Centre for Internet and Society

The policy langurs

Shyam Ponappa — 2012-05-10T10:15:17Z

The comforts of civilised living for all Indians require dedicated collective effort. The article by Shyam Ponappa was published in the Business Standard on 6 January 2011.

At this difficult point in our hapless trajectory as we thread our way through the divine comedy, there is a sudden burst of light, cutting through the gloom of the new year: an uncharacteristic but effective bipartisan effort by a group of parliamentarians in dealing with a practical problem. This is the saga of the hapless and troublesome monkeys of Raisina Hill and its environs, booted out by the Brits to build the Rashtrapati Bhavan and the Central Secretariat, and the parliamentarians who live on Mahadev Road nearby. Press reports say that BJP Spokesman Prakash Javadekar adopted a problem-solving approach by suggesting to six of his neighbours (five Congress MPs and one Independent) that they collectively hire a langur patrol to shoo away the monkeys that have been marauding in their gardens. Five of the six responded positively, and so they have a langur patrol, as do a number of government buildings there. And the monkeys stay away.

Why is this important? Because of how powerfully it illustrates the obvious: that collective, goal-oriented action can be very effective in achieving results. Now, if this could be extended to bipartisan initiatives (in the sense of government and the Opposition in the context of our fragmented politics), e.g. in building national assets like infrastructure, then constructive, forward-looking policies can be framed, and we can start building on what has gone before. This will take us past the blight of being in a perpetual stall. One example is resource-sharing for countrywide broadband and communications services. Another is our approach to energy production and supply. And so on.

The bipartisan imperative

I have written earlier on the rationale for spectrum- and network-sharing for broadband and telecommunications.

The framework for this kind of resource-sharing and organisation cannot be done without bipartisan efforts at the policy formulation stage for conceptualisation and during implementation, because various state and local governments will be involved, as will many central government ministries and departments. A bipartisan approach is also essential for devising supportive tax policies, including the development and execution of uniform, inexpensive rights-of-way charges at the state level. Not least will be the question of spectrum pricing, a matter muddied by so much contention and confused thinking regarding the economics and the technology, aggravated by opportunists seeking to make a killing, together with the well-intentioned but ill-informed flailing of strident advocates urging counterproductive measures like cancelling licences without due process and/or holding more auctions, all supposedly in the national interest, oblivious of the consequences.(Click for OPTIC FIBRE CABLE NETWORK)

To appreciate the compelling logic, consider the network of an organisation like RailTel, with over 35,000 route km of optical fibre cable (OFC) network, or Gailtel with about 14,000 route km of OFC and planning close to 19,000 OFC in the next few years (interactive maps at: http://www.gailonline.com/gailnewsite/businesses/telecomnetwork.html).

BSNL has over 67,000 route km in the southern region alone, and other PSUs and private operators like Bharti Airtel and Reliance have their own extensive networks. Combining or integrating these will shift the focus to the tasks of last-mile access and spectrum deployment to achieve potential connectivity for most households and users.

Imagine the potential with some (three or four?) consortiums of wholesale service providers for the country having access to the combined networks of all or several such owners, including the collective capacity in terms of spectrum, access, aggregation and backhaul. These, in turn, could enable access to many retailers for local services to end users.

A second substantive aspect of such a bipartisan initiative is in structuring the national backbone facilities organisation, e.g. on the lines of Singapore’s OpenNet*. This may be an opportunity to capitalise on the BSNL and MTNL networks and revive them, perhaps as the anchor investors (possibly with other PSUs, such as RailTel, GAIL, and Powergrid). This anchor investor consortium could hold, for instance, 30 per cent of the equity in the venture. Other participants could include international companies like Axia, which design, build and operate next generation networks. Axia started out in Canada over 10 years ago and now has projects in France, Spain and Singapore, and has bid for a project in America. Other participants could be like Spectrum Bridge, a US company which runs centrally managed spectrum networks in America in the TV “white spaces”, the digital dividend from TV spectrum reallocated for telecom purposes. Their database-driven approach could be applied to the entire pooled spectrum of a large network with the participation of systems integrators like Infosys, TCS, Wipro, or IBM.

A third potential initiative is to encourage R&D and applications, perhaps seeking the development of local standards for wireless communications in the long term, even the Holy Grail of inexpensive “cognitive radio” (self-managing end-user equipment) with open spectrum. The size of our market offers the potential for such ambitious and potentially beneficial development. This will need policy support, especially for collaboration between defence and the private sector, with the creation of sustained support over a long period.

We know the apocryphal tales like that of the four bulls and the lion: the bulls are safe as long as they stay united, but when they squabble among themselves, the lion picks them off one by one. There is Aesop’s fable of the old man who shows his sons that while they can easily break one stick at a time, the same sticks bound together cannot be broken. Or the Mongolian story of the five siblings, the ancestors of the Mongolian clans, whose mother shows them that while each can easily break a single arrow, the five arrows tied together are unbreakable.

Despite this knowledge and evidence that the comforts of civilised living for all Indians require dedicated collective effort, we refuse to work to this truism of the need for collaborative effort. Suddenly, Mr Javadekar’s can-do Langur Initiative changes the game.

Even as the due process of law continues with regard to past wrongdoing, our parliamentarians should be grappling with substantive issues of nation-building such as those described above, instead of wasting time on tearing each other down.

Read the original in the Business Standard here

For more details visit https://cis-india.org/telecom/blog/policy-langurs

Spectrum auctions - 'Jhatka' or 'Halal'?

Shyam Ponappa — 2012-05-10T09:57:32Z

The choice is between sudden death and a slow one. The article by Shyam Ponappa appeared in the Business Standard on 3 February 2011.

Why do people advocate spectrum and licence auctions? Is it because they think auctions work? Is it the appeal of an ideology, like capitalism or socialism? Or is it because governments often collect large sums, and auctions seem fair (in a market-driven sense) and transparent? Theorists apparently cannot find better ways to allocate spectrum or licences, despite the alternative of technical and financial short-listing followed by a lottery. Yet, while desiring high government collections, people really want reasonably-priced good infrastructure, and continue to rail against government waste. Let’s review some so-called “successful” auctions and what followed.

1994: The US spectrum auction Prior to 1994, the US used to allocate spectrum on demonstrated capacity and merit (“beauty contests”). The spectrum auction in 1994 netted record bids. The Federal Communications Commission chairman reportedly said: “Auctions have proven once again to be a success not only by awarding licences to those that value them most, but also by decreasing the national debt.” Then disaster struck, with a number of “successful” bidders declaring bankruptcy. As BusinessWeek put it in 2010 with the benefit of hindsight, “... over time, beauty contests have delivered fewer problems and higher value to society than have airwave auctions.”1

1994: India telecom licences In 1994, India auctioned telecom licences. Chaos followed owing to overbidding and default. Thereafter, the sector struggled from one contention to the next, with the government and operators deadlocked by 1998. The New Telecom Policy of 1999 provided a breakthrough, tossing aside the auction bids in favour of shared revenues. After the percentage share was reduced to reasonable levels, and “Calling Party Pays” halved tariffs in 2003, mobile services grew exponentially to over 725 million subscribers by 2010. Interestingly, the Telecom Regulatory Authority of India estimated that auction fee foregone till March 2007 was over Rs 19,000 crore, whereas actual revenue collections were double, at Rs 40,000 crore; by March 2010, the collections were 80,000 crore.

2000: The UK 3G auctions The 3G auction in the UK was hailed as a spectacular success, reaping bids of about $35 billion.

2000: The France and Germany 3G auctions Germany followed, netting $67 billion, and the finance minister quipped that the auction was for unexpected revenue to pay the national debt. France demanded a flat fee of $4.5 billion per licence.

The dotcom bubble burst in March 2000, followed by communications and technology companies a year later, and the bidders went into a tailspin. The collapse nearly bankrupted not only British Telecom owing to the enormous debt it incurred for the bids, but the entire industry worldwide. The economic slump that followed made it impossible for firms to pay off high debts, as their interest payments increased while their ratings fell.

A contrarian move in France is noteworthy for its prescience and insight. CEO Martin Bouygues (pronounced “Bweeg”) of the third mobile operator, Bouygues Telecom, refused the government’s demand of $4.5 billion as the fee for a 3G licence, making it the only mobile communications company in Europe with no investment in 3G. Mr Bouygues’ letter in May 2000 appeared on the front page of Le Monde, asking: “What should I tell my employees? … That we have a choice between a sudden death and a slow one?” While his opposition was ignored, by 2002, the French government dropped its asking price by more than 85 per cent to induce Bouygues to accept a 3G licence.

In terms of results, the auction “failures” – the Netherlands, Switzerland, Sweden, and “non-auction” countries like South Korea, Japan and Finland (until 2009) – have the best broadband services. 2

Kapil Sibal’s appointment as India’s telecom minister has brought hope, with prospects of radical improvements in infrastructure, especially broadband, with a clean hand. Mr Sibal’s recent pronouncements on a new telecom policy, however, raise the spectre of another deadlock. Here are two examples: (a) “Adequate spectrum will be provided to all service providers.”

This is feasible not through slivers of spectrum for many operators, but only if there is a common carrier access, that is, all operators can access spectrum for a reasonable fee. There is no indication of what “adequate” means, nor of pooling or sharing spectrum.

Let’s hope the domain experts have been heard and not shouted down on “adequacy”. For instance, the Telecom Equipment Manufacturers’ Association had recommended that two blocks of 50 MHz each in the 698-806 MHz band be allocated to facilitate the development of wireless equipment and services. Large blocks of contiguous spectrum offer far more efficient capacity than many narrow bands. For local innovation, to get low costs, we have to think of adequacy in these terms, and not slivers of 4.4 MHz or 6.2 MHz.

(b) “Spectrum henceforth will be awarded only on a market-based mechanism.”

If the criterion for success is high bids and not delivered services, in effect, this means auctions, and the result is likely to be dismal. Those enamoured with auctions focus on the success of bids, ignoring the purpose of spectrum/licence allocation, which is service delivery resulting in consumer surplus (societal benefits).

If the operators choose to roll over and accept authoritarian decrees, the conflict will be between government and the public interest, as spelt out below.

The government’s choices include:

a genuine effort at developing comprehensive and integrated policies for reasonably priced services, while carrying along stakeholders;
a cosmetic effort, letting stakeholders vent, and then issuing arbitrary decrees that leaves a mess. For example, too many operators with fragmented spectrum; or
attempting a political or populist fix, seeking to make the United Progressive Alliance look good, the Opposition look bad, bleeding all operators to avoid accusations of a sell-out, and still leave a mess

The first alternative is in the public interest; the second and third are not. The issues that need comprehensive transformation are spectrum and network sharing for service delivery at least cost. The government and Mr Sibal have the opportunity to choose an approach resulting in excellent delivery including broadband at reasonable prices.

