Unmet Needs In Wireless Regulations

1. Telecommunications need priority as the primary enabler for growth, climate mitigation, and living conditions.  This holds for primary infrastructure as well in energy, transportation, water and sanitation, and for secondary infrastructure such as healthcare, education, and financial services. 

2. In the last decade, governments in India have taken out more than they have put into telecommunications by way of funding and/or enabling policy formulation. 

3. Given the high costs and impracticality of installing ubiquitous fibre, policies for wireless middle- and last-mile telecom connectivity are urgently required.

 Shyam Ponappa    |    February 14, 2023

Setting aside the uproar in financial markets and politics for a moment, consider just some mundane facts on a deficient aspect of infrastructure. The urgent present and future need is to address the missing links in our connectivity chain with appropriate, enabling regulations.

One would think that in this era, governance in India would focus on digitisation and digital connectivity. It is one of our critical infrastructure needs in a set that includes transport and energy. One might even assume from the schemes and announcements about digitisation that the government accords priority to these areas. So what is it that gives one pause?

India touts its resolve in this sector. Yet, in the ground realities of its expenditure on the sector, policies and actual reforms, this resolve is lacking. Moreover, many urgent requirements are actually for appropriate, timely policy responses, not for government funding, as discussed below.

The table (Spending Plan) shows budgeted expenditure (revised figures for 2022) for roads, railways, and communications in the last three years.

The expenditure on roads and railways is twice the amount on communications, for which there is also a lower increment for next year. Of the Rs 1.23 trillion, BSNL gets Rs 52,937 crore, the rest of telecommunications gets Rs 44,642 crore, and postal projects get Rs 25,814 crore.

If emphasis on digitisation and connectivity is really critical, is the budgeted amount disproportionately low? Considering that efficiency and productivity drive growth, climate mitigation, and living conditions, and gain from these enablers regardless of the mix of technology, capital, land, and human resources, digital effectiveness and efficiency need prioritisation as multipliers. It is as though we simply do not recognise that communications is the leading enabler.

What Can Be Done About This?

The way the following instances were dealt with over the last several years show how policy deficiencies may be more purposefully addressed. 

The Vodafone Saga

The handling of the Vodafone saga by both the United Progressive Alliance and the National Democratic Alliance exemplifies one type of problem. Briefly, Vodafone was saddled with arbitrarily imposed retrospective taxes in 2007, which the Supreme Court set aside in 2012. Then Finance Minister Pranab Mukherjee piloted legislation whereby retrospective policy changes justified tax claims on offshore stake acquisitions of Indian companies. Vodafone and other operators were also battling licence fees claimed on non-telecom revenues included in “aggregate gross revenues” (AGR) since 2003, with mounting interest dues. In August 2021, the government finally gave in on retrospective taxes on Vodafone (and Cairn Energy) after arbitration awards against it. In September 2021, a telecom relief package offered a four-year moratorium for the beleaguered operators’ debt repayments, while finally excluding non-telecom revenues for licence fee calculations.

The relief was temporary, with interest accruing on all outstanding dues. There was much more that needed to be done to prevent prolonged attrition with high opportunity costs, because of the non-availability of services severely constraining India’s capacity and productivity. Examples include revenue sharing for spectrum as for licence fees, and active network sharing through open access to operators on payment (see https://organizing-india.blogspot.com/2021/10/telecom-reforms-relief-with-hope.html).

Vodafone Idea and India’s users suffered the cost and deprivation of services until the government decided on February 3 to convert Vodafone’s dues of Rs 16,133 crore into government-held equity. Meanwhile, Vodafone Idea was down to under 244 million subscribers by the end of November 2022, having lost 21 million users. Its debt rose because the government dithered with the afterthought that Vodafone Idea should invest more before the government fulfilled its conversion of dues to government-owned equity. Clearly, future policies need to be stable and well-thought-out in the public interest, without whimsical changes or arbitrary conditions.

The irony is that in the UK and Europe, Vodafone competes with Orange, BT, Telefonica, and Deutsche Telekom with state-of-the-art services, and runs Europe’s largest 5G network in 12 countries. In partnership with the Kumar Mangalam Birla group, it is the sole surviving international telecom operator in India.

What if governments had acted quickly to correct anomalies such as retrospective taxes and defined AGR rationally? Imagine what the opportunity gains might have been with three strong operators in a well-regulated market of over a billion.

