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.

---

 Shyam (no space) Ponappa at gmail dot com

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.

---

Shyam (no space) Ponappa at gmail dot com

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

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.

---

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

Recapturing the Commons

Regulations that facilitate infrastructure with appropriate public resource use will enhance productivity.

Shyam Ponappa   |   March 7, 2019

Growth in the third quarter was disappointing, but there are signs of a cyclical recovery, with a Purchasing Managers Index for manufacturing at a 14-month high. For a significant upward shift of our growth curve, however, apart from lower interest rates, policy-makers have to be constructive. What might we wish for? Here are some suggestions.

Accept the reality that investible funds in India are insufficient for our needs. These include our stock and net inflow of capital, and profits available for investment. We can try to increase our productive capacity or choose business-as-usual, thereby staying below our potential. Why? Because our activities aren’t profitable enough to induce and sustain investment. We need investment —in hard infrastructure, such as transportation and logistics, electricity, water and sewerage, and communications, and in second-order infrastructure, such as security and law and order, health care, education and training, banking, finance and insurance. There’s also the need for reorganisation of markets and practices, e.g., in agriculture, infrastructure, and government procurement.

There’s little doubt that digital connectivity is invaluable for all these. While the imperative is clear, the question is how to orchestrate achieving the desired results.

The telecom operators, alas, have low profitability, inadequate network coverage, and too much debt. Continuing as before means subpar access and productivity for all. We are all hamstrung, and even more so in rural areas. Because of the expanse an7d scattered users there, connectivity entails much higher costs with lower revenue potential.

Self-Organising Infrastructure – A Conceptual Flaw Without Regulatory Support

Meanwhile, there are conceptual flaws in our approach. The National Optical Fibre Network (Bharat Broadband Network Limited or BharatNet) was conceived as a countrywide fibre backbone. The plan was for optical fibre links to 250,000 gram panchayat villages covering India’s approximately 600,000 inhabited villages. A major assumption, however, was that private operators would build access networks to villages and to users. This was unrealistic for a number of reasons. First, there’s the cost of covering sparse users over large expanses with low revenue potential. Second, the supportive regulations for wireless technologies to build the access networks were/are not in place. For example, even for the established 5 GHz WiFi range used globally for WiFi hotspots, restrictive policies meant that 5 GHz equipment could not be used effectively in India in urban or rural installations. This changed with new regulations for 5 GHz, but only four months ago in October 2018 (for details see https://organizing-india.blogspot.com/2018/11/a-great-start-on-wi-fi-reforms.html).

Other wireless technologies for intermediate- and last-mile links are still blocked, and need enabling regulations.

• The 700 MHz band: No operators bid for this given its high price, although it is very useful for covering distances of 5-10 km, and can penetrate walls and foliage. This band together with the 500 and 600 MHz bands could be used to connect gram panchayats to nearby villages. A study of inter-site distances in 14 states shows that most villages would be covered with this range (see Chart below).
  
  
  Study of Inter Site Distances - Gram Panchayats and Villages

• Source: https://tsdsi.in/wp-content/uploads/2019/02/Krishna-Ganti-Day-1-5th-Session-1.pdf

• The 500 and 600 MHz bands are allocated for TV, and therefore are part of the “tragedy of the unused commons”. Only a small fraction is used for broadcasting in India because of limited free-to-air TV and better alternatives. As they are earmarked for broadcasting, they are not used for telephony either.

• The 70-80 GHz band (E-band) is effective for short-range links covering more users at 3-4 km, but not permitted in India, although it is light-licensed in many countries with nominal fees, e.g., the USA, UK, Russia, and Australia. While ideally our regulations should align with global norms, there are exorbitant charges on operators (reportedly 37 per cent, plus corporate taxes), a debt overhang from spectrum auctions, huge investment needs, and relatively low revenue potential. Compelling arguments to let operators use the E-band with unlicensed access, with registry on a geo-location database to manage interference, to be reviewed after some years. The additional traffic will generate revenues from which government collections will increase.

• The 60 GHz (V-band for distances up to 1.6 km): the Cellular Operators Association of India (COAI) opposes making it licence-free as in most countries, and wants it assigned to operators for access and backhaul. For the same reasons as for E-band, operators could be allowed unlicensed access, with a review after some years.

Market Structure and Organisation

A larger problem is that legacy structural and organisational issues need concerted efforts to take requisite policy initiatives. This is perhaps a greater, more urgent need for ubiquitous connectivity.

Successive governments have struggled with revival plans for BSNL and MTNL, somewhat analogous to Air India and Indian Airlines in aviation. Governments have not provided sustained support for ambitious connectivity objectives. There is sometimes inadequate understanding of fast-changing, technically complex enterprises, and episodic attention is given to large enterprises that need timely capital- and skill-intensive decisions (and decision-makers in place), and the upgrading of skills and operating practices. BSNL and MTNL are declining, with bailouts, market disruption through price-cutting, and inability to deliver profits. This is a huge opportunity cost on citizens. However, it is conceivable that with appropriate leadership, and organisational and capital backing, these enterprises could contribute effectively to ubiquitous connectivity, rather than being a drag and/or a disruptive factor. This could happen, for instance, if an alliance were possible with private sector operators providing leadership, organisation and capital, while state ownership concentrates on safeguarding the public interest.

Bharti Enterprises’ Chairman Sunil Mittal has suggested an alliance with Vodafone for an optical fibre network. Bharti and Vodafone already have a joint venture, Indus Towers, providing passive infrastructure services to operators. If regulations enabled active infrastructure from a consortium including BSNL and MTNL, it would leverage the infrastructure while reducing the capital requirements, and increase delivery capability. The entire thrust of regulations could be oriented to facilitating service delivery, leveraging capital, equipment and human resources.

The regulatory approach should aim to facilitate access equitably to public resources that belong to citizens, and not to create obstacles.

---

Shyam (no space) Ponappa at gmail dot com