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HIGHLIGHTS OF KEY GENERAL AND SPECIFIC SECTORAL REQUIREMENTS FOR ESTABLISHING AND MANAGING AN SPV-PPP IN NIGERIA’S TELECOM SECTOR: - SELECTED EXPERIENCES OF THE PRACTICE OF SPV-PPP.
BY
PROF MUHAMMED TAWFIQ LADAN
TELECOM
POLICY, LEGAL, REGULATORY AND LICENSING EXPERT.
EMAIL:
- mtladan@gmail.com
GSM:
- 08037015634
INTRODUCTION
This
Policy Issue Brief aims at highlighting the telecom specific sectoral
regulations and showcasing selected experiences of the practice of SPV-PPP in
Nigeria’s telecommunications sector. This brief further identifies regulatory
bottlenecks and impact analysis, and proposes a way forward in the search for
an appropriate framework for the deployment of the 90,000 km Fibre optics
cable, telecom infrastructure in Nigeria.
Highlights
of Specific Sectoral Requirements for a Telecom Infrastructure SPV under
Telecom Laws and Regulations
A
Special Purpose Vehicle (SPV) established for telecom infrastructure
development in Nigeria must comply with various legal and regulatory
requirements outlined in the Nigerian Communications Act, 2003 (NCA 2003) and
regulations issued by the Nigerian Communications Commission (NCC). [1]These
requirements encompass licensing and approvals,[2]
competition and abuse of dominance rules[3]
and pricing regulations. [4]Compliance
with these sector-specific requirements ensures the efficient operation of
telecom infrastructure SPVs while fostering competition, market stability, and
consumer protection outside the general provisions of the Companies and Allied
Matters Act, 2020 (CAMA 2020), which governs the incorporation and corporate
governance of companies in Nigeria, telecom infrastructure SPVs must adhere to
additional sector-specific regulations. These regulations provide
industry-specific guidelines for licensing, competitive practices, and pricing
frameworks to ensure efficient and sustainable telecom infrastructure
deployment.
Specific
sectoral requirements (relating to licencing, approval, competition, abuse of
dominance position and pricing regime) for a telecom infrastructure SPV under
the telecom laws and regulations: - The
Nigeria Communications Act 2003 prohibits the operation of a communication
system or facility or communication service provision without a license duly
authorising such operation or service provision or an exemption granted.[5]
Accordingly, the Nigeria Communications Commission (NCC) is mandated to issue
licenses for the operation of communications service or facilities which could
either be individual or class licenses on conditions as the NCC may determine.
Furthermore, the NCC may exempt an entity from the licensing requirements on
such terms to be determined by the NCC.[6]
The NCC has issued the Licensing Regulation 2019 which provides for the
licensing/exemption conditions. They are-
(a) the
applicant is required to be a corporate body registered under the laws of
Nigeria;[7]
(b) the technical requirements for operating such
a license must be met;[8]
(c) the
applicant is required to satisfy the NCC of sufficient financial capacity to
provide long term service;[9]
(d) any other condition the NCC may require must
be satisfied;[10]
(e) in
the case of a resource-dependent service, the NCC is satisfied of the
availability of the required resource and that the applicant has secured such
resources including spectrum and numbering;[11]
(f) application
to be made to NCC in the prescribed application forms accompanied with evidence
of payment;[12]and
(g) payment
of licensing and administrative fees as NCC may determine from time to time.[13]
A
licensee is prohibited from engaging in any conduct which has the effect of substantially
lessening competition in any segment of the Nigerian Telecom Industry (NTI).[14]Sector
-specific requirements relating to competition and fair practices are
regulated. Accordingly, the NCC may issue regulations clarifying the meaning of
‘substantial lessening of competition.’[15]
In particular, the NCC has issued the Competition Practices Regulations, 2007
which applies to all licensees as well as all other providers of communications
services in Nigeria.[16] The NCC
considers the following to assess whether a conduct substantially lessens
competition-[17]
(i) impact
of the conduct on existing competitors in the identified markets,
(ii) impact
of the conduct on further market entry,
(iii) impact
of the conduct on consumers, including availability and pricing of products and
services, and
(iv) degree
of interference with competition that results in identifiable injury to
consumers or competitors.
Furthermore,
a licensee is prohibited from entering into any arrangement for rete fixing,
market sharing or boycott of another competitor or licensee.[18] Part of
the measures put in place to ensure competition include the requirements for-[19]
(i) limiting
interconnection or other essential facilities to a competing licensee,
(ii) discriminatory
treatment in the provision of interconnection or other communication services,
(iii) bundling of communication services,
(iv) pre-emptive
acquisition of scarce facilities or resources to deny another licensee
(v) cross-subsidisation
of a communication service using revenues from another communication service
etc.
The
NCC is empowered to regulate the pricing regime of communication services in
the NTI through tariff rate regulation.[20]
Licensees are required to publish their tariff rates for services as approved
by the NCC. The NCC determines rates on the basis of the following principles-[21]
. rates
to be fair and not discriminatory,
. rates
shall be cost-oriented and shall not admit cross-subsidisation,
. rates
to be structured at levels sufficient to attract investments into the NTI,
. rates
to reflect regulations and recommendations of international organisations of
which Nigeria is a member.
The
NCC also has dominance obligations which enables it to determine if a service
provider holds a dominant position or a significant market power, it is
mandated to impose obligations on the service provider in that capacity to
prevent them from misusing that power.[22]
i.
Licensing and Approval Requirements
A
telecom infrastructure SPV must obtain the necessary licenses and approvals
from the NCC before commencing operations. [23]The
primary license required is the Infrastructure Company (InfraCo) License, which
authorizes the SPV to build, operate, and manage critical telecom
infrastructure such as fiber optic networks, broadband facilities, and telecom
towers. The application for an InfraCo License requires the SPV to demonstrate
financial capacity, technical expertise, and a viable business model that
aligns with Nigeria’s National Broadband Plan.[24]In
addition to the InfraCo License, the SPV may need to obtain other regulatory
approvals from relevant authorities. These include permits from state and local
governments for right-of-way (RoW) approvals, environmental impact assessments
(EIAs) from the Federal Ministry of Environment, and compliance with the
National Information Technology Development Agency (NITDA) regulations on data
protection and cybersecurity. Given the increasing demand for digital
infrastructure, ensuring adherence to cybersecurity laws is critical for
protecting consumer data and preventing cyber threats.Another key licensing
requirement for telecom infrastructure SPVs is adherence to the NCC’s Unified
Licensing Regime (ULR).[25] Under
this framework, different types of licenses are issued based on the scope of
services provided. An SPV may need to acquire additional licenses, such as the
Metropolitan Fiber Cable Network License or the National Long-Distance Operator
License, depending on its operational scope. The NCC also requires licensed
entities to comply with periodic reporting obligations, renew their licenses as
stipulated, and maintain operational standards.[26]
ii.
