Consultation paper on_regulations_for_infrastructure_sharing in_telecommunications_industry

Consultation paper no. 1 of 2014
CONSULTATION PAPER ON INFRASTRUCTURE
SHARING FRAMEWORK.
October 2014
1 | P a g e Consultation paper on Regulations for Infrastructure Sharing in Telecommunications Industry - 2014

TABLE OF CONTENTS
CHAPTER SUBJECT PAGE NO.
1 INFRASTRUCTURE SHARING: AN
INTRODUCTION
5
2 FORMS OF INFRASTRUCTURE SHARING 8
3 INFRASTRUCTURE SHARING POLICY
OPTIONS AND TRENDS
18
4 PROPOSED APPROACH FOR
INFRASTRUCTURE SHARING IN ZIMBABWE
26
5 LICENSING AND REGULATORY ISSUES 30
6 GENERAL TERMS AND CONDITIONS FOR
INFRASTRUCTURE SHARING
36
Annex A LIST OF CONSULTATION QUESTIONS ON
INFRASTRUCTURE SHARING FRAMEWORK
40

PREFACE
The Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ) has
the responsibility under the Postal and Telecommunications Act 2001 to ensure access
to reliable, reasonably priced and modern telecommunication services to the greatest
number of people as far as practicable. The past five years have witnessed rapid
growth in telecommunications industry as evidenced by the mobile penetration ratio of
106.4% as at first quarter 2014 and broadband penetration of 43.1%. Operators
continue to invest rapidly in order to keep abreast with changes in technology trends
and consumer needs. Large investments in 3G networks, 4G and other Next
Generation Networks (NGN) are being undertaken by Fixed and Mobile Operators alike.
However revenues from these investments are still some time away, and are also being
threatened by new over -the –top (OTT) services that are riding on these networks.
Increasing or maintaining the remarkable growth of the ICT sector calls for the
construction of infrastructure requiring significant investment. Such investment
requirements mean that operators can only realise gains from the investments by
charging high tariffs. This can be self-defeating as consumers may end up not affording
the services thereby rendering the investments unviable. This calls for strategies that
ensure the optimum utilization of existing and new infrastructure.
The Zimbabwe Agenda for Sustainable Social and Economic Transformation
(ZIMASSET) blueprint has identified infrastructure and utilities as one of the critical
clusters that shall spur economic growth for the country. In the spirit of ensuring the
success of the ZIMASSET, it has become pertinent for the country to come up with a
framework that facilitates the maximum utilization of utility assets without necessarily
duplicating infrastructure where existing infrastructure can be shared and utilised at
much lower costs.
To this end, and recognizing the fact that access to affordable broadband services has
become a key driver of a country’s competitiveness and economic growth, POTRAZ
has identified infrastructure sharing based on a model of open access as the panacea
to most challenges currently being faced in the ICT sector. It is envisioned that an

infrastructure framework based on an open access model, will go a long way towards
the attainment of universal access to broadband and other ICT services on a reliable
basis and at affordable prices in line with technological developments.
It is in this vein that POTRAZ has come up with this consultation paper on Infrastructure
sharing aimed at soliciting the views of concerned stakeholders on forms and
modalities of such a framework. In case of any clarification/information, please contact
Mrs. Hilda Mutseyekwa. Stakeholders are requested to send their comments and views
on the various issues addressed in the consultation paper by 30 November 2014 to:
The Director General
POTRAZ
Block A
Emerald Business Park
30 The Chase
P.O. Box MP843
Mt Pleasant
Harare

CHAPTER 1: INFRASTRUCTURE SHARING: AN OVERVIEW.
1.1 WHAT IS INFRASTRUCTURE SHARING?
In general, the term infrastructure sharing refers to the sharing of basic physical
structures, services and other resources necessary for the operation and functioning of
telecommunication networks. The main reason for infrastructure sharing is to maximize
the use of existing and future network facilities aimed at reducing unnecessary
infrastructure duplication thereby saving on both capital and operating expenditures for
operators.
1.2 STAKEHOLDER BENEFITS OF INFRASTRUCTURE SHARING
From studies that were done in other countries, a range of benefits accrue to the ICT
stakeholders if infrastructure sharing is implemented. Some of the benefits are listed
below:
 Benefits to Operators: Infrastructure sharing provides opportunities for
significant reduction in investments or capital expenditure. Industry sources cite
that passive infrastructure sharing can potentially yield overall cost savings as
much as between 15% and 30%, with clear cost savings on yearly site capital
expenditure of up to 60% (notably due to less investment duplications) in addition
to significant savings in operational expenditure (mainly costs of renting the sites,
site maintenance, personnel and power, air conditioning and fuel expenses). For
new operators, sharing provides a significant opportunity to reduce time to the
market in as much as it is a reduction in market entry barriers.
 Benefits to Consumers: Infrastructure sharing benefit consumers by
increasing the availability of telephony service, accelerating the pace of network
rollout, increasing consumer choice and reducing the cost of services.
 Increased Competition Benefits: Infrastructure sharing may stimulate
competition by lowering the entry barriers for new entrants thus increasing the
possibility of new players coming into the sector. One of the main impediments to
market entry in the sector is the cost of network deployment. Sharing allows
operators to enter the market at a much lower cost than what they would
encounter if they were required to construct their own network infrastructure.

Sharing also helps to overcome barriers to competition such as the control of
bottleneck facilities by dominant operators.
 For dominant operators, there will be a shift from coverage competition to service
based competition. As operators focus attention and resources towards service
provision, the consumers also benefit immensely from increased service choice,
quality of service and prices.
 Risk reduction: With infrastructure sharing, risk is spread across all sharing
parties thus a substantial risk reduction is achieved. A reduction in risk has a
strong bearing on cost of capital.
 Environmental benefits: Site and mast sharing can substantially reduce the total
number of masts in a given geographical area. Sharing power and air
conditioning equipment will also substantially reduce the total power consumed at
a site, thereby reducing utility as well as pollution mitigation/reduction costs.
 Regulatory benefits: Universal service is one of the key objectives of POTRAZ.
Infrastructure sharing can help expand services for the reach of all including to
seemingly uneconomical areas such as rural areas and resettlement areas where
people are sparsely populated and average revenue per user (ARPU) levels are
low. This has an important policy dimension in that it can meaningfully speed up
universal access to services at a much lower cost thereby reducing the required
Universal Service Fund (USF) levy which comes as an additional cost to
consumers.
 Optimal usage of scarce finite resources: Another important aspect of network
sharing from the regulator’s perspective is the optimal usage of scarce national
resources, such as spectrum resources and rights of way. The sharing of rights
of way leads to a significant reductions in the cost of civil works on one hand, and
makes the planning and management of servitudes easier on the other.
Question 1: Do you agree with the above general views on benefits of
infrastructure sharing which the Authority buys into? If not please provide
reasons.

