Airtel has recommended against redefining broadband from 512Kbps, arguing that this speed is enough for most broadband use in the country. “Throughput speed of >512 Kbps on broadband connection is sufficient to carry all data services, including video conferencing, e-commerce, digital financial services, and any other peer to peer services,” Airtel said. Most broadband connections offered in the country tend to be tens or hundreds of times faster than this, and while any one of the functions Airtel cited can be supported by 512Kbps connections, doing them simultaneously strains slow networks.

Fixed line broadband can be redefined to 8Mbps, but only around two years later, Airtel said. Like Jio, the telco used a consultation on broadband penetration conducted by the Telecom Regulatory Authority of India as an opportunity to send across a regulatory wishlist. Airtel also suggested that two new agencies be created, one for optical fibre management, and another for right of way.

Broadband speeds in India are low due to overreliance on mobile networks, Airtel argued. On top of blaming spectrum shortfall, as Jio does, the company blamed an “unviable business model” due to high capital costs. The company reiterated its demand of a floor tariff rate on a temporary basis (presumably to counter Jio’s pricing advantage) and said that taxes and levies on the telecom industry must go down. It further argued that it should be allowed to conduct “reasonable traffic management practices” to offer “differentiated experience to the customers”. This is likely a reference to the company’s now-discontinued Platinum 4G plans, which gave postpaid users paying more higher speeds.

Optic Fibre Regulatory Authority

  • OFRA for faster fibre rollouts: Curiously, Airtel has recommended an entirely new agency to support telcos’ rollout of fibre. The telco recommended that an “Optic Fiber Regulatory Authority be formed to achieve faster, transparent, and economic roll-out of fiber and ensure optimum utilization by effective sharing among service providers.” The telco recommended that OFRA facilitate liaising between the public and private sector, and between central and local governments. Additionally, OFRA should keep track of dark fibre, track progress of fibre deployment, facilitate infrastructure sharing, and to “facilitate the creation of MDCs (Mini Data Centers) / POPs to host the equipment and provide connectivity and access to end-customers.” An OFRA-like agency doesn’t seem to have any equivalent or precedent abroad.
  • State utilities refuse to share fibre: “Powerlines & state electricity boards, and even state-driven fiber infrastructure SPVs are reluctant to provide dark fiber to end-users,” Airtel complained. Dark fibre is inactive fibre infrastructure that can be tapped into by a telco on leasing space or purchasing the network. “Many [state utilities] have explicit rules not to share dark fiber, and some others maintain a complete lack of transparency to discourage the same. A significant part of this is underutilized without any active larger participation to full fill the needs of Digital India,” Airtel said.
  • Infrastructure sharing: “The broadcasting and power sector’s existing assets should be made available for sharing at affordable rates. This will ensure faster telecom connectivity and efficient utilization of existing national resources. Therefore, national fiber authority should be created,” Airtel said. The company said that fibre infrastructure in the country was poor because of a high rate of cuts compared to other countries (presumably due to how much fibre remains above-ground and exposed).
  • No need to disclose congestion, regulate contention ratio: The company argued that market forces were enough for users, and so telcos shouldn’t be required to disclose details of congestion on their networks. The company also argued against capping contention ratios, which limit how many subscribers a certain amount bandwidth can be shared with. “We do not recommend the need for any policy or regulatory intervention by way of mandating certain checks relating to RAN user plane congestion,” the company added, referring to the type of congestion typical in crowded places with many users and too little telecom infrastructure to support them.

“As a PPP model, TSPs can allocate/ provide fiber connectivity to all government & private buildings, public infrastructure for Government usage at district / state / central level. These fiber pairs can be used to build a broadband network for smart cities, security agencies & e-governance projects,” Airtel said.

Right of Way

Airtel recommended sweeping changes to the Right of Way framework that determines how telcos get access to roads and other public property to build their networks.

  • Council for RoW: The telco recommended that a council be created along the lines of the GST Council to make sure that states had similar ways of granting right of way to telcos. “A National level authority must be created with appropriate empowerment to govern & grant RoW at pre-defined rates, rules, guidelines & timelines, including grievance resolution in a time-bound manner,” Airtel said. The company also argued for an “aerial fibre” policy framework, but did not elaborate.
  • RoW fees to be waived off: “The RoW Charges should be waived off or at least restricted to the cost of restoration to accelerate fiber roll-out,” Airtel recommended. States sometimes charge a lot of money to telcos for the right of building infrastructure on public property. “Rates and time limits for all terrains & territories should be predefined. Rates should be rationalized and conducive to the growth of fiber build across urban, rural & remote areas,” the company said in a separate point.
  • Implementing 2016 RoW rules: The 2016 Right of Way rules formulated by the central government should be adopted by all states, Airtel said. “All the State Governments should implement Gazette notification on RoW and uniform policy on underground & overhead infrastructure at the earliest. Till date, only 16 State Governments have done this, and rest have either not come out with any policy or have policy inconsistent with Gazette notification,” the company said. It added that single window clearance should be granted for right of way within 14 days.
  • Building codes: “All infrastructure sectors such as road construction authorities/agencies like NHAI/SH/PP Projects should include, in their construction design policy, a provision for a utility duct to enable laying of OFC for all new infrastructure and also adopt similar measures in existing projects in a “Dig Only Once” policy approach,” the company said. Dig Once policies reduce the amount of construction work needed to lay various public utilities by only doing digging work once. The company added that buildings should be required to have telecom access ducts.

Read Airtel’s filing here.

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