3G Services and Broadband Wireless Access

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					AUSPI/12/2006/       118                               30th June, 2006

Shri Nripendra Misra,
Telecom Regulatory Authority of India,
A-2/14, Safdarjung Enclave,
New Delhi - 110029

Sub: AUSPI Response to TRAI’s Consultation Paper No. No.9/2006
     dated 12th June 2006 on ‘Allocation and pricing of spectrum for
     3G Services and Broadband Wireless Access’.

Dear Sir,

At the outset, we have a grave doubt whether the 3G Policy is required at all.
Our license authorizes provision of voice and data services and 3G is
nothing but a higher data application.

Unified Access Service licensing regime is technology and service neutral
and service providers are permitted to provide all types of access services
and the licenses do not define whether the services being provided is 2G or

TRAI, most importantly must look into the inequality and non-level
playing field of allocation of spectrum today for CDMA operators. This
needs to be corrected urgently.

Also, we like to point out that references have been made in the consultation
paper that 2 GHz band is for 3G services whereas WRC 2000 has not made
any    distinction     regarding      utilization of  other    bands     viz.
800/900/1800/1900/2100 MHz for 3G services.

In addition, we would also like TRAI to initiate process of due diligence
regarding utilization of present Cor-DECT band of 1880-1900 MHz. This
review be conducted particularly in the metro and large cities where this
band is not being utilized at all so that this band be considered for allocation
to CDMA operators.
However, we are enclosing our response to the issues raised by TRAI in the
above Consultation Paper.

AUSPI requests the TRAI to kindly take our views into consideration while
coming out with its recommendations on the subject.

Thanking you,

Yours faithfully,


Encl: As above

Copy: Shri Rajendra Singh, Secretary, TRAI
              Shri S N Gupta, Principal Advisor (FN), TRAI
              Shri Sudhir Gupta, Advisor (MN), TRAI
              Dr. M Kannan, Advisor (Eco), TRAI



i)   What principles and criterion should be taken into consideration
     for identification of specific bands for 3G services in India?

     (a)   The following principles and criterion should be taken into
           Consideration for identification of specific bands for 3G
           services in India.

              Technology neutral judicious allocation of spectrum to all
               service providers.

              Equality principle for all technologies and no discrimination.

              Compatibility with frequency band working in India. Present
               availability of compatible equipment / handsets from
               multiple vendors’ world wide in the bands so as to leverage
               economies of scale.

              Sufficient upfront allocation to allow efficient planning based
               on international norms in order to provide voice, video &
               data services comparable to international standards to

              Feasibility of international roaming.

     (b)   To make the service affordable to the subscribers, AUSPI
           recommends that spectrum for 3G            services should be
           considered as an extension of 2G mobile services and should
           necessarily be treated in the same manner as 2G. There is
           nothing exclusive about the 3G spectrum band or services. 3G
           services are capable of being provided in various bands as has
           been recognized by ITU. ITU has explicitly stated that different
           administrations have allocated different bands for different
           services and hence for various 3G applications also ITU has
           identified different bands. There is no specific frequency band
           reserved for 3G services. All bands globally identified for these
      services have equal status. Depending on the country any
      band including all existing bands where 2G services are
      available, 3G services can be provided.

(c)   Under Unified Access Service Licensing regime, which is
      technology and service neutral, service providers are permitted
      to provide all types of access services and the licenses neither
      define whether the service being provided is 2G or 3G, nor the
      license provides which technology should be used. Therefore,
      there is no justification that spectrum in 2.1 GHz band be
      considered separately for provisioning of only 3G services as
      these services are in no manner different from what is possible
      in other bands identified by ITU.

(d)   In the recommendations issued by the Authority in May, 2005 it
      was recommended that spectrum for 3G will be allotted in 2.1
      GHz band only. (Clause 2.6.3 of Executive summary of TRAI
      recommendations).        The     Authority   made       these
      recommendations on the basis of the handset manufacturers’
      response that handsets capable of working in CDMA band 800
      MHz & 2.1 GHz bands can be manufactured in six months
      time. The Authority, while postulating its recommendations,
      had expressed the hope that dual band handsets in 800 MHz/
      2.1 GHz will be available as per the response of the
      manufacturers. However, a year has passed since the time the
      recommendations were given, and so far, no manufacturer has
      come out with dual band handsets in 800 MHz/ 2.1 GHz. In this
      connection, we have checked with other vendors – Samsung,
      Lucent, Qualcomm and Motorola etc but we have not
      received any affirmative response from them.