Read the original in the Business Standard here

The Business Standard took an editorial stand in support of shared spectrum and comprehensive, systemic solutions advocated in the article.

For more details visit https://cis-india.org/telecom/blog/jhatka-or-halal

Big-Bang Budgets?

Shyam Ponappa — 2012-07-26T10:10:21Z

Clarity of planning and conceptualisation needs to be the hallmark of policy planning for the Budget, says Shyam Ponappa in this article published in the Business Standard on March 3, 2011.

A good holding action in the face of turbulence is a real achievement. It’s a tremendous relief, with a positive spin. That’s what the finance minister seems to have given us with this year’s Budget. So, the glass could well turn out to be half-full, if heaven plays its part, and the demons — for example, rising oil prices because of turmoil in the Arab world — are in abeyance. For now, India’s spirits are up, and we have a shot at getting on with it. And if we don’t, heaven forefend, the government could resort to something as irresponsible as another spectrum auction (2.5 GHz for 4G/LTE) to pull itself out of the morass.

Given this reprieve, how best can we capitalise on it? Some of us have this notion that it is a tradition that major projects or schemes are announced at the time of the Budget. Is this a good way for the government to proceed? Are there better ways, and if so, what might they be? Also, after the Budget, several opinions reflected disappointment with the lack of big moves. What sort of actions would deserve the “Big Move” label?

Ignoring for the time being the FM’s statements about bills for banking, insurance and pension funds that could add up to a big bang, there was in fact a Big Move, with the ground prepared well beforehand, as it should be: the proposed cash transfer of Rs 37,000 crore allocated for kerosene, LPG and fertilisers to BPL users. This move to cash transfers will be a major change that should be for the better, despite apparent misgivings from the Left. In fact, its effect should be much more than an equivalent allocation in the previous system, with its infamous leakages. The logical extension of this process would be smart-card purchases of specified products with designated limits from any retailer, with direct rebates from the government in a single transaction. No forms, no fuss, thanks to the Unique Identification Number (UID). Next could be food subsidies of over Rs 74,000 crore through smart cards.

In this time of drift over several years, there has been an apparent lack of visible leadership until the appointment of a new telecom minister after the destabilisation of the past few months. This was followed by the prime minister’s assertive statements in both houses of Parliament. Similarly, the UID thrust and the first step with cash transfers show that the government can indeed take well planned initiatives. Here we have a set of steps taken with clear objectives (although somewhat muddled in the telling), with plans being developed and executed with what we hope will manifest as high quality, on time and within Budget. So it’s possible, although not our usual practice. If only we could get more of this assertive leadership to good ends.

Imagine if we brought the same clarity of objectives and conceptualisation to, say, addressing the supply of energy to end users. True, this is a very difficult area because of the multiple challenges across several ministries/agencies (fuel production and distribution, transportation, power generation, transmission, distribution, pricing, state electricity boards), and our habitual malpractices as users. The approach, however, would presumably be the same as for the UID. We would start with clear objectives that are coherent, ie, not disjointed or contradictory, and undertake a systematic, multidisciplinary effort — no ivory tower geniuses — to plan and execute through a process of sound project management to achieve the desired results. This would be an end-to-end effort that would have little to do with the budget except for the annual announcement of financial allocations, once the activities and resource requirements are specified. Its fundamental characteristic would be that it would have to be an integrated systems approach to get results.

Most important are well planned, convergent, goal-directed activities. Whether for food storage, anganwadis, power, roads, railways, integrated energy and transport programs, or communications and broadband, the process flow needs to be defined thoroughly, and every aspect specified for our environment in the implementation plan. This process would improve the odds of achieving the objectives. For instance, if cold stores are not meshed with production and markets, or transport linkages are deficient, chances are that they will fail.

The process could begin at any time of the year, and not necessarily announced at budget time in the annual cycle. Once the initial approach is conceptualised and the initiative launched, the programme plans would be scoped and spelt out, and the budget estimation completed. At budget time, as with the cash transfers linked to the UID, there would be an allocation of funds for the activities in the next 12-month phase.

Now to the Railway budget: the much touted Railways desperately need rehabilitation. In view of the significant multiplier effect that the Railways have on many other sectors, the government really must reassert its leadership in the next couple of months (after the West Bengal elections?), and reclaim this crucial area of transportation. The urgent need is to reverse the atrophy over recent years, as well as to begin to build for the future, as for instance China has done, with trains that take passengers over 1,000 km in three hours.*

To conclude, it is time the government took one infrastructure sector or programme at a time, including education/vocational education/continuing education, and developed clear, goal-driven plans to provide the framework for the next budget session.

* 'China Sees Growth Engine in a Web of Fast Trains', Keith Bradsher, New York Times, February 12, 2010:

Read the original article in the Business Standard here

For more details visit https://cis-india.org/telecom/blog/big-bang-budgets

India's untapped potential: Are a billion people losing out because of spectrum?

Shyam Ponappa — 2012-12-14T10:31:43Z

As one of the world’s fastest growing economies and with over 65% of its billion-plus population under 35, India has huge potential. But according to Shyam Ponappa of the Centre for Internet & Society, its spectrum management – the electromagnetic waves that are used from home appliances like microwaves and remote controls, to radios, cell phones, and of course, the internet – could be a huge barrier to the country’s economic and social development.

Until the global economic downturn that began about two years ago, the economic model for spectrum distribution in India and many developing countries was based on the free market. But Ponappa demonstrates in a new report for APC that spectrum is worth treating as a public utility the way we do roads, electricity and other basic infrastructure, which would allow for people in rural areas to access spectrum-dependant services like mobile phones and wifi and increase quality of services for all.

Currently in India, as in most other countries, spectrum is being treated as a property, where “chunks” of spectrum are sold to the mobile phone and telecommunications operators with the highest bid. Commonly there are 3 – 4 operators in a developed country; however, in India there are up to sixteen. The extreme competition has resulted in the Indian bidders paying outrageous fees that they are never able to recuperate. So while the government makes a profit on the sale, this profit comes at a societal cost.

Ponappa proposes pooling spectrum and to have a set of network providers, who in turn serve operators for retail users. This effectively opens up the spectrum and could make costs ten or fifteen times cheaper than they are now.

“It is appropriate to push the concept of open spectrum in developed markets who underwent their development phase some 60 – 100 years ago and put in place basic infrastructure systems. But in countries like India and the Asian sub-continent, it does not make sense to do this because we are not at the same stage of economic development,” Ponappa told APCNews.

“When markets are well structured and organised,” he continues, “[government control] can be less effective and efficient for society as a whole, compared with open competition. However developing economies don’t have the integrated systems in place that advanced economies do. India does not have an adequately developed network of copper, optical fibre or microwaves covering most of its population. And we are at a stage of development at which infrastructure is a fundamental determinant of productivity, as well as of a reasonable quality of life.”

Ponappa argues that in India’s case it would be advisable for governments to work with other stakeholders – corporations, state-owned agencies, and civil society – on a collaborative solution. “It would be much more conducive to a sound economy to have either the government step in and open up the commercial spectrum, or to have two to three main operators (possibly subsidised, but not necessarily) as we do with the provision of utilities,” he says. Yet, the free market mentality continues to reign, and a surfeit of operators is trying to make a profit in the telecommunications wireless sector.

Everybody wants a piece of the pie

In India, every operator is assigned a sliver of spectrum for their exclusive use and the rest is assigned to the government, the public sector and defence.

The result is high-cost infrastructure for operators (setting up networks with multiple sets of more advanced equipment because of the limited spectrum, with the capital constraints resulting in less extensive networks in rural areas) as well as for users (who have to pay for all this equipment).

“Too many operators make for increased capital costs for each operator, and cumulatively for all operators,” Ponappa explains.

And these higher costs are increasingly difficult to recover from consumer-generated revenue, as India undergoes huge price wars. Many operators may eventually go bankrupt. While no consumers ever complain about low costs –and India has some of the world’s lowest mobile rates– they will complain about poor quality and unreliable service. Consequently, consumers may not have to pay much to use mobile services, but they may not always be able to make or receive calls when they need to, and do not have access to broadband.

While most countries have moved on to 3G networks (which has more capacity for a given spectrum band than 2G, meaning better call quality) as many as four of India’s sixteen operators have not even developed their 2G networks. Making the switch to 3G seems like a good idea, but there are substantial costs associated with deploying these more advanced techniques to both operators (for network upgrades) and for end users (in terms of new handsets).

Too much competition in this case has made operators inefficient.

Spectrum as a national common good

If spectrum were treated as if it were a public utility, posits Ponappa, each operator would have access to a bigger chunk of spectrum, and the traffic-handling capacity of each would increase at a lower cost.

“With the current model the capacity of networks is suffering because networks cannot afford to expand or make technical improvements without economic losses. Other infrastructure services such as electricity and water supply are managed by utility companies, which are typically monopolies for a product-segment, or duopolies for purposes of competition. So why not treat spectrum the same way?” suggests Ponappa.

Ponappa suggests treating networks, and spectrum as a part of networks, as we would an oil pipeline, where everyone accesses the same one, and pays a fee for its use.

This would bring more people onto the network and increase revenues, since operating costs would be shared. The more revenue it can generate, the more efficient operators will be, using the same high-capacity circuits. The more revenue the main operators have, the more they could invest in up-to-date technology to extend their networks and provide a better service to clients. The better the technology, the more people could access the internet and other now vital sources of information, as well as focus on broadband and infrastructure to the country’s isolated rural areas, which today have rudimentary communications infrastructure.

India’s rural populations, the lost resource

As a predominantly rural country, lack of basic IT infrastructure means that the largest segment of India’s population has no access to information and communications technologies.

Ponappa grew up on a farm in a rural area some 200 km from Bangalore where even fixed line phone networks were unreliable. “We have multiple telephone lines because we never know which one will work,” he says.

Given India’s massive rural population, this means that there are hundreds of millions of people that are unable to access the internet. Services like quality distance education are not even an option if basic infrastructure such as fixed telephone lines is not in place and the country itself is losing out on the incalculable potential of this untapped human resource.

Download the report here [pdf - 280 kb]

See the report in the APC website

This article was written as part of the APC’s project work on Spectrum for development, an initiative that aims to provide an understanding of spectrum regulation by examining the situation in Africa, Asia and Latin America.

Photo by kiwanja. Used with permission under Creative Content licensing.