Competition and Abuse of Dominance Position
The
telecom sector in Nigeria is highly regulated to prevent anti-competitive
practices and ensure a level playing field for all market participants. The NCC
enforces competition laws to curtail market dominance abuses by major operators
such as MTN, Airtel, and Glo. As an SPV operating in the telecom infrastructure
space, compliance with these competition regulations is crucial.[27]
The
NCC defines market dominance based on market share, barriers to entry, and the
ability to set prices independently of competitors. If an SPV is deemed to hold
a dominant position in the telecom infrastructure market, it is subject to
additional regulatory oversight to prevent anti-competitive behavior. This
includes restrictions on exclusive agreements, obligations to provide fair
access to infrastructure, and prohibitions against discriminatory pricing that
could disadvantage smaller players.To promote competition, the NCC mandates
that dominant players, including SPVs, engage in infrastructure sharing and
co-location agreements.[28] This
guidelines ensures that telecom
operators can access essential network facilities without facing unfair
restrictions or exorbitant fees. The Open Access Model, introduced by the NCC,
encourages InfraCos to operate in a non-discriminatory manner, allowing
multiple service providers to utilize the same infrastructure at regulated
rates.
Furthermore,
the Federal Competition and Consumer Protection Commission (FCCPC)[29] collaborates
with the NCC to enforce competition laws and prevent monopolistic practices.
The SPV must comply with merger and acquisition regulations, ensuring that any
consolidation within the sector does not result in reduced competition or harm
consumer interests. Regulatory interventions, including price caps,
transparency obligations, and dispute resolution mechanisms, are in place to
prevent abuse of dominance and promote sustainable competition.
iii.
Pricing Regime and Tariff Regulations
The
NCC regulates the pricing of telecom infrastructure services to ensure
affordability, fair competition, and market stability. As an SPV providing
critical infrastructure, adherence to pricing guidelines is essential for
ensuring a balanced telecom ecosystem.The pricing regime for telecom
infrastructure services is primarily governed by the NCC’s Pricing and
Competition Regulations. These regulations establish pricing models based on
cost-oriented principles, ensuring that tariffs reflect the actual costs
incurred in deploying and maintaining telecom infrastructure. The goal is to
prevent price gouging while allowing operators to recover their investments
sustainably.
For
telecom infrastructure SPVs, the NCC sets guidelines for interconnection rates,
lease fees for fiber optic networks, and access charges for co-location
services.[30] The
commission periodically reviews these tariffs to reflect market conditions,
inflationary trends, and changes in the cost of infrastructure deployment. The
SPV must submit tariff proposals to the NCC for approval, demonstrating
compliance with regulatory benchmarks and fair pricing principles.A significant
aspect of the pricing regime is the regulation of wholesale and retail pricing
structures. Telecom infrastructure SPVs primarily operate in the wholesale
market, providing services to mobile network operators (MNOs), internet service
providers (ISPs), and other licensed telecom entities. The NCC enforces
non-discriminatory pricing policies, ensuring that no single operator receives
preferential pricing treatment to the detriment of competitors.
Additionally,
the Universal Access and Service Fund (UASF) plays a role in the pricing
framework by supporting infrastructure deployment in underserved and rural
areas.[31] SPVs
benefiting from UASF subsidies must adhere to specific pricing obligations,
ensuring that services remain affordable in regions with low commercial
viability. This aligns with Nigeria’s broadband expansion goals and promotes
digital inclusion. Regulatory interventions also extend to consumer protection,
requiring SPVs to adhere to service level agreements (SLAs) that outline
quality-of-service (QoS) standards and penalties for non-compliance. By
enforcing transparent pricing models and quality benchmarks, the NCC ensures
that telecom infrastructure SPVs contribute to a competitive and
consumer-friendly telecom industry in Nigeria.
In
summary, the establishment and operation of a telecom infrastructure SPV in
Nigeria require strict adherence to sector-specific regulatory frameworks
beyond the general corporate provisions of CAMA 2020. Compliance with licensing
and approval requirements ensures that SPVs operate within the legal framework
set by the NCC and other regulatory bodies. Furthermore, adherence to
competition laws mitigates the risk of market abuse by dominant players and
fosters a competitive telecom ecosystem. The enforcement of a fair pricing
regime, including non-discriminatory access to infrastructure, ensures
sustainability and consumer protection within the telecom sector. By aligning
with these regulatory requirements, telecom infrastructure SPVs can effectively
contribute to Nigeria’s digital economy while maintaining operational integrity
and financial viability.
Models of Telecommunications sector SPVs-PPP practiced
in Nigeria
Special
Purpose Vehicles (SPVs) have become indispensable legal instruments for
executing large-scale projects across various sectors in Nigeria, including
infrastructure development, public-private partnerships (PPPs), and the
telecommunications industry. These entities are established primarily to
isolate financial risks, enhance project financing, and ensure the efficient
execution of capital-intensive initiatives.
|
Focus on Output specifications |
|
Performance linked payments |
|
Optimal Risk Allocation |
|
Whole life costing |
|
Long-term contractual arrangement |
|
Financing |
|
Characteristics of PPP |
A
public-private-partnership (PPP) involves a contract between a public sector
authority and a private party, in which the private party provides a public
service through a well-defined project and assumes substantial financial,
technical, and operational risks in the project. The characteristics of a PPP
project are depicted in the figure 1 above.The characteristics of a PPP project
can be classified into two categories, namely contractual characteristics
(which can be long term or through a
separate entity called an SPV) and financial characteristics.
As
shown in figure 2 above, most PPP frameworks will include a range of inputs
from stakeholders on PPP policy setting out objectives, scope and implementing
principles for the project – that must be supported by a robust legal
framework. The policy and legal framework inform and establish the central
components of the PPP, namely processes and institutional responsibilities,
public financial management, and PPP program governance.