1.3 FACTORS THAT INHIBIT INFRASTRUCTURE SHARING
Studies have shown that while infrastructure sharing has picked momentum in both
developed and developing countries, a number of impediments still exist particularly in
the emerging markets. Some of the factors that inhibit infrastructure sharing are listed
below.
 Coverage as a competitive tool: Operators who perceive coverage as their
competitive tool are less likely to go into voluntary sharing. To stem this inhibitor
there may be need for regulatory intervention in the form of mandates or sharing
guidelines.
 Monopolistic tendencies among big players: Often big players in the market
have access to strategic sites and rights of way. Denying new entrants or small
operators’ access to such resources tends to slow down new entrants network
deployments. Regulatory authorities may find it necessary to provide direction
when such monopolistic behaviour is detected.
 Operator Asymmetry: Operators may fail to enter into infrastructure sharing
agreement due to difference in technology and site quality.
 Personnel issues: In cases where a joint venture company is created personnel
issues such as labour laws, staff resistance and transformational issues may
impede progress on establishing sharing agreements.
 Asset management Model: Without a properly crafted asset management
model, infrastructure sharing may fail to take off. All legal and commercial issues
about the jointly owned or shared assets need to be comprehensively covered.
 Regulatory Regime: Regulations in place may not allow infrastructure sharing.
Question 2:
a. Do you agree with the above views on factors that may inhibit
Infrastructure sharing? If not please provide reasons.
b. In your view which of the above factors are possible impediments to
infrastructure sharing in Zimbabwe and how best can they be addressed?

CHAPTER 2: FORMS OF INFRASTRUCTURE SHARING
2.1 INTRODUCTION
Infrastructure sharing can take a number of forms based on the degree of sharing that
is permissible depending on the existing licensing and regulatory frameworks as well as
national priorities. In broad terms, infrastructure sharing can be based on the passive
elements of a telecommunications network which is often referred to as “Passive
infrastructure sharing” or can be based on the active elements also referred to as
“Active infrastructure sharing”. The table below illustrates the passive and active
elements of a telecommunication network.
Passive Components Active Components
1. Sites
2. Towers
3. Shelter and support cabinet
4. Electrical supply
5. Air-conditioning equipment
6. Diesel/electric generator
7. Easements and roads
8. Premises
9. Access road
10. Ducts
11. Dark fiber
12. Rights of way
13. Civil and engineering works
1. Base station
2. Microwave radio equipment
3. Switches
4. Antennas
5. Transceivers

2.2 PASSIVE INFRASTRUCTURE SHARING
Passive infrastructure sharing entails the sharing of non-electronic infrastructure
facilities. It includes sharing of physical sites, buildings, shelters, towers / masts, electric
power supply and battery backup, grounding / earthing, air conditioning, security
arrangement, poles, ducts, trenches, right of way. There are many forms of passive
infrastructure sharing options available to operators for implementation. These include
mast sharing and site sharing as illustrated below:
2.2.1 Site Sharing/Collocation
Under site sharing /co-location arrangements, operators share the premises on which
their facilities are installed. Each operator builds their own infrastructure including
masts, antennae, cabinets, generators and feeder cables. The savings on operational
expenditure from the collocation variant of site sharing are derived from site rentals,
security, rights of way, road construction, and power supply to the site and civil works.
This is the simplest mode of site sharing with minimal chances of disputes between
service providers and ease of exit from sharing the arrangement for operators.
Implementation of site sharing may sometimes pose challenges in cases where
property rights of existing sites are unresolved. This may in some cases be exacerbated

in situations where the legal framework is not sufficiently robust to allow firms to have
confidence in the enforceability of contracts and agreements signed between them and
where there is a general lack of confidence in the legal system.
2.2.2 Tower Sharing
Tower or mast sharing is a more advanced and more cooperative form of site sharing.
Under a basic tower sharing arrangement operators use the same tower to mount their
antennae. However each will build their own equipment cabinets and will install their
own access infrastructure including the BTS, air conditioning and backup power supply
as well as backhaul equipment. Tower sharing requires consideration of load bearing
capacity of the tower, azimuth angle of different service providers, tilt of the antenna,
and height of the antennae before implementing the agreements.
In cases where service providers sharing a tower have the same azimuth orientation
requirement, there is bound to be a technical limitation. The height of the antenna
mounting and tilt of the antenna are also very important parameters.
While new towers can be built taking into consideration the ultimate load bearing
capacity required, some of the existing towers may not have been designed to cater for
the combined load of antennae of service providers sharing the tower resulting in
unsuitability of such towers for sharing.
The feasible number of antennae per tower is also a limitation. For example, in cases
where operators are using different technologies requiring different antennae systems,
the number of antennae required may make it impossible for one tower to
accommodate several operators. This means that infrastructure has to be designed
keeping in view the ultimate requirement including those of other service providers
interested in sharing the infrastructure. Tower has to be designed for higher load
bearing capacity and base space requirement among others. All this will change the
tower specifications, which will have direct impact on selection of sites as well as the
foundation for erection of such towers.
2.2.3 Comprehensive site sharing

A much deeper form of site sharing is when operators share the full set of passive
infrastructure at the cell site. This form of sharing is often referred to as comprehensive
site sharing. Under this arrangement operators share all passive site elements
including civil engineering works, tower, shelter, air conditioning, cable trays and
standby batteries or generators.
2.2.4 Passive Backhaul Sharing
The backhaul is often referred to as the black hole in telecommunications as it is
responsible for a significant percentage of network total costs. As traffic processed by
the base stations increases most networks in Zimbabwe are turning to optic fibre as the
backhaul connecting the BTS back to the BSC and on the other lap the BSC back to the
MSC. The backhaul offers great opportunities of savings through infrastructure sharing.
This section discusses various options available to operators for creating synergies in
this area.
2.2.5 Rights of Way
In telecommunications, Rights- of-way refers to the easements, or strips of land that
operators get usually along public roads for installation of their equipment. Rights-of-way
are a scarce resource thus it is not practicable for all operators to have such a
resource along the same route. Operators are normally required to pay for rights of way
to the owners of rights of way who may be municipal authorities, rural district councils,
provincial councils, and any other government authority like railway companies. These
bodies often apply very different rules and procedures to obtaining rights of way. The
processes for obtaining these rights may be very slow and not always subject to clear
procedures. This creates a lack of transparency for potential investors and has the
overall effect of slowing down plans that might otherwise be implemented relatively
quickly.
Time taken in digging up roads to lay network equipment usually add significantly to the
chaos and disruption of the process, particularly in urban areas if rights of way are
granted randomly. Also, if each operator has to buy rights of way separately, the total
cost may become horrendous. If rights of way are shared, operators will share the
rentals or acquisition costs thereby reducing costs.
2.2.6 Duct Sharing

