Fact-checking the fad for delicensing mid-band spectrum

India needs to secure and plan the availability of the 6 GHz band spectrum to meet the future needs of 5G mobile communications and beyond

In the world of telecom, the spectrum can easily be considered Oxygen. It is, without doubt, the most vital component in a complex mix of ingredients required to produce an efficiently working network and deliver connectivity services to the customers. It is no surprise then, that adequate spectrum is the primary factor to determine the efficiency of how the telecom networks perform.

Given that over 96% of subscribers in India access broadband through mobile devices, it is important to ensure that the spectrum supply is sufficient to cater to their incredibly fast-rising appetite for data. This is beside the fact that as we move to more advanced technologies like 5G, 6G and so on, the spectrum requirements are shifting to higher bands like mmWave, which have much higher capacities, but lack in coverage reach. This is where the mid-band spectrum comes into play, as they offer a great balance between both capacity and reach, and would be critical for the deployment of 5G in India.

The criticality of mid-bands for 5G and its evolution is established by the fact that out of the 176 global 5G networks rolled out, around 70% (~120 networks) have harnessed mid-bands.

However, a contention has been rising in this regard as certain quarters are lobbying for the mid-band spectrum, especially the 6 GHz band, to be delicensed for Wi-Fi use. The advocacy is based on how global economies like the EU, South Korea, USA, UK, etc. have dealt with it (partially in most cases). The prime issue in India, however, is the unrealistic comparison with such countries. One must understand that being a stationary technology, Wi-Fi is more dependent on last-mile connectivity for effective functioning.

The primary requirement, in this case, is a robust fixed line network with fibreisation of ~80%, which is true for the mentioned nations as compared to a meagre 35% in India. So, delicensing precious mid-band spectrum for Wi-Fi will not garner many benefits. The existing unlicensed spectrum in the 2.4 GHz and 5 GHz, amounting to 688 MHz bandwidth, is more than adequate for meeting India’s needs for Wi-Fi connectivity in the 2025-30 timeframe. The sector regulator TRAI, in its Recommendations on Roadmap to Promote Broadband Connectivity and Enhanced Broadband Speed (31 August 2021), has clearly stated that “… in India the existing spectrum bands for Wi-Fi i.e., 2.4GHz and 5GHz have still not been fully utilised”.

Even during the Covid pandemic, it was observed that mobile users in India spent the least time on Wi-Fi, substantiating the fact that International Mobile Communications (IMT) and cellular networks continued to serve as the preferred source of connectivity in the country (see the table Mobile Experience during the COVID-19 pandemic).

It is also important to understand that delicensed and unlicensed spectrum comes with its own set of disadvantages.

Higher congestion: Some frequency bands are heavily utilised and, as a result, they may be completely useless to mobile network operators. This is especially true for the 2.4 GHz spectrum band, which is commonly used for personal and business reasons.

Regulatory limits: Many frequency bands operate under regulatory limits on effective radiated power. Users must be aware of and comply with the regulations for their region.

An inadequate allocation in the 6 GHz band will lead to a 50% reduction in 5G speeds. The speed may go down by 80% if only 700 MHz is allocated to 5G.

Reduced security: Since access is public, unlicensed spectrum increases the risk of unauthorised access, control and manipulation of information. This is vital given the aspects of both national security as well as data security of the consumers against fast-rising cases of cyberattacks and frauds. In future, this is expected to increase further, with more sophistication and technological advancement being adopted by such inimical entities.

Last but not the least, delicensing of the access spectrum creates a non-level playing field which goes against the principle of fair competition.

Industry data shows that 2022 has been the worst year so far for India when it comes to cyberattacks, a problem that has only grown with increasing digitalisation. Unlicensed spectrum, though it may seem more cost-effective, greatly increases the risk of congestion and cyberattacks, threatening a system’s operational integrity.

On a commercial level too, while unlicensed spectrum is favoured by new participants because of its availability and lack of acquisition cost, conversely, it leads to the national government missing out on revenue. While this may be an amicable solution in the short term while the technical viability of technologies is being established, it poses a long-term risk.

