Elon Musk’s SpaceX urged the Indian government to facilitate approvals to use satellite technology for internet access in remote areas. “While existing telecommunications networks have performed well to meet [internet access] needs in many areas, billions that live in the most rural and remote areas, and even those in urban environments, remain on the wrong side of the digital divide. Powerful next-generation satellite systems flying today that can reach all corners of the country with high-speed, affordable service are critical to bridging this gap,” Patricia Cooper, Vice President, Satellite Government Affairs at SpaceX, said in a filing with the Telecom Regulatory Authority of India.

Cooper was referring to Starlink, a constellation of over 4,400 satellites providing internet access at tens of megabits per second at reasonably low latency. Her comments came as a part of a TRAI consultation on enhancing broadband access and penetration in India. “A diverse mix of broadband technology platforms and service providers, including those new to India’s market, will best accelerate broadband access across the nation,” she said. “SpaceX stands ready to discuss how innovation in satellite design, deployment and ground networks can support the country’s broadband goals.”

SpaceX’s comments come at a time when Indian Space Research Organisation has floated a draft Space Communications Policy to replace the earlier Satellite Communications Policy.

SpaceX pushes for rule changes to allow Starlink

A common theme runs along SpaceX’s recommendations: each of the changes it suggests would allow it to set up shop in India faster.

  • New rules may be required for Starlink: To enable services like Starlink to take off in India, SpaceX said, there need to be tech-neutral broadband definitions, spectrum allotments for satellite systems, promoting spectrum sharing, safeguarding innovation in higher frequency spectrum (which likely translates to less burdensome regulation), and taking a look at fees and taxes that disincentivised broadband adoption.
  • Policies “deterring” satellite may be causing low speeds: TRAI asked in a question why fixed broadband speeds were so low in India. In response, SpaceX said that policies discouraging the participation of high speed satellite internet technologies like Starlink’s in broadband deployment played a role in driving up costs of fixed line broadband and making speeds slower. This claim may only hold up in remote areas where it may not be financially viable to lay fibre. “Terrestrial fixed wired and wireless technologies have brought economic and social advancement across India, but come with an inherent infrastructure expense based on a cost per kilometer that is difficult to scale while maintaining affordable prices for end users when connecting remote or rural communities,” SpaceX said, adding that satellite broadband would reduce cost-per-kilometre in rural areas.
  • Performance standards for broadband definitions: SpaceX said that while TRAI can set any minimum broadband speed it finds appropriate, standards should be set for performance that are technology-agnostic. On top of VoIP calling, SpaceX said, internet networks should support “web browsing, video streaming, digital meeting platforms, tele-health, tele-medicine, virtual learning, e-Commerce, e-Governance, online banking and e-payments”.
  • Blanket licensing: SpaceX argued for “blanket licensing” to be allowed in India to “streamline the site-per-site licensing requirements and accelerate widespread deployment of two-way satellite broadband terminals to support innovative satellite services in India” such as Starlink. “Many regulators around the world recognize the benefit of blanket licensing to advance their goals for broadband access and administrative efficiency. Specifically, Australia, Austria, Canada, Chile, France, Germany, Greece, New Zealand, Spain and the United Kingdom, among others, have adopted blanket licensing approaches,” SpaceX said, adding that the US’s FCC also had rules permitting blanket licensing.
  • Ka-band frequency: SpaceX says that ka-band frequency, which is normally used to connect ground stations to fixed satellite systems, should be assigned to providers. “While India has long encouraged satellite operators to deploy gateway earth station facilities within the country, this policy is thwarted by the absence of Ka-band frequency assignments that are required to communicate with those gateway earth stations. SpaceX encourages TRAI and spectrum agencies in India to develop an approval process for these assignments. This effort is fundamental to expanded high-speed broadband service in India,” SpaceX said.
  • Keep e- and v-bands open for satellite providers: TRAI has suggested in its consultation paper that e- and v-band spectrum, which are often floated as useful for 5G networks — but are often only used in short distances for backhaul — should be leveraged for broadband deployment in India. “In working towards this goal, however, it is important that TRAI take into account the impact of proposed rules changes on satellite use of the E- and V-bands, and that new uses of the spectrum do not infringe upon planned and future FSS operations,” SpaceX said.

“While E-band services are still in early development, SpaceX has also actively promoted the ability for satellite innovation to unfold in the 71-76 GHz and 81-86 GHz portions of the 70/80/90 GHz frequency band. Safeguarding technology innovation for satellite in these bands is particularly timely, given that investment and deployment of satellite technology and [non-geostationary orbit] systems is at an all-time high, and such NGSO constellations are poised to bring advanced broadband access services to India, including heretofore unserved and underserved rural areas” — SpaceX

  • Spectrum sharing between private players: SpaceX said that private players should be allowed to share spectrum, and batted for a “band-splitting model” that incentivises using spectrum efficiently. “SpaceX agrees with the ITU and other regulators, including the U.S. FCC, that private coordination between operators is the most efficient means for two NGSO satellite operators to manage shared spectrum. Because operators are best positioned to understand the capabilities of their systems and their business objectives, successful coordination ensures the most efficient use of shared spectrum,” SpaceX said.

“SpaceX notes that the current rule in the United States actually sets the wrong incentives by granting [a] right of first spectrum choice to the operator that is first to launch a satellite and operate in the frequencies in question, because it encourages operators to quickly launch a small number of satellites without consideration of actual service provision or spectral efficiency, leaving the potential for an inefficient system that hinders any that follow. Instead, a rule that assigns first choice of spectrum to the more efficient NGSO system creates a race-to-the-top in which operators compete to develop the most spectrally efficient technology” — SpaceX

Read SpaceX’s filing here

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