The Elusive Goal Of Optical Fibre For All 

A second instance of inappropriate policies is that of wireless policies and the use of optical fibre. Ratings firm ICRA recently stated that full-scale 5G deployments across India would require expenditure of about Rs 3 trillion for densification, because nearly two-thirds of the towers lack fibre connectivity. Heavy investment appears unlikely given the telcos’ expected debt of Rs 6.3 trillion by March 2023 (see https://www.business-standard.com/article/economy-policy/5g-infra-to-cost-rs-3-trn-in-next-4-5-yrs-amid-elevated-debt-levels-icra-123013001026_1.html).

With the high costs for fibre rights-of-way and the installation difficulties on the ground, it is baffling that our policymakers in the government including the Department of Telecommunications (DoT) have not engaged with the urgent need for enabling wireless policies even for towers, based on successful models in other countries.

The DoT did, in fact, model the enabling wireless regulations for 5 GHz in October 2018 on the FCC template for Wi-Fi (for access and for point-to-point with limited capacity: https://organizing-india.blogspot.com/2018/11/a-great-start-on-wi-fi-reforms.html). However, this was not followed up with regulations for middle-mile, high-capacity wireless for towers and small cells, as is only logical, that is, for 60 GHz V-band and 70-80 GHz E-band for longer distances. Without these, and with pricing for microwave being restrictive here, there are gaps between the user-access-end and the core-network-with-fibre-termination-points. These gaps would be too expensive to fill out entirely with fibre optic cables, as is evident from ICRA’s estimate above. Yet, many officials repeatedly talked about fibre connectivity to all, which after consideration should strike anyone as patently infeasible because of our size, population distribution, and cost-and-revenue structure.

Other critical wireless regulation required now is enabling 6GHz for Wi-Fi, allowing speeds of up to 10 Gbps, and support for local product development and production instead of relying on imports.

Considering how resources are channelled and regulations attended to, the communications sector needs far greater emphasis and action on well-thought-out, timely policy intervention as indicated above to better support our economy and society.

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 Shyam (no space) Ponappa at gmail dot com

Empowering Gati Shakti - The Transport & Logistics Platform

Done right , the smart platform for infrastructure planning and execution could lead to tremendous productivity benefits.

Shyam Ponappa   |   November 2, 2022 

The National Master Plan for logistics development on a digital platform, Gati Shakti (Speed and Strength), was introduced in October 2021. It is a much-needed initiative to introduce effective management systems in coordinating relevant ministries for all aspects of transportation and logistics. It establishes digitised institutional processes for comprehensive, integrated project planning and execution, to assist ministries and infrastructure sectors in achieving results. The aims are more efficient outcomes at reduced cost and time. Done correctly, this will result in tremendous productivity benefits at a low cost and with better environmental impact.

A primary purpose of Gati Shakti is prioritisation for growth. Based on limited lay access (more on this later), an element that needs attention is telecommunications reform. The need is for inexpensive, higher capacity/intensity connectivity, by enabling spectrum usage for wireless and shared networks at lower capital investment with better utilisation. The platform’s effectiveness depends on this.

Gati Shakti is based on the recommendations of the National Transport Development Policy Committee1 in January 2014. Government agencies such as the railways, roads and highways, shipping, aviation, power, telecom, and so on reportedly use this for integrated planning and execution. During the past year, ministries responsible for fertiliser, coal, ports and the like reportedly identified nearly 200 “infrastructure gaps” in first-mile or last-mile logistics. An inter-ministerial expert panel monitors and recommends corrective action. Presumably, this will be tracked through the digitised database and portal, which also has geographic positioning capabilities.

Prioritisation And Policy Changes More Essential Than Capital 

As observed in an earlier column, a World Bank study across many countries validates the importance of telecommunications (and electricity) for growth.2 A report published by the Asian Development Bank Institute confirms that for India and China, internet and mobile density contribute to their high rate of growth.3

Apart from these findings from past data, telecommunications and digitisation are now essential to most aspects of living. Most importantly, telecommunications and the internet need major policy changes on network sharing and reduced taxes. These are needed even more than capital, to accelerate network coverage and delivery. Examples of changes required include permitting high-speed wireless without loading discretionary costs, such as up-front auctions, high costs for wireless links, and onerous procedures. Policy changes can reduce pricing and sticky process/procedures for operators and, ultimately, users and society as a whole. Until this is done, users are either deprived of services because they are simply not there, or constrained by erratic and low-quality services, or burdened with high charges. The impact is in many areas as indicated below:

- Environmental care & climate mitigation: Effective broadband coverage and shared networks significantly improve both.