(e)   Based on the above, we had written to the Telecom Equipment
      Manufacturers Association (TEMA) for providing us the details
      of such handset and equipment which are compatible in 800
      MHz/ 1800 MHz/ 2100 MHz frequency. From several exchange
      of communication with them since last year, it is now clear that
      no country in the world is commercially deploying the dual
      band handsets in 800/2100 MHz bands.

      A record of communication exchanged with TEMA and
      handset/ equipment vendors is attached as Annex – I
(f)   For CDMA, multi band handsets/ equipment in 800/1800/2100
      MHz bands are neither currently available nor there is any
      future plan from the vendors to manufacture dual band
      handsets compatible in 800 MHz and 2100 MHz bands.

(g)   TRAI in this consultation paper has indicated that since
      WCDMA equipment is presently not available in the 900 MHz
      and 1800 MHz bands, it is not feasible to consider these bands
      for the allocation of 3G services. We submit that under the
      same principle, 2100 MHz band is also not feasible for CDMA
      in view of our above submissions.

(h)   Worldwide, CDMA is considered among leading technologies
      and it has made tremendous progress in third generation
      system. Due to availability of dual band handsets and
      infrastructure, CDMA operators can deploy networks in
      both 800 MHz and 1900 MHz bands only. In US, Canada and
      Mexico, spectrum to CDMA operators has been allotted in
      1900 MHz band. A list of CDMA operators operating in 1900
      MHz as was annexed with AUSPI’s response to TRAI
      consultation paper is attached as Annex – II.

(i)   It is worth mentioning that the policy of technological neutrality
      has paid rich dividends to the growth of mobile services in
      India. CDMA technology has made tremendous contribution in
      making the mobile services affordable. To provide further
      impetus to the growth of telecom sector as a whole and
      achieve the Government’s target of 500 million subscribers by
      2010, it is highly desirable that the technology neutrality should
      continue to be maintained and CDMA operators are allotted
      spectrum which is in line with International standards and
      practices for CDMA i.e. 800 MHz and 1900 MHz bands.

(j)   In the response to the consultation paper on spectrum related
      issues, we maintained that CDMA technology should be
      allocated spectrum in 1900 MHz band. This is what is being
      used by all the CDMA operators in the world.

         There is compatibility of infrastructure equipment between
          800 MHz and 1900 MHz in CDMA network.

         Multi band handsets are internationally available with many
          vendors in 800/ 1900 MHz band.
             International roaming for consumers would be feasible with
              800/1900 MHz band, as majority of the CDMA networks
              internationally are there now in these bands.

             Working Group – 2 of NFAP 2004 Review Committee
              agreed for consideration of non-overlapping portion of this
              band for CDMA based systems.

(k)   2.1 GHz band is being considered for allocation of 3G while
      this band is yet to be vacated. TRAI may consider 1900 MHz
      band for allocation to CDMA operators as has been done in the
      case 2.1 GHz band. In view of this, 1900 MHz band be
      allocated to CDMA operators.

(l)   It is understood that Government has allocated Rs. 1000
      crores for changing over Defence network from wireless to wire
      line. This should help Defence in releasing more spectrum in
      1700 – 2100 MHz band including spectrum in 1900 MHz band.

(m)   TRAI has recognized that 1900 MHz is the only band, which
      has been used by the CDMA operators all over the world along
      with 800 MHz band. However, TRAI has not recommended its
      allocation to the CDMA on the grounds that:

                Defence has not agreed to vacate this band.

                It overlaps with 2.1 GHz band.

                There will be issues of interference in case of mixed
                 band allocation of 1900 MHz and 2.1 GHz.