For more details visit https://cis-india.org/telecom/blog/untapped-potential

NTP 2011 Objective: Broadband

Shyam Ponappa — 2012-07-26T10:09:17Z

The Indian government has to choose between accessible, affordable services and short-term revenue, writes Shyam Ponappa in this article published in the Business Standard on June 2, 2011.

Apart from the scams, confused ideas are roiling India’s telecom sector. One instance is the finance ministry urging spectrum auctions to collect Rs 30,000 crore to help bridge the fiscal deficit. Another is the Ashok Chawla committee recommending spectrum auctions for transparency, making transparency the criterion for managing spectrum. The committee apparently does not mention the disastrous US auction, and attributes the UK fiasco to extraneous reasons; presumably, they knew the facts. Such issues need logical and systematic remedies. Otherwise, the success of the telecom sector will degenerate into yet another failure.

Objectives: the transaction should be structured in the public interest;
A life-cycle analysis of costs and benefits, and not just windfall revenues (since short-term cash drives the finance ministry’s concerns, it is important for the ministry and the government to step back and consider alternatives, such as the sale of BSNL’s vast real estate. If the goal is ubiquitous and affordable broadband, this would be much less damaging to the public interest than spectrum auctions); and
End-to-end solutions are required from an integrated systems perspective.

The New Telecom Policy ’11

For the New Telecom Policy 2011 (NTP ’11), the first requirement is to define convergent goals. We could take a leaf from countries with excellent broadband that built high-quality next generation networks. While the US and UK have strong initiatives, Japan, Sweden, South Korea and Finland have highly rated broadband. Australia and Singapore are now building next-generation networks. Both are common-access, open-to-all service providers.

Spectrum Management

In India we must begin with unravelling the mess of spectrum management. There are two separate skeins. Legacy issues of irregularities and scams form one stream, to be dealt with by the process of law. On the other hand, policies for next-generation networks need a process of stakeholder workouts to deliver services. Broadly, there are two ways of approaching spectrum management. One is to allocate specified bands for exclusive use, as was customary until now. An alternative is to create a common spectrum pool for use by all service providers. In other words, any provider can dynamically access spectrum for carrying voice, image and/or data. This method of dynamic spectrum access is now feasible, and the US is starting off with TV white space. The Federal Communications Commission has appointed nine companies including Spectrum Bridge and Google as database administrators; a tenth, Microsoft, is under consideration. India could start out on this if the government chooses the objective of accessible and affordable services.

Network vs Revenue

The choice is between building/configuring a high-quality, least-cost network and high short-term government collections. Over a longer period, a restrained approach emphasising networks and services is likely to be superior to aggressive government fees, as we found with NTP ’99 — revenue sharing resulted in explosive growth together with higher collections than the amount foregone from licence fees (see data from the Telecom Regulatory Authority of India and the Comptroller and Auditor General2).

How can the government evaluate this trade-off? The diagram below outlines alternative approaches to spectrum allocation and the likely outcomes. The outcomes should be evaluated as public interest costs and benefits.

The first step is to choose between exclusive spectrum use and common access. Exclusive use entails allocation through auctions; methods like first come, first served (FCFS); or “beauty contests”, for example, the evaluation of stipulated criteria such as technology, financial capacity and so on. Auctions are transparent. Common access, too, is completely transparent, provided the usage and payment systems have integrity.

If there are few operators (three or four), each can be allocated 20 MHz or more for exclusive use. In such circumstances, the relative merits are not obvious. However, in an emerging economy like India – without a ubiquitous network and with too little spectrum distributed among many operators – the logical choice for efficient spectrum management is common access.

Auctions often lead to service deprivation because of high costs (the “winner’s curse”). However, there are exceptions, where bidding is kept reasonable, as in Finland, or France because of its timing, after the fiasco of the European auctions. The other alternatives, FCFS or beauty contests, can result in low or high costs depending on government policies. High fees ratchet up costs with windfall gains to government in the short term, but users are deprived of these funds for networks and services. For example, in India, while the government collected nearly Rs 1,03,000 crore for 3G and broadband wireless access auctions, new facilities and services have been slow. Instead, this spectrum is largely used to support 2G users.

Low fees would have improved the odds of high-quality and low-cost facilities, affordable pricing, and better coverage. The government, however, would have lost its short-term windfall gains.

Once the government sets the objective of affordable, high-quality services, the next steps will be:

Spectrum allocation and management

The decision criteria are:

Technology: The rationale for optimal channel width is that with lower capital cost there is greater throughput with a 20 MHz band than with several smaller bands.
Economics: The capital cost of shared facilities through common access is far lower than if each operator invested in separate access networks.
Practical results: High-quality broadband in countries like Japan, Sweden and South Korea was built without spectrum auctions.
Carbon footprint and resources: Both are minimised with shared facilities, such as towers and equipment.

These reasons make common spectrum the logical choice, as against auctions for exclusive allocations.

Common network

A common network is, therefore, a logical and environmentally sound choice. The question is how best to own and operate it.

Notes

E.g. see: "Winner’s Curse", Chris Anderson, Wired, May ’02:http://www.wired.com/wired/archive/10.05/change.html
Trai’s estimate of foregone revenues by March ’07: under Rs 20,000 crore: “Indicators for Telecom Growth”, Trai, ’05: http://www.trai.gov.in/trai/upload/StudyPapers/2/ir30june.pdf
Revenue share collections by March ’07: Rs 40,000 crore; by March ’10: Rs 80,000 crore: "Performance Audit Report on the Department of Telecommunications, Ministry of Communications and Information Technology", http://saiindia.gov.in/cag/union-audit/report-no-19-performance-audit-issue-licences-and-allocation-2g-spectrum-department-tele

Read the original here

For more details visit https://cis-india.org/telecom/blog/ntp-2011-objective

Response to TRAI Consultation paper No. 6/2009

radha — 2011-08-24T08:06:46Z

CIS Distinguished Fellow, Shyam Ponappa, provides a detailed response to the Telecom Regulatory Authority of India's Consultation paper No. 6/2009 "Overall Spectrum Management and review of license terms and conditions". Shyam Ponappa is suggesting that, the TRAI approach the telecom policy in a manner which will facilitate greater user access and, more generally, be designed to serve the public interest in the long-term.

Shyam Ponappa November 12, 2009
Distinguished Fellow
Centre for Internet & Society
Bangalore/New Delhi
cis-india.org

shyamponappa@gmail.com

Telecom Regulatory Authority of India
Attn: Sh. Sudhir Gupta, Advisor (MN)
Mahanagar Doorsanchar Bhawan
Jawahar Lal Nehru Marg, New Delhi-110 002
Tel. No.011-23220018 , Fax No.011-23212014

E-mail : advmn@trai.gov.in

TRAI Consultation paper No. 6/2009- October 16, 2009

"Overall Spectrum Management and review of license terms and conditions"

Sir,

It would help to have a logical framework that defines overall objectives, prioritizes issues, and structures and organizes issues and questions. This would facilitate analysis and response, as we have attempted below.

We begin by responding to Question 57 as a preamble to all the questions:

57. What in your opinion is the desired structure for efficient management of spectrum?
[This question addresses only one of two essential criteria, efficiency. The other criterion is effectiveness; both need equal emphasis.]

Please see separate attachment for answers to Questions 1-56.

Status

Currently, communications services in India comprising Internet, voice and SMS have the following attributes:

Low broadband usage, with relatively high prices: eg, direct satellite TV subscriptions at Rs. 200/month, compared with 512 kbps Internet at Rs. 1,000/month.
Fragmented spectrum allocation for exclusive use by each operator in a service area.
Very high intensity of spectrum use by operators compared with international norms because of constrained availability.
Too many operators per service area (11-14 or more [15-16 with all potential operators with GSM and CDMA counted separately], versus the global average of 4-5).

[For details on (2), (3) and (4), please see: 'An assessment of spectrum management policy in India', David Lewin, Val Jervis, Chris Davis, Ken Pearson, Plum Consulting, December 2008
http://www.plumconsulting.co.uk/pdfs/GSMA%20spectrum%20management%20policy%20in%20India.pdf]

Needs

Our needs are:

good services for Internet, voice and SMS,
at reasonable prices, eg, comparable pricing for TV and broadband,
accessible from/to most households across the country.

The need is especially great in rural areas, as broadband can be the medium for delivery of essential services like education (from basic to advanced to vocational training and Continuing Education at all levels, including high-level professional CE), health (again, from basic diagnostics and monitoring at home, to advanced care at adequately equipped centres), and security and law-and-order services at significantly higher levels than is possible without excellent communications infrastructure.

In view of the above, we suggest that the Government of India consider adopting the following policy goals in the public interest ( and therefore, that where appropriate, the TRAI set these objectives/make appropriate recommendations to the GOI).

Suggested Policy Goals/Objectives [based on needs]

Adopt the criteria of long-term net benefits in the public interest for decisions, eschewing short-term cash collections from auctions and fees.
An approach to policies for telecommunications services (not for broadcasting) that limits the number of operators per service area in line with international experience, because of the economics of networks.
[This implies an explicit reversal of prior policies to maximize competition, and requires allowing for consolidation through mergers and acquisitions.]
Access to broadband (to be defined as at least 512 kbps in keeping with international norms) at all feasible locations in the country for all users.
Develop incentives and penalties favouring good rural service provision, with the emphasis on broadband: an Administered Incentive Pricing mechanism.
Explore ways to structure policies to reduce costs/maximize utility through facilities and resource sharing, so that prices can be reduced while maintaining good scope for investment from growth and profits.

This implies two areas of exploration:
a) Shared use of facilities and equipment/networks;
b) Shared use of spectrum.

(i) This is best done by collaborative consultations between experts (from the GOI, private sector and academia), operators, equipment providers, and government. Without the requisite interdisciplinary skills combined with operating expertise and investment capability, the effort is too complex for an iterative, serial consultation process.
(ii) Even within the GOI, this requires interdisciplinary and cross-jurisdictional convergence, both to develop solutions as well as to implement them.
(iii) This also needs GOI initiatives to invite companies like Ericsson, Nokia, Motorola and Qualcomm as well as Google and Intel, possibly cable companies like Liberty Global, and electricity companies that deliver Internet through their networks.
(iv) The GOI also needs to depute experienced representatives from various ministries and departments including the WPC, the Defence Services, and specialist agencies such as the DRDO/NTRO.
[Please see ‘Managing Spectrum’ in the Business Standard November 5, 2009, and related references: http://organizing-india.blogspot.com/2009/11/managing-spectrum.html]
Monitor operations online and intervene actively where revenues (the totality of rates/tariffs) are far above total costs, i.e., profits are unreasonable. This is a necessary adjunct to accepting a monopolistic/oligopolistic market structures.