Table
1: Different Types of PPP Delivery Models
Public-private
partnerships (PPPs) can be of various types encompassing various role players,
ownership arrangements, and allocations of risk between private and public
partners. These different types of partnerships are called PPP models. The
choice of a PPP model depends on the objective of the government such as
improving service efficiency, transferring investment risk, maintaining service
control or improving the quality of service. The table 1 below presents the
different types of PPP models and their corresponding characteristics.
|
(Duration) |
|
Characteristics |
|
Nature of
service & Payment to contractor |
|
|
Asset
ownership |
O&M |
Capital
Investment |
Commercial
Risk |
||
|
Service Contract (1-3 years) |
Public |
Public & Private |
Public |
Public |
A definitive, often technical type of service, fee
paid by government for service |
|
Nature of contract (Duration) |
|
Characteristics |
|
Nature of service & Payment to contractor |
|
|
Asset ownership |
O&M |
Capital Investment |
Commercial Risk |
||
|
Management Contract (3-8 years) |
Public |
Private |
Public |
Public |
Manage the
operation of a government service; fee paid by government for service and a
performance-based incentive |
|
Lease Contract (5-10 years) |
Public |
Private |
Public |
Private |
Manage, operate,
repair and maintain a public service to specified standards and outputs. All
revenues, fees or charges are recovered from consumers or the users of the
service; the service provider pays the government rent for the facility. |
|
Concession (25-30 years) |
Public |
Private |
Private |
Private |
Manage, operate,
repair, maintain and invest in public service infrastructure to specified
standards and outputs. All revenues are sourced from consumers for the
provision of the service; the service provider pays a Concession fee to the
government and may assume existing debt. |
|
BOT/BOO/ Others (15-25 years) |
Private & Public |
Private |
Private |
Private |
Construct and
operate, to specified standards and outputs, the facilities necessary to
provide the service. The Government mostly pays the service provider on a
unit basis. |
SPV
Option: - The SPV would protect the sponsor or parent
entity by disaggregating such risks as cost overruns and delays across a
multitude of stakeholders. The SPV would also provide operators a formal
organisational structure to share the costs, risks and ownership of an asset
that they all need and where it makes no sense to duplicate the asset for each
provider. Such SPVs are typically established so that the government shares
will be divested at a later date to the operators. Sharing costs in this way is
particularly useful in poorer environments, such as Somalia, where
international fiber-optic connectivity would likely not be feasible without the
involvement of and subsidies from government and multilateral organizations. In
simple terms, the SPV would borrow the required funds from debtors, grantors or
shareholders, which can be public or private entities, multilateral
institutions, or debt or equity financiers. Debt or returns on equity are paid
back using the cash flow generated from the project. This cash flow is normally
paid to an escrow agent, and thus ring-fenced in order to prioritize payments
to debtors and investors. These relationships are represented in the graphic
immediately below.
Governments
have set up SPVs, with operators and multilateral organizations as investors,
to finance the fibre optic backbone in such places as Benin, Gambia, Liberia,
Sao Tome Principe and Sierra Leone. A particularly good example comes
Gambia’s efforts to attract its first submarine cable.
EXAMPLES OF MODELS PRACTICED
The deployment of telecommunications infrastructure in
Nigeria requires substantial investment, technical expertise, and regulatory
oversight. Given the capital-intensive nature of this sector, Special Purpose
Vehicles (SPVs) operating within Public-Private Partnership (PPP) frameworks
have emerged as an effective legal and financial mechanism to enhance telecom
infrastructure, bridge connectivity gaps, and drive digital transformation.
SPV-PPP models in the Nigeria’s telecommunications sector are structured to
ensure risk-sharing between public and private entities, leverage external
financing, and promote sustainable development while maintaining regulatory
compliance under the Nigerian Communications Act (2003) and the Infrastructure
Concession Regulatory Commission (ICRC) Act (2005). Below are the key models:
The InfraCo SPV Model
The InfraCo (Infrastructure Company) SPV model is a
licensed Public-Private partnership
arrangement designed to facilitate the deployment of fiber-optic
broadband infrastructure across Nigeria. Under this model, private sector
entities are granted regional licenses by the Nigerian Communications
Commission (NCC) to serve as InfraCos, responsible for rolling out open-access
metropolitan fiber-optic networks.
The Model was established under the NCC’s
National Broadband Plan (2020–2025), governed by the Nigerian Communications
Act (2003) and subject to PPP oversight under the ICRC Act (2005). However, the Licensing framework requires
InfraCos to meet stipulated Quality of Service (QoS) and Universal Access
Obligations. The benefits are to encourages regional broadband expansion,
reducing the cost of internet access, leveraging private sector expertise while
maintaining public interest oversight and ensuring infrastructure sharing and
non-discriminatory access to telecom operators.
Examples of InfraCos that are SPVs are: MainOne Cable Company Limited,
HIS Towers, Zinox Technologies and Broadband Communications.
Examples
MainOne
Cable Company Limited(Lagos InfraCo Licensee)
tasked with developing fiber-optic infrastructure to enhance broadband
connectivity in Lagos.[32] The InfraCo license granted to MainOne by the Nigerian
Communications Commission (NCC) is part of Nigeria’s National Broadband Plan to
drive open-access infrastructure development.[33]
An SPV is typically a company created for a specific purpose and as Lagos
InfraCo Licensee MainOne fits into the SPV
model. This is because MainOne was originally a wholesale submarine
cable and data services company but was
chosen for a specific purpose , that is as the InfraCo licensee for
Lagos to deploy metropolitan fiber infrastructure and provide last-mile
broadband connectivity. Also,MainOne as
Lagos State InfraCo Licensee in
collaboration with Tolaram Group also launched a multimillion-dollar
connectivity project at the Lagos Free Zone (LFZ).[34]The
project with Tolaram Group mentioned above
is aimed at boosting internet connectivity in the Lagos Free Zone, enabling
businesses and individuals to power their operations and provide services to
customers with high-speed internet. The project requires the deployment of over
50km of fibre optic network infrastructure from MainOne’s data centre located
at Ogombo to Lagos Free Zone. The partnership with Lagos Free Zone is to
provide strategic value to forward-thinking businesses who seek to enjoy the
ease of doing business. Organizations at the Zone will experience increased
speed, security, and connectivity ..[35]
IHS
Towers got its licence to cover the North Central
geopolitical zone including Abuja. The InfraCo licences are based on the NCC’s
Open Access Model (OAM) in line with the National Broadband Plan (NBP) of (2013
– 2018).[36] However,
in 2018, IHS returned the license to the NCC, citing difficulties in securing
Right-of- Way (RoW) approval to deploy equipment in the North Central zone of
Nigeria. The challenge of RoW shows how regulatory barriers could impede timely
network deployment by infraCos. [37]
Zinox Technologies & Broad-based Communications: Zinox Technologies and
Broad based communications were among the infrastructure companies (InfraCos)
licensed by the Nigerian Communications Commission to roll out metropolitan fibre-optic infrastructure
across Nigeria especially the Southeast
through the open-access model with
focus on deployment of broadband services.