(n)   TRAI, in its earlier recommendation to the government on 13th
      May 2005 has not agreed to allocate 1900 MHz band. Here it is
      pertinent to point out that Government had allocated 1800 MHz
      band for GSM services at that time Defence also has not
      vacated the band. Subsequently, the Defence started vacating
      the band. Similar principle be followed for allocating 1900 MHz
      band. The Defence would vacate the band ultimately.

(o)   On the interference issues, the presentation given by CDMA
      operators has neither taken into account in the earlier
      recommendations of TRAI of 13th May 2005 nor any reference
      made in the present consultation paper.

      This is also against the consideration of this issue by the WPC
      itself in one of the Sub-Groups. The minutes of the said sub
      group meeting record the following, “…He (the Chairman)
      opined that 1900-1910 MHz p/w 1980- 1990 MHz could be
      considered for CDMA based system with suitable guard band
      carved out equally from both side of the bands taking due note
      of channeling arrangements. Besides this appropriate filter
      would also need to be incorporated by both CDMA and GSM
      based systems, to mitigate the possible interference problem
      between the two systems

(p)   Moreover, TRAI has not followed the provisions of the TRAI
      Act [Section 11(4)] while giving its recommendation of 13 th May
      2005 in so far as Aegis Report is concerned regarding the
      interference issue for the allocation of mixed band of 2.1 GHz
      and 1900 MHz band. This report is referred to in para 3.83 of
      the TRAI recommendation of 13th May 2005.                   TRAI
      recommendation does not mention when this report was called
      for and what were the terms of the reference. TRAI has also
      not called for comments of the stake holders in this regard.

(q)   On account of the issues of interference, the bands have to be
      necessarily harmonized and synchronized as per the
      international norms. The ITU Radio Regulation also provides
      that the different frequency allocations should be in line with
      the international benchmarks to ensure economies of scale
      and also ensuring the most effective and efficient use of

      The Hon’ble Parliamentary Standing Committee on Information
      Technology has also recommended that all efforts should be
      made to allot as much spectrum as the Government can in the
      800/1900 MHz for the CDMA operators.

      “Part-II Para 8
      All efforts should be made to allot as much spectrum as
      the Government can in the 800/1900 MHz for the CDMA
      operators …..”
       In view of our above submissions, there is presently no alternative
       but to allocate 1900 MHz band for CDMA operations in India.

ii)    Whether spectrum in 2GHz should be given to all the

       As we have stated above in our submission 2 GHz is not the only
       band for 3G services. So far 3G services is concerned, all
       operators who want it, be given relevant spectrum in
       800/900/1800/1900/2100 MHz bands in equal amount.

iii)   What should be the quantum of spectrum, which should be
       allocated to each operator?

       The present inequality in spectrum allocation to CDMA operators
       must be corrected as it is a clear case of non-level playing field.

       For 3G services at least 5+5 MHz spectrum be initially allocated
       and one carrier of 2 x 5 MHz be reserved for each operator for
       future expansion. Equal spectrum should be given irrespective of
       the technology used by the service providers.

iv)    Should the spectrum in 2GHz be allocated only after ensuring
       that at least 2 X 5MHz is available to all operators in a service

       Yes. For future expansion, one more additional carrier of 5+5
       MHz be reserved for each operator.

v)     If the available spectrum is less than the demand then what
       should be the criteria of allocation of spectrum to existing
       mobile operators in 2GHz band?

       TRAI should make all out efforts to make spectrum available to all

vi)    Should the present spectrum allocation criteria be modified
       so that available spectrum is immediately allocated?

       For 3G, there is neither present criteria available for allocation nor
       has TRAI recommended any criteria in its recommendation of 13th
       May 2005.
        However, in our response above, we have proposed allocation of
        at least 5 + 5 MHz spectrum for 3G Services initially and
        reservation of one carrier of 5 + 5 MHz for each operator for future
        expansion. There should be equal spectrum to all operators
        irrespective of the technology used.

vii)    Should roll-out obligations be specified for IMT-2000 (3G)
        services. If yes, please specify the roll out obligations to be
        imposed. Please also indicate the penalty to be imposed in
        case of failure to meet the obligation.

