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Licensing, roaming charges, spectrum management, privacy of users: TRAI’s IoT paper


IoT based devices and smart systems installed at homes, offices are now under the TRAI’s scrutiny, as it seeks to regulate Machine-to-Machine (M2M or IoT) devices under a licensing framework, set national/international roaming charges, assign spectrum, determine QoS and privacy of users, among others things.

In a consultation paper (pdf) titled “Spectrum, Roaming and QoS related requirements in M2M Communications”, TRAI notes that IoT devices communicate over several networks: WiFi, Bluetooth, cellular networks, another specialized Local and Wide Area Networks. Therefore, “in case of wireless, different spectrum bands may be used…they may be used on IP protocol but could also use SMS, USSD, and automated calls…,” TRAI added. It is seeking comments from stakeholders to regulate Machine-to-Machine communication or broadly wired/wireless networks that allow devices, machines to communicate with each other.

The regulator has identified 8 different industry verticals in which IoT/M2M devices can operate, and TRAI says that it is hence necessary to have a “collaborative approach” to form a common architecture (for devices) to facilitate interoperability. “This will not only allow a uniform framework but also achieve economies of scale and interoperability standards across different domains,” according to  TRAI.

Why TRAI wants to regulate IoT/M2M

The regulator proposes several reasons throughout the paper stating why M2M and IoT needs to be regulated. These include:

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Reducing complexity by creating an open infrastructure that could ultimately lead to services and applications to run on a single framework.
Cost savings by pooling several independent application under singular architecture or framework.
To allow sensor information to be shared in a secure manner across any application, and to allow any device to connect with any application.
To develop communication standards for M2M/IoT. TRAI seeks to develop standards through global partnerships and mentions that the oneM2M alliance for standards formed between 8 countries (including India) and consortiums could benefit the Indian M2M/IoT market. “The existence of standards guarantees that components of different suppliers and technologies can interact seamlessly,” TRAI added.
Cyber security related issues including vulnerability in networks in which IoT devices are connected to. “A hacker may be able to penetrate into important establishments and pose a threat to national security triggered due to online systems,” the regulator said.

How the TRAI plans to regulate M2M/IoT communication

  • Regulation of TSPs providing M2M/IoT service under UL: Few telecom service providers are planning to launch IoT services in the country, and in context of M2M, some providers also use unlicensed spectrum to launch WiFi. For this, TRAI suggests to “amend their license to facilitate M2M services or add a chapter of authorization in the Unified License for the new licensees.
  • By regulating M2M service providers/non-telco based providers under MVNO license: TRAI said that such service providers “could either be a licensed entity with certain obligations cast upon it or be a registered agency with DoT. For non-telecom providers TRAI suggests “adding one chapter in VNO license so that M2M Service Proiders (MSPs) can obtain authorization for M2M services using backend infrastructure of the existing TSPs.”
  • By identifying spectrum bands for M2M/IoT: Several devices, and vehicles these days use IoT based sensors, and these can run on multiple networks including LANs, MANs, WANs, and other Wireless networks. And in case of radio or cellular networks, M2M can use both licensed and unlicensed spectrum to operate, according to TRAI. “There is a need to clearly identify the bands as well as the quantum of spectrum for M2M communication at this stage itself so as to promote ecosystem development in those bands,” it added.
  • Using LTE bands (700MHz) for hosting IoT communication: TRAI mentioned that the premium 700 MHz band which had no takers for this year’s auctions could be used for IoT devices that use cellular networks. “One option could be to explore technical feasibility of utilizing a portion of center gap spacing for say 3 MHz (751-754 MHz) for M2M operations as a long term  perspective as  unlicensed band for M2M/IoT usages,” said TRAI.
  • By determining tariff for national/international roaming: Devices and some automobile manufacturers use SIM-supported method to connect it to the Internet. For Interconnection between SIMs, M2M and IoT providers could either be assigned their own set of Mobile Number Codes (MNCs) or partner with a telecom service provider to provide numbering and identification. However, TRAI points out that it is beneficial for M2M/IoT providers to have their own set on numbering system rather than partnering with telcos. “…it is important to estimate segment wise the percentage of M2M devices that shall require national and international roaming (regulations),” added TRAI.
  • By assuring security of data: Different IoT/M2M services will have different requirements for security and TRAI mentioned that there is an impending need to ensure reliable and secure communication between devices. The regulator said that since some IoT devices might connect with servers outside the country it poses national level challenge for law enforcement agencies to carry out lawful interception. Therefore TRAI is seeking comments from stakeholder to overcome these challenges.
  • By ensuring user privacy: IoT/M2M devices can also pose a threat to user privacy since some devices are installed in intimate spaces like homes, cars, wearables, etc. “Deriving value from IoT depends on the ability of organizations to collect, manage and mine data. Securing such data from unauthorized use and attacks will be a key concern,” TRAI mentioned.
  • By taking user consent before collecting data: Some user data generated through use of IoT and M2M may be personal or commercially sensitive, so “it will be important to ensure that it is stored and processed securely and in the  manner in which users have previously agreed,” added TRAI.

