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IAFI tells TRAI to permit full sharing of active infrastructure

ITU-APT Foundation of India (IAFI), in its comments to the TRAI on consultation on Telecommunication Infrastructure Sharing, Spectrum Sharing, and Spectrum Leasing, recommended that sharing must be permitted across all telecommunication service licenses it will substantially reduce the entrance and operational costs and further reduce the development risks for all operators when offering new services and applications. Also, infrastructure sharing will enable rationalization of legacy networks, such as basic, 2G or 3G networks along with 4G or Long-Term Evolution (LTE) networks especially considering the falling revenues of these legacy networks.

On active infrastructure sharing, IAFI advocates that active infrastructure elements which are not permitted to be shared at present should be permitted to be shared among licensees of telecommunication services because by sharing active infrastructure, operators can reduce their capital and operational expenses, while still providing high-quality service to their customers. Also, by using open interfaces and standardized protocols, operators can mix and match equipment from different vendors, reducing vendor lock-in and increasing competition. In addition to the benefits of interoperability and vendor diversity, active infrastructure sharing can also reduce costs.

IAFI also suggested that DoT should regularly monitor the sharing of active infrastructure and may ask the licensed operators to submit status reports from time to time as a precautionary measure as sharing of additional active infrastructure elements is a complex process involving many interfaces but is necessary for cost efficiencies and for maintaining strategic differentiation within service providers.

IAFI also advocates that there should also be a long-term commitment between the operators regarding the time-bound sharing of various components of the active infrastructure, as service providers have the right to reserve capacity for future use based on the future network roll-out plans. However, details of such commitments should be left to the operators to decide without any guidance from the licensing authorities. IAFI supports an open environment for active infrastructure sharing as it expands the ecosystem, and with more vendors providing the building blocks, there is more innovation and more options for the Operators which can help them focus on the services and thus they can add new service offerings.

Furthermore, the DoT has a role to play in ensuring that telecommunications networks are secure and resilient. By promoting the use of software-defined networking and virtualization, as well as encouraging operators to share infrastructure, the DOT could help to create a more flexible and robust network that is better able to withstand cyber-attacks, natural disasters, and other disruptions.

IAFI On the other hand, there are potential downsides to involving the DoT in the implementation of open RAN or active infrastructure sharing. One concern is that regulatory involvement could stifle innovation and slow down the development of new technologies. Another concern is that the DoT could inadvertently create new barriers to entry or favour certain players over others, thereby undermining the very competition it seeks to promote. Ultimately, whether the DoT should be involved in active infrastructure sharing depends on the specific circumstances and goals of DoT. Therefore, IAFI is of the view that while it may be beneficial in some cases, it should not be mandatory across the board. Instead, the DoT should take a measured approach that balances the potential benefits with the need to promote innovation, competition, and consumer welfare.

On should there be any obligation on telecom service providers to share infrastructure that has been funded, either partially or fully, by the Government through Universal Service Obligation (USO) Fund or otherwise, with other telecom service providers, IAFI suggests that since Infrastructure developed by any TSP’s as per the direction and funds from USOF, are generally assigned to TSPs on nomination or on a tender basis by the USOF where the service provider is required to set up, operate, maintain, and manage the respective infrastructure as per the terms and conditions laid down in the agreement signed between TSP and USOF, therefore, IAFI is of the view that the infrastructure so created by TSP, utilizing public money must be made available to all TSPs through some mandatory infrastructure sharing regulation to extend the benefits to more and more population living in such area and should not be restricted to the subscribers of the particular TSP. IAFI believes DoT should issue suitable guideline for the same.

On what measures could be taken to encourage roaming arrangements among telecom service providers in remote and far-flung areas, IAFI is of the view that considering the hardship faced by the subscribers due to connectivity issues in remote and far-flung areas and non-availability of the network of any service provider in a complete area, the licensor/DoT should encourage the operators to enter into roaming arrangements among the various mobile service providers operating in such areas by providing some incentives to the operators. DoT should publish a list of such area on its portal.

IAFI is of the view that the best way to ease out the hardship faced by the subscribers in remote and far-flung areas due to connectivity issues would be for accessing high-speed broadband connection, through Wi-Fi, Haps or through Satellite. DOT should consider delicensing more spectrum for Wi-Fi, particularly in 6GHz and V band. Further many NGSO satellite service providers are also working toward improving their services with improved performance, faster data speeds, and larger capacity for easier downloading of data. Wi-Fi routers with mast/tower can be installed for providing last mile services. DOT needs to ease the licensing norms for such systems, including their Gateway earth stations. Further, Funds collected by USOF can be provided to such willing service providers as CAPEX/OPEX subsidy for extending high-speed broadband services in such difficult area.

IAFI advocates that there is no possibility of any adverse impact on competition and dynamics of the spectrum due to inter-band spectrum sharing, as 5G services have started rolling out in India and the development of the complete eco-system may take at least two to three years. This is in reference to if TRAI were to permit inter-band access spectrum sharing among access service providers, what measures should be put in place to avoid any potential adverse impact on competition and dynamics of spectrum auction. Since many 5G/ IMT Applications requires very large amount of data, therefore IAFI cautions that more spectrum will be needed by all telcos by 2025. It should be kept in mind that all natural resources should be optimally used including spectrum.

On the issues relating to Authorised Shared Access (ASA) of Spectrum, IAFI has argued that in a dynamic spectrum sharing, the Secondary User’s (SU) opportunistically access the spectrum to discover routes and to transit the data. The basic components of this system include spectrum opportunity identification, opportunity exploitation and regularity policy. The biggest challenge in such a system is the interference management. Considering interference and security aspect, many spectrum bands currently being used could be considered for dynamic spectrum sharing. Examples of CBRS in USA could replicated in India in mid bands.

The potential spectrum bands in which ASA (Authorized Shared Access) implementation could be considered include mid bands between 3 GHz and 7 GHz. In particular, the 3.5 GHz band, 4.9 GHz band, 6-7 GHz band, and TV white spaces are most suitable for ASA. Such sharing can provide excellent spectrum resources for Private or Industrial networks in the bands which are currently occupied.

According to IAFI, the methodology for spectrum assignment to secondary users should be based on factors such as the amount of spectrum available, the type of service or application being used, and the level of demand for spectrum in a particular area. Spectrum charging mechanisms for such assignments can include auctioning, administratively assigned prices, or revenue-sharing arrangements.

The work of managing shared access of spectrum can be entrusted to a regulatory body or committee tasked with overseeing the implementation and management of ASA. This can include developing guidelines and regulations for spectrum sharing, coordinating spectrum use among multiple users, monitoring interference, and resolving disputes. The regulatory body can work closely with industry stakeholders and other relevant organizations to ensure the effective implementation of ASA.

To ensure that the ASA technique-based dynamic spectrum sharing is transparent and predictable. IAFI believes that it can be achieved by providing clear guidelines for the use of the technology and ensuring that ASPs have equal access to spectrum. By monitoring the impact of ASA technique-based dynamic spectrum sharing on competition and the dynamics of spectrum auctions. This can be achieved by collecting data on spectrum usage, ASP market share, and auction outcomes. Also, IAFI propounds the establishment of a dispute resolution mechanism to handle any conflicts that may arise between ASPs. This can be achieved by establishing an independent regulatory body to oversee the use of the ASA technique-based dynamic spectrum sharing and to resolve any disputes that may arise.

In summary, permitting the ASA technique-based dynamic spectrum sharing among access service providers can have several benefits, including improved spectrum efficiency, increased availability, and enhanced competition. However, regulatory issues need to be carefully considered.

CT Bureau

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