- Education and work life reach: Extending broadband coverage to the many millions living in rural or distant areas is one obvious need. This is also true for the many urban users who endure poor services, beyond the privileged, relatively few who have fibre or reliable high-speed wireless. Undoubtedly, a whole gamut of content and methods will need to evolve to enable effective learning for less educated users, as will ways to mitigate costs to provide access. But it is probably the only way crucial services can reach so many quickly, channel our population productively and pre-empt their degeneration into disruptive problem creators. This will open education to many more boys and girls, and employment opportunities to men and women.

-  Similar benefits are feasible in areas such as e-commerce, distributed healthcare, government services, in small and medium manufacturing and services enterprises for work process support systems, and entertainment.

Temples to Metaphysics and Physics

In the 1890s, Acharya Jagadish Chandra Bose (Sir Jagadis Chandra Bose) demonstrated wireless technology at 60 GHz (V-band),4 but his pioneering work languished in India. Meanwhile, countries such as the USA, the UK and others, including China, have exploited this technology for high-speed gigabit wireless in their networks in place of fibre.

Much time and public resources are devoted to overt religiosity in India. Whereas Bose, scientist extraordinaire, in his inaugural address dedicated the Bose Institute in Kolkata in 1917 as not merely a laboratory but a temple. Adding Paramahansa Yogananda’s “keen interest in evidence that India can play a leading part in physics, and not metaphysics alone”, we would do well to apply more physics and science—as in using wireless technology in our networks, and having more temples to science, systems, and other practical disciplines.

India has just enabled restricted use of 60 GHz, although devices were available abroad for years. If government permits telcos to use 60 and 70-80 GHz “mmWave” technology for pay-for-use backhaul with no loading of extraneous costs (auctions, extra taxes), there would be enormous service and cost benefits in India, as in San Francisco and London (see the device maps in the charts for one supplier).

 

V-Band and E-Band Devices in San Francisco and London for One Vendor (2017)

Figure 3: Siklu radios in San Francisco, CA, according to FCC database

Source: https://go.siklu.com/blog/custom-blog/the-evolution-of-mmwave-2 

Figure 5: Siklu radios in London, UK, according to OFCOM database

Source: https://go.siklu.com/blog/custom-blog/the-evolution-of-mmwave-2 

Changes are also needed to institutionalise easier access to spectrum for authorised institutions and researchers, so that India’s research and development for commercial and defence is freed of arbitrary, self-imposed constraints and delays.

Public access to the Gati Shakti portal, limited for security reasons, was allowed from October 2022. A cursory look at the portal does not disclose project details on sectors. It may be more amenable to authorised users; to a lay user, it appears to be a repository of reports that does not cater to meaningful queries or logical searches. Adding such capabilities would make it more informative and useful, although this will need to be balanced with security.

The essential points are that improving living conditions requires enabling and applying technology and know-how. Attention to scientific and domain applications to deal with ground realities will help improve our state of infrastructure for productivity and ease of living. Prioritising digitisation and telecommunications will help correct losing out on growth and associated living conditions because of inappropriate policies, and genuinely add both Gati and Shakti to our efforts.

 

 

 Shyam (no space) Ponappa at gmail dot com

  

1: India Transport Report

Moving India To 2032

Vol I - Executive Summary

National Transport Development Policy Committee, January 31, 2014

Rakesh Mohan et al

Summary Recommendations: http://www.aitd.net.in/NTDPC/rep_ntdpc_v1.pdf

 

2: How Much Does Physical Infrastructure Contribute to Economic Growth?

An Empirical Analysis

Govinda Timilsina, David I. Stern, Debasish K. Das

World Bank Group, Development Economics

December 2021

https://openknowledge.worldbank.org/handle/10986/36780

 

3: Digitalization and Economic Performance of Two Fast-Growing Asian Economies: India and The People's Republic of China

Dukhabandhu Sahoo, Suryakanta Nayak, and Jayanti Behera

ADB Institute Working Paper Series

No. 1243

March 2021

https://www.adb.org/publications/digitalization-economic-performance-fast-growing-asian-economies-india-prc

 

4: Jagadis Chandra Bose: Millimetre Wave Research in the Nineteenth Century

Darrel T. Emerson

National Radio Astronomy Observatory

949 N. Cherry Avenue, Building 65

Tucson, Arizona 85721

1998

https://www.cv.nrao.edu/~demerson/bose/emerson_delhi.pdf

The 5G Opportunity For A Unitary Paradigm

Adopt high-speed wireless subnetworks of small cells, and a commons approach.

Shyam Ponappa   |   October 6, 2022

An explanatory note on the draft Indian Telecommunication Bill touches on how spectrum is similar to atma, the soul. If this idea is pursued through a unitary approach to regulation, emphasising functionality and avoiding fragmentation, services would proliferate because of lower costs and easier installation. The truth, however, is that the regulatory environment in the last decade has not been coherent and integrated.

