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What telcos have to say on satellite regulations for low-bandwidth applications in India

The responses to TRAI’s consultation paper on low-bandwidth applications for satellite technology are in. Here’s what telecom operators have to say on the questions raised in the paper. (You can read our summary of the questions here.) “Low-bandwidth applications” generally refer to applications, which unlike TV broadcasting and satellite internet, don’t need a lot of data to work, such as simple IoT devices.

  1. Spectrum bands: TRAI asked which spectrum bands should be used for providing IoT services through satellite.
    • “Frequencies in L-band, C-band and S-band are crucial to mobile communication, earmarked for current and future IMT rollout and should not be considered for satellite communication services,” Vi said.
    • “We believe all the existing Satellite Frequency bands, as per the frequency plan of the country, should be exploited to provide satellite services,” Airtel said. But telcos cautioned against giving away too much spectrum that could otherwise go toward supporting 5G. “Since India is on the cusp of bringing the 5G to masses, ensuring right quantum of sufficient spectrum for 5G services at affordable prices to mobile networks should remain the priority specially in the existing IMT bands or bands with high 5G potential,” Airtel added.
    • Tata Communications suggested that spectrum bands that don’t lead to too much power waste should be used. “Higher bands being susceptible to atmospheric absorption would lead to higher transmission power nodes and this will directly impact the battery life of IoT devices and sensors used in low data rate applications,” it said in its submission.
  2. Licensing framework: TRAI asked if there should be a separate licensing framework for low bitrate satellite providers.
    • Airtel suggested using the Global Mobile Personal Communication by Satellite (GMPCS) framework under the Unified License to simplify things.
    • “All the existing service authorizations permit data connectivity. The IoT is also a kind of data connectivity (albeit, a low data-rate). Therefore, there is no need to recommend a new authorization for a niche IoT service,” Tata Communications said.
    • Vi said that having a different licensing framework for IoT services provided through satellite and those provided by terrestrial mobile networks would create a non-level playing field.
  3. Foreign bandwidth: TRAI asked if licensees should be able to get bandwidth from foreign providers for low-bandwidth satellite applications.
    • Airtel and Tata Communications said that this should be allowed.
    • However, Vi argued that only Indian providers should provide this bandwidth, “[i]n line with various Government initiatives like Atmanirbhar Bharat, domestic manufacturing, localization.” (emphasis added)
    • Airtel argued that an “Open Skies” approach should be followed and foreign satellite bandwidth should not be heavily regulated.
    • Tata and Vi said that if foreign satellite bandwidth is being used, the ground station must be located in India.
  4. Direct-to-satellite vs LPWAN (satellite constellations): For facilitating the Internet of Things, TRAI asked which model was better, Direct-to-Satellite connections, or LPWAN connections which often involve constellations of low-earth orbit satellites that can handle a lot more traffic.
    • Airtel said the framework must be “deployment architecture agnostic”, and both technologies can be used.
    • Vi concurred, saying that a hybrid model should be allowed under the Unified License.
    • “In our view, there should not be any regulatory prohibition on either of the two models,” Tata Communications said.
  5. Type of satellite: Geostationary orbit satellites, low earth orbit satellites, and medium earth orbit satellites. Which should be permitted to provide low bitrate services?
    • Vi had no comment.
    • Airtel said LEO constellations (like SpaceX’s Starlink and Bharti-backed OneWeb) held the most promise. “The licensing regime should provide flexibility in terms of acceptance of modifications in technology as satellite technology is constantly improving,” Airtel said.
    • Tata Communications said that the market should be able to decide what is best: “Technology and market forces should be allowed to take its course, subject to the requirement that it meets relevant regulatory requirements, as may be specified,” it said in its submission.
  6. Reducing cost of satellite: Satellite services are too expensive in India, TRAI observed, asking what can be done to make them more affordable.
    • Airtel and Vi said that administrative licensing levies should be simplified.
    • Tata Communications said that barriers to doing business in satellite services should be lowered, such as by allowing Indian companies to directly acquire bandwidth from low-earth-orbit constellations. “[L]icensed telecom operators as well as entities providing teleport services and DTH services should be allowed to procure bandwidth directly from Foreign Satellite service provider companies by entering into agreement with them,” Tata said.

Airtel’s submission | Vodafone Idea’s submission | Tata Communications’s submission

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