ISpA responds to TRAI's consultation paper on spectrum for satellite communication

If spectrum is auctioned, it will fragment it and unnecessarily divide this very vital resource which is there and we have to go by globally accepted and harmonized methods

Industry participants, regulatory bodies, and telecom carriers are debating how India should allocate spectrum for satellite communication. A recent consultation document on the assignment of spectrum for space-based communication from the Telecom Regulatory Authority of India, (TRAI) has generated a range of responses from stakeholders. While some support the administrative methodof allocating spectrum, others are in favour of open auctions.

Global best practises, according to ISpA, a significant industry group in the space industry, promote administrative allotment of satellite spectrum.

Lt. Gen. AK Bhatt, DG, Indian Space Association (ISpA) recently made a submission at TRAI OHD on Consultation Paper on 'Assignment of spectrum for space-based communication services’. The submission stated:

Chairman TRAI, all distinguished officials on behalf of ISpA, we are thankful to TRAI, first for taking out a very comprehensive and detailed paper on the critical issue of assignment of spectrum and secondly and most importantly, agreeing to have a more open and 360º discussion on the wider aspect of assignment of spectrum keeping in mind the best global practices and more importantly, the needs of the nation’s space industry and not limiting the discourse only to the method of how to auction spectrum. We firmly believe that TRAI’s inclusive approach will benefit our members, our nation, to make an informed decision on this very important issue of assignment of spectrum for space.

Space-based Communication Services to connecting unserved and underserved areas

The first issue is space provides connectivity to the furthest corners in India and today where rural internet is only 38.93%, this can overcome the digital divide and provide services including vital services for education, health care, and everything to the furthest corner. And of course, we recommend that all our members believe that if spectrum is assigned by administrative method, this opportunity will grow more.

Globally Accepted and Harmonized Method

Very importantly, if spectrum is auctioned, it will fragment it and unnecessarily divide this very vital resource which is there and we have to go by globally accepted and harmonized methods. We have an organization called ITU where spectrum for different services is there and we need to pay attention to this that answers my first question, that ITU has laid out and it is laid out where all services spectrum has to be used, we need to pay attention to that.

Social Impact and Public Good vis à vis Economic Value

Most importantly, we have to see the public good and the social impact and not the economic value of allocation because, if only economic value for revenues are important, space is at a weaker wicket compared to terrestrial communication. But if we are looking at the future, we are looking to overcome the digital divide, space has to be a co-traveler.

Overhang of 2G Decision

I will just say one line on the 2G decision which has been an overhang in the whole discussion, we need to see the Presidential reference in more detail and especially pay attention to the issue where it says that for the common good auction is not the only method and other methods can be exercised by the government.

Exclusive Use of Spectrum creates unnecessary fragmentation

And most importantly, one danger of auction which we have to avoid is that we don’t make inefficient gatekeepers and people who hoard spectrum. For question two, we have given you a little detail of how L band S band and others are used and more details as we get from the members, we will be forwarding it to you. The third question which you have asked sir, that is there a practical limit, presently this issue is also being discussed in the ITU. But what it stands today, there is no limit. Of course, technology cannot be infinite, there will be a limit there for which discussions are already going on in ITU and we need to pay attention to it and not restrict it today only for our nation.

Submission No. 2

Exclusive Use of Spectrum creates unnecessary fragmentation

Flexible use would be dangerous, both technically and commercially. Technically because satellite communication is the one which will suffer if there is flexible use between terrestrial and satellite that has been explained by one of the previous speakers. And similarly, commercially what you can gain for terrestrial, you cannot gain and use it for space. Again, this nascent industry will be affected by that. So, if our aim is growth, opportunity, and getting the smaller, new startups which are the larger part of space, who have opportunities and especially in certain areas like telemetry, usage in EO and usage for ISR and RS, we need to protect the interests by not auctioning the spectrum.

Reciprocity and International Alignment

Now, one issue which has not so far come, and which is only once mentioned by OneWeb, of course, so there are existing satellite constellations which have identified the bands they are using. If we think of an auction, and I'm talking about theoretical example, that if that auction is won by something, that means that service, that satellite constellation is not available to India, that may be in the GEO or it may be in the NGSO number that will one. What will happen in the future, I see one of the Indian constellations providing global service, the other way around. We will be stopped by reciprocation because we have not allowed people by having auctioneers and this is the reason why in USA, they had taken out the Orbit Act (2000), that competitive bidding will not be permitted for satellite spectrum.

We should keep it in mind and most importantly, sir, we cannot say we will stand alone, we have to in space, where it is controlled by no boundaries, our rules, our procedures have to be in alignment with the global system. And India has believed in ITU allocations, ITU processes we have so far honored and followed them, we need to continue to do that.

Auction models will create artificial scarcity of spectrum

So, the one which was in the last but I'm just coming to it, is the model which we have been thought of auctioning. Model I restrict competition, which is wrong if we only limit it to three to four, that was two model the example was that and we do not recommend it for that. And then Model II is the auction and thereafter share. We are only creating a perception that it is being auctioned, and actually it would be sharing. We might as well do it from the beginning and give it by administrative method and let it be shared as it is there. 28 Gigahertz or as you would know world over is being used by space players. If this is given to IMT many of the services world over will not be available to us. Secondly, we need to learn from the experience of nations which have given 28 gigahertz to IMT and have withdrawn. We have the advantage of learning from what people have done and not repeat the same mistake.

Vodafone and Reliance Jio, on the other hand, object to the administrative allocation procedure and reference a Supreme Court ruling that requires the transfer of the licence to use such spectrum through open auctions. These telecom companies stress how crucial it is to follow the court's ruling while expressing worry about potential legal repercussions.