regulatory, and Licensing Fee Exemptions. These fees and duties are difficult for community network operators to afford and can delay or prevent their development.
  • Enhance Transparency. Regulators should provide clear, public guidance on the specific policies and regulatory requirements (and exemptions) for community networks.
  • Expand Universal Service and Other Public Funding Opportunities, and publicize that community networks are eligible for funding.
  • Pursue Innovative Approaches to Providing Spectrum Access, such as:
    • Direct Licensing of Community Networks, including social purpose licensing, experimental licensing, and providing spectrum auction credits;
    • License Exemptions and Unlicensed Use;
    • Secondary Use and Dynamic Spectrum Sharing; and
    • Secondary Market Transactions.

Additional Resources

Internet Society, Policy Brief: Spectrum Approaches for Community Networks (Oct. 10, 2017),

Ritu Srivastava, Community Networks: Regulatory Issues and Gaps-Experiences from India (Oct. 5, 2017),

Carlos Rey-Moreno, Supporting the Creation and Scalability of Affordable Access Solutions: Understanding Community Networks in Africa (May 23, 2017),

Carlos Rey-Moreno, First Summit on Community Networks in Africa Report (Jan. 12, 2017),

Community Connectivity: Building the Internet from Scratch, Annual Report of the UN IGF Dynamic Coalition on Community Connectivity (Luca Belli ed., Dec. 2016),

The netCommons Project, Report on Existing Community Networks and Their Organization, Version 1.0 (Oct. 12, 2016),

Internet Society, A Policy Framework for Enabling Internet Access (Sept. 14, 2016),

1 World Connected—Data-Driven Research to Bring Billions Online, Case Studies,

Oliver, Miquel and Salas, Francisco, TV White Space as a Feasible Solution to Spread Mobile Broadband (March 31, 2017),


i The Internet Society’s goal supports the United Nations Sustainable Development Goal of achieving universal and affordable access to the Internet. See Sustainable Development Goal 9, United Nations Sustainable Development Goals,

ii Internet Society Global Internet Report 2017: Paths to Our Digital Future, Internet Society, at 79 (2017),

iii International Telecommunication Union, The State of Broadband: Broadband Catalyzing Sustainable Development, at 10 (September 2017),

iv See Leandro Navarro, et al., Advances in Wireless Community Networks with Community-Lab Testbed, at 1 (2016),

v See World Bank, World Development Report 2016: Digital Dividends (2016),; United Nations, Press Release: Closing Digital Divide Critical to Social, Economic Development, Delegates Say at Second Committee Debate on Information and Communications Technology (Oct. 28, 2015),; Internet Society, Policy Brief: Spectrum Approaches for Community Networks (Oct. 10, 2017),; Ritu Srivastava, Community Networks: Regulatory Issues and Gaps—An Experience from India (Oct. 5, 2017),; Vassilis Chryssos, Building a Sustainable Community Network in Sarantaporo Greece (Feb. 10, 2018),

vi Sustainable Development Goals, United Nations,

vii See Dynamic Coalition on Communication Connectivity,

viiiSee The netCommons Project, Report on Existing Community Networks and Their Organization, Version 1.0 (Oct. 12, 2016),

ix See Community Connectivity: Building the Internet from Scratch, Annual Report of the UN IGF Dynamic Coalition on Community Connectivity, at 11 (Luca Belli ed., Dec. 2016),; Internet Engineering Task Force (IETF), Request for Comments (RFC) 7962 on Alternative Network Deployment.

x See Ericsson Mobility Report (June 2017),

xi See Kathryn Brown, MWC Shanghai Keynote: “Bridging the Connectivity Gap” (June 29, 2017),; Raúl Echeberría, Every Connection Matters—Shape Tomorrow and Help Close Digital Divides (Oct. 5, 2017),

xii See Rajnesh Singh, Experiencing the Internet’s Role in Community Empowerment, Internet Society (Dec. 14, 2016),; Internet Society, A Journey Through Digital Empowerment in Rural India (Dec. 11, 2013),

xiii DNA India, Telecom Panel Says Companies Need to Have Rs 100 Crore Net Worth to Participate in Airwave Auction (Jan. 5, 2015),

xiv See, e.g., Nyani Quarmyne and Kevin Granville, Hauling the Internet to an Ex-Soviet Outpost High in the Caucasus Mountains, New York Times (Jan 5, 2018),; Internet Society, Clearing a Path to the Outside World (2017),

xv Carlos Rey-Moreno, Internet Society, Supporting the Creating and Scalability of Affordable Access Solutions: Understanding Community Networks in Africa, at 38 (May 23, 2017),

xvi Some estimates suggest that backhaul service could cost as much as $1,000 per megabit per second for an Asymmetric Digital Subscriber Line. See id.

xvii Alliance for Affordable Internet, Are Universal Service Funds Being Used to Close the Online Gender Gap? (May 10, 2017),

xviii Electronic Communications Act No. 36 of 2005, Section 88 (“The money in the Universal Service and Access Fund must be utilized exclusively for the payment of subsidies . . . to any broadcasting service licensee and electronic communications network service licensee for the purpose of financing the construction or extension of electronic communications networks in underserviced areas as prescribed . . . .”).

xixBusiness Standard, Telecom Firms May Soon Pay Less for Universal Service Obligation (Sept. 9, 2014),

xx Intel, The Benefits of Applying Universal Service Funds to Support ICT/Broadband Programs, 3, 4 (2011),

xxi United States Department of Agriculture, Rural Development, Community Connect Grants (2017),

xxii EURACTIV, EU Agrees to Fund Free Wi-Fi for European Towns with No Internet Coverage (May 30, 2017),

xxiii Government of Canada, Press Release: Connect to Innovate (Oct. 6, 2017),

xxiv Testimony of Erin P. Fitzgerald, Regulatory Wireless Counsel, Rural Wireless Association, Inc., before the U.S. House of Representatives, Committee on Small Business, Subcommittees on Health and Technology and Agriculture, Energy, and Trade, 1-4 (Mar. 6, 2018),

xxv Instituto Federal de Telecomunicaciones, Agreement by Which the Plenary of the Federal Telecommunications Institute Modifies the Annual Programme of Use and Exploitation of 2015 Frequency Bands (June 4, 2015),

xxvi See Rhizomatica, So Much Going On! (Jan. 14, 2015),

xxvii See The Economist, DIY Telecoms (Mar. 5, 2015),

xxviii Dynamic Spectrum Alliance, Press Release: Dynamic Spectrum Alliance Welcomes the Indian Government’s Issuing of Eight Experimental Licenses in the 470-582 band for TV White Space Trials (Mar. 17, 2016),

xxix Id.

xxx See FCC, Updating Part 1 Competitive Bidding Rules, WT Docket No. 14-170, FCC 15-80 (rel. July 21, 2015),

xxxi Testimony of Erin P. Fitzgerald, Regulatory Wireless Counsel, Rural Wireless Association, Inc., before the U.S. House of Representatives, Committee on Small Business, Subcommittees on Health and Technology and Agriculture, Energy, and Trade, 3 (Mar. 6, 2018),

xxxii Anatel, New Regulation of Restricted Radiation Equipment Approved (June 26, 2017),

xxxiii Steve Song, A Look at Spectrum in Four African Countries, Many Possibilities (March 31, 2014),

xxxiv See Steve Song, Open Spectrum for Development South Africa Case Study, Shuttleworth Foundation, Association for Progressive Communications, at 10 (Oct. 2010),

xxxv International Telecommunication Union, WRC-03, Resolution 229 [COM5/16] (2003),

xxxvi Ritu Srivastava, Community Networks: Regulatory Issues and Gaps-Experiences from India, at 28-29 (Oct. 5, 2017),

xxxvii Id.

xxxviii Id., at 29.

xxxix Id.

xl Dynamic Spectrum Alliance, Press Release: Dynamic Spectrum Alliance Welcomes the Indian Government’s Issuing of Eight Experimental Licenses in the 470-582 band for TV White Space Trials (Mar. 17, 2016),

xli Telecom Regulatory Authority of India, Consultation Paper on Proliferation of Broadband through Public Wi-Fi Networks, No. 14/2016, at 14-15 (July 13, 2016),

xlii Ritu Srivastava, Community Networks: Regulatory Issues and Gaps—An Experience from India, at 24 (Oct. 5, 2017),

xliii See Submission by Zenzeleni Networks NPC in Conjunction with the Association for Progressive Communications and the University of the Western Cape (Jan. 31, 2018),

xliv – The technological project, (Dec. 19, 2016),

xlv OECD, New Approaches to Spectrum Management, No. 235, at 28 (Jan. 2014),

xlvi See FCC, White Space,

xlvii White Spaces Database, Microsoft,

xlviii Project Kgolagano, Worldwide Commercial Deployments, Pilots, and Trials, Dynamic Spectrum Alliance,

xlix See Studies on the Use of Television White Spaces in South Africa: Recommendations and Learning from the Cape Town Television White Spaces Trial, Tertiary Education and Research Network of South Africa, at 7,; Craig Wilson, Inside SA’s ‘White Spaces’ Broadband Trial, TechCentral (Jan. 10, 2013),

l See C. Mikeka, et al., Malawi Television White Spaces (TVWS) Pilot Network Performance Analysis, Journal of Wireless Networking and Communications, at 27 (2014); Studies on the Use of Television White Spaces in South Africa, at 30.

li MAKAIA, Internet Access in Schools and Fincas of Mesetas, Meta (Nov. 10, 2017),

lii See FCC, 3.5 GHz Band/Citizens Broadband Radio Service,

liii See European Commission, Radio Spectrum Policy Group: RSPG Opinion on Licensed Shared Access, RSPG13-538 (Nov. 12, 2013),

liv See Shaddi Hasan, et. al, GSM White Spaces: An Opportunity for Rural Cellular Service, Electrical Engineering and Computer Sciences University of California at Berkeley, No. UCB/EECS-2013-198 (Dec. 8, 2013),

lv IT Web Africa, Connectivity as a Service Rollout in Rwanda (Feb. 27, 2017),

lvi USAID, Closing the Access Gap: Innovation to Accelerate Universal Internet Adoption, at 47-49 (Feb. 2017), See, e.g., Endaga, Inc., Customer Profile: Airwave Missions Papua, Indonesia,

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