Zinox Technologies and Broad-based Communications
were to enable high-speed broadband service through the open access model in the various geopolitical zones,
especially to deploy the services in the
South-east region.[38]
Open Access Model for Rural Telephony (PPP-SPV for
Underserved Areas).
This SPV model is tailored to extend telecommunications infrastructure to
underserved and rural areas where commercial viability is low. The Nigerian
government, through the Universal Service Provision Fund (USPF) under the NCC,
partners with private telecom companies to deploy rural broadband and mobile
connectivity infrastructure with funding from the USPF as provided under
Sections 112-120 of the Nigerian Communications Act (2003), which
establishes the USPF as a funding mechanism.[39]
The model also operates under PPP financing arrangements where the government
provides grants, subsidies, or co-financing through an SPV arrangement. It reduces the rural-urban digital divide
while lowering the cost of network expansion for private telecom operators
through government-backed incentives. It promotes telecom infrastructure
sharing through co-location and wholesale broadband services.
Examples
The USPF’s
Rural Broadband Initiative (RUBI) :
As stated earlier, an SPV is created for a specific purpose . The
initiative was set up using the PPP-SPV
model that is government and private
sector partnership specifically designed to deploy base stations, fiber-optic
connectivity, and mobile access points in underserved/rural communities in Nigeria.[40]
SPVs are usually created for specific projects,
and RUBI has a clearly defined goal under the National Broadband Plan
(NBP) . he USPF partners with licensed InfraCos such as Mainone and telecom
operators such as MTN to execute broadband expansion projects. any SPVs
are used in PPPs to facilitate government-funded projects while
involving private-sector execution, making RUBI an SPV.Thee USPF manages funds separately from the broader NCC
budget and ensures that these funds are only used for universal service
projects. This restricted funding model is a key SPV characteristic.
SPVs are often
subject to special regulatory conditions separate from the broader market. .
The USPF’s RUBI operates under specific NCC policies aimed at bridging the
digital divide, making it an SPV that
is subject to regulatory oversight.
Through the RUBI project, the USPF provides subsidies to operators for the
deployment of network to support the establishment of core delivery mechanisms
for broadband services in the rural/semi-urban areas of Nigeria.[41]
The Base Transceiver Station (BTS) Co-location Project, where private entities develop shared telecom towers
in rural areas. The BTS Co-location Project in Nigeria,
spearheaded by the Universal Service Provision Fund (USPF) and the Nigerian
Communication Commission (NCC), aims to improve telecommunications
infrastructure by encouraging shared infrastructure (like towers and masts)
among different operators, reducing costs and potentially improving service
quality.[42]
TowerCo SPV Model (Passive Infrastructure PPP
Arrangement)
This model involves the creation of independent Tower
Companies (TowerCos) as SPVs, responsible for deploying, owning, and
managing telecommunications towers, fiber backhaul, and passive infrastructure.
These SPVs lease infrastructure to telecom operators, thereby promoting cost
efficiency, infrastructure sharing, and environmental sustainability.[43] The SPV
model Operates under the Co-location and Infrastructure Sharing Guidelines
(2021) issued by the NCC[44] and also
complies with PPP principles under the Reviewed National Integrated
infrastructure Master Plan (NIIMP).[45] The good thing about this model is that
it lowers capital expenditure (CAPEX)
burdens on telecom operators ,reduces network duplication and fosters a greener
telecom ecosystem. It also enhances service quality and network resilience.
Examples
IHS Towers and American Towers Corporation (ATC
Nigeria) operate as SPVs by leasing
telecom towers to MTN, Airtel and 9mobile with IHS
Towers being a major player in Nigeria and other African markets.[46]
Rising partnerships with public entities such as NITDA
and State Governments to promote smart
city telecom infrastructure.[47]
The collaboration will involve eight cities nationwide in the first phase,
including Abuja, Lagos and one city selected from each of the six geopolitical
zones.
Government-Owned SPVs with Private Sector Concession
(Hybrid Model)
In some cases, the Nigerian government establishes
SPVs to own telecom infrastructure while granting long-term concessions to
private sector operators for management, maintenance, and service provision.
This ensures public ownership of critical infrastructure while leveraging
private efficiency. The ICRC Act (2005) and the Concession Guidelines under the
National Broadband Plan guide such hybrid models. The National Information
Technology Development Agency (NITDA) and the Ministry of Communications and
Digital Economy often act as the government stakeholders in such SPVs.[48] The
benefits include balancing public control with private efficiency, ensuring
long-term infrastructure sustainability through government-backed funding and
encouraging cross-sectoral telecom integration (e.g., e-government services,
smart grids).
Example
Galaxy Backbone Limited: An SPV owned by the Federal Government of Nigeria,
providing ICT and broadband services to government institutions while engaging
private telecom operators for infrastructure expansion. Galaxy
Backbone (GBB) has over time deployed state-of-the-art fibre optic network in
cities such as Lagos, Ibadan and Ilorin. [49]
Identified Regulatory Bottlenecks
licensing, approvals, competition and pricing on SPV Practice in Nigeria in
Telecom Infrastructure Deployment.
The deployment
of telecom infrastructure in Nigeria through Special Purpose Vehicles (SPVs)
and Public-Private Partnerships (PPPs) faces several regulatory bottlenecks,
primarily in the areas of licensing, approvals, competition, and pricing. Below
is a detailed analysis:[50]
Licensing
Bottlenecks
The Nigerian
Communications Commission (NCC) regulates telecom licensing under the Nigerian
Communications Act (NCA) 2003. However, the underlisted challenges persist:
Multiplicity of
Licensing Requirements: Telecom infrastructure developers often require
multiple licenses from federal and state governments including those for
infrastructure sharing, spectrum usage, and right-of-way (RoW), can lead to
bureaucratic delays.[51]
Slow License
Processing: The approval process for new telecom projects,
especially under the PPP model, can take months due to compliance checks and
inter-agency coordination.[52]
Fragmented Regulatory Jurisdiction: Apart from the NCC, other
agencies such as the National Environmental Standards and Regulations
Enforcement Agency (NESREA) and state governments impose additional licensing
hurdles.[53]
Approval
Bottlenecks
Right-of-Way
(RoW) Issues: Obtaining RoW permits from federal, state, and
local governments is often slow and costly. Different states impose varying
charges, which discourages investment. Though the telecom industry in Nigeria has been urged to
address critical barriers that hinder its growth, including right-of-way
bottlenecks and multiple taxation, which have continued to slow down
infrastructure development and digital transformation.[54]
Environmental
Impact Assessments (EIA): Projects require multiple approvals related to
environmental compliance, further delaying deployment.