        No roll out obligations needs to be specified for IMT 2000 (3G)
        services as it is continuance of existing licenses.

        Rollout obligation has not been considered and specified by the
        government for the NLD/ILD licenses. In view of this, rollout
        obligation is not necessary for 3G services.

viii)   Should allocation of spectrum in IMT-2000 band be linked to
        Infrastructure sharing? If yes, please specify the conditions
        to be imposed?

        Infrastructure sharing and allocation of spectrum are not related.
        Sharing of infrastructure is being done by operators themselves for
        expansion of service. There is no need to link allocation of
        spectrum to infrastructure sharing. For infrastructure sharing,
        TRAI and Government need to do much more like helping in
        acquiring land, getting permission for towers, RoW etc.

ix)     Keeping in mind the requirement of IMT-2000 and Wi-MAX
        what should be the criteria for allocation of spectrum in
        2500-2690 MHz band?

        The frequency band 2.5 GHz to 2.69 GHz be considered for
        allocation for WiMAX only.

x)      Which of the following criteria should determine the 3G
        spectrum pricing?

           Demand and supply situation i.e. reflecting scarcity
           Economic and social benefits
           Revenue to the Government and requirement of the funds for
           Combination of the above

xi)     Should the service provider pay additional one time charge for
        IMT-2000 spectrum? If yes, then how should this additional
        charge be determined e.g. should it be based on auction, bidding
        process, etc. or should it be based on the cost of reforming the

xii)    What should be the amount of annual spectrum charge on IMT-
        2000 spectrum?

xiii)   Should the existing criterion of annual spectrum charge based
        on percentage of AGR continue for IMT 2000 spectrum?

xiv)   a) What should be the ideal frequency bands for WiMAX (both for
       802.16d/802.16e) for India?


xv)    b) Is it possible to indicate any hierarchy of preference for the
       frequency bands in the context of availability of spectrum and
       global manufacturing plans? If yes please indicate.

       The issue placed here is to choose the ideal frequency band for
       WiMAX and to indicate the hierarchy of preference for the frequency
       band in the context of availability of spectrum and global
       manufacturing plans.

       In this connection, TRAI Consultation Paper indicates some the
       frequency bands viz;

       i)         3400 – 3600 MHz
       ii)        5725 – 5825 MHz
       iii)       2300 – 2400 MHz
       iv)        2469 – 2690 MHz
       v)         3300 – 3400 MHz and
       vi)        3400 – 3800 MHz.

       AUSPI feels that the most important issues for consideration for
       selecting a band are:

                 Availability of equipment and handsets internationally with multi
                  vendors in the band.

                 Availability of multi band handsets having WiMAX compatibility
                  with Indian mobile bands.

                 Various issues like mobility, software and security must be
                  taken care for WiMAX in the band.

       In view of above, AUSPI proposes 3400-3800 MHz and 2300- 2400
       MHz frequency bands most suitable for WIMAX applications.
        700 MHz bands should not be considered as a frequency band for

xvi)    What should be the optimum / minimum quantum of spectrum to
        be assigned per operator for WiMAX for efficient network
        deployment and business viability point of view?

        The optimum / minimum quantum of spectrum to be assigned per
        operator for WIMAX for efficient network deployment should be
        approx. 20 MHz in contiguous band.

xvii)   How the spectrum allocation for WiMAX deployment is to be
        done if sufficient spectrum is not available?

        If sufficient spectrum for allocation is not available for WIMAX
        deployment, then the priority of allocation should be first to Unified
        Access Service Licencees (UASLs). Thereafter, only eligible ISPs be

xviii) Whether the existing pricing formula (MCW) for WiMAX
       deployments should continue or needs modification? What
       should be alternative pricing methodology?

        The existing pricing formula, R=M*W*C for WiMAX deployments is
        not suggested. The pricing mechanism for WiMAX deployment should
        be levy of revenue share as is done for access providers. The
        amount should be < 1% only to cover the administrative cost and
        encourage the growth of broadband service and to achieve the
        objectives of the broadband policy of the government.