With 5G, India has the opportunity — once again — of adopting a resource-sharing approach, as is the case in some other forms of infrastructure. Airlines, for instance, share flight paths and airports, while vehicles and transporters share highways and transport facilities, and ships and shipping companies share routes and ports. In the same way, shared telecom infrastructure and spectrum will maximise efficient use of capital for 5G. The need is for integrated networks with many small cells, which are also effective for 4G. Both users and service providers benefit from capital-intensive infrastructure that permits open access to authorised operators paying for usage. Telecommunications has evolved in a more fragmented way than airlines and transport by land and sea. The latter systems are organised around the principle of a unitary approach to resource-sharing for efficient use.

One reason telecommunications evolved in this way was because of technology limitations, particularly wireless interference. Another was the approach in developed markets, particularly the US, the UK, and Europe. From the 1990s, these markets experienced waves of deregulation, privatisation, and a worshipful attitude to competition.¹  Meanwhile, the dissolution of the Soviet Union encouraged indiscriminate acceptance of free-market ideas. The strongest impetus driving governments, however, may have been the windfall revenues from spectrum auctions. This was amplified by the incongruous phenomenon of people equating government collections with public benefit, paradoxically as capitalism was in the ascendance. Auctions were idolised even after the collapse of telecom in the 2000s. The sector recovered gradually after many years, although services were seen as being deficient globally, resulting in broadband policy interventions even in the US, as in many countries.

However, barring notable exceptions, the concept of property rights continues to dominate spectrum assignment, as does homage to unfettered competition. Consequently, alternative approaches are scarce, although the technological and economic rationale for sharing integrated infrastructure, as in roads, rail, air and waterway routes and facilities, is self-evident, and is unquestioned. Quite simply, it is the logic of sharing high fixed and operating costs to maximise capacity utilisation, whether for communities or for nations. There are similar compelling reasons for sharing wireless technology and equipment, with developments in reduced interference, reuse in smaller areas with wider spectrum bands, and technological innovation far beyond earlier benchmarks. But this is not yet widely accepted, and much less so in India.

Some countries with a propensity for cooperation, as in Scandinavia, have successfully implemented a consortium approach, but this may be restricted to places with a collaborative culture. Others have tried government control of common access networks or spectrum, such as Mexico’s 700 MHz network, Australia’s Next Generation Network, or Africa’s open access network, none with success. The opposite, private control of networks and spectrum, prevails, as espoused by the US and followed by many, including India. The US, however, is moving rapidly to shared secondary use of spectrum as well as more open access, both of which are promising when it comes to effectiveness and efficiency.

Yet another way is the commons approach, with common carrier sectoral access to a public resource, spectrum, for the public good, with a fair sharing of costs for usage, as for airlines and other infrastructure. The example below shows how this could be done.

New Paradigm For Low-Cost Networks 

This outline is for 5G services in cities with fibre optic connections, which is extendable to rural areas without fibre. A recent press report mentions a government plan for Patna as a model for 5G rollout in cities. The city map is apparently divided into grids of 200 square metres to estimate the number of towers required, with the finding that the towers have to be doubled to over 3,000 for quality coverage. Whether this is really under consideration or not, the government surely needs to evaluate a wireless approach that is less expensive and more feasible than towers and fibre.

A conceptual plan by an equipment manufacturer for 5G serving a million users in 400 sq km is shown in the chart. Hexagonal cells with sides of 3 km and area of about 23 sq km cover this service area with 60 radios and 50 node switches. These can be installed on existing towers, buildings, and street furniture.

Source: https://elva-1.com/data/files/docs/ELVA-1_Dual-band_Urban-Scale_Wireless_Networking_Concept.pdf

This calls for a true paradigm shift in India’s policies, applicable for both 4G and 5G networks. The following administrative changes in regulations are required:

1. Permit authorised operators wide bandwidth use of V-band (60 GHz) and E-band (70-80 GHz) for multi-gigabit transport, with operators paying for actual usage. Permit channel width of 2.16 GHz (currently only 250 MHz for E-band) and channel aggregation for multi-gigabit throughput.

2. Permit Wi-Fi in the 6 GHz and 60 GHz bands for end user access.

3. Adapt US regulations for these bands to India’s needs, as has been done for 5 GHz in October 2018.

4. Implement these changes urgently. The need for speedy clearances and action cannot be overemphasised, given the inordinate delays.