Infrastructure
Co-location Challenges: While infrastructure sharing is encouraged,
approvals for co-location (e.g., multiple operators using the same towers) are
sometimes delayed due to anti-competitive concerns from dominant market
players.[55]
Competition Barriers
Market
Dominance by a Few Operators: The Nigerian telecom market is largely
controlled by a few big players like MTN, Airtel,Glo and 9mobile. This makes it
difficult for smaller SPVs or PPP-based operators to compete effectively.[56]
Interconnection
Challenges: New entrants face difficulties in obtaining fair
interconnection terms from incumbent operators, leading to unfair competition.[57]
Limited
Incentives for Small Players: The regulatory framework favors established
operators over smaller PPP initiatives, limiting market penetration for new
players.
Pricing Issues
High Cost of
Infrastructure Deployment: The cost of laying fiber optics and building
towers is high due to RoW fees, security challenges, and foreign exchange
volatility affecting equipment importation.[58]
Tariff
Regulations: The NCC regulates telecom tariffs, limiting the
flexibility of operators to set competitive pricing models.
Broadband and
Spectrum Pricing: The Frequency Pricing Regulations set high costs
for spectrum acquisition, discouraging new entrants from investing in broadband
expansion.[59]
Other
Challenges
Multiple
Taxation and Regulatory Bottlenecks: SPVs often face multiple levies from local,
state, and federal authorities, increasing project costs. The government is
working on a “one-stop-shop” regulatory approach to streamline compliance
requirements.[60]
Infrastructure
Security and Vandalism: Telecom infrastructure is vulnerable to vandalism,
theft, and sabotage, particularly in remote areas. The NCC and security
agencies are working on measures to enhance infrastructure protection.[61]
Emerging
Technologies
SPVs must adapt
to 5G deployment, satellite-based networks, and edge computing, requiring
continuous regulatory updates to accommodate new technologies.[62]
Addressing these regulatory challenges requires harmonization of
licensing procedures at all levels of government using a multistakeholder
approach, streamlining approval processes, reducing RoW fees, and creating a
more competitive pricing model. A clear regulatory framework for PPP and SPV in
telecom infrastructure deployment is essential to ensure sustainable sector
growth.
Why and How can the Current Initiative use SPV to Deploy 90,000 KM of
Fibre Optic Cables in Nigeria?
This section will address the following questions.
·
Should the new Initiative to use SPV Model to
deploy the 90,000KM Fibre optic cables
be subjected to the same bottlenecks /challenges currently experienced
in the telecom industry?
·
Or should it be a unique model devoid of these pricing competition
and licensing regulatory bottlenecks?
·
If yes what about the fear of abuse of
dominance position ?
Should the new
Initiative to use SPV Model to deploy the 90,000KM Fibre optic cables be
subjected to the same bottlenecks /challenges currently experienced in the
telecom industry?
The deployment of 90,000 km of fiber optic cables in Nigeria through a
Special Purpose Vehicle (SPV) model is crucial for national broadband
expansion. The development of the Strategic Plan for the Federal Ministry of
Communications, Innovation and Digital Economy by the Minister is laudable,
however there is an urgent need for a policy framework for implementation of
the strategic plan especially pillar 3 of the strategic document which is on
infrastructure.[63]
Pillar 3 specifically stated the need to
construct a robust digital infrastructure for a prosperous digital economy. The goal is
the laying of 90,000 kilometers of fiber optic cable and others. However, previous infrastructure projects
have encountered significant regulations, competition, and pricing
bottlenecks as well as challenges
arising from the RoW which must be addressed if we want the initiative of
laying 90,000 KM fibre optic cables to succeed.[64] The bottlenecks that must be addressed are as
follows:
Regulatory Bottlenecks to avoid
a. Delays in
Licensing and Approvals Multiple
Agency/ State and Local Government Approvals: The Nigerian
Communications Commission (NCC), National Environmental Standards and
Regulations Enforcement Agency (NESREA), State governments,[65] and
Local government councils all impose different regulations, leading to
bureaucratic delays. This must be avoided for
the initiative to lay 90,000
kilometers of fibre optic cable to
succeed.
Right-of-Way
(RoW) Challenges: The high cost and inconsistency of RoW charges
across states have historically slowed fiber deployment. Despite NCC
interventions, some states still impose exorbitant fees, delaying
infrastructure rollout. This must be avoided for the initiative to succeed.
Slow
Environmental and Technical Approvals: Long approval times for environmental impact
assessments and technical permits have hampered past broadband projects. This
should also be fast tracked for the laying of the 90,000KM fibre optic cables
to succeed.
b. Inconsistencies in Regulatory Frameworks
The InfraCo
model introduced by the NCC has faced repeated reviews due to funding and
implementation challenges. [66] There
is need to ensure regulatory stability
free from the identified bottlenecks mentioned above to facilitate the new SPV Initiative and also prevent constant adjustments that
could delay execution . Lack of inter-agency coordination/collaboration often
results in conflicting regulations, increasing the cost and complexity of
compliance for investors.
Competition Bottlenecks to Avoid
a. Risk of Market Monopoly and
Anti-Competitive Practices
If a single operator dominates the SPV initiative, it could lead to
monopolistic control of broadband infrastructure, limiting competition. This
should be avoided by encouraging other operators to explore the initiative .. To avoid this also, an open-access model
should be enforced, ensuring that all licensed operators have equal and
non-discriminatory access to the fiber network especially the 90,000 KM fibre
optic cables initiative.
b. Challenges in Infrastructure Sharing
Dominanttelecom operators sometimes resist infrastructure sharing,
preferring to control their own networks. If dominant players discourage
smaller ISPs from accessing fiber infrastructure, broadband expansion goals
will not be met and the aim of the initiative to lay 90,000Km fibre optic
cables will be defeated. Regulatory oversight is needed to enforce fair
infrastructure-sharing rules and prevent anti-competitive behavior.[67]
Pricing Bottlenecks to Avoid
a. High Cost of Infrastructure Deployment
Excessive RoW charges, forex fluctuations affecting fiber equipment
importation, and multiple taxation increase the overall cost of fiber optic
deployment. The government should standardize RoW fees nationwide and provide
tax incentives to SPV investors to reduce costs.
b. Unfair Pricing Models for Broadband Access
If the SPV
controlling the fiber network imposes high leasing costs, smaller ISPs and
telecom operators may struggle to afford access, limiting broadband
affordability for consumers.
Pricing
regulations must ensure that fiber access costs are reasonable and transparent,
with NCC oversight preventing price gouging.
To ensure the
success of the 90,000 km fiber optic deployment, the government and regulators
must:
i. Streamline licensing and approvals
through a single-window clearance system.
ii. Standardize Right-of-Way (RoW)
fees across all states.
iii. Enforce open-access
infrastructure to prevent monopoly abuse.
iv. Provide incentives such as
tax breaks for private investors in SPVs.
v. Security
of Infrastructure -ensure protection of infrastructure
vi. Ensure cost-based pricing to promote broadband affordability.
Therefore to address the question: - ‘Should deployment of
the 90,000KM fiber optic cables be
subjected to a unique model devoid of
these pricing , competition and licensing
regulatory bottlenecks? . The deployment of the fiber optic cable
should be devoid of the above mentioned bottlenecks to accelerate broadband
penetration in Nigeria. By addressing the existing bottlenecks, Nigeria can
accelerate broadband penetration in line with the National broadband Alliance
for Nigeria Policy initiative[68] which
aims to expand internet access nationwide and attract investment and create a
more competitive telecom market. The national Broadband alliance aligns with
the Nigeria’s National Broadband Plan (2020-2025)[69] and
Strategic Blueprint which promotes the deployment of 90,000 KM fiber optic
cables across the country.
If yes what about the fear of
abuse of dominance position? It has been identified earlier that where a
single entity dominates the SPV initiative, it could lead to monopolistic
control of broadband infrastructure, limiting competition. This should be
avoided for the initiative to succeed. To avoid this, an open-access model
should be enforced, ensuring that all licensed operators have equal and non-discriminatory
access to the fiber network especially the 90,000 KM fiber optic cables
initiative. Once the open access model
is used, it will address the fear of dominance position.
Therefore, SPV is the best tool to explore for deployment of the 90,000KM
fiber optic cables in Nigeria, outside being a laudable initiative it will
expand broad band penetration in Nigeria and where possible end the issue of
dominance position once a single entity does not dominate the SPV initiatives.
However, the open access model is encouraged when deploying SPV in the telecom
sector. Also, the deployment of the SPV for the 90,000KM fiber optic cables
should be devoid of the existing regulatory, pricing, and licensing challenges
currently experienced[70] in the
telecom sector.
Regulatory Impact Analysis
Introduction of a new regulatory framework for Special Purpose Vehicles
(SPVs) in Nigeria’s telecom sector presents an opportunity to address existing
challenges and reshape market dynamics. While SPVs have the potential to
enhance infrastructure development and attract investment, it is crucial to
ensure that dominant players such as MTN, Airtel,9mobile and Glo do not exploit
these entities to reinforce their market power.[71] A
well-structured regulatory framework for
the Nigerian Telecom sector must be designed to promote competition, ensure
fair infrastructure access, and prevent anti-competitive behavior.
The current regulatory framework in the Nigerian telecom sector faces
several challenges which has been discussed earlier in this paper and these
challenges hinder the effective utilization of SPVs. One major issue is the
limited infrastructure-sharing policies, which allow dominant players to
control essential telecom assets and restrict access to smaller operators.[72]
Additionally, there are regulatory gaps in the governance and oversight of
SPVs, [73]creating
loopholes that could be exploited by major telecom firms to entrench their
market dominance. The complex licensing and compliance procedures further
discourage new entrants from investing in infrastructure, reinforcing the
stronghold of existing market leaders.
A well-designed SPV regulatory framework can significantly alter the
structure of the telecom industry by ensuring that infrastructure-sharing is
fair and inclusive. One of the most critical aspects of this framework should
be the prevention of dominance abuse. If left unchecked, MTN, Airtel, 9mobile
and Glo could create SPVs that limit competition by controlling access to
telecom infrastructure. To mitigate this risk, the new regulatory framework should
mandate open-access policies, ensuring that infrastructure financed and
developed through SPVs is available to all operators under transparent and fair
conditions. This would help foster a competitive environment where smaller
players can participate without being unfairly excluded.[74]
The financial and investment climate in the telecom sector would also
benefit from a reformed SPV framework. By providing clear guidelines on SPV
ownership, taxation, and governance, the regulatory framework can enhance investor
confidence and attract foreign direct investment. Institutional investors, both
domestic and international, would be more willing to invest in Nigerian telecom
infrastructure if there were assurances of transparency, fair competition, and
regulatory stability. Additionally, a well-structured SPV system can help
telecom operators mitigate financial risks, enabling them to undertake
large-scale projects without directly exposing their core businesses to
significant liabilities. However, it is essential that regulations prevent
dominant players from exploiting SPVs to engage in regulatory arbitrage, such
as tax evasion or circumventing market rules.
Regulatory oversight will play a crucial role in ensuring that SPVs do
not become tools for anti-competitive behavior. The Nigerian Communications
Commission (NCC), in collaboration with the Federal Competition and Consumer
Protection Commission (FCCPC), must establish clear anti-trust regulations to
prevent collusion among dominant players. Stronger monitoring mechanisms should
be put in place to oversee SPV activities, ensuring that they do not serve as
disguised extensions of major telecom firms seeking to monopolize
infrastructure access. Additionally, independent licensing for SPVs should be
introduced, with strict conditions to prevent exclusive control by dominant
telecom operators.
To ensure the effectiveness of the new SPV regulatory framework, several
policy measures should be implemented. First, anti-competitive safeguards must
be enforced, preventing SPVs from being monopolized by major operators.
Infrastructure-sharing should be mandated, requiring SPV-funded networks to be
accessible to all telecom service providers on a fair and non-discriminatory
basis. Furthermore, an independent regulatory body should be established to
oversee SPVs separately from traditional telecom operators, reducing the risk
of biased decision-making. Lastly, regulatory authorities should collaborate
with anti-trust bodies to ensure that the framework aligns with competition
laws and consumer protection policies.[75]
Finally, the introduction of a new SPV regulatory framework in Nigeria’s
telecom sector has the potential to drive competition, attract investment, and
improve infrastructure development for deployment of the 90,000KM fibre optic
cables.. [76]However,
the framework must be carefully structured to prevent market abuse by dominant
players such as MTN, Airtel, 9Mobile and Glo. Through strict regulatory
oversight, open-access policies, and robust anti-trust measures, SPVs can serve
as a tool for industry-wide progress rather than a mechanism for reinforcing
existing monopolies. If properly implemented, this regulatory reform could
create a more competitive and inclusive telecom market, ultimately benefiting
consumers, investors, and smaller industry players alike.
Lessons Learned and Recommendations on How
to Address the Regulatory Bottlenecks on SPV Practice in the Telecom
Infrastructure Deployment in Nigeria.
This section will examine the lessons
learned and recommendations on the
need to
simplify or introduce a new SPV regulatory framework for the telecom sector
devoid of the existing bottlenecks to promote industry progress in the
deployment of infrastructure in Nigerian
telecom sector.
Lessons Learned
The Special Purpose Vehicle (SPV) initiative presents a significant
opportunity for enhancing infrastructure deployment in Nigeria’s
telecommunications sector. While the National Communications Act (NCA) 2003 and
Nigerian Communications Commission (NCC) regulations provide a solid
foundation, they were not designed to address the complexities of emerging
technologies and innovative financing models such as SPVs. Existing laws and
regulatory frameworks lack clear provisions for the governance, operation, and
risk mitigation strategies required for SPVs to function effectively in telecom
infrastructure projects. Without targeted reforms, the implementation of SPVs
may face legal uncertainties, bureaucratic bottlenecks, and challenges related
to competition and market dominance.
To fully harness the potential of SPVs, law and policy reforms must
establish a clear regulatory framework that defines the rights, obligations,
and risk-sharing mechanisms among stakeholders. Given the dominance of major
telecom operators such as MTN, Airtel, and Glo, regulations should incorporate
safeguards to prevent anti-competitive practices while encouraging fair
participation from smaller industry players. Additionally, frameworks should
address issues such as acscess to financing, ownership structures, and dispute
resolution mechanisms to ensure that SPVs operate efficiently and
transparently. A forward-looking regulatory approach will not only promote
investment in critical infrastructure but also enhance the sustainability and
scalability of telecom projects across Nigeria.
Achieving these reforms requires a multistakeholder approach, involving
government agencies, industry players, financial institutions, consumer
advocacy groups, and international partners. Collaborative engagements will
help identify regulatory gaps, mitigate risks, and develop policies that
balance innovation with public interest. Regular stakeholder consultations,
regulatory sandboxes, and pilot programs can serve as effective mechanisms for
testing and refining SPV models before full-scale implementation. By fostering
an inclusive regulatory environment, Nigeria can create a resilient telecom
infrastructure framework that supports emerging technologies while ensuring
equitable and competitive market conditions.
Conclusion
The deployment of Special Purpose Vehicles (SPVs)
within PPP frameworks has significantly enhanced the expansion of Nigeria’s
telecommunications infrastructure. Each model, whether InfraCo licensing, rural
broadband PPP-SPVs, TowerCo leasing arrangements, or government-owned hybrid
SPVs plays a critical role in fostering financial sustainability, network
expansion, and regulatory compliance. However, to maximize the effectiveness of
SPV-PPP models in the telecommunications sector, Nigeria needs to enhance legal
frameworks to ensure transparency and accountability in PPP arrangements,
streamline regulatory approvals to reduce bureaucratic delays in SPV licensing
and infrastructure deployment and strengthen investor confidence through legal
safeguards, enforceable contracts, and dispute resolution mechanisms. By
refining these models, Nigeria can accelerate its broadband penetration, bridge
digital divides, and position itself as a leading ICT hub in Africa.
[1] Nigerian Communications Act, 2003
[2] NCC Licensing Regulations
2019
[3] NCC Competition Practices
Regulations 2007
[4] Frequency Spectrum (Fees
and Pricing, etc.) Regulations 2004
[5] ibid n5; s31 (1)
[6] ibid s32
[7] Licensing Regulations
2019, r10 (1) (a)
[8] ibid r10 (1) (b)
[9] ibid r 10 (1) (c)
[10] ibid r 10 (1) (d)
[11]ibid r10 (1) (e)
[12] ibid r 10 (2) (a)
[13] ibid 10 (2) (b)
[14] ibid n5; s 91 (1)
[15] ibid s91 (2)
[16] Competition Practices
Regulations 2007, r 3
[17] ibid r 6 ((a)- (e))
[18] ibid n31; s91 (3)
[19] ibid n33 r8
[20] ibid n31; s108
[21] ibid 108 (4)
[22]NCC Consumer Portal,’
Policy Competition and Economic
Analysis’<https://consumer.ncc.gov.ng/information-educationfaqs/37-policy-competition-economic-analysis>accessed
31 March 2025
[23] NCC, Regulations < https://ncc.gov.ng/> accessed 28 March 2025
[24] NCC,
Licensing Application Process <https://ncc.gov.ng> accessed 28 March 2025
[25] ULR: VGC, Bodex,
MTN, Danjay scale NCC hurdle <https://www.itrealms.com.ng> accessed 28 March 2025
[26] Ibid (n.21)
[27] Ibid (N.18)
[28] NCC, Guidelines On Co-Location And Infrastructure Sharing https://ncc.gov.ng accessed 28 March 2025
[29] Federal Competition and
Consumer Protection'Act, 2018 https://fccpc.gov.ng accessed 28 March 2025
[30] Ibid (n.25)
[31] Universal Service
Provision Fund <https://www.uspf.gov.ng>accessed 28 March 2025
Infrastructure Concession Regulatory Commission. PPP Manual for Nigeria <
https://www.icrc.gov.ng> accessed 29 March 2024
World Bank Group, Strategy and PPP Options for
Supporting the ICT Sector and Broadband Connectivity in Somalia <https://documents.worldbank.org>
accessed 29 March 2025
the need for the operators to be involved and
to mitigate their risks, and the likely difficulty in attracting sufficient
investment to rely solely on commercial interest, some mix between a commercial
joint
venture and cooperative SPV may be favoured.
Commercial
Joint Venture:
This PPP structure is centered on investor participants (both international and
national, and from both inside and outside the sector) that establish a
for-profit commercial enterprise as a unique entity for the provision of
wholesale connectivity services and in limited cases retail
capacity. This structure is highly dependent on investors willing to assume the
risk of participation.
Cooperative: A cooperative approach is
one in which capacity rights are determined by investment in a Special Purpose
Vehicle (SPV), a legal entity created by the sponsor or originator to fulfill a
temporary objective. Here, the SPV would likely build, own, and operate the
national backbone. Wholesaling in this model is not a profit driven process,
and as such, market competition is pushed to the access network providers.
In 2008, the Gambian government entered
discussions to join the Africa Coast to Europe (ACE) submarine cable, an Orange
Group initiative to connect Europe
to the west coast of Africa. The government set up a SPV that later
received a World Bank loan for US$25 million to fund its investment in the ACE
cable and include a Gambian landing station. The plan called for divesting part
of the shareholding of the vehicle to the private sector on favourable terms as
an incentive for participation in the PPP. This occurred in 2012, with a total
of 51% divested to Gambian ISPs. As further incentive, Gambia has not charged a
fee to the SPV for the licence to operate a submarine cable landing station and
has informally indicated that it is likely to not charge for any subsequent
cable landings. The cable began service in December 2012.
