The Telecom Regulatory Authority of India has released a consultation paper on in-flight WiFi and calling, seeking views from citizens about whether or not in-flight connectivity should be allowed in India, and the government licensing framework for this. Answers may be sent to Syed Tausfic Abbas, Advisor (Networks, Spectrum and Licensing) at TRAI, at advmn@trai.gov.in by October 27th 2017, and counter comments by 3rd November 2017.

TRAI is hosting this consultation following a reference from the Department of Telecom on 10th August 2017. Download the consultation paper here.

Broadly, the TRAI is asking the following questions (more detailed questions below):

What should be allowed?

  • Whether Internet or calling should be allowed on Indian flights, or both.
  • Should international airlines flying over multiple jurisdictions be allowed to provide in-flight connectivity over Indian airspace?
  • What restrictions and regulations should be applicable to in-flight connectivity providers?

Licensing and Spectrum

  • Should the standards for offering these services be the same as global standards? How do you ensure that in-flight connectivity doesn’t interfere with terrestrial connectivity?  Should it be technology neutral, or restricted to the same frequency bands as in the EU? Should it only be allowed via INSAT?
  • Should connectivity be in-flight only or can it be gate-to-gate?
  • Should any Unified License holder (Category A) be allowed to provide In-Flight connectivity, or should there be a separate category of license?
  • Can an In-flight connectivity provider tie-up with an existing licensee with authorisation provide services on airlines registered in India? Should this require a separate permission?
  • How should IFC providers be charged in case of foreign registered airlines and Indian registered airlines?

Security concerns

The TRAI has already decided that security agencies should be able to monitor traffic to and from user terminal in Indian airspace. It has placed the following four options for deciding how interception may be possible, and you have to pick one:

  • The use of Indian Satellite System while travelling over Indian airspace can be mandated, but there are two challenges here: firstly that the domestic satellite capacity may be limited, and secondly, foreign airlines may not switch to the Indian Satellite System
  • Permit the use of Indian or foreign satellites through the department of space. Under this, “airborne IFC equipments should get connected to Ground Earth Stations located in India.”
  • Traffic to and from user terminals in Indian airspace may be sent to a node owned and operated by an Indian entity to address the requirement of lawful interception directly or in mirror mode.
  • Not put any such restriction on international flights

Note that there’s no question being asked here about authentication of inflight WiFi usage, which is odd, given that

All the questions

Q.1 Which of the following IFC services be permitted in India?
a. Internet services
b. Mobile Communication services (MCA service)
c. Both, Internet and MCA

Q.2 Should the global standards of AES/ESIM, shown in Table 2.1, be mandated for the provision of AMSS in Indian airspace?

Q.3 If MCA services are permitted in Indian airspace, what measures should be adopted to prevent an airborne mobile phone from interfering with terrestrial cellular mobile network? Should it be made technology and frequency neutral or restricted to GSM services in the 1800 MHz frequency band, UMTS in the 2100 MHz band and LTE in the 1800 MHz band in line with EU regulations?

Q.4 Do you foresee any challenges, if the internet services be made available ‘gate to gate’ i.e. from the boarding gate of the departure airport until the disembarking gate at the arrival airport?

Q.5 Whether the Unified Licensee having authorization for Access Service/Internet Service (Cat-A) be permitted to provide IFC services in Indian airspace in airlines registered in India?

Q.6 Whether a separate category of IFC Service Provider be created to permit IFC services in Indian airspace in airlines registered in India?

Q.7 Whether an IFC service provider be permitted to provide IFC services, after entering into an agreement with Unified Licensee having appropriate authorization, in Indian airspace in airlines registered in India?

Q.8 If response to Q.7 is YES, is there any need for separate permission to be taken by IFC service providers from DoT to offer IFC service in Indian airspace in Indian registered airlines? Should they be required to register with DoT? In such a scenario, what should be the broad requirements for the fulfillment of registration process?

Q.9 If an IFC service provider be permitted to provide IFC services in agreement with Unified Licensee having appropriate authorization in airlines registered in India, which authorization holder can be permitted to tie up with an IFC service provider to offer IFC service in Indian airspace?

Q.10 What other restrictions/regulations should be in place for the provision of IFC in the airlines registered in India.

Q.11 What restrictions/regulations should be in place for the provision of IFC in the foreign airlines? Should the regulatory requirements be any different for an IFC service provider to offer IFC services in Indian airspace in airlines registered outside India vis-à-vis those if IFC services are provided in Indian registered airlines?

Q.12 Do you agree that the permission for the provision of IFC services can be given by making rules under Section 4 of Indian Telegraph Act, 1885?

Q.13 Which of the options discussed in Para 3.19 to 3.22 should be mandated to ensure control over the usage on IFC when the aircraft is in Indian airspace?

Q.14 Should the IFC operations in the domestic flights be permitted only through INSAT system (including foreign satellite system leased through DOS)?

Q.15 Should the IFC operations in international flights (both Indian registered as well as foreign airlines) flying over multiple 31 jurisdictions be permitted to use either INSAT System or foreign satellite system in Indian airspace?

Q.16 Please suggest how the IFC service providers be charged in the following cases?
(a) Foreign registered airlines.
(b) Indian registered airlines.

Q.17 Should satellite frequency spectrum bands be specified for the provisioning of the IFC services or spectrum neutral approach be adopted? Q.18 If stakeholders are of the view that IFC services be permitted only in specified satellite frequency bands, which frequency spectrum bands should be specified for this purpose?

Department of Telecommunications (DoT), through its reference dated 10th August 2017 (Annexure 1.1) has requested TRAI to furnish its recommendations on licensing terms and conditions for provision of In-Flight connectivity (IFC) for voice, data and Video services and associated issues such as entry fee, licence fee, spectrum related issues including usage charges & method of allocation and other conditions as per clause 1(1)(a) of TRAI Act 1997 as amended.