Moreover, managing interference between adjacent users is more difficult in unlicensed than licensed spectrum. Why? Because the usage is uncoordinated and haphazard, with no regulatory restrictions other than a restriction on the transmission power.

The technical rules that are required to support unlicensed use of spectrum, like radiated power restrictions, also lead to some intrinsic limitations, such as the unsuitability for providing wide area coverage, ‘on the go’ services and predictable quality of service, which in turn, limit the use cases.

On the other hand, licensed spectrum offers greater reliability and better performance. For emerging applications such as IoT, companies using delicensed bands for IoT deployments run into reliability and performance issues more frequently than those using licensed spectrum, in part because they simply can’t control what other people do. It may work today, but might not work tomorrow, for say, a baby monitor placed in the vicinity of your smart meter. That makes it a risky choice, particularly for companies concerned with liability and security issues. Licensed spectrum provides wider coverage, exclusive access, faster performance and supports high usage. This would help support 5G by enabling low-latency connectivity, security and increased data transfer rates, which are aligned with the growing demands of the users.

Importantly, it is understood that the National Frequency Allocation Plan (NFAP) should conform with the ITU Radio Regulations. This has been the practice so far and is important for ensuring a global harmonised approach, inter-operability and economies of scale, which are critical for the success of any technology or service. Spectrum identified exclusively for IMT Services should not be assigned for non-IMT services, and should not be delicensed either. Also, any spectrum below 2 GHz frequency (even non-IMT band) should not be delicensed. Any decision on delicensing of the new band(s) must be taken only after demand studies, current usage audit, impact on competition, impact on existing investments and due recommendations from the Regulator.

As of now, several spectrum bands are already unlicensed in India. These include 2.4 GHz and 5.8 GHz bands for Wi-Fi access, 865 MHz-867 MHz band used by RFID devices, 402 MHz – 405 MHz spectrum band used for medical wireless devices, 335 MHz for remote control of cranes, and so on. However, the provision of a minimum of 2 GHz of mid-band spectrum is critical for mobile communications in the country, especially beyond 2025. In that context, 6 GHz (5925 MHz – 7125 MHz) is the only mid-band spectrum range where a contiguous bandwidth of 300-400 MHz per TSP is available for evolving demands towards 2030, and can enable the growth of sustainable 5G capacity on 5G sites. It is also evident through various sources that the timely availability of 6 GHz, at reasonable conditions and price, will drive cost-efficient network deployment, help lower the broadband usage gap and support digital inclusion in the country.

As per a GSMA Intelligence study, any shortage of 6 GHz spectrum would compel TSPs to densify networks to meet the IMT-2020 performance requirement for 5G. The country would have to account for around 60% higher annual costs to achieve the performance expected from 5G services without adequate spectrum in the 6 GHz band, or 20% higher if only 700 MHz is allocated to IMT, compared to an assignment of 1.2 GHz. In addition to cost hikes, densification on large scale would negatively impact the commitments made by India in reducing the country’s carbon reduction and related green objectives.

An inadequate allocation in the 6 GHz band will lead to a 50% reduction in 5G speeds. Similarly, the speed may go down by 80% if only 700 MHz is allocated to 5G. To overcome the speed issue due to the lack of spectrum, TSPs will have to undertake network densification. Hence, the most optimal allocation for the country in the 6GHz band is to identify the entire 5925-7125 MHz i.e., 1200 MHz spectrum for IMT applications as this would maximise the economic and societal benefits for achieving the national target of becoming a USD 1 trillion digital economy.

Given the experience of worldwide network deployments to date, it is reasonable to assume that, going forward, mobile technologies relying on the licensed spectrum will play a much bigger role than technologies relying on the unlicensed spectrum in closing the digital divide, especially in rural and remote areas. With the rapidly advancing global technology scenario, a forward-looking approach is necessary for India to ensure that future requirements would be met adequately going forward. It would, therefore, be crucial for the nation to secure and plan the availability of mid-bands to meet the requirements of the spectrum demand for mobile communications in the 2025-2030 timeframe.

By Lt Gen Dr S P Kochhar

Lt Gen Dr Kochhar is the Director General of COAI

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