A more advanced sharing model in the backhaul section is the sharing of ducts. Under
this arrangement operators use the same duct to run their cables. They may also
choose to share manhole along the route and power supply at repeater points. Duct
access or duct sharing can reduce or eliminate this capital cost which in essence is a
huge barrier of entry to Greenfields.
Many commercial and operational models are available for the sharing of ducts and
other passive elements within the backhaul section of the network. Commercial
models of duct sharing include:
a. Shared investment at the time of survey, procurement, dig and ducting. The
backhaul project is managed as a joint venture.
b. Expression of interest at the time of dig followed by duct purchase or lease. The
relationship is mainly a master/ slave arrangement.
c. Duct purchase or lease after dig.
d. Sharing of operational costs.
Operational models of sharing include:
a. Joint or shared network planning
b. Unrestricted access to manholes and equipment rooms
c. Managed access to manholes and equipment rooms.
2.2.7 Tower Companies
Infrastructure provision by tower management companies is emerging as the most
popular form of infrastructure sharing. This involves the construction or acquisition of
infrastructure by one company which is then leased to other operators on a wholesale
basis. The main reason why this model is gaining popularity is increasing competition
amongst various operators which makes mutual sharing and joint construction of
network facilities is the cheaper way to roll out services. It is difficult to conclude and
manage due to conflict of interest and suspicion among operators. The model also
enables quicker and cheaper service roll out for competing operators.
Three main business models are turning out to be the most commonly used in setting
up of tower companies. The most common model is where an individual operator

owning a site or other network resources provides access to the use of its site and
network resources to other operators. This type of model is mostly applicable for the
sharing of existing infrastructure.
The second model entails a consortium of operators jointly building a site or a network
that is jointly shared. This is mostly applicable for infrastructures to be built in the future.
The third model entails independent Telecommunications infrastructure network
facilities companies constructing infrastructure for lease to network service providers.
This is increasingly becoming the most popular mode of sharing particularly in countries
that have adopted converged licensing frameworks.”
Question 3: a. Do you agree with the description of the above forms of
passive infrastructure sharing?
b. Are there any other forms of passive sharing that are possible between
operators? If any give details.
2.3.0 ACTIVE INFRASTRUCTURE SHARING
Active infrastructure sharing is a deeper form of infrastructure sharing where operators
share active elements of the network. It includes sharing of Base Transceiver Station
(BTS) / Node B; spectrum; antenna; feeder cable; microwave radio equipment; billing
platform; switching centres; routers; Base Station Controller (BSC) / Radio Network
Controller (RNC); optical fibre / wired access and backbone transmission network. The
issues involved in relation to active sharing are more complex and sharing
arrangements are often difficult to exit as compared to passive infrastructure sharing.
2.3.1 Radio Access Network (RAN) Sharing
RAN sharing entails the sharing of radio access network equipment which includes
antenna, feeder cable and transmission equipment. In simple terms, it is the sharing of
the hardware portion of the RAN with separate management of the logical part
(software) and use of frequencies. Under such sharing arrangements, two logically
distinct base stations/ Nodes share one physical unit. Each operator remains in control

of their equipment and spectrum resources assigned to them. The Core Network is not
shared in this model.
In the case of 2G technology, multiple operators can share all site equipment except
transceivers. Accordingly, each shared base station will have two sets of transceivers,
one using operator Xps frequencies and another one using operator of arties will also
share feeders, antennas, and other ancillary and transmission equipment.
In general, RAN sharing arrangements are technically complex to implement as
operators may find it difficult to negotiate on issues to do with hardware upgrades of the
network to add capacity or functionality as the requirements of the service providers
sharing the network may differ.
RAN sharing may have adverse effects on quality of service (QoS) due to reduction of
the signal strength. This may result in poor coverage and may reduce signal strength to
such an extent that fulfilment of quality of service parameters may not be possible in
some pockets.
2.3.2 Common back-haul sharing
Common back-haul sharing will be very useful in rural environment where traffic from
BTS to BSC is very low. A common RF or Optical fibre medium can be utilized. This will
reduce cost and maintenance efforts. Exit from such sharing arrangements can easily

be provided if it is warranted at a later phase due to increase in traffic or other
administrative reasons.
2.3.3 Spectrum Sharing
Spectrum sharing entails the simultaneous usage of a specific radio frequency band in
a specific geographical area by a number of separate licensed operators enabled
through mechanisms other than traditional multiple- and random-access techniques.
Subscribers are able to access the services of their respective operators through all the
frequencies that are shared in the access network. In essence, this means merging
spectral ranges from different spectrum owners into a common pool without requiring
any changes to the actual licensed system.
The goal of spectrum pooling is to enhance spectral efficiency by overlaying a new
mobile radio system on an existing one without requiring any changes to the actual
licensed system. However, this may call for a completely new way of spectrum
allocation.
In some cases of spectrum sharing, an operator can lease a part of its spectrum to
another operator on commercial terms. This mechanism is common in the US, Europe,
Singapore and Australia.
Sharing or pooling of spectrum is the most complex form of active sharing. Unless
service providers have very close association/coordination, such models cannot be
successful. Ensuring quality of service and other parameters may be very difficult. Such
models do not provide an easy exit path in case of disputes arising between service
providers. From a regulatory perspective, it is generally viewed that spectrum sharing
reduces competition.
2.3.4 Core Network Sharing / MVNO
It entails sharing of the core network where capacity exists in an existing operator’s
core transmission ring, switching centre and core network logical platforms.

Core network sharing may pose technical limitations with regards to the technology
platform of the operator and the standards employed by the equipment vendor. This
likely to be the case with 2G networks and GPRS which traditionally have been
specified and designed on a circuit switched architecture and are not as flexible as 3G
networks which are more flexible for interworking with other IP-based systems.
2.3.5 Mobile Virtual Network Operators (MVNOs)
Generally, core network sharing is the model sharing which facilitates the operation of
mobile virtual networks (MVNs). Under such arrangements, the mobile virtual operator
(MVNO) does not have its own infrastructure but rides on another operator’s network to
provide services using its own subscriber database and survives on buying minutes in
bulk from the network operator and using its own brand to sell the minutes to
subscribers.
The MVNO model is the most cost saving infrastructure sharing model. However, it
should be noted that the deeper the sharing the more complicated the relationship
becomes and the more concerned the regulator should be with regards to competition
issues.
2.3.6 Geographical Splitting/ Network Sharing
This occurs where a network infrastructure is created expressly for the purpose of
sharing resources. For example, in Sweden 70% of the country is covered by a shared
network built as a joint venture between Telenor Sweden (originally Vodafone Sweden)
and HI3G (Hutcheson Investor). When a user is in one of the main cities his calls are

carried by the native network infrastructure of Telenor or HI3G while outside the cities
his call roams onto the shared network provided by 3GIS.
2.3.7 National Roaming
Under National roaming arrangements subscribers of two competing networks within
the same country are allowed to roam onto a host network if the home network is not
present in a particular location. Under such arrangements, operators can compensate
for lack of presence and offer users contiguous coverage and service using the same
handset and SIM. This is particularly useful in areas of low subscriber density,
particularly remote underserved areas where investment in a dedicated site by each
operator may not be viable.
Question 4:
a. In your opinion, should active infrastructure sharing be encouraged? Give
reasons for your answer.
b. Given the various forms of active infrastructure sharing described above,
which ones do you think are most suitable for the Zimbabwean case.
Please provide reasons for your choice. You are free to suggest a hybrid of
various forms of sharing.
c. In your view, do you consider the option to licence Mobile Virtual Network
Operators (MVNOs) as a viable option to encourage active infrastructure
sharing in Zimbabwe?
d. What other modes of active infrastructure sharing will be useful in the
Zimbabwean scenario? Suggest actions which you feel necessary to
encourage such sharing.