Suggested Approach

The use of a decision tree as in the ‘Issue Map for Spectrum & Broadband’ below (please see Exhibit) facilitates a logical sequence and prioritization in exploring alternatives. (Please note that this is for broadband, voice and SMS, and not for broadcasting.) A similar exploration process for networks and facilities (sharing versus exclusive use for delivery) could follow. However, stakeholders should be free to use any analytical process to improve on this in the common interest.

Once decisions are taken on these two issues (spectrum and network/ facilities sharing), other issues like pricing and consolidation can be logically addressed based on these decisions, probably within the scope of existing laws and regulations.

New regulations or laws should be considered only after comprehensive analysis on the lines of Project LARGE (Legal Adjustments and Reforms for Globalising the Economy by Sh. Bibek Debroy).

Exhibit: Issue Map on Spectrum & Broadband

Shyam Ponappa
Centre for Internet & Society
cis-india.org

Attachment – Question 1-57

TRAI Consultation paper No. 6/2009 – October 16, 2009

Overall Spectrum Management and review of license terms and conditions

Chapter 1
Spectrum requirement and availability

Do you agree with the subscriber base projections? If not, please provide the reasons for disagreement and your projection estimates along with their basis?
Do not disagree.
Do you agree with the spectrum requirement projected in ¶ 1.7 to ¶1.12? Please give your assessment (service-area wise).
Agree if exclusive bands of spectrum are used by different operators, and the spectrum requirement is linked to subscribers. Disagree if common use of spectrum is adopted. Please see preamble (reply to Question 57) for details of shared/pooled spectrum approach.
How can the spectrum required for Telecommunication purposes and currently available with the Government agencies be re-farmed?
(a) By rationalizing usage, as advocated in the preamble for commercial operators, by pooling spectrum for common use where possible.
(b) By inducting equipment that allows more efficient usage and usage of other bands.
In view of the policy of technology and service neutrality licences, should any restriction be placed on these bands (800,900 and 1800 MHz) for providing a specific service and secondly, after the expiry of present licences, how will the spectrum in the 800/900 MHz band be assigned to the operators?
(a) Please see suggestions on shared/pooled spectrum as above.
(b) In the event that common use of spectrum is infeasible/not accepted by the Government of India, and exclusive bands of spectrum are assigned to operators as is the practice now, work out ways to consolidate fragmented bands (other than through M&A) for operators, to enable operators to hold contiguous bands for greater efficiency, and explore shared use of pooled spectrum.
How and when should spectrum in 700 MHz band be allocated between competitive services?
Preferred method: for common use (can be pooled or shared even if assigned for exclusive use, immediately).
What is the impact of digital dividend on 3G and BWA?
Should extend its reach and access because of lower costs.

Chapter 2
Licensing Issues
Should the spectrum be delinked from the UAS Licence? Please provide the reasons for your response.
If spectrum is treated as a common resource, the logical requirement is for a linkage that is not dependent on ownership, but to access for service delivery, i.e., common access.
In case it is decided not to delink spectrum from UAS license, then should there be a limit on minimum and maximum number of access service providers in a service area? If yes, what should be the number of operators?
Follow global practice: do not exceed five operators in any service area unless there are compelling reasons to do so.
What should be the considerations to determine maximum spectrum per entity?
Minimum contiguous band for effective rollout and efficient delivery, i.e., inexpensive capital outlay for equipment and towers/network while maintaining Quality of Service.
Is there a need to put a limit on the maximum spectrum one licensee can hold? If yes, then what should be the limit? Should operators having more than the maximum limit, if determined, be assigned any more spectrum?
This depends on the overall approach to spectrum management, i.e., common use, or exclusive use. The logic for a limit is effective delivery capability at ‘normal’ cost. There is no logic for assigning more than this. However, if spectrum is for common/shared use, the only criterion is throughput/capacity.
If an existing licensee has more spectrum than the specified limit, then how should this spectrum be treated? Should such spectrum be taken back or should it be subjected to higher charging regime?
As in No. 10. If common/shared spectrum use is adopted, there needs to be a transition worked out, as in the transition to revenue sharing.
In the event fresh licences are to be granted, what should be the Entry fee for the license?
The principles followed should be:
(a) Low license fees to minimize access costs.
(b) Provided licenses are delinked from spectrum and few in number, there need to be strict rollout requirements.
(c) Incentives for broadband and rural coverage in the form of a structured Administrative Incentive Pricing mechanism.
(d) Penalties for failure.
In case it is decided that the spectrum is to be delinked from the license then what should be the entry fee for such a Licence and should there be any roll out condition?
As in No. 12.
Is there a need to do spectrum audit? If it is found in the audit that an operator is not using the spectrum efficiently what is the suggested course of action? Can penalties be imposed?
(a) Operating attributes should be monitored online on a continuous basis.
(b) Spectrum use probably needs to be monitored as an operating attribute.
(c) Penalties and incentives are needed, including forfeiture for continued transgression.
Can spectrum be assigned based on metro, urban and rural areas separately? If yes, what issues do you foresee in this method?
This needs to be considered only if common/pooled usage is decided against. With common use or sufficiently large blocks/bands of spectrum, no problems are likely to arise.
Since the amount of spectrum and the investment required for its utilisation in metro and large cities is higher than in rural areas, can asymmetric pricing of telecom services be a feasible proposition?
Yes.

M&A issues
If the common/shared use approach is adopted, M&A can be under existing laws and regulations.
Whether the existing licence conditions and guidelines related to M&A restrict consolidation in the telecom sector? If yes, what should be the alternative framework for M&A in the telecom sector?
Whether lock-in clause in UASL agreement is a barrier to consolidation in telecom sector? If yes, what modifications may be considered in the clause to facilitate consolidation?
Whether market share in terms of subscriber base/AGR should continue to regulate M&A activity in addition to the restriction on spectrum holding?
Whether there should be a transfer charge on spectrum upon merger and acquisition? If yes, whether such charges should be same in case of M&A/transfer/sharing of spectrum?
Whether the transfer charges should be one-time only for first such M&A or should they be levied each time an M&A takes place?
Whether transfer charges should be levied on the lesser or higher of the 2G spectrum holdings of the merging entities?
Whether the spectrum held consequent upon M&A be subjected to a maximum limit?

Spectrum Trading
Is spectrum trading required to encourage spectrum consolidation and improve spectrum utilization efficiency?

At present, trading is required to allow consolidation. However, if a comprehensive approach is taken to spectrum use, and especially if common use through common access is established, this set of problems will no longer exist after a transition period. Nor will there be any shortage of spectrum.
Who all should be permitted to trade the spectrum ?
As in No. 24.
Should the original allottee who has failed to fulfill “Roll out obligations” be allowed to do spectrum trading?
There should be penalties and forfeiture for failure to meet rollout obligations, and clawbacks as an interim measure during the transition.
Should transfer charges be levied in case of spectrum trading?
What should be the parameters and methodology to determine first time spectrum transfer charges payable to Government for trading of the spectrum? How should these charges be determined year after year?
Should such capping be limited to 2G spectrum only or consider other bands of spectrum also? Give your suggestions with justification.

This question assumes there is a difference in “2G spectrum” and other spectrum, which is incorrect. The difference is in equipment that has evolved in different phases along different bands. Spectrum should be treated as technology-neutral for the purposes of service delivery. Any service should be deliverable on any band, subject to interference limitations.
Should size of minimum tradable block of spectrum be defined or left to the market forces?
Should the cost of spectrum trading be more than the spectrum assignment cost?

Spectrum sharing

These questions are addressed in the preamble in the cover note.
Should Spectrum sharing be allowed? If yes, what should be the regulatory framework for allowing spectrum sharing among the service providers?
What should be criteria to permit spectrum sharing?
Should spectrum sharing charges be regulated? If yes then what parameters should be considered to derive spectrum sharing charges? Should such charges be prescribed per MHz or for total allocated spectrum to the entity in LSA?
Should there be any preconditions that rollout obligation be fulfilled by one or both service provider before allowing the sharing of spectrum?
In case of spectrum sharing, who will have the rollout obligations? Giver or receiver?

Perpetuity of licences
Should there be a time limit on licence or should it be perpetual?
What should be the validity period of assigned spectrum in case it is delinked from the licence? 20 years, as it exists, or any other period
What should be the validity period of spectrum if spectrum is allocated for a different technology under the same license midway during the life of the license?
If the spectrum assignment is for a defined period, then for what period and at what price should the extension of assigned spectrum be done?
If the spectrum assignment is for a defined period, then after the expiry of the period should the same holder/licensee be given the first priority?

Uniform License Fee
What are the advantages and disadvantages of a uniform license fee?
Whether there should be a uniform License Fee across all telecom licenses and service areas including services covered under registrations?
If introduced, what should be the rate of uniform License Fee?

License fees should be treated as part of the overall scheme of Administered Incentive Pricing.

Chapter 3
Spectrum assignment
If the initial spectrum is de-linked from the licence, then what should be the method for subsequent assignment?
Please see comments on common/shared use in the preamble in the cover note.
If the initial spectrum continues to be linked with licence then is there any need to change from SLC based assignment?
The SLC basis for spectrum assignment gives rise to many distortions and is not in line with international practices.
In case a two-tier mechanism is adopted, then what should be the alternate method and the threshold beyond which it will be implemented?
Should the spectrum be assigned in tranches of 1 MHz for GSM technology? What is the optimum tranche for assignment?
In case a market based mechanism (i.e. auction) is decided to be adopted, would there be the issue of level playing field amongst licensees who have different amount of spectrum holding? How should this be addressed?
In case continuation of SLC criteria is considered appropriate then, what should be the subscriber numbers for assignment of additional spectrum?
In your opinion, what should be the method of assigning spectrum in bands other than 800, 900 and 1800 MHz for use other than commercial?

Spectrum pricing
Should the service providers having spectrum above the committed threshold be charged a one time charge for the additional spectrum?
In case it is decided to levy one time charge beyond a certain amount then what in your opinion should be the date from which the charge should be calculated and why?
On what basis, this upfront charge be decided? Should it be benchmarked to the auction price of 3G spectrum or some other benchmark?
Should the annual spectrum charges be uniform irrespective of quantum of spectrum and technology?
Should there be regular review of spectrum charges? If so, at what interval and what should be the methodology?

Structure for spectrum management
What in your opinion is the desired structure for efficient management of spectrum?

Please see the preamble in the cover note.