To recap, our requirement is regulations for high-speed wireless in V-band and E-band, in wide bandwidths allowing for multi-gigabit transport for authorised operators paying for usage, together with end-user access through Wi-Fi in the 6 and 60 GHz bands. The costs, difficulty in installation, and completion time will reduce considerably, with far less towers and fibre because of the use of buildings and street furniture for wireless equipment. Radios will connect through wireless links in a mesh for coverage. Within cells, towers will connect to sub-cells for user access through Wi-Fi in the existing 2.4 and 5 GHz bands, or faster through 6 and 60 GHz.

This is an opportunity the government must not lose.

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Shyam (no space) Ponappa at gmail dot com

1: Paul Starr: "The Great Telecom Implosion," The American Prospect (September 9, 2002), 20-24.

Improving The Odds For 5G

Fixing the approach for networks and services is necessary for getting to 5G.

Shyam Ponappa   |  July 7, 2022 

Towards the end of 2021, the government acted admirably in the public interest, making difficult and courageous decisions to partially resolve legacy problems in telecom, such as redefining adjusted gross revenues and withdrawing retrospective tax demands. This gave rise to expectations that reforms would be less constraining, and more beneficial for the public interest. The announcement in June of 5G spectrum auctions and limited E-Band backhaul allocation, alas, falls far short. Why the disappointment, and how might the situation be improved?

Two areas need changes: Backhaul, and access spectrum. One aim is to remove self-imposed constraints. Another is to replicate the successful pattern of other sectors, where enterprises build their business, earn revenues, and then pay taxes. For some reason, this does not apply to communications despite it being a critical essential service.

Backhaul – E-Band

A fundamental problem is the limited backhaul spectrum. Two bands of 250 MHz of E-band spectrum (70-80 GHz) are to be assigned to each telco that wins 5G spectrum. This is puzzling, as there are 10 GHz available (20 times 500 MHz). If press reports that this is temporary are correct because these frequencies are to be auctioned— and telcos must agree to pay the auction price at that time — the situation is disastrous, because 5G needs large backhaul capacity.

In other countries such as the US or the EU, policies are framed so as to enable usage of the full 10 GHz at minimal cost. This provides flexible capacity for much higher throughput, whereas we are creating a self-imposed constraint by restricting capacity. This means that the Organisation for Economic Co-operation and Development countries gain more from increased productivity than a developing country with the same resource. This can be remedied by adopting their regulations as appropriate.

The public interest is well served when policies enable telcos to use available resources to increase productivity and efficiency, instead of being obstructed in delivering services, or having to spend more to achieve comparable service levels. The same goes for the discriminatory allocation of spectrum to non-telcos (private companies), who will apparently be allotted spectrum on preferential terms compared with telcos. India’s networks cannot compare with those of the OECD countries that have such policies, which is why such allocations would be too disruptive here.

Just as we are deprived of network capacity because spectrum is either not permitted for use, or is extortionately priced (both self-imposed conditions), limiting wireless backhaul or pricing it high will hamstring 5G and even 4G, because wireless backhaul will not be deployed extensively if the cost is prohibitive. These circumstances are aggravated by the threat of auctions for backhaul spectrum.

Without extensive wireless backhaul, access spectrum from auctions cannot be fully utilised because of limited direct fibre connectivity. Unlike countries that have good wireless backhaul— business hubs such as Mumbai’s Bandra Kurla Complex or Nariman Point, Gurugram’s DLF Cyber Hub, Connaught Place or the Dhaula Kuan, — the Airport stretch in Delhi, hospital and medical research complexes, engineering and manufacturing clusters, and so on, are denied vastly improved communications and access to data using gigabit wireless mesh networks. Even the spread of 4G small cells is constrained, reducing efficiency and productivity.

It would be useful to base India’s regulations on what others such as the US, the EU, and the UK are doing with E-band. They require non-exclusive nationwide licences, with mandatory coordination and link registration (usually through a geolocation database). Our comparatively less developed networks make it inadvisable to adopt their policies wholesale, because it would disrupt equitable network development in India, accentuating the divide by skewing investment to the most profitable areas.

Our authorities need to focus on setting up and institutionalising processes such as non-exclusive licensing to telcos, and the mechanism of geolocation databases for backhaul spectrum for mandatory coordination and registration. Policies need to be framed so as to help builand grow gigabit wireless links to reinvigorate the sector, to recoup its stellar trajectory and contribution as in the past.

An instructive example is the approach taken by the City of London, or the “Square Mile”, in addressing communications for its 400,000 workers every day, 10 million visitors annually, and 9,000 residents. The mix of historical buildings and modern architecture poses a challenge for mobile network services. In 2017, the City initiated a project for providing free public gigabit Wi-Fi throughout the Square Mile.¹ The design incorporated 4G small cells for better connectivity, and the City offered 3,000 street assets (such as lampposts), stipulating that the system must be a neutral host open to all service providers.