CHAPTER 3: INFRASTRUCTURE SHARING POLICY OPTIONS AND
TRENDS
3.0 INTRODUCTION
A regulator may decide to mandate, encourage and approve infrastructure sharing
arrangements. Such regulatory decisions are usually made after analysing the
competitive impact of sharing in line with national priorities and good regulatory
principles such as transparency, efficiency, non-discrimination and independence.
3.1 Mandatory Infrastructure Sharing.
Mandatory infrastructure sharing is commonly applied on passive sharing of sites, poles
and masts. In general, mandatory site sharing is mainly triggered by the limited
availability land suitable for setting up masts as well as environmental considerations.
Other considerations for mandatory site sharing include the need to cut capex and opex
with a view to reduce end-user charges as well as speeding up network roll outs
thereby increasing competition. Passive infrastructure sharing is normally considered
not to materially affect competition because operators retain control over their own
networks.
Initially, site and mast sharing was only mandated in a limited number of countries, such
as Cyprus, India (limited to Delhi and Mumbai) and Norway (limited to incumbent
operator Telenor offering co-location). Of late, mandatory passive infrastructure sharing
has spread to Asia, Africa and Latin America.
In China, the Ministry of Industry and Information Technology (MIIT) and the State-owned
Assets Supervision and Administration Commission (SASAC) have issued a
notice requiring all telecom infrastructure enterprises that include China Telecom, China
Mobile, and China Unicom – to implement sharing and joint construction for all towers
and pole lines, as well as sharing and joint construction for base station equipment and
transmission lines. In addition, exclusive lease agreements for third-party facilities are
not allowed and penalties are applied on operators who are found in violation of the
new rules. A national workgroup for the joint construction and sharing of telecom

infrastructure facilities, headed by the MIIT and SASAC, and with participation from the
telecom industry, has been set up to oversee and mediate in the joint construction and
use of national telecom infrastructure, and to make decisions on major projects.
In Hong Kong the regulator is empowered to direct the cooperation and coordination
among the licensees to share network infrastructure taking into consideration factors
such as bottleneck facility, duplication of network resources. The regulator may also
make Determinations on terms and conditions of the shared use of facility should
operators fail to reach an agreement. Many countries in Asia are following India’s lead
in considering the benefits of mobile infrastructure sharing, including Bangladesh,
Bhutan, Nepal and Pakistan.
In the USA, the Telecommunications Act 1996 contains requirements for collocation
which fall under the section on Interconnection which mandates all carriers to provide
access to poles, ducts, conduits and rights-of-way to competing carriers on a first come
first served non- discriminatory manner.
In the Latin American region, Ecuador introduced mandatory site sharing in December
2009. In Trinidad and Tobago, the regulator has mandated collocation where it is
technically feasible. Any new site constructions have to be approved by the regulator.
Some countries in Europe also mandate collocation and site sharing.
In Switzerland, Swiss operators are obliged to share sites and masts wherever such
capacity exists, and there are no legal or economic reasons inhibiting such sharing. In
Denmark, sharing of sites and masts is mandated and is overseen by the
municipalities. In France passive infrastructure sharing is mandated by law since 2006.
All mobile operators are obliged to share facilities when they roll-out new sites and have
to accept reasonable access requests. In 2008, France also mandated active sharing of
the 3G networks of all the operators in most rural areas. In Finland an obligation to
lease radio masts or sites may be imposed on dominant operators.
In Saudi Arabia, bylaws mandate collocation to be provided where economically
feasible. The operators negotiate the charges for collocation and the regulator only
intervenes in cases where there are disputes.

3.2 Site Sharing Mandatory Upon Request
In New Zealand mobile site sharing is mandatory upon request. However, service
seekers and service providers are free to set their own pricing arrangements for
collocation. The Commerce Commission released a “Standard Terms Determination”
(STD) in 2008 aimed at providing service seekers and service providers with
appropriate incentives to make efficient use of mobile network resources for the long-term
benefit of consumers. The Commission identified three aspects of the STD in
particular, that it considered could stimulate more rapid collocation of mobile network
transmission and reception equipment:
o the standard type site solution process;
o the ability for service seekers to make multi-site applications; and
o the Service Level capacity limit for each service provider of ten
applications per access seeker per five day working period.
Since 2001, joint guidelines have been produced by OPTA, the NCA and the ministry in
the Netherlands on joint construction and sharing of UMTS network elements. Mobile
licences do not allow for sharing of core networks. Operators are obliged to allow site
and mast sharing upon reasonable request.
3.3 Infrastructure sharing encouraged by licensing regimes
In some instances, infrastructure sharing is indirectly instituted by regulators through
the licensing processes and licence categories. For example In Malaysia, network
facility sharing is one of the criteria used in evaluation of licence applications.
The converged licensing frameworks which vertically separate licence categories on a
technology neutral basis have also in a way facilitated infrastructure sharing.
Converged licensing frameworks have resulted in the emergency of Tower companies
which are proliferating across the world. Such companies are active in several
countries, including in India, Brazil and Mexico and North America. These include,
American Tower, Crown Castle, Global Tower Partners and SBA Communications.
Closer home, a case in point is that of Kenya where the Kenyan government recently
put forward a plan to offer the management of the band (up to 190MHz of spectrum,
which is suitable for high-speed mobile data services) to an independent company in
order to create an open access wholesale Network. The aim is to promote cost-effective

use of the 2.6GHz band whereby operators will be able to buy from the company, and
bundle it into packages and products that they would sell to end users.
In Portugal, infrastructure sharing has been part of the analysis criteria used in a public
bid based on proponents’ characteristics (beauty contest). Together with the provisions
from other applicable Portuguese regulation, the more recent Decree no.123/2009
(specific regime that governs the construction, access to and set up of communications
networks and infrastructures) also conveys a legal incentive to the infrastructure
sharing.
3.4 Infrastructure Sharing Voluntary with Regulatory Safeguards
In majority of cases, regulators intervene in voluntary infrastructure sharing by putting
safeguards in place largely aimed at mitigating any anti competition concerns. The
nature of the safeguards depends on the type of infrastructure that is being shared and
the extent to which sharing is permitted or encouraged rather than being mandated.
Examples of safeguards include:
• Capacity being sold on a first-come, first-served basis.
• Operators being required to log all infrastructure sharing activities and the logs
to be made available to the regulator, if requested.
• Regulator acting as a negotiator to move along commercial negotiations.
In most countries such as Hong Kong, Singapore, where infrastructure sharing is not
generally mandated and each operator allowed to build or lease the use of the
infrastructure that it requires, there are provisions that the regulator may direct
operators to share infrastructure where it is deemed to be in the public interest. Other
considerations such as whether the facility is a bottleneck facility or not; the cost of
duplication and whether the facility is critical in the supply of competitive services by
other operators are taken into account.
In Sweden, under the current 3G licensing framework, network infrastructure sharing is
allowed as long as each service provider has 30% of the population covered with its
own infrastructure and the remaining 70% can be shared. Active infrastructure sharing
is permitted as long as operators retain full control and independence over their
frequencies. In Norway there is a similar arrangement, which set minimum coverage