Shyam Ponappa
Centre for Internet & Society
cis-india.org

November 12, 2009

For more details visit https://cis-india.org/telecom/blog/response-to-trai-consultation-paper

India Study Tour - Report: The South African Telecommunications Sector: Poised for Change

radha — 2011-08-24T08:02:09Z

CIS in collaboration with the LINK Centre, Graduate School of Public and Development Management, University of the Witwatersrand, South Africa and in association with different institutions across India organized a Lecture Tour by Sagie Chetty from 19th Oct to 30th Oct. A report on this study tour is given by Sagie Chetty.

India Study Tour Report

2009-10-17 to 2009-11-01
Sagie Chetty, Masters of Management ICT Policy & Regulation
Student Number 0617514V
Supervision: LINK Centre
Graduate School of Public and Development Management
University of the Witwatersrand

Sagie Chetty is a Senior Manager at Eskom, South Africa’s largest Electricity Utility and a Masters of Management student in the field of ICT Policy and Regulation at Wits University. My research dissertation is entitled “Analysing processes for regulating interconnection in India and South Africa.” Wits LINK Centre and the Centre for Internet and Society (CIS) in Bangalore arranged for a study/lecture tour to India for the period from 17th October 2009 to 1st November 2009. As part of the tour, I presented a number of talks to students and faculty members at various universities and institutions around the country, on the subject of the Telecommunications Landscape in South Africa. I used the opportunity to inform students on the development of the telecommunications sector in South Africa; to build relationships between the LINK centre and the institutions I visited; and, most importantly, to conduct interviews with academia, economists and regulatory authorities in India to gather essential material for my research paper.

Presentations were held at a number of universities, namely the Indian Institute of Technology (IIT), Chennai and IIT, Mumbai; the International Institute of Information Technology (IIIT), Bangalore; and the Indira Gandhi National Open University (IGNOU), the National Institute of Science, Technology and Development Studies (NISTADS) and the Jamia Millia Islamia University – all based in Delhi. The visit concluded with meetings with officials from the Telecoms Regulatory Authority of India (TRAI).

The presentations were well attended and discussions were robust and thought provoking. The South African telecommunications sector was seen as being non-competitive with unnecessarily high ownership by government in the telecommunications sector. From the information provided, students concluded that the SA telecommunications regulator was weak and lacking in the commensurate skills to manage this highly technical sector.

On the other hand, students gravitated between having admiration for India’s own telecommunications regulator, TRAI and criticism of TRAI’s inability to improve broadband take-up in India. Students commended TRAI’s technical skills, independence and its courage in standing up to powerful mobile companies and incumbent telecommunications companies. However, lack of policy direction with regard to broadband rollout is seen as a major failure. Comments regarding this failure are attributed to TRAI’s driving down of telecommunications prices to levels that do not allow for infrastructure investment.

The future for broadband in India lies in mobile technology and some predict that fixed line will be defunct by 2025. Some academics also believe that there are too many players in the telecommunications sector in India making spectrum allocation highly competitive and therefore, very expensive. These costs will have to be recovered and the end users will pay dearly for this. Therefore, the model that the Department of Telecommunications (DOT) is using for spectrum auctions is being questioned by students and academics.

The innovation that I observed in India relates to CIS’s early work in projects assisting the visually impaired to read; the writing of 4G standards at the IITs and the innovation with regard to interconnection usage charges (IUC) at TRAI. These are some of the lessons that I have taken back to South Africa.

My observation of students in India is that they are highly motivated and eager to learn. Entrance to the universities is highly sought after and universities have high standards and are generally difficult to get into. The IITs certainly are increasing the requirements for students to get into them. The institutions are vibrant and are fertile grounds for thought leadership and innovation. India is producing a veritable number of PhDs and institutions seem to offer funding for capable students. South Africa needs to re-examine the funding model for students here. My impression is that students in South Africa do not have similar support as their counterparts in India.

The talks generally concluded with a re-affirmation of the strong historical and cultural links between South Africa and India. Mahatma Gandhi’s time spent in South Africa developing his notion of non-violent protest is well known in India and will always bind our countries together.

India is a vibrant country with an economic engine that is gathering revolutions. Its future is bright and its institutions are producing bright young minds to take their place in this awakening economic giant. South Africans can do well in learning from this super power in the making.

Report

Videos

For more details visit https://cis-india.org/telecom/blog/india-study-tour-report-by-sagie-chetty

Developments in spectrum sharing

radha — 2011-08-18T04:54:47Z

New ways to share spectrum can revolutionise broadband in India - An article in the Business Standard by Shyam Ponappa / New Delhi December 3, 2009, 1:35 IST

As the Telecom Regulatory Authority of India (Trai) deliberates on spectrum and licensing after the hearings ending December 2, some important points are worth highlighting. Spectrum is public property and, therefore, need not add a layer of cost (through auctions and such other artifices), provided it is available to network builders, and these networks are available to operators for their customers on payment. The question is whether the government should give spectrum
free, or for an up-front price, i.e., a hefty spectrum fee, or through a progressive revenue-sharing arrangement as for telecommunications. This can be to network builders for their use, or to operators, to pool through either their own arrangements or through network builders-cum-operators.

One way to think about communications networks is to consider an analogy with road networks. The road network is accessed by paying road taxes and special tolls as required, e.g., when using a toll bridge or highway. The rest of the time, once a transport operator pays road taxes, the fleet’s vehicles have access to the entire public road network.

In the same way, it should be feasible for operators to access communications networks. These networks may be the operator’s own, or the public network, i.e., the Public Switched Telephone Network, paying as they go. In other words, whether operators use their own or others’ networks should be immaterial as long as they pay the tariffs, which result from a mesh of interconnection agreements. In this manner, network builders/service providers can use the spectrum as part of their “plant” for wireless transmission, just as they use optical fibre and copper wire for wire-line transmission.

Networks are already being built and operated by network builders-cum-operators. According to The Economist on developments in network operations, initially in New Zealand and then extended on a much larger and broader scale in India, “The vendors... gain economies of scale because they build, run and support networks for several Indian operators. Ericsson’s Mr Svanberg says his firm can run a network with 25% fewer staff than an operator would need. Bharti’s operating expenses are around 15% lower than they would be if it were to build and run its network itself, and its IT costs are around 30% lower, according to Capgemini.”*

Meanwhile, a momentous experiment in spectrum sharing is taking place in America. A company called Spectrum Bridge has developed a database-driven model for dynamic spectrum allocation in unused spectrum bands, the “white space” in the TV bands. This is in the 200 to 600 MHz band, with considerable advantages in propagation over distances, through foliage and walls, without attenuation as experienced at higher frequencies.

This system is being tried in Claudville, a rural community on the border of Virginia and North Carolina. As is likely to be true in rural India, using open spectrum that is unlicensed is impractical because of the distances, terrain and foliage. Fibre and copper lines are not only impractical, but also prohibitively expensive, a fact that people who suggest the use of existing wiring for broadband don’t seem to realise.

In this context, given the discussions on the possibility of spectrum trading as a solution going forward in the Trai hearings, it is instructive to note that despite the US Federal Communication Commission’s secondary market initiatives taken in 2003, not much spectrum trading had actually taken place until Spectrum Bridge’s introduction of their tracking and trading model, SpecEx (see www.specex.com). Subscribers view available spectrum at a chosen location and frequency band with pricing details when they want to buy, or list available spectrum to sell by location and frequency band. Therefore, any recommendations by Trai or decisions by the Empowered Group of Ministers (EGoM) or the government should take this into account in considering the path of market traded spectrum based on exclusively assigned bands. It would be unrealistic to expect such trading to take place simply because it is allowed, without other
facilitating developments as have been achieved by Spectrum Bridge in America.

A second problem is that trading in spectrum can result in effects equivalent to land-grabbing in real estate. This serves less for effective communications than as an asset play for profit.

Like SpecEx for priced spectrum, www.ShowMyWhiteSpace.com is a free website that the company supports to show free TV white space (the “digital dividend” that is talked about) that can be used on the basis of open access to unlicensed or open spectrum.

In the trial at Claudville, Spectrum Bridge deployed the network with Dell and Microsoft contributing computer equipment and software to the local school. Teachers can now incorporate distance learning resources into the school’s curriculum.

Our policy-makers need to move beyond debates over slicing and dicing the spectrum to determine the smallest efficient band — 2.5 MHz for CDMA and 4.4 for GSM? Is 6.2 MHz all that any operator needs?... and so on. A direct solution is to not assign spectrum for exclusive use, and instead enable its use as a common resource that must be accessed by everyone
who needs to communicate on the network, exactly as public roads are accessed by paying road taxes and tolls. If spectrum must be assigned nominally to operators for administrative reasons, they should be obligated to pool this spectrum for common access.

Once we are able to aggregate spectrum in the frequency range which allows propagation over distances and through natural and man-made obstacles — buildings, foliage, etc. — we will have the open “highways” for broadband for its widespread usage across the country. This can only be achieved at relatively low cost through a progressive revenue-sharing arrangement, which is what happened eventually for voice communications with the National Telecom Policy 1999.

These are complex technical and commercial issues, and require the concerted effort of stakeholders and experts to devise the most effective solution in the public interest. The Trai hearings are the first step in this process.

shyamponappa@gmail.com <mailto:shyamponappa@gmail.com>

* ‘The mother of invention’, The Economist, September 24, 2009

Link to the original article

For more details visit https://cis-india.org/telecom/blog/developments-in-spectrum-sharing

Plan and Execute for Results

Shyam Ponappa — 2012-05-10T10:51:12Z

Good SOPs are a starting point, but there's more under the surface that will affect results.

What is a good way to plan and build enduring systems, e.g., for sanitation and water in our cities and countryside, roads (rail/waterways/air for logistics), or a broadband network for communications? Some thoughts on Standard Operating Procedures (SOPs) — beginnings, processes and ends — and on some “invisible” aspects that facilitate good outcomes.

The Big Picture

Start with the big picture: the engineering background of China’s leaders has no doubt contributed to their conceptualisation and achievement so far. President Hu Jintao and Premier Wen Jiabao were engineers, as were former President Ziang Zemin, and Premiers Zhu Rongji and Li Peng. While pondering if that’s what it will take to improve India’s record on conceptualisation and execution, we find that former President Deng Xiaoping, who got China going on its current track, didn’t have it. No engineering degree, although he went to France when he was 16 for a work-study programme. Despite a difficult experience with entry level jobs in shoe manufacturing, metals, automobiles, and restaurants, he was very effective in applying himself to building China. So, there’s hope if our leaders apply themselves to long-term solutions, rather than to self-aggrandisement. This might be of their own volition, or because the public and/or circumstances force them to do so. For instance, if RTI activists concentrate on one major objective at a time, while paying attention to facts, thinking, talking and acting logically in close cooperation and coordination, i.e., with sound direction, we might get results.