[32] Nigerian
Investment Promotion Council, Mainone to Invest N2bn in Lagos Fibre Infratructure <
<https://www.nipc.gov.ng/2019/05/22/>
accessed 5 March 2025
[33] NCC, Press
Release : NCC Board approves
Two New Infraco Licenses for South East and North East < https://ncc.gov.ng > accessed 7 March
2025
[34] MainOne
kicks off multimillion-dollar connectivity at Lagos Free Zone < https://lagosfreezone.com> accessed 7 March 2025
[35] Ibid
[36] NCC, Press
Release : NCC Board approves
Two New Infraco Licenses for South East and North East < https://ncc.gov.ng > accessed 7 March
2025
[37] Fakade Aina,Critical
Review of InfraCo Licensing Project in Nigeria <https://www.linkedin.com>
[38] extensia ,
Nigeria: ZInox to deploy Fibre Optic Cable Infrastructure in South East
<https://extensia.tech/>
accessed 7 March 2025/
[39] The Nigerian
Communication Commissions Act 2003, S.114
[40] RUBI, Rural
Broadband Initiatives
<https://www.uspf.gov.ng> accessed 8 March 2025
[41] Ibid
[42] BTS-Base
Transceiver Stations
<https://www.uspf.gov.ng> accessed 8 March 2025
[43] Christopher Greaves, ‘Pan African Towers embarks on its next
strategic phase’ < https://www.towerxchange.com> accessed 8 March
2025
[44] NCC, Guidelines on Co-;location and
Infrastructure Sharing 2021 <https// ncc.gov.ng> accessed 8 March 2025
[45] Reviewed
National Infrastructure Plan 2020,< https://nationalplanning.gov.ng> accessed 7 March 2025
[46] Joseph Olaoluwa, MTN Nigeria renegotiates
Tower Lease with HIS and ATC quashes conflict rumours <https://techcabal.com>
accessed 6 March 2025
[47] Itedgenews, NITDA Collaborates with States on Smart City
Initiatives < https://www.itedgenews.africa/> accessed 7 March 2025
[48] Federal Ministry of Communications, Innovation and
Digital Economy, Ministry Receives Presidential Approval Towards Increasing Nigeria’s Connectivity backbone by 90,000km
<https://fmcide.gov.ng> accessed 8 March 2025
[49] NCC, NCC strengthens ties
with Galaxy Backbone on Digital Connectivity<https://www.ncc.gov.ng/>
accessed 6 March 2025; Galaxy Backbone’s
Fibre Optic Network Now Live in Lagos, Ibadan and Ilorin < https://galaxybackbone.com.ng> accessed 6 March
2025
[50] NESG Research
, Making Public-Private Partnerships work in Nigeria
<https://www.ajol.info> accessed 9 March 2025
[51] Maxwell Ukpeborang Oluwole and another , Federal High Court
Upholds Powers of States to Regulate siting of Telecom Infrastructures
https://www.mondaq.com> accessed 10 March 2025
[52] Ibid
[53] Ibid
[54] Justice Okamgba, Telcos Urged to overcome ROW Bottlenecks and Multiple Taxation < https://punchng.com>
accessed 10 March 2025
[55] Seun Ibiyemi, Telecom
sector risks stifled growth, underinvestment amidst grappling challenges < https://nigeriannewsdirect.com> accessed 11 March 2025.
[56]
Olayinka Adigun,
Dominance dilemma: Market consolidation and averting potential monopoly in
Nigerian telecoms sector< ttps://businessday.ng> accessed 10 March 2025
[57] Ibid
[58] Seun Ibiyemi, Telecom sector risks stifled
growth, underinvestment amidst grappling challenges < https://nigeriannewsdirect.com> accessed
11 March 2025
[59] Ibid
[60] Deji Elumoye, Tinubu: We’ll
Review Our Telecom Sector’s Regulatory Framework and Operations < https://www.thisdaylive.com> 11 March 2025
[61] NCC , NCC and NSCDC sign MOU on Critical Telecommunication
Infrastructure Protection < https://www.ncc.gov.ng> accessed 10 March
2025 .
[62] See the National Policy on Fifth generation (5G) Networks
for Nigeria Digital Economy < https://fmcide.gov.ng> accessed 11
March 2025
[63] Timi Olagunju , A
critique of the Strategic Plan for
Ministry of Communications, Innovations and digital economy
<https://www.thecable.ng> accessed
11 March 2025.
[64] Royal Ibe , How FG can
Achieve 90,000KM Fibre Project <https://leadership.ng> accessed 11 March 2025
[65] Juliet
Umeh , States threaten FG’s ambitious 90,000km fibre
project < ttps://www.vanguardngr.com>
accessed 12 March 2025
[66] Ibid (n.2)
[67] Osasómé C.O, Telecom Stakeholders warn
of Challenges to Nigeria’s 90,000KM Fiber Optic Project <https://www.itedgenews.africa> accessed 11 March 2025
[68] Federal Ministry of Communications, Innovation
and Digital Economy, Ministry Receives
Presidential Approval Towards Increasing Nigeria’s Connectivity backbone by 90,000km
<https://fmcide.gov.ng> accessed 8 March 2025
[69] NDPC, Nigeria
Launches National Broadband Alliance to Drive Connectivity < https://ndpc.gov.ng> accessed 11 March 2025
[70]
Chinenye
Anuforo, challenges cloud Nigeria’s
ambitious 90,000km fibre optic projecthttps://thesun.ng/ accessed 11 March 2025.
[71] Olayinka Adigun , Dominance dilemma: Market consolidation and averting
potential monopoly in Nigerian telecoms sector < https://businessday.ng> accessed 13 March 2025.
[72] The World
Bank, The Infrastructure Sharing Imperative
https://digitalregulation.org/ accessed 17
March 2025
[73] Joseph Yusuf ONNI, Demystifying Special Purpose
Vehicles (SPVs) in Investment: Understanding Limitations and Strengths <
https://medium.com> accessed 12 March 2025
[74] Ibid
[75] The World
Bank, The Infrastructure Sharing Imperative
https://digitalregulation.org/ accessed 17
March 2025
[76] Samson
Akintaro, FG to provide 50 percent funding
for 90,000 KM fibre project
through loans -Bosun Tijani < https://nairametrics.com/> accessed 11 March
2025.
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