The project was awarded to a joint venture of which one company is active in India. The backhaul uses a self-organising millimetre wave (mmWave) mesh as a “neutral host” that enables use by multiple operators. The mesh gives all service providers gigabit backhaul and access applications at 12Gbps with its 60GHz mmWave access and backhaul.

5G Access Spectrum

Assuming the objective is ubiquitous 5G and other services, India needs a different approach. Spectrum auctions will not get us there. We achieved a level in mobile telephony by adopting a reasonable revenue share on licensing around 2003 after NTP-99. The same needs to be done for spectrum.

One proposed approach² suggests that as there are only three serious telecom operators, spectrum can be allocated equitably to all three without auctions. This seems reasonable, as the funds diverted to auctions could then be invested in networks, and collections from revenue sharing are likely to far exceed collections from auctions, as they did after NTP-99.³ The downside is that it would require the development of three networks, unless the operators share infrastructure. An alternative approach would be mandatory infrastructure sharing with one neutral host network, or two competing networks owned by different consortiums.

If the authorities could take these points into consideration in improving the regulations, we are likely to have better outcomes in terms of networks, services, and the state of the sector.

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Shyam (no space) Ponappa at gmail dot com

1) The City of London Case Study: https://www.gsma.com/futurenetworks; 

2) Rajat Kathuria and Mansi Kedia: https://indianexpress.com/article/opinion/columns; 

(3) See Chart 2: Telecom Auction Fees Foregone vs Licence Fees + Spectrum Charges at: https://organizing-india.blogspot.com/2020/08/configuring-indias-digital-ecosystem.html

4G, 5G, or 6G - All Need Wireless Backhaul

A rose is a rose - or is there one that is sweeter?

Shyam Ponappa   |   December 2, 2021

Calling our networks 4G, 5G, or 6G makes little difference. What matters is service delivery to users. Once there is connectivity, the criteria for judging a network are speed, capacity, and latency (lag in response time). Our 4G experience is far short on these measures. Improvements are possible if our government proceeds on the basis of (a) objective assessment, and (b) concerted action on systematic, realistic, and phased plans and execution. The starting point is a factual assessment of our networks and service delivery compared with the rest of the world. The next steps are to frame policies and regulations to enable the better use of available resources for service delivery, without irrational hurdles.

An aspect of telecom not obvious to users is the reality of layered technologies that exist even in advanced environments. For instance, a country with excellent mobile services such as Norway has achieved among the fastest average speeds of over 50 Mbps with continued investment in 4G networks. 4G has evolved considerably and provides the core network, except for Standalone 5G networks. 4G has latency down to two-digit milliseconds, and speeds comparable to 5G in the lower user bands (below 6 GHz). High-frequency 5G provides faster user access on 4G platforms.

Realistically, we should plan for a mix of technologies going forward as 4G continues to evolve over the next decade. However, we need policies that result in full 4G coverage of good quality, not merely indulgent talk. Also, while 3G is being phased out because of its less efficient use of spectrum, it will take years to transition fully to 4G and beyond because of the cost and scale. In Europe, for example, even 2G is to continue until 2025 for certain applications.

What are the policies that can give us improved services? A good place to start is the Parliamentary Committee report tabled in February titled, “India’s Preparedness for 5G”.¹ Its main findings are that while 59 countries had deployed 5G, though largely on a limited scale, India had not done so. No 5G trials had been permitted as of January, and sufficient preparatory work had not been done. The challenges highlighted are:

• Inadequate spectrum, with only 50 MHz per operator, half the global average. For 4G, average spectrum per operator was even less, at a quarter of the global average.
• Exorbitant spectrum prices.
• Insufficient development of 5G use cases.
• Low fibre network availability.
• Deficient backhaul capacity.

The report emphasises the need for heavy investment to develop fibre networks, including for backhaul, and then deals with other aspects such as investments and local manufacturing.

Fibre does indeed provide the best connectivity. While highly desirable, it is the gold standard, and often prohibitively expensive. Fibre connections to towers are ordinarily justifiable only when financially viable. Second, small cells have to proliferate for 4G, 5G, and 6G, with wireless or fibre links (backhaul) to networks and Wi-Fi user access. The question is whether aiming for full or even substantial fibre connectivity to towers and small cells is realistic, compared with alternatives and technology trends.