Fundamental SOPs

Some fundamentals are clear enough, although we rarely seem to follow them, like an integrated systems perspective with disciplined project management (listed below). There are, however, many assumptions and enveloping circumstances that affect the drivers directly, as well as their boundary conditions and interactions. These can be easily lost sight of in pursuing a line of thought or action, or even particular disciplines. This is valid for all issues, for instance, increasing the hit rate for road projects put to bid by the National Highways Authority of India (NHAI), or the successful completion of power projects, or efforts to structure and manage spectrum for broadband. Therefore, for user-centric area planning/spatial planning, the overriding emphasis is necessarily on an interdisciplinary (i.e., multidisciplinary) approach. This is because societies and their needs are multi-dimensional, and solutions must work in a complex set of circumstances. Silo thinking and action won’t work.

This is true whether for neighbourhoods or for country-wide networks such as road systems, railways, or broadband. It is also true for the content, i.e., for broad areas like education from kindergarten to postgraduate levels including vocational training and Continuing-Education for all people, or for a single vertical space, such as health care or hospitality.

The fundamental elements (SOPs) include:

End-to-end systems, i.e., comprehensive, integrated pieces that fit.
Convergent objectives.
Systematic, disciplined project management, starting with the desired end results, and a backward induction for intermediate goals at each step with the required resources and time, all the way back to the start.
An interdisciplinary/multidisciplinary approach, because sound inputs are required from multiple perspectives, such as overall strategy, structure, systems, technology, human resources, finance, and markets, tailored to our culture and practices, even as we improve them.
Coordination & Direction: above all, there needs to be convergence of efforts to achieve a desired goal or direction. Without coordination and direction, efforts are unlikely to converge, and therefore unlikely to achieve desired outcomes.

Other Essential Aspects

Self-Governing Systems vs Government Intervention
Much has been made recently of Prof Elinor Ostrom’s ideas on polycentric governance and self-regulation. However, there is insufficient appreciation of and attention to her stress on (a) trust as the most critical attribute, and (b) checks and balances (incentives/penalties) that are “accepted”, as she understates it. Cooperative action is certainly a winner, provided there is an effort by players to build trust, and sound rules are devised and applied impartially. Can you imagine a country-wide highway system or broadband network in the public interest, designed and developed by independent commercial interests? Possible, but unlikely. That’s why governments need to act in the public interest.
Allowing for the Non-Rational & Emotional
Years ago, Carl Sagan popularised the ideas of Paul MacLean, who headed the Laboratory of Brain Evolution and Behavior in America’s National Institute of Mental Health. The concept was of a three-part structure of the brain: the deep down R-complex (for reptilian-complex) where aggression resides, the limbic system which is the seat of emotions, and the neocortex, which is rational and cognitive. While neurology has moved on in the details, e.g., the hippocampus is now apparently thought to be less important in emotions than in MacLean’s view, and the brain may be less simply compartmentalised, the idea of rational man is no longer assumed as a truism.
The Normal Curve & Dysfunctional Elements
For those not familiar with statistics, there is a universal phenomenon of distribution along the “normal” curve: any group of objects (or people) measured for any attribute — height, weight, goodness — is likely to be distributed along a probability curve, as in the graph above, with some outliers spread over the lower and higher ends or “tails”, and the rest bunched around the middle/mean/average.

The takeaway: plan for the dysfunctional elements in the left tail, and build protection mechanisms in systems. Consideration with item 2 above indicates the kind of protection robust systems might need.

Good SOPs are a starting point, but there’s more under the surface that will affect results, regardless of external factors.

Link to the original article on Business Standard

For more details visit https://cis-india.org/telecom/blog/plan-execute-results

Alternative Scenarios

Shyam Ponappa — 2012-05-10T10:49:46Z

Only about 48 per cent of India is covered by the telecom network with only 20 per cent rural coverage, says Shyam Ponappa. In his article published in the Business Standard on 4 February, 2010, he points out how alternative approaches may enhance extensive coverage.

Like the industrial revolution, India missed the infrastructure systems building stage. As a consequence, even in 2001, the telecom network covered a mere 4 per cent of our population. Now, it covers about 48 per cent, but with only 20 per cent rural coverage. Our need being extensive coverage, the following what-if scenarios explore how alternative approaches might pan out.

The market-driven scenario

One approach is that all that’s required for an effective communications infrastructure is to go ahead with the spectrum auctions — that long-delayed, but always expected “3G” auction, to begin with. Imagine that it happens. What then?

Current policies will result in three winners of 10 MHz each. If they are from among present operators, they could be any three of Airtel, Vodafone, Reliance, Idea, Tata… or one or more new players: Google, Intel… until one of these wins the fourth “3G” slot when that band is made available, and so on. These operators will probably roll out networks and services where heavy traffic is expected, as with 2G so far: more extensively in urban areas. Provided other policies evolve rationally, e.g., that acquisitions are allowed and spectrum holdings can be consolidated, in the long run India may have around five or six large countrywide operators. There may be regional/segment operators with lesser franchises, or addressing specific segments. Each company will incur capital costs for spectrum and network investment, which then must be recovered from users. Network growth is likely to be on similar lines as before.

Take the evolution of India’s telecommunications policies in the 90s, and the desultory state of the sector until the reforms of the National Telecom Policy ’99 (NTP ’99), followed by reductions in revenue share to more reasonable levels in 2002. Even so, the facts show that:

network growth is skewed heavily towards urban users; and,
broadband coverage is abysmal.

Urban bias in network growth
By November 2009, urban coverage was at 107 per cent of the population, while rural coverage was at 20 per cent. In addition, rural wireless lines grew to 91 per cent, while the wire-line share dropped to 9 per cent; hence the increased importance of spectrum. Networks need more rural reach.

Low broadband coverage

Broadband subscriptions in August 2009 were at just seven million, two million short of the estimate for 2007. According to Comscore, at the end of September 2009, India had under 36 million Internet “unique visitors” (excluding access from Internet cafes, mobile phones and PDAs). This is roughly equivalent to the installed base of PCs, compared with about 560 million phone lines, of which under 40 million are wire-line. Something must be done to increase broadband coverage at lower prices.

The shared-network scenario

Now, imagine what shared-network facilities could do to lower costs, with no duplication of capital investment. Consider the added benefits of shared spectrum as part of this shared network — which, given the fragmented, inefficient present allocation, is the primary need for effective last-mile coverage. Then, add the benefits of substituting revenue sharing for up-front spectrum auction payments. With incentives for performance, the savings in time and money in network build-up and throughput will be immense, while the green footprint from less network hardware will be a double bonus. Government revenues will be far in excess of the foregone auction bids, together with more tax from higher profits, provided the revenue-share percentage is reasonable, as witnessed after NTP ’99 plus reduced revenue-share.

Need for reforms: Networks, spectrum and broadband

Significantly, much of the wire-line rural network is reportedly unsuitable for broadband, because of the length of “last-mile” connections, their quality and the problems of maintenance in difficult terrain. Besides, the cost — more than five times wireless, according to one operators’ association — and difficulty of laying cables in rural terrain, compounded by the impediments of clearances from multiple local authorities, render this impractical. The need is for more coverage with the same investment, even if it is private sector investment.
Therefore, network-building with spectrum reform and broadband need more supportive policies. In particular, incentives and disincentives/penalties are needed for intensive rural coverage as well.

Imagine the IT companies capturing the Y2K opportunity and outsourcing without special communications facilities and tax breaks. Those regulatory measures enabled the development of an essentially outward-oriented IT services sector. Likewise, NTP ’99 with lower revenue-share has led to high growth in telecommunications. This appears to be the best way to establish broadband as an essential infrastructure, especially in rural and semi-urban areas.

Required measures

The initiatives required cover three areas:

Policies that make it profitable to build networks and provide broadband services all across the country, not just in heavily-trafficked areas. This will enable communications access to all, providing a platform for service delivery for government and the private sector with tremendous user benefits. These services could encompass education, health and sanitation, extension services related to economic activities, including logistics, telecommuting, entertainment and information.
Formulating incentives and implementing them so that the primary objectives are achieved. The public-interest broadband objectives are likely to be on the lines of access anywhere — realistically, in most populated places — at reasonable prices. Key results have to be defined and tracked to ensure achievement. There’s a mountain of work in defining reasonable cost so that many more people can access broadband, while the business is commercially attractive. However, that is a separate issue. It needs to result in a large number having subsidised access, just as they must have access to food, education, and other necessities.
Equally important, formulating disincentives that are then applied impartially, so that transgressions that detract from the objectives are penalised.

These issues must be addressed simultaneously from the perspectives of technology, economics, defence and security, and commercial interests, including existing operators’ legacy interests. For this, the government has to work with all stakeholders and specialists to develop solutions with experienced, objective facilitation. Business, government, and consumers can benefit.

The article appeared in Business Standard.

For more details visit https://cis-india.org/telecom/blog/alternative-scenarios

India’s ‘Self-Goal’ in Telecom

Shyam Ponappa — 2020-04-09T07:18:26Z

This post was first published in the Business Standard, on March 5, 2020.

The government apparently cannot resolve the problems in telecommunications. Why? Because the authorities are trying to balance the Supreme Court order on Adjusted Gross Revenue (AGR), with keeping the telecom sector healthy, while safeguarding consumer interest. These irreconcilable differences have arisen because both the United Progressive Alliance and the National Democratic Alliance governments prosecuted unreasonable claims for 15 years, despite adverse rulings! This imagined “impossible trinity” is an entirely self-created conflation.
If only the authorities focused on what they can do for India’s real needs instead of tilting at windmills, we’d fare better. Now, we are close to a collapse in communications that would impede many sectors, compound the problem of non-performing assets (NPAs), demoralise bankers, increase unemployment, and reduce investment, adding to our economic and social problems.
Is resolving the telecom crisis central to the public interest? Yes, because people need good infrastructure to use time, money, material, and mindshare effectively and efficiently, with minimal degradation of their environment, whether for productive purposes or for leisure. Systems that deliver water, sanitation, energy, transport and communications support all these activities. Nothing matches the transformation brought about by communications in India from 2004 to 2011 in our complex socio-economic terrain and demography. Its potential is still vast, limited only by our imagination and capacity for convergent action. Yet, the government’s dysfunctional approach to communications is in stark contrast to the constructive approach to make rail operations viable for private operators.
India’s interests are best served if people get the services they need for productivity and wellbeing with ease, at reasonable prices. This is why it is important for government and people to understand and work towards establishing good infrastructure.

