Reliance Jio is not in agreement with its two counterparts on inter-band spectrum sharing among telecom service providers.
TRAI had invited comments on its consultation paper, Telecommunication Infrastructure Sharing, Spectrum Sharing, and Spectrum Leasing.
In the comments the respective telcos wrote,
Airtel. “Inter-band access spectrum-sharing among access service providers should be permitted particularly because, since 2015, spectrum sharing in India is in existence with the sole objective of enhancing spectral efficiency by combining/pooling the spectrum holding.
However, till now, spectrum sharing has only been permitted intra-band. Before this, prior to the deployment of 4G, specific spectrum bands were used for providing 2G and 3G technologies. For example, for GSM (2G) Technology, only 900, 1800 MHz were used, while for CDMA technology, only the 800 MHz band was used. With the maturing of 4G services, and technological innovation and spectrum becoming liberalized, TSPs have started offering the same technology across spectrum bands.
4G can be deployed in multiple bands like 800, 900, 1800, 2100, 2300, etc.. Similar case is with 5G. Since the practice of linking a particular technology with only a specific spectrum band(s) has been discontinued, the time has come to extend spectrum sharing to ‘inter-band’ as well, not just limiting it to ‘intra-band’.
This will be consistent with the objective of further efficient utilisation of spectrum and will lead to better QoS and wider coverage. In fact, with traffic increasing significantly, this is now even more relevant. To cite an example, over the last 3 years, data traffic has increased by 4X, i.e., 4.5 exabytes in 2018 to 14.4 exabytes in 2022. It is expected that traffic will triple to 21 exabytes by 2025 in future.”
Vodafone Idea. “Inter-band access spectrum sharing should be permitted in the country. As the spectrum is purchased on a market price through an open and transparent auction, the spectrum holding TSP should have the right to fully exploit commercial value of the spectrum, including through Inter-band spectrum sharing.
The lock-in of 2/3 years from the start of spectrum allocation can be kept during which TSP would not be allowed to enter into inter-band spectrum sharing.
Inter-band spectrum sharing would primarily work in part geographies of a LSA.The scenario wherein a TSP would surrender the spectrum in whole LSA and would opt for inter-band spectrum sharing in part-LSA would be far-fetched.”
Jio. “The concept of inter-band spectrum sharing has whole different connotations and would have many negative fall outs. We submit that this will help to provide access to spectrum bands that the TSP has never opted to acquire in spectrum auction and would be detrimental to competition in sector and can lead to collusion among TSPs to bring down the spectrum prices with availability of spectrum for their respective use. We also agree with similar apprehensions expressed in para 3.14 of the consultation paper.
Further, as spectrum sharing will necessarily be done on LSA level, it will provide the TSPs an opportunity for pre-auction understandings that will impact the fair competition in auction and will lead to fall in market price of spectrum thereby making spectrum auction a failure.
Furthermore, we understand that inter-band spectrum sharing will have the impact of virtual network sharing and can lead to a situation where two entities have intermingled joint networks in all service areas and act virtually like a giant dominating behemoth without passing through the competition related rigours of mergers and acquisitions. In view of this inter-band spectrum sharing should not be permitted.
Inter-band spectrum sharing will in turn reduce the CapEx and OpEx digital infrastructure investments by service providers with easy access to spectrum and network without actually investing. This will adversely impact competition in the sector,”
All three telcos agreed that spectrum leasing should be allowed, and Jio suggested that it should be the preferred route to set up captive non-public networks (CNPN) or private networks.
TRAI had also sought views on mandatory sharing of infrastructure that has been funded, either partially or fully, by the government through universal service obligation (USO) fund, or otherwise. Here too the telcos stood split, with Vi in favour and Jio and Airtel opposing the suggestion.