Interestingly, the GSM Association published two reports addressing this in February 2021. The first was a study on backhaul in 40 countries titled, “Wireless Backhaul Evolution: Delivering next generation connectivity”.² The second was on the spectrum required for this titled, “Spectrum for Wireless Backhaul: GSMA Public Policy Position”.³

The first report indicates that 5G’s growing traffic and network capabilities will need massive augmentation of backhaul capacity through evolution. Wireless links are estimated to constitute 65 per cent of global backhaul links between 2021 and 2027, evolving to higher frequencies with wider channels, with regulators’ decisions helping or hindering specific 5G markets. The E-band (70-80 GHz) is expected to dominate wireless backhaul from 2021 to 2027. Many countries are also using V-band (60 GHz) delicensed for Wi-Fi. Even countries with high levels of fibre such as Japan and South Korea are using E and V bands for backhaul. Shouldn’t we do this, too? (See chart)

Chart: Full 4G + Some 5G with V-Band and E-Band

India has many urban and rural sites where fibre is infeasible, because of factors such as congestion, distance, terrain, dispersed users, and limited commercial potential. Wireless backhaul can fill in where fibre is not accessible or affordable, although evolution to higher, wider bands will be necessary. Meanwhile, wireless V and E bands are now reasonable alternatives for distances of about 1 km, and 3-4 km or more, with the disadvantage of rain attenuation. The GSMA report suggests this could be mitigated with carrier aggregation (combining) of E-band with lower bands (such as 15, 18 or 23 GHz) to provide 10 Gbps links for up to 10 km.

Active Network Sharing

Regulators worldwide are considering or pursuing the substantial benefits of active network sharing for enhanced coverage, reduced costs, and faster deployment. A McKinsey report in 2018 cited network sharing becoming a standard model for mobile operators, with a reduction in the total cost of ownership by 30 per cent, while improving network quality.⁴

Steps for Consideration

Formulate policies, laws and regulations for the following, with mandated spectrum/network sharing, paid for by reasonable revenue share (2-3 per cent) after a moratorium of 3-5 years (no auctions). Cap profits, and penalise diversion of revenues/profits.

1. Small cells: For Wi-Fi user access, V-band lower range and 6 GHz (using FCC model, as done for 5 GHz). Consider 12 GHz for Wi-Fi next.

2. Wireless backhaul, small cells/towers: V-band upper range and E-band, with light-licensed sharing among telcos for connecting to networks.

3. Private networks, small cells and backhaul: V-band light-licensed* for private networks, with public network connection through licensed telcos.

* After reconsideration December 4, 2021: "V-band allowed in private spaces for private networks and extensions, with public network connection through licensed telcos."

4. Active network sharing: Consider enabling or mandating active sharing of all elements of networks to speed up deployment, reduce clutter and radiation, and for efficient capital investment.

Orchestration and coordination across government departments and consultation with industry, as for NTP-99, to ensure better outcomes.

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Shyam (no space) Ponappa @ gmail dot com

1. https://eparlib.nic.in/bitstream/123456789/799780/1/17_Information_Technology_21.pdf

2. https://www.gsma.com/spectrum/wp-content/uploads/2021/02/wireless-backhaul-spectrum.pdf

3. https://www.gsma.com/spectrum/wp-content/uploads/2021/02/wireless-backhaul-spectrum-positions.pdf

4. https://www.mckinsey.com/industries/technology-media-and-telecommunications/our-insights/network-sharing-and-5g-a-turning-point-for-lone-riders

Telecom Reforms: Relief - With Hope?

 

This could be a good first step towards a real transformation.

  Shyam Ponappa    |   October 7, 2021

At first glance, the big-bang telecom relief package last month might seem disappointing. A closer look shows the possibility of real promise. Could it be a subtle masterstroke, the first in a series of steps that will revive the sector? Here’s why.

• By not fully resolving the debt burden to result in sustainable cash flows, it gives the impression of a grudging debt-restructuring that doesn’t quite revive the patient, while prolonging the agony.
  
  
• However, it provides immediate relief with a four-year moratorium on cash outflows.
  
  
• An issue that defied resolution since 2003, of what constitutes revenues for sharing, has been defined rationally as revenues from telecom.
  
  
• The spectrum usage charge has been rescinded.
  
  
• Solutions for revival are to be worked out as next steps.
  
  

Although the last three are prospective, telcos get immediate relief without awaiting the formulation of complex solutions. The relief is temporary though, as outstanding dues must be paid with interest. Unless much more is done, there will be a prolonged attrition, with high opportunity costs from the continuing non-availability of services that severely constrain our capacity and productivity.

Meanwhile, another significant reform was introduced unobtrusively: Active network sharing. Blocking active sharing amounts to depriving the country of full utilisation of capital-intensive resources. Imagine having separate private road systems, or gas pipelines, and insisting that vehicles (or gas) must go from place to place only on their own networks. This was the situation in telecom until interconnection was made mandatory, but the latter did not eliminate network duplication, whereas active network sharing allows for eliminating it.