What the Government Can Do

An absolute prerequisite is for all branches of government (legislative, executive, and judicial), the press and media, and society, to recognise that all of us must strive together to conceptualise and achieve good infrastructure. It is not “somebody else’s job”, and certainly not just the Department of Telecommunications’ (DoT’s). The latter cannot do it alone, or even take the lead, because the steps required far exceed its ambit.

Act Quickly

These actions are needed immediately:

First, annul the AGR demand using whatever legal means are available. For instance, the operators could file an appeal, and the government could settle out of court, renouncing the suit, accepting the Telecom Disputes Settlement and Appellate Tribunal (TDSAT) ruling of 2015 on AGR.

Second, issue an appropriate ordinance that rescinds all extended claims. Follow up with the requisite legislation, working across political lines for consensus in the national interest.

Third, take action to organise and deliver communications services effectively and efficiently to as many people as possible. The following steps will help build and maintain more extensive networks with good services, reasonable prices, and more government revenues.

Enable Spectrum Usage on Feasible Terms

Wireless regulations

It is infeasible for fibre or cable to reach most people in India, compared with wireless alternatives. Realistically, the extension of connectivity beyond the nearest fibre termination point is through wireless middle-mile connections, and Wi-Fi for most last-mile links. The technology is available, and administrative decisions together with appropriate legislation can enable the use of spectrum immediately in 60GHz, 70-80GHz, and below 700MHz bands to be used by authorised operators for wireless connectivity. The first two bands are useful for high-capacity short and medium distance hops, while the third is for up to 10 km hops. The DoT can follow its own precedent set in October 2018 for 5GHz for Wi-Fi, i.e., use the US Federal Communications Commission regulations as a model.1 The one change needed is an adaptation to our circumstances that restricts their use to authorised operators for the middle-mile instead of open access, because of the spectrum payments made by operators. Policies in the public interest allowing spectrum use without auctions do not contravene Supreme Court orders.

Policies: Revenue sharing for spectrum

A second requirement is for all licensed spectrum to be paid for as a share of revenues based on usage as for licence fees, in lieu of auction payments. Legislation to this effect can ensure that spectrum for communications is either paid through revenue sharing for actual use, or is open access for all Wi-Fi bands. The restricted middle-mile use mentioned above can be charged at minimal administrative costs for management through geo-location databases to avoid interference. In the past, revenue-sharing has earned much more than up-front fees in India, and rejuvenated communications.2 There are two additional reasons for revenue sharing. One is the need to manufacture a significant proportion of equipment with Indian IPR or value-added, to not have to rely as much as we do on imports. This is critical for achieving a better balance-of-payments, and for strategic considerations. The second is to enable local talent to design and develop solutions for devices for local as well as global markets, which is denied because it is virtually impossible for them to access spectrum, no matter what the stated policies might claim.

Policies and Organisation for Infrastructure Sharing

Further, the government needs to actively facilitate shared infrastructure with policies and legislation. One way is through consortiums for network development and management, charging for usage by authorised operators. At least two consortiums that provide access for a fee, with government’s minority participation in both for security and the public interest, can ensure competition for quality and pricing. Authorised service providers could pay according to usage.
Press reports of a consortium approach to 5G where operators pay as before and the government “contributes” spectrum reflect seriously flawed thinking.3 Such extractive payments with no funds left for network development and service provision only support an illusion that genuine efforts are being made to the ill-informed, who simultaneously rejoice in the idea of free services while acclaiming high government charges (the two are obviously not compatible).
Instead of tilting at windmills that do not serve people’s needs while beggaring their prospects, commitment to our collective interests requires implementing what can be done with competence and integrity.

Shyam (no space) Ponappa at gmail dot com
1. https://dot.gov.in/sites/default/files/2018_10_29%20DCC.pdf
2. http://organizing-india.blogspot.in/2016/04/ breakthroughs- needed-for-digital-india.html
3. https://www.business-standard.com/article/economy-policy/govt-considering-spv-with-5g-sweetener-as-solution-to-telecom-crisis-120012300302_1.html

For more details visit https://cis-india.org/internet-governance/indias-self-goal-in-telecom

July 2019 Newsletter

praskrishna — 2019-08-09T13:50:49Z

Centre for Internet & Society (CIS) newsletter for July 2019.

Highlights for July 2019
CIS presented its comments on the proposed rules 29,30,31 of the Draft Copyright (Amendment) Rules, 2019 to the Department for Promotion of Industry and Internal Trade, Ministry of Commerce and Industry, Govt. of India. The comments were made in response to Notification G.S.R 393(E) published in the Gazette of India on May 30, 2019. CIS submitted that in the domestic approach to modernising our copyright legislation, we must refrain from considering distribution of born-digital/ digitised works over the public Internet equivalent to the function of broadcasting works over cable/ satellite. The Indian National Trust for Art & Heritage Pune Chapter is working with various organisations to preserve the natural heritage places like rivers in Pune district of Maharashtra, India. After the presentation of 'Project Jalbodh' by CIS-A2K in River Dialogue organised by INTACH in April 2018, several organisations have shown keen interest in collaboration. Subodh Kulkarni shares some insights in his report. ICANN has Advisory Committees which help guide the policy recommendations that the ICANN community develops while its Supporting Organizations are charged with developing policy recommendations for a particular aspect of ICANN's operations. ICANN publishes a combined budget for all these bodies under the head of policy development. CIS inquired about the financial resources allocated to each of them specifically. CIS in partnership with the Internet Society organized an event on the impact of consolidation in the Internet economy. It was divided into two roundtable discussions, the first one focusing on the policies and regulation while the latter dealt with the technical evolution of the Internet. The roundtables aimed to analyze how growing forces of consolidation, including concentration, vertical and horizontal integration, and barriers to market entry and competition would influence the Internet in the next 3 to 5 years. The report by Akriti Bopanna and Gurshabad Grover provides an insight into the developments. As part of its Researchers at work programme on key thematics at the intersections of internet and society, CIS called for abstracts for essays that explore social, economic, cultural, political, infrastructural, or aesthetic dimensions of the ‘list’. Ten abstracts would be shortlisted by August 9 from the list of submissions and the selected authors would be requested to submit the full essay of their draft by September 15. Final versions of the essays are expected to be published in October. With the rise and popularity of app-based platforms such as Ola, Uber, Swiggy Zomato, and others, there is a growing public conversation about regulation of such 'gig-work' platforms and the working conditions of people who work for them. To explore this further CIS conducted a panel discussion at its Bangalore office. Researchers associated with the project presented their preliminary findings. Panelists preliminary field insights along with reflections on what it meant to do such studies, how they went about studying gig-work, and challenges that arose in their work. An excerpt from an essay by Maya Indira Ganesh, written for and published as part of the Bodies of Evidence collection of Deep Dives titled You auto-complete me: romancing the bot explains human relations with bots. The Bodies of Evidence collection, edited by Bishakha Datta and Richa Kaul Padte, is a collaboration between Point of View and the Centre for Internet and Society, undertaken as part of the Big Data for Development Network supported by International Development Research Centre, Canada.

CIS and the News

The following articles were authored by CIS secretariat during the month:

Fostering Strategic Convergence in US-India Tech Relations: 5G and Beyond (Justin Sherman and Arindrajit Basu; The Diplomat; July 3, 2019).
Fix Problems Before Complete Failure (Shyam Ponappa; Business Standard; July 4, 2019).
What is the problem with ‘Ethical AI’? An Indian Perspective (A rindrajit Basu and Pranav M.B; cyberBRICS; July 17, 2019).
Old Isn't Always Gold: FaceApp and Its Privacy Policies (Mira Swaminathan and Shweta Reddy; The Wire; July 20, 2019).
The worrying survival of moon landing conspiracy theorists (Nishant Shah; Indian Express; July 22, 2019).
India Is Falling Down the Facial Recognition Rabbit Hole (Karan Saini and Prem Sylvester; The Wire; July 23, 2019).
Why I’m not going to tell you about the dangers of apps like FaceApp (Nishant Shah; Indian Express; July 28, 2019).
The Digital Identification Parade (Aayush Rathi and Ambika Tandon; Indian Express; July 29, 2019). The authors acknowledge Sumandro Chattapadhyay, Amber Sinha and Arindrajit Basu for their edits and Karan Saini for his inputs.
In India, Privacy Policies of Fintech Companies Pay Lip Service to User Rights (Shweta Mohandas; The Wire; July 30, 2019).

CIS in the News

CIS secretariat was consulted for the following articles published during the month in various publications:

PIB plans a fact-checking unit to counter fake news (Smriti Kak Ramachandran; Hindustan Times; July 3, 2019).
How Sai Baba Was Made To Spy On Your Phone For Credit Ratings (Gopal Sathe; Huffington Post; July 4, 2019).
Mozilla is funding a way to support Julia in Firefox (Catalin Cimpanu; ZD Net; July 8, 2019).
Deepfakes: Algorithms at war, trust at stake (Rajmohan Sudhakar; Deccan Herald; July 14, 2019).
Digital public information system design: Talk to experts, find the right way (Prachatai; July 18, 2019).
Easing the US-India divergence on data localisation (Shashidhar KJ and Kashish Parpiani; Observer Research Foundation; July 22, 2019).
For sex workers, mobile phone becomes a double-edged sword (Tushar Kaushik; Economic Times; July 23, 2019).
Twitter reacts to the India's cryptocurrency drama (Rajarshi Mitra; FXStreet; July 26, 2019).

Access to Knowledge

Access to Knowledge is a campaign to promote the fundamental principles of justice, freedom, and economic development. It deals with issues like copyrights, patents and trademarks, which are an important part of the digital landscape.

Copyright and Patent

Research on harms caused to consumers, developing countries, human rights, and creativity/innovation from excessive regimes of copyright, patents, and other such monopolistic rights over knowledge:

Submission

Comments on the Draft Copyright (Amendment) Rules, 2019 concerning Statutory Licensing (Anubha Sinha; July 11, 2019). This submission presents comments to the Department for Promotion of Industry and Internal Trade (“DPIIT”), Ministry of Commerce and Industry pertaining to the notification G.S.R 393(E) containing the draft Copyright (Amendment) Rules, 2019 issued on 30th May 2019.

Wikipedia

Under a grant from Wikimedia Foundation we are doing a project for the growth of Indic language communities and projects by designing community collaborations and partnerships that recruit and cultivate new editors and explore innovative approaches to building projects.

Blog Entries

Orientation programme, Wikipedia workshop & Action Plan meeting in PAH Solapur University (Subodh Kulkarni; July 19, 2019).
Wikimedia Workshop on Rivers under Project Jalbodh (Subodh Kulkarni; July 30, 2019).
Re-licensing Sessions with Authors and Organisations (Subodh Kulkarni; July 31, 2019).