requirements as a condition for infrastructure sharing. Active sharing is permitted on
condition that operators retain logical control over their networks and spectrum.
Regulators are allowing active sharing arrangements on condition that operators meet their
coverage obligations. In Finland, service providers are allowed to share 3G networks
from April 2004, although each license holder must still have their own network covering
35% of the population. In Ireland, infrastructure sharing is only allowed where each
service provider has established a 3G-radio access network infrastructure capable of
serving at least 20% of the population-using infrastructure, which is wholly under the
control or ownership of that operator.
In Brazil, the National Telecommunications Agency (ANATEL) has set rules, conditions
and standards for sharing of ducts, conduits, poles, towers and rights of way and also
prescribed a methodology for actual calculation of infrastructure costs.
3.5 Sharing Not Permitted for Facilities Providing Same Services
In the USA, under the Telecommunications Act 1996, Infrastructure Sharing is
permitted only in cases, where the service provider who is sharing another service
provider’s facilities uses them only for services that do not compete with the provider of
the infrastructure. The USA does not have specific regulations on infrastructure sharing
except for the sharing of poles. The regulator has been called upon to scrutinize any
issues on a case-by-case basis several infrastructure sharing joint ventures between
various mobile service providers aimed at assessing their impact on competition.
Also in Singapore, an operator is not required to ‘‘share’’ the use of any infrastructure
that it controls with its competitors. Each operator is expected to build or lease the use
of the infrastructure that it requires. However, the regulator may mandate infrastructure
sharing where it deems certain infrastructure as Critical Support Infrastructure, or where
it concludes that sharing is in the public interest.
3.6 Sharing Permitted on Condition of Full Control and
Independence Of Networks
In Germany, infrastructure sharing of wireless sites, masts, antennas, cables,
combiners and cabinets is allowed provided that full legal control of the networks and

competitive independence remains intact.
Similarly, in the Netherlands, a coordinated approach involving the Netherlands
Competition Authority, the telecommunications Regulator (OPTA) and Ministry of
Transport, Public Networks and Water management authorizes operators to jointly
collaborate in deploying 3G networks on the condition that such arrangements are not
detrimental to competition between service providers. For competition reasons, joint
use of frequencies and core network sharing is restricted.
In Pakistan, different networks in Pakistan can share most of the infrastructure: masts,
antennae, power supplies, housing, transmission routes including Node B and Radio
Network Controllers except for the intelligent control of frequency resources.
In Jordan, Telecommunications Regulatory Commission (TRC) of Jordan intervenes by
investigating and coming up with determinations in instances where the requesting
service provider and the other service provider fail to reach and issue.
3.7 Voluntary Infrastructure Sharing
In the Middle East, site sharing becoming more common, with agreements signed in
recent years by operators in Kuwait, Qatar and the UAE. In Ireland, 3G MNOs have
signed a code of practice for site sharing. The Code provides guidance on a common
site sharing framework for all 3G operators active in Ireland.
3.8 Active Sharing Becoming Popular
The common practice across the globe is that active infrastructure sharing is happening
through voluntary mutual agreements reached between service providers. Since 2009,
many new larger sharing deals in terms of network size, scope and number of
subscribers involved were signed across the globe. A large number of network sharing
deals, ranging from cash-generating tower sharing to highly complex RAN-sharing
agreements. Shared infrastructure companies are emerging as key strategic partners to
service providers as operators realize that network coverage is not a sustainable
distinctive competency.

RAN sharing, has generally been permitted by regulators, provided that operators’
coverage requirements are met. RAN sharing is generally considered as having no
negative impact on competition. This is largely the case in Europe where RAN sharing
agreements have been stitched up in Spain, UK and Italy between T-Mobile and
Hutchison; Wind and Hutchison respectively.
In the UK, the current trend is towards large-scale network sharing rather than ad -hoc
arrangements. Regulatory pressure to cover the entire population by 2012 has seen
operators such as Vodafone and O2 planning to pool their networks. T-Mobile and 3
have also signed deals on network sharing. All companies will continue to compete
under their own brand names. It is expected that by putting together their networks they
would enable faster roll out of mobile broadband into more rural areas and also allow
them to reduce the 51,000 base stations dotted across the country by eliminating
duplication. Currently there are three bilateral network sharing deals between T-Mobile
and H3G, Vodafone and Orange, and Vodafone and O2.
In France, a RAN sharing agreement was signed by the four MNOs in July 2010).
In Spain, there is an agreement between Orange and Vodafone for full 3G RAN sharing
in small towns with less than 25000 inhabitants, since 2006.
3.9 Spectrum Sharing Generally Not Permitted
International experience indicates that spectrum pooling has not been permitted in any
country so far. The reason being that if service providers are permitted to pool or share
the spectrum then the group can get added advantage in deployment of services.
Generally, in most EU countries, each mobile operator must use its own frequencies to
deploy the radio access network, and in this sense frequency sharing is not allowed or
subject to limitations. In most countries, spectrum rights are linked to the obligation for
licensees to roll-out nationwide infrastructure. In the Netherlands, France, spectrum
sharing is not permitted as collaboration is limited to the joint construction and use of
the 3G network infrastructures such as masts, aerials and network operation. Joint use
of frequencies and core networks is not allowed. In Germany, the regulator stated that
each 3G licence holder would be required to build its own network, each of which
needed to ensure its `competitive independence’ during the lifetime of the license,
though permitting passive sharing. This means that service providers would not be

allowed to share backbone facilities such as switching centres even though they could
share network elements such as masts and antennas.
3.10 network sharing permitted subject to fulfilment of certain coverage
conditions.
In several countries, network sharing arrangements are permitted on condition of
fulfilment of certain coverage conditions. Such pioneering network-sharing agreements
led to support for RAN sharing being incorporated within the 3GPP standards for HSPA
and LTE. Examples where such arrangements are operational include Sweden where
network infrastructure sharing is allowed under the present 3G licensing regime as long
as each service providers has 30% of the population covered with its own infrastructure,
the 70% remaining being sharable. Similarly, in Denmark, a licensee is required to meet
certain coverage obligations for the deployment of 2G and 3G network, having full
control of the respective core network and Radio Access Network (RAN).
3.11 Core Network Sharing
Core network sharing is in its infancy and although commercial proposals have been
discussed, there are limited examples of this occurring in practice. Whilst such
agreements may lead to greater efficiency, through economies of scale effects,
regulators are mainly concerned about the impact of decreasing wholesale competition.
However, provided that the retail mobile market remains competitive then there may be
limited opportunities for vertically integrated mobile network operators to leverage any
increase in wholesale market power into the retail market. Therefore the competitive
harm to consumers may be minimal compared to the efficiency gains.
 National roaming has in some cases been mandated and in others encouraged,
in particular at the early stages of 3G roll-out and in peripheral areas, while it has
also been identified as a potential threat to competition in a limited number of
cases.
• MVNO access, where commercially negotiated has been considered to facilitate
competition, and in some cases it has been mandated where operators have
been found to have market power

CHAPTER 4: PROPOSED APPROACH TO INFRASTRUCTURE
SHARING IN ZIMBABWE.
4.1 THE STATUS OF INFRASTRUCTURE SHARING IN ZIMBABWE
Infrastructure sharing in Zimbabwe is regulated by Statutory Instrument 28 of 2001 on
Interconnection Guidelines that empowers POTRAZ to issue guidelines to the licensees
and service providers relating to infrastructure sharing. Currently infrastructure sharing
is not mandatory in Zimbabwe as it is left to commercial negotiation between operators.
This has resulted in a scenario where infrastructure sharing is minimal in Zimbabwe.
From a study that was done by POTRAZ it was observed that currently the most
commonly shared infrastructure among operators is passive infrastructure in the form of
towers, Equipment rooms and Power supply. The study also revealed that only 13.4%
of the total telecommunications passive infrastructure is shared. It was also revealed
that none of the operators are sharing active infrastructure or backhaul elements.
Question 5
Do you agree with the above analysis on the status of infrastructure sharing in
Zimbabwe? If not, give reasons and statistics to prove otherwise.
4.2. STATEMENT OF THE PROBLEM
The above state of affairs is testified by the multiplicity of towers and ducting belonging
to different operators which are built at the inconvenience of the public in terms of the
civil works and the harm to the environment that come with construction of such
infrastructure. This depicts unnecessary duplication of infrastructure which can easily
and economically be shared and reduces costs of providing services.
The above situation is further corroborated by findings of the recently concluded cost
studies for telecommunication services which identified infrastructure duplication and
the high cost of procuring telecommunication equipment in Zimbabwe as major
contributors to high cost of service provision.