Questions for consultation

TRAI has issued a 16-point questionnaire regarding this consultation paper. These are attached below:

Q1. What should be the framework for introduction of M2M Service providers in the sector? Should it be through amendment in the existing licenses of access service/ISP license and/or licensing authorization in the existing Unified License and UL (VNO) license or it should be kept under OSP Category registration? Please provide rationale to your response.

Q2. In case a licensing framework for MSP is proposed, what should be the Entry Fee, Performance Bank Guarantee (if any) or Financial Bank Guarantee etc? Please provide detailed justification.

Q3. Do you propose any other regulatory framework for M2M other than the options mentioned above? If yes, provide detailed input on your proposal.

Q4. In your opinion what should be the quantum of spectrum required to meet the M2M communications requirement, keeping a horizon of 10-15 years? Please justify your answer.

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Q5. Which spectrum bands are more suitable for M2M communication in India including those from the table 2.3 above? Which of these bands can be made delicensed?

Q6. Can a portion of 10 MHz centre gap between uplink and down link of the 700 MHz band (FDD) be used for M2M communications as delicensed band for short range applications with some defined parameters? If so, what quantum? Justify your answer with technical feasibility, keeping in mind the interference issues.

Q7. In your opinion should national roaming for M2M/IoT devices be free?

(a) If yes, what could be its possible implications?

(b) If no, what should be the ceiling tariffs for national roaming for M2M communication?

Q8. In case of M2M devices, should;

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(a) roaming on permanent basis be allowed for foreign SIM/eUICC; or

(b) Only domestic manufactured SIM/eUICC be allowed? and/or

(c) there be a timeline/lifecycle of foreign SIMs to be converted into Indian SIMs/eUICC?

(d) any other option is available?

Please explain implications and issues involved in all the above scenarios.

Q9. In case permanent roaming of M2M devices having inbuilt foreign SIM is allowed, should the international roaming charges be defined by the Regulator or it should be left to the mutual agreement between the roaming partners?

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Q10. What should be the International roaming policy for machines which can communicate in the M2M ecosystem? Provide detailed answer giving justifications.

Q11. In order to provide operational and roaming flexibility to MSPs, would it be feasible to allocate separate MNCs to MSPs? What could be the pros and cons of such arrangement?

Q12. Will the existing measures taken for security of networks and data be adequate for security in M2M context too? Please suggest additional measures, if any, for security of networks and data for M2M communication.

Q13. (a) How should the M2M Service providers ensure protection of consumer interest and data privacy of the consumer? Can the issue be dealt in the framework of existing laws?

(b) If not, what changes are proposed in Information Technology Act. 2000 and relevant license conditions to protect the security and privacy of an individual?

Please comment with justification.

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Q14. Is there a need to define different types of SLAs at point of interconnects at various layers of Heterogeneous Networks (HetNets)? What parameters must be considered for defining such SLAs? Please give your comments with justifications.

Q15. What should be the distributed optimal duty cycle to optimise the energy efficiency, end-to-end delay and transmission reliability in a M2M network?

Q16. Please give your comments on any related matter not covered in this consultation paper.

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