Openness

Our work in the Openness programme focuses on open data, especially open government data, open access, open education resources, open knowledge in Indic languages, open media, and open technologies and standards - hardware and software:

Participation in Event

Learning and Understanding the Frameworks of Rights at Work (Organized by Kai Hsin Hung; IT for Change; Bangalore; July 13, 2019). Torsha and Mira attended the workshop.

Internet Governance

The Tunis Agenda of the second World Summit on the Information Society has defined internet governance as the development and application by governments, the private sector and civil society, in their respective roles of shared principles, norms, rules, decision making procedures and programmes that shape the evolution and use of the Internet. As part of internet governance work we work on policy issues relating to freedom of expression primarily focusing on the Information Technology Act and issues of liability of intermediaries for unlawful speech and simultaneously ensuring that the right to privacy is safeguarded as well.

Freedom of Speech & Expression

Under a grant from the MacArthur Foundation, CIS is doing research on the restrictions placed on freedom of expression online by the Indian government and contribute studies, reports and policy briefs to feed into the ongoing debates at the national as well as international level. As part of the project we bring you the following outputs:

Blog Entry

DIDP #34 On granular detail on ICANN's budget for policy development process (Akriti Bopanna; July 6, 2019).

Participation in Events

13th European Summer School on Internet Governance (Organized by European Summer School on Internet Governance; Meissen; July 13 - 20, 2019). Akriti Bopanna attended the school.
ICANN 65 De-briefing Meeting (Organized by Indian Council for Research on International Economic Relations ; July 16, 2019). Akriti Bopanna remotely presented on the Human Rights related developments that took place at the Marrakech meeting, over the course of the 4 days.

Privacy

Under a grant from Privacy International and IDRC we are doing a project on surveillance. CIS is researching the history of privacy in India and how it shapes the contemporary debates around technology mediated identity projects like Aadhar. As part of our ongoing research, we bring you the following outputs:

Blog Entry

The Impact of Consolidation in the Internet Economy on the Evolution of the Internet (Akriti Bopanna and Gurshabad Grover; July 3, 2019). The blog post was edited by Swaraj Barooah, Elonnai Hickok and Vishnu Ramachandran. Swagam Dasgupta provided inputs.

Participation in Events

Digital ID Forum 2019 (Organized by UNDP; Chulalongkorn University, Thailand; July 3, 2019). Sunil Abraham was one of the panelists at this event.
BIS LITD 17 meeting (Organized by Bureau of Indian Standards; New Delhi; July 3, 2019). Gurshabad Grover attended the sixteenth meeting of the Information Systems Security and Biometrics Section Committee (LITD17).
Facebook Data for Good in Bangalore (Organized by Facebook; Indian Institute of Science, Bangalore; July 25, 2019).
Roundtable with the WhatsApp leadership (Organized by WhatsApp; Mountbatten, The Oberoi, New Delhi; July 26, 2019). Will Cathcart, WhatsApp's new global head, visited India and invited Sunil Abraham for a discussion.
Facebook Data for Good in New Delhi (Organized by Facebook; University of Chicago Center, New Delhi; July 29, 2019).

IT / Information Technology

A research on the usage of systems (computers and telecommunications) for storing, retrieving and sending information as well as the IT Act:

Participation in Event

Leveraging Web Application Vulnerabilities for Reconnaissance and Intelligence Gathering (Organized by Has Geek; GRD College of Science, Coimbatore; July 5, 2019). Karan Saini gave a talk at the JSFoo Conference.

Artificial Intelligence

With origins dating back to the 1950s Artificial Intelligence (AI) is not necessarily new. However, interest in AI has been rekindled over the recent years due to advancements of technology and its applications to real-world scenarios. We conduct research on the existing legal and regulatory parameters:

Participation in Events

Roundtable Discussion on “The Future of AI Policy in India” (Organized by Indian Council for Research on International Economic Relations, New Delhi; July 1, 2019).
Emerging AI technology in health care in India, health equity and justice: Critical reflections and charting out way forward (Organized by HEaL (Health, Ethics, and Law Institute of Training, Research and Advocacy) of FMES (Forum for Medical Ethics Society) in collaboration with CPS (Centre for Policy Studies), Indian Institute of Technology-Bombay; July 13, 2019). Radhika Radhakrishnan, participated in a roundtable discussion on "Emerging AI technology in health care in India, health equity and justice: Critical reflections and charting out way forward."

Gender

Presentation to Amnesty International on researching the Future of Work (Organized by Amnesty Interntional, New Delhi; July 18, 2019). Aayush Rathi and Ambika Tandon made a presentation on CIS research on Future of Work.

Telecom

The growth in telecommunications in India has been impressive. While the potential for growth and returns exist, a range of issues need to be addressed for this potential to be realized. One aspect is more extensive rural coverage and the second aspect is a countrywide access to broadband which is low at about eight million subscriptions. Both require effective and efficient use of networks and resources, including spectrum.

Monthly Blog

Fix Problems Before Complete Failure (Shyam Ponappa; Organizing India Blogspot; July 4, 2019).

Researchers@Work

The researchers@work programme at CIS produces and supports pioneering and sustained trans-disciplinary research on key thematics at the intersections of internet and society; organise and incubate networks of and fora for researchers and practitioners studying and making internet in India; and contribute to development of critical digital pedagogy, research methodology, and creative practice.

Event Organized

#MappingDigitalLabour - Panel discussion on platform-work in Mumbai and New Delhi (CIS, Bangalore; July 19, 2019). Watch the session recording video here.

Blog Entries

Studying the Internet Discourse in India through the Prism of Human Rights (Deva Prasad M.; July 1, 2019).
#DigitalPedagogies (Ashutosh Potdar, Maya Dodd, Nidhi Kalra, and Ravikant Kisana; July 1, 2019).
#OpenAccessScholarlyPublishing (Abhishek Shrivastava, Dibyaduti Roy, and Nirmala Menon; July 11, 2019).
#RenarrationWeb (Anuja Mirchandaney, Deepak Prince, Dinesh and Shalini; July 23, 2019).

About CIS

CIS is a non-profit organisation that undertakes interdisciplinary research on internet and digital technologies from policy and academic perspectives. The areas of focus include digital accessibility for persons with disabilities, access to knowledge, intellectual property rights, openness (including open data, free and open source software, open standards, open access, open educational resources, and open video), internet governance, telecommunication reform, digital privacy, and cyber-security. The academic research at CIS seeks to understand the reconfigurations of social and cultural processes and structures as mediated through the internet and digital media technologies.

Follow CIS on:

Twitter: http://twitter.com/cis_india
Twitter - Access to Knowledge: https://twitter.com/CISA2K
Twitter - Information Policy: https://twitter.com/CIS_InfoPolicy
Facebook - Access to Knowledge: https://www.facebook.com/cisa2k
E-Mail - Access to Knowledge: a2k@cis-india.org
E-Mail - Researchers at Work: raw@cis-india.org
List - Researchers at Work: https://lists.ghserv.net/mailman/listinfo/researchers

Support CIS:

Please help us defend consumer and citizen rights on the Internet! Write a cheque in favour of 'The Centre for Internet and Society' and mail it to us at No. 194, 2nd 'C' Cross, Domlur, 2nd Stage, Bengaluru - 5600 71.

Collaborate with CIS:

We invite researchers, practitioners, artists, and theoreticians, both organisationally and as individuals, to engage with us on topics related internet and society, and improve our collective understanding of this field. To discuss such possibilities, please write to Sunil Abraham, Executive Director, at sunil@cis-india.org (for policy research), or Sumandro Chattapadhyay, Research Director, at sumandro@cis-india.org (for academic research), with an indication of the form and the content of the collaboration you might be interested in. To discuss collaborations on Indic language Wikipedia projects, write to Tanveer Hasan, Programme Officer, at tanveer@cis-india.org.

CIS is grateful to its primary donor the Kusuma Trust founded by Anurag Dikshit and Soma Pujari, philanthropists of Indian origin for its core funding and support for most of its projects. CIS is also grateful to its other donors, Wikimedia Foundation, Ford Foundation, Privacy International, UK, Hans Foundation, MacArthur Foundation, and IDRC for funding its various projects.

For more details visit https://cis-india.org/about/newsletters/july-2019-newsletter

Healing self-inflicted wounds

Shyam Ponappa — 2011-12-05T09:10:20Z

A spate of dysfunctional actions and retrograde developments has led to an unimaginable mess for India. Can the damage to growth prospects be undone? Does it need to be? If so, how? Three areas are discussed below.

Some months ago, the spectre was of consoling ourselves with a reduction of two per cent in growth, from 9.5 to 7.5 per cent. That’s history. What looms ahead is a larger, more serious threat. This ominous tidal-wave-in-the-making comprises many separate currents converging to undermine India’s take-off yet again. The prospect is long-term growth hamstrung by policy stand-offs, foreign direct investment in retail being a case in point, and social tensions fuelled by high unemployment.

Those who think India has arrived should be aware that it will take another decade of eight to nine per cent growth to be able to fund reasonable basic infrastructure and necessities for everyone. Why should it matter if you live in a rich cocoon? At the very least, you’ll be able to go out without stepping into filth or smelling it, or seeing masses of people struggling to survive.

Instead of a high-growth trajectory, we may get six to seven per cent, with luck. These prospects are clouded by wasteful expenditure, such as the perpetuation of an ill-functioning public distribution system and its concomitant, ration-shop-mentality, instead of efficient direct retail subsidies through electronic transfers. The negativity is amplified by fractious social and political tensions, and shoddy infrastructure crippling productivity: power outages, low-speed communications and poor logistics. One can argue (ah, argument) that the tensions are justifiable as an antithesis to increasing levels of corruption from political, bureaucratic and corporate kleptocracy feeding off the land and people, or hardening sectarian interests competing for predatory control. But if there’s one thing we can learn from others’ experience, it is to work together for better outcomes, or suffer; in game theory parlance, collaborate to optimise, or settle for worse.

Undoing Sectarian Alignments

Undoing the fractious underpinnings of sectarian alignments of language, caste and religion is beyond the scope of this article. The unpleasant reality is that unless such structural social impediments are addressed, malfunctions will continue. So we have this reality where, at one level, India is wonderful in the way people stream and swirl together, and at another, it is horrible because our potential is not manifested in living standards, with people fed, clothed and housed properly, and clean streets.

To return to misapplied intelligence in the political economy, consider three areas: interest rates, airlines, and telecommunications.

Interest Rates

It seems only the Reserve Bank of India (RBI) was unