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What COAI, Jio, Airtel have said about TRAI’s WiFi consultation paper


In a submission (pdf) to TRAI’s consultation on ‘Proliferation of Broadband through Public Wi-Fi networks’, telecom lobby association COAI has contended that Internet services in the country, delivered via WiFi, Cellular networks or any wired technology, can be provided  “only by licensed TSPs/ISPs who have their own network to extend the last mile access”.

In July TRAI suggested in a consultation that “there could be small entrepreneurs or even a very small entity (such as small stores) which would like to participate in common and shared WiFi network for larger public use.  However COAI said that the notion of using “public Wi-Fi networks for providing ubiquitous citywide coverage is incorrect,” since cellular networks owned and operated by telcos are the only mediums that can be used to expand broadband on a citywide or circle-wise basis.  

How COAI reasons that WiFi should be deployed by telcos only

To support these comments, COAI indicates how Wi-Fi as a technology has evolved over the years stating that WiFi was originally developed to facilitate users to connect their devices via a wireless medium rather than the legacy wired medium. “Overtime Wi-Fi was also used for accessing Internet as well,” and to an extent WiFi technology can be used to create smaller hotspots for non-commercial use within people’s houses, hotels or companies after buying broadband from telcos, adds the lobby body

“Thus,  only  Licensed  TSPs/ISPs  having  their  own  networks  to  enable  access  up  to  the last mile are allowed to provide Internet Access in the current Licensing Regime. Any reselling of data can happen only through MVNO route, for which, the framework has already  been laid  down,” COAI said in the submission.

‘WiFi is just like another medium of Internet access’: COAI further refers to the current Unified License regime, stating that “there is no separate category of Wi-Fi service providers in the licensing regime”, and that WiFi is just an “access technology” like any other technology used for providing Internet access like GSM, HSPA, LTE or DSL. Telcos pay huge amounts for acquiring spectrum, and other extra levies and dues, while it asks the regulator to consider lowering such levies to help spread broadband in the country.

On de-licensing spectrum for Wifi services :In addition, the lobby association contends that there is no need to de-license any additional spectrum for WI-Fi, especially under the sub-1GHz band since “”DoT  has  already  stated  that  it  will  not  be  de-licensed”. However note that he DoT’s stance of not releasing unlicensed white space spectrum in the 470-698MHz spectrum band seems to come after COAI pressurized it stating that “unlicensed usage of devices” could cause inferences in the network and that such spectrum should be accessible to licensed players only. The direction from DoT comes as a blow to Microsoft and Google who have been piloting use of white spaces for providing internet connectivity in rural reaches.

What other telcos said in their submission

Reliance Jio

Jio, which is also a part of the COAI said in its submission (pdf) that the country could look into city-wide models of public Wi-Fi for promoting a higher Internet adoption rate. These models can be categorized as follows (according to Jio):

  1. Complete Public Funding: Public WiFi projects funded by municipal corporations or state governments.
  2. Public Private partnerships: Municipalities could partner with ISPs and/or advertisers to fund public Wi-FI projects. Customers could be provided with free access for certain amount of time or until a data-limit and later could be charged for further use.
  3. Complete Private Funding: Private ISPs could fund an entire Public WiFi project and install these in cities, and other state-owned areas and locations with permission from the relevant authorities.

Monetization via Wifi services: Jio also suggested implementing voice over WiFi (VoWiFi) to further monetize from such public hotspots and to provide an alternate voice service to customers. Offloading cellular data by charging customers directly from data packs instead of paying a standalone price for WiFi access was also suggested. In addition, Jio also proposed implementing data analytics by recording usage patterns of customers on Public WiFi networks. Such data can be compiled and sold to merchants looking for means of targeted advertising, added Jio.

‘Only licensed players should be allowed to provide WIFi’: However Jio also contends that WiFi services should be provided only by licensed telecom players: “There have been cases where it can be seen that some non-Telecom players set up hotspots and offer WiFi as a complimentary service. Such practice should be discouraged with effective licensing regime enforcement.”

On de-licensing more spectrum for WiFi, Jio differs from what COAI said. The Ambani-owned telco suggested de-licensing spectrum in the 2.4GHz and 5GHz bands while stating that this could help deliver significant benefits and economic value. “In India, as of now only two channels are available for outdoor use in the 5GHz band. There is a need to allow other channels as well which can be used for indoor purposes,” it added.

Bharti Airtel

Airtel in its submission states that WiFi as a technology is only meant for indoor locations or smaller outdoor locations, and because of this limitation, WiFi shall not be used to build and maintain ubiquitous stand-alone city-wide networks. The telco further said that WiFi hotspots should not be considered for expansion in rural/remote areas, because of this limitation.

“Qualitative  and  quantitative  analysis (pdf) of  some  of  the  most  advanced markets reveals that the majority of today’s Wifi traffic is incremental or  complementary to cellular traffic,” said Airtel in its submission.

Further Airtel asks the regulator to bring down costs and suggested levying zero license fee for providing Internet services via Public WiFi hotspots. It also recommended creating Right of Way permission for setting up hotspots, and setting up kiosks at particular locations to help proliferate Internet access via WiFi.

Customers do not pay after free-usage limits: Interestingly, Airtel says that customers use WiFi hotspots “as long as they are made available for free of cost” and most of them stop paying for the service after they exhaust initial free data limits. “Thus, the myth of Wifi as a free service should also be dismantled to encourage more people to pay for Wifi services.  This will significantly improve the business case of a stand-alone WiFi network,” added Airtel.

Regarding de-licensing more spectrum for Wifi hotspots: Existing spectrum that is unlicensed for providing WiFi services are underutilized, Airtel said in its submission. It therefore sides with COAI’s stance that no more spectrum should be de-licensed for providing Wi-Fi services. “We, therefore, recommend that as a policy unlicensed band for outdoor usage should be kept away from licensed  bands assigned to telecom operators via auction,” added Airtel.  The telco also reiterated what COAI had said in a letter to DoT in May regarding de-licensing TV white space spectrum. It states that “there are no TV white spaces in India” and spectrum band in the 470-698Mhz is largely unused in the country.

“Therefore the  very  term  White Spaces, is a misnomer and any allocations in the spectrum band 470-698 MHz should not be done in a manner  that will distort the market through inappropriate or inequitable  regulation resulting in an unfair advantage much against the principle of level playing field,” added Airtel.

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