Notwithstanding the above, many masts are being put on the roof tops of the buildings.
The locations of such masts are decided based on the Radio Frequency coverage map.
The suitability of the building and strength to support such loads are not properly
checked- a situation which may result in damages and risk to human life living near
such installations especially in the rainy season and windy weather.
Government, through its various arms such as the Environmental Protection Agency
(EMA); Ministry of Transport and Infrastructural Development and local authorities
including chiefs in rural areas are also involved in authorizing the construction of
telecommunication infrastructure in their respective areas of jurisdiction. All this is done
in a haphazard manner and increasing the time and cost of doing business for
operators. The end result is that such costs are passed on to the consumer- making
services unaffordable. Therefore there is need for uniform guidelines and coordination
for the construction/installation of telecommunications infrastructure. This should
involve all concerned parties such as municipal/local authorities including chiefs, EMA,
other utility providers such as electricity, railways, roads and POTRAZ.
It is POTRAZ’s considered view that the current infrastructure sharing arrangements as
espoused in SI 28 on interconnection rates have failed to stimulate the desired levels of
infrastructure sharing thereby increasing cost of services and causing harm to the
environment, hence the need to review the existing framework.
Question 6:
Do you agree with the statement of the problem to be addressed with regards to
infrastructure sharing and POTRAZ’s view on the need to review and improve on
the existing framework? If not in agreement, give reasons.
4.3 THE OBJECTIVES OF INFRASTRUCTURE SHARING IN
ZIMBABWE
Considering that building and operating infrastructure is a significant cost for operators
contributing up to 60% in total cost of service provision, POTRAZ view is that network
sharing may provide the panacea to the industry challenges. The goal of network

sharing is to reduce costs associated with rolling out telecommunications networks with
the expected outcome of speeding up service roll out and attainment of universal
access to services. The objectives of coming up with infrastructure sharing guidelines
include:
 Ensure that the incidence of unnecessary duplication of infrastructure is
minimized or completely avoided thus making a saving on scarce financial
resources;
 Ensure that the economic advantages derivable from the sharing of facilities are
harnessed for the overall benefit of all telecommunications stakeholders;
 Protect the environment by reducing the proliferation of infrastructure and
facilities installations or deployment;
 Encourage the operators to take public health and safety and the environment
into account when constructing and or deploying infrastructure;
 Promote the availability of wide range of high quality, efficient, cost effective and
competitive telecommunication services throughout Zimbabwe by ensuring
optimum utilization of telecommunication resources;
 Minimise operators’ expenditure on supporting infrastructures and to free more
funds for investment in core network equipment upgrades and rolling out of
innovative and affordable services.
 Promote fair competition through equal access being granted to the Passive
infrastructure of operators especially for bottleneck facilities and wherever
applicable on fair terms.
 To reduce both capital and operating expenditures in order to make services
affordable whilst maintaining sustainable levels of profitability in the face of
increasing use of over-the-top (OTT) services which are eating into operators;
revenues.
Question 7:
Do you agree with the Authority’s views regarding the objectives of infrastructure
sharing in Zimbabwe? If not please provide reasons or any additional objectives
that need to be included.
The Authority recognizes that sharing should not only be confined within the boundaries

of the telecommunication industry, but together with other infrastructure industries such
as electricity, water and sewage, roads and Broadcasting as well. In the context of
technological development, joint infrastructure building with other market players and
with other industries should be encouraged, providing for timed, organized opportunities
for access to ducts and conduit (for example, for the joint laying of fiber) to distribute the
cost of civil works among service providers and reduce the inconvenience for traffic in
towns and cities. This will also provide for a positive environmental and aesthetic
impact, in particular by reducing the number of mobile masts and towers as well as
damage to roads.
Question 8
Do you agree with the Authority’s view on the need for infrastructure sharing to
extend to other utility providers such as roads, municipalities, water, electricity
and broadcasting?

CHAPTER 5: LICENSING AND REGULATORY ISSUES
5.1 ROLE OF GOVERNMENT
Government has a key role to play in facilitating the most effective use of infrastructure
assets and in identifying those parts of the country where there are gaps and getting
coverage extended to them. Most highways are owned and run by the Government and
so are the rights-of-way along these roads. This presents an opportunity for government
to foster infrastructure sharing by placing sharing conditions on those who acquire
rights of way. As a condition of approval government can stipulate the minimum size of
duct to be installed and further place heavy taxes and charges on exclusive users.
Central government can also direct local authorities to standardize approval procedures
for rights of way.
These procedural issues at times result in increased costs, delayed investments, higher
roll out time and poor quality of service. Therefore, POTRAZ recommends that
Government needs to streamline the procedures through a national policy supported by
an appropriate legal framework and structures to achieve faster growth of
telecommunication services in the country. As such, it is recommended that
government considers setting up a one- stop- shop infrastructure sharing facility to
facilitate faster and efficient infrastructure sharing among telecommunication operators
and other utility providers. The one-stop-shop facility would facilitate the coordination of
trenching and ducting works between telecommunications service providers as well as
between telecommunications service providers and those of other utilities aimed at
simplifying administrative proceedings and ensure timely response to requests for
infrastructure sharing.

Question 9
Do you agree with POTRAZ view on the need for setting up a one stop shop
infrastructure sharing facility aimed at standardising and monitoring
infrastructure roll out? If so, how can this be crafted and who should be
responsible. If not in agreement, kindly give reasons thereof.
5.2 ROLE OF POTRAZ
POTRAZ as the regulatory body for the telecommunications sector has the overall role
of enforcing the infrastructure sharing framework. For mandatory infrastructure sharing,
the Authority shall analyse and approve all agreements among operators.
The Authority shall maintain a database of all telecommunication sites and equipment
installations in the country to facilitate infrastructure sharing. The database shall contain
information on existing infrastructure as well as future infrastructure installations that
can be available for sharing.
The Authority shall use its mandate to further the opportunities for infrastructure
sharing, provided there is no risk of the lessening of competition. In particular, the
Authority will take action to:
 Identify areas that require mandatory infrastructure sharing.
 Encourage redevelopment of existing facilities amenable to infrastructure sharing
to increase their capacity.
 Advise local and regional authorities on the adoption of schemes which would
encourage the sharing of infrastructure.
 Support the development of the capability among operators to deal with issues of
infrastructure sharing in a competent way.
Question 10
Are you in agreement with the above cited roles of POTRAZ in facilitating
infrastructure sharing? If not in agreement, what do you think needs to be
included or excluded from the roles highlighted above?
The Authority may order the discontinuation of an infrastructure sharing arrangement
subject to the following conditions:

 Where it determines that an infrastructure sharing arrangement is inconsistent
with the scope and terms and conditions of relevant Licence(s) and/or
 Identifies a risk of lessening of competition as a consequence of such
infrastructure sharing.
Question 11
Are you in agreement with the conditions under which POTRAZ may order the
discontinuation of an infrastructure sharing arrangement? You may suggest
other conditions.
5.3 Licensee Rights and Obligations for Facility Sharing
All Licensees shall furnish the Authority detailed information on infrastructures available
for sharing with other operators. The list shall be updated on a quarterly basis. All
licensees shall have to fulfil all of their individual obligations including but not limited to
rollout obligations as contained in their individual licences irrespective of infrastructure
sharing agreements with other operators.
5.4 Optical Fibre Networks
The Authority’s view is that Licensees shall jointly develop, build, maintain and operate
new infrastructure for providing telecommunication services to subscribers. Licensees
will not be permitted to build optical/wired backbone transmission networks in areas
where similar networks owned by other licensees are already available for sharing.
Incumbent operators should take necessary measures to augment the capacity of
existing optical /wired backbone transmission network for sharing.
Licensees shall jointly develop, build, maintain and operate optical/wired backbone
transmission network if such networks are not existing / not available for sharing from
the existing infrastructures in a particular zone/area. However, an individual licensee
may build optical /wired backbone transmission network with the permission of the
Authority.
Licensees shall be obliged to provide open access to bottleneck facilities, at both
national and international levels including internet connectivity through colocation and
connectivity to submarine cable landing stations and internet exchange points.

5.5 Co-location/Site Sharing
Licensees shall collaborate in negotiating co-location agreement issues relating to site
access, security access, damage insurance and compensation, and fair rate. Where
there are disputes, the areas of contention shall be identified and referred to the
Authority for resolution in an agreed defined period before a decision is made on a
particular application.
Licensees shall co-operate with each other to construct a new tower as per these
Guidelines for joint usage. Notwithstanding the above, the following factors may inhibit
or delay co-location:
i) Lack of structural capacity to support weights, orientation, heights and wind
loads from additional equipment.
ii) Lack of ground space to accommodate shelter for base stations and other
equipment.
5.6 Tower sharing
Tower sharing shall be mandatory for all new towers where possible, such that any
operator who wishes to construct a new tower must first establish that it is not
technically or practically feasible to share an existing tower and that the costs of
upgrading the existing tower exceed that of building a new tower.
Mandatory tower sharing may be done through joint development of new infrastructure
where possible or through licensees whose licence scope permits them to build
infrastructure.
Licensees shall, and in consultation with the Authority, where necessary ensure the
use of approved existing sites for the development of new installations. A person who
intends to construct a tower must demonstrate that all reasonable steps have been
taken to investigate tower sharing before applying to the permitting agencies to
construct a new tower within a specified radius of the proposed site.
Where tower heights are shorter, a smaller search radius can be used as follows:
i) Two towers above 46m, a radius of 400m shall apply; and
ii) Two towers below 46m towers, a radius of 300m shall apply.

Where either of the above is not technically feasible, a written documentation in the
form of a co-location statement, which indicates the reason why co-location is not
possible, shall be supplied by the site owner within five (5) working days to the
applicant. The applicant shall submit the co-location statement to the Authority on
application for a new site.
Licensees shall collaborate in negotiating co-location agreement issues relating to site
access; security access; damage insurance and compensation as well as chargeable
rates. Where there are disputes, the areas of contention shall be identified and referred
to the Authority for resolution in an agreed defined period before a decision is made on
a particular application.
The owner(s) of a tower shall provide information to the Authority to maintain a
database of towers that are available for collocation. Where an existing tower is
incapable of supporting co-location, the option of decommissioning the old tower and
the erection of a new one capable of accommodating other antennas may be
considered.
Where an old tower is decommissioned to erect a new stronger one capable of
accommodating other operators’ the new operators shall be liable for the cost of the
new tower on an incremental cost basis.
5.7. Ducts and rights of way
Ducts and rights of way shall be shared for installations that serve a similar purpose,
which allows for optimal use and shall be offered on a first-come first served basis
subject to commercial agreements under fair pricing conditions.
5.8. Comprehensive/ Deep Passive Site Sharing
Deep site sharing shall be mandatory in rural areas unless exempted by the Authority.
In Zimbabwe this is already in practice whereby funds from the Universal Service fund
are being used to build towers which are shared by operators.

5.9. Common back-haul sharing
Common back-haul sharing will be mandatory in rural areas where traffic from BTS to
BSC is deemed very low and a common RF or Optical fibre medium can be utilized.
This will reduce cost and maintenance efforts. Exit from such sharing arrangements
shall be permissible wherever it is proven that it is warranted at a later phase due to
increase in traffic or other administrative reasons.
5.10. Active Sharing
Active RAN sharing and Node B sharing shall be optional and encouraged only in
cases where it does not compromise competition through collusive behaviour among
operators.
Question 12
Given the proposed approaches to infrastructure sharing, do you agree with
POTRAZ view to make site/tower, backhaul, duct sharing mandatory in both
rural and urban areas; Deep passive site sharing mandatory in rural areas and
Active RAN sharing optional to operators? If not in agreement, please give
reasons.

CHAPTER 6
GENERAL TERMS AND CONDITIONS FOR INFRASTRUCTURE
SHARING
6.0 Agreements on Infrastructure Sharing
All licensees shall provide capacity on its infrastructure to other operators on a non-discriminatory
“first come, first served” basis.
Licensees shall enter into an agreement for sharing infrastructure.
In case of any dispute regarding the tariff and charges the decision of the Authority
shall be final and binding upon the parties. Any agreements to be executed shall be
submitted to the Authority for approval within 15(fifteen) days from the date of
agreement.
Question 13
Do you agree with the need for licensees to enter into formal infrastructure
sharing agreements and the cited conditions under which sharing agreements
shall be arranged? If not in agreement give reasons and cite alternative/additional
conditions.
6.1 Procedure for Infrastructure Sharing:
Infrastructure Seeker shall submit request to Infrastructure provider expressing the
interest of sharing infrastructure. Infrastructure Provider shall enter into negotiation with
other operators to share the infrastructure. An operator shall provide capacity on its
infrastructure to other operators on a “first-come, first served” basis, determined in
accordance with the order in which it receives requests for infrastructure sharing. An
operator shall reserve the right to refuse an application for infrastructure sharing on
grounds of;
(a) Insufficient capacity
(b) Safety, reliability, incompatibility of facilities

Request for Infrastructure Sharing by the Infrastructure Seeker to the Infrastructure
Providers and the approval / rejection of the request by the Infrastructure Provider must
be in writing. Any agreements to be executed shall be submitted to the Authority for
approval within 15(fifteen) days from the date of agreement. All negotiations for
Infrastructure Sharing must be done in utmost good faith. The Infrastructure Provider
shall not:
(a) Obstruct, delay negotiations in resolving disputes.
(b) Refuse to provide information relevant to an agreement including information
necessary to identify the facility needed.
(c) Refuse to designate proper representative to expedite negotiation.
Infrastructure Providers shall reserve the right to refuse an application for infrastructure
sharing on grounds of insufficient capacity. Infrastructure Providers have the right to
reserve not more than 50% (fifty percent) of spare capacity for new towers or
infrastructure.
The period to respond (either acceptance or rejection) by the Infrastructure Provider to
any request for Infrastructure Sharing shall be 4 (four) weeks and the time frame for
negotiation of an Infrastructure Sharing Agreement shall be 6 (six) weeks from the date
of receiving the request. If no response is received within 4 (four) weeks of request, the
Infrastructure Seeker shall refer the matter to the Authority and the Authority shall take
necessary steps.
Question 14
Do you agree with the above proposed procedure for infrastructure sharing, the
cited conditions for refusal to share infrastructure and the expected time frame
within which a request and negotiations for infrastructure sharing must be
responded to and concluded? If not in agreement give reasons and alternative
suggestions.
In the event of any differences or disputes between the Infrastructure Provider and
Infrastructure Seeker and failure to resolve the differences or disputes amicably among
themselves, aggrieved party shall refer the matter to the Authority for resolution of the
same. The decision of the Authority in that regard will be final and binding.

Question 15
Do you agree with the above cited dispute resolution mechanism for
infrastructure sharing disputes? If you do not agree give reasons and alternative
suggestions.
6.2 Infrastructure Sharing charges and Costs
Prices for infrastructure sharing shall be non-discriminatory, reasonable, and based on
the actual costs incurred by the owner of the facility. Determination of the costs
underlying prices should be transparent and neutral and should be incorporated in the
infrastructure sharing agreement for the Authority`s approval.
Tariff and charges for Infrastructure Sharing shall be on an incremental cost basis. In
essence, the annual cost of sharing should not exceed an equal fraction of the
annualised cost of owning and operating a similar facility.
Question 16
Do you agree with the above cited pricing principles for infrastructure sharing? If
you do not agree give reasons and alternative suggestions.
6.3. Standardization
To facilitate improved co-ordination and compatibility of equipment, parties to an
infrastructure sharing arrangement should endeavour to develop and employ standard
procedures for provision and operations under the arrangement. Parties should not
install incompatible equipment which may cause interference to other parties’
equipment or impede usage of space allocated to them.
The standard procedures to be developed by parties under the arrangement will be in
the areas of:
(a) Maintenance
(b) Fault clearance
(c) Access at the facility
(d) Emergency

(e) Cleaning
(f) Safety
(g) Security
(h) Labelling of cables and equipment with owner’s name
Parties are also to ensure that standardized professional installation procedures are
followed.
Question 17
Do you agree with the need for standard procedures and the above cited areas
where such procedural standards should be maintained? If not in agreement,
give reasons and alternative suggestions.
6.4. Dispute Resolution
The Authority has the power to intervene to resolve any dispute pertaining to
infrastructure/site sharing at the request of either party and to impose sharing
arrangements between operators after consultation with the parties. Where there are
disputes arising out of infrastructure / site sharing, the areas of contention shall be
identified and referred to the Authority for resolution.
The power of the Authority to intervene in disputes shall include the right to request for
and receive all such necessary information as may be required to reach a decision. The
Authority shall establish within five (5) working days, a dispute resolution process in
accordance with provisions of the Act. The decision of the Authority which shall be
final, save for the right of appeal to a court of competent jurisdiction will be notified to
the parties and published.
Question 18
Do you agree with the role and powers given the Authority in infrastructure
sharing dispute resolution? If you do not agree give reasons and alternative
suggestions.

ANNEX A: LIST OF CONSULTATION QUESTIONS ON
INFRASTRUCTURE SHARING FRAMEWORK
Questions
Responses from Stakeholders Position of the Regulator
(POTRAZ)
Question 1 Do you agree with the general views which the
Authority buys into regarding the benefits that
may be realised if Infrastructure is shared in
Zimbabwe? If not please provide reasons.
Responses
Question 2 a. Do you agree with the above views on
factors that may inhibit Infrastructure
sharing? If not please provide reasons.
b. In your view which of the above factors are
possible impediments to infrastructure
sharing in Zimbabwe and how best can they
be addressed?
Responses
Question 3 Issues for consultation:
a. Do you agree with the description of the
above forms of passive infrastructure
sharing?
b. Are there any other forms of passive
sharing that are possible between
operators? If any give more
Responses
Question 4 c. In your opinion, should active infrastructure
sharing be encouraged? Give reasons for your
answer.
d. Given the various forms of active infrastructure
sharing described above, which ones do you
think are most suitable for the Zimbabwean
case. Please provide reasons for your choice.
You are free to suggest a hybrid of various
forms of sharing.
c. In your view, do you consider the option to
licence Mobile Virtual Network Operators
(MVNOs) as a viable option to encourage active

infrastructure sharing in Zimbabwe?
d. What other modes of active infrastructure
sharing will be useful in the Zimbabwean
scenario? Suggest actions which you feel
necessary to encourage such sharing.
Responses
Question 5 Do you agree with the above analysis on the
status of infrastructure sharing in Zimbabwe? If
not, give reasons and statistics to prove
otherwise.
Responses
Question 6 Do you agree with the statement of the problem to
be addressed with regards to infrastructure
sharing and POTRAZ’s view on the need to review
and improve on the existing framework? If not in
agreement, give reasons.
Responses
Question 7 Do you agree with the Authority’s views regarding
the objectives of infrastructure sharing in
Zimbabwe? If not please provide reasons or any
additional objectives that need to be included.
Responses
Question 8 Do you agree with the Authority’s view on the
need for infrastructure sharing to extend to other
utility providers such as roads, municipalities,
water, electricity and broadcasting?
Responses
Question 9 Do you agree with POTRAZ view on the need for
setting up a one stop shop infrastructure sharing
facility aimed at standardising and monitoring
infrastructure roll out? If so, how can this be
crafted and who should be responsible. If not in
agreement, kindly give reasons thereof.
Responses
Question 10 Are you in agreement with the above cited roles of
POTRAZ in facilitating infrastructure sharing? If
not in agreement, what do you think needs to be
included or excluded from the roles highlighted
above?
Responses
Question 11 Are you in agreement with the conditions under
which POTRAZ may order the discontinuation of
an infrastructure sharing arrangement? You may
suggest other conditions.
Responses

Question 12 Given the proposed approaches to infrastructure
sharing, do you agree with POTRAZ view to make
site/tower, backhaul, duct sharing mandatory in
both rural and urban areas; Deep passive site
sharing mandatory in rural areas and Active RAN
sharing optional to operators? If not in agreement,
please give reasons.
Responses
Question 13 Do you agree with the need for licensees to enter
into formal infrastructure sharing agreements and
the cited conditions under which sharing
agreements shall be arranged? If not in agreement
give reasons and cite alternative/additional
conditions.
Responses
Question 14 Do you agree with the above proposed procedure
for infrastructure sharing, the cited conditions for
refusal to share infrastructure and the expected
time frame within which a request and
negotiations for infrastructure sharing must be
responded to and concluded? If not in agreement
give reasons and alternative suggestions.
Responses
Question 15 Do you agree with the above cited dispute
resolution mechanism for infrastructure sharing
disputes? If you do not agree give reasons and
alternative suggestions.
Responses
Question 16 Do you agree with the above cited pricing
principles for infrastructure sharing? If you do not
agree give reasons and alternative suggestions.
Responses
Question 17 Do you agree with the need for standard
procedures and the above cited areas where such
procedural standards should be maintained? If not
in agreement, give reasons and alternative
suggestions.
Responses
Question 18 Do you agree with the role and powers given the
Authority in infrastructure sharing dispute
resolution? If you do not agree give reasons and
alternative suggestions.
Responses

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