Thereafter, news that the government may change its position on spectrum charges due suggests more pragmatism. If the above interpretation is correct, the subtlety and quick action while avoiding opposition by not seeming to give away too much augur well.

For transformative reforms and a genuine revival, the Ministry of Communications and Information Technology could take the approach that worked reasonably well for NTP-99, with coordinated planning and initiatives through the PMO across ministries and corporations, and external advice as appropriate. While it was not perfect, the NTP-99’s adoption of revenue sharing succeeded in expanding mobile telephony enormously. Learning from that experience in handling the details may help to avoid situations such as the legal wrangles on the scope of revenues, and the false starts. For instance, the government’s share was set too high initially at 15 per cent, and thereafter, spectrum auctions after the “2G scam” crippled the sector because of the “winner’s curse”, as auctions did in much of the world. We had best avoid such situations.

Wi-Fi Small Cells

The ongoing evolution to small cells amplifies the need for sharing. Mobile handoff to Wi-Fi is already the norm for 4G. Ubiquitous 4G networks and later upgrade to 5G and 6G will require the installation of many more small cells, with Wi-Fi for high-speed user access. These could augment existing Wi-Fi bands (2.4 and 5 GHz) with 6 GHz and 60 GHz when these bands are permitted. Proliferation of small cells will be more feasible because of lower costs and easier installation with wireless point-to-point links instead of fibre, and mandatory sharing. “Wireless fibre” links could use light-licensed (open access to licensed service providers for connecting to the internet) spectrum in the 60 GHz (V-band) and 70-80 GHz (E-band). Gigabit delivery at far lower cost than fibre could be deployed across urban, semi-urban, and rural markets.

Small cells for users need to be built out with “wireless fibre” links from where fibre terminates in much of the country, in urban as well as rural areas. An alternative depending on costs is satellite links to small cells. In effect, the need is for the national fibre network, BharatNet, to be extended to non-urban users outside district and block headquarters. Small cells funded by the Universal Service Obligation Fund combined with the BSNL’s and other installed networks could fulfill this need, with service providers given non-discriminatory access on payment through revenue sharing. A consortium approach with private sector leads could be considered.

Shared Spectrum & Infrastructure

A burdensome remaining constraint for network proliferation is licensed spectrum costs. Yet, the alternative of giving access to a spectrum pool without auctions for a share of revenues would probably result in much higher government revenues, as happened with licence fees after NTP-99 (see charts).

Chart 1: Operator Revenues ($ Billion)

https://www.ibef.org/download/Telecommunications-June-2020.pdf

Chart 2: Revenue Share Collections Exceed Auction Payments After NTP-99

          Telecom Auction Fees Foregone vs Licence Fees + Spectrum Charges

For explanation, see: https://organizing-india.blogspot.com/2020/08/configuring-indias-digital-ecosystem.html

Shared access by licensed telcos to pooled spectrum will enable broadband for more areas and people, with full utilisation of unused spectrum greatly increasing traffic and revenues. The DoT needs to start with regulations for spectrum bands in 60 GHz, 70-80 GHz, and 6 GHz. Thereafter, regulations could be considered for shared spectrum without auctions. (1)

Debt Resolution for Cash Flows

An immediate priority for the sector is sustainable cash flows. The burden of adjusted gross revenue (AGR) and spectrum usage dues arose from misconceived policy errors, by efforts to include unrelated revenues, and overcharging for spectrum. Debt restructuring customarily involves elements such as reduced principal (“haircuts”), interest waivers, and extension of repayment periods, to enable sustainable cash flows. Much of the principal for AGR dues was created by including revenues unrelated to the licences to be paid for, an error corrected going forward. Past licence-related revenues would be much less, and favourable judgments prior to 2019 upheld this. The interest component in AGR dues is about three times the principal. The government could justifiably adopt policies to reduce most or all outstandings with this reasoning, as also consideration of the effort, cost and hardship endured by service providers, their employees, and the public for service deprivation of the critical support that broadband can/could have provide/(d). Further, this would also facilitate investment for better services.

Corrective Policies, Laws, Regulations

A participative process on these issues starting with debt resolution could be used to frame policies going forward, including the requisite legislation and regulations. The above measures can revive and invigorate our telecom sector.

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Shyam (no space) Ponappa at gmail dot com

(1): See “Enable Spectrum Usage on Feasible Terms” at:  https://organizing-india.blogspot.com/2020/03/indias-self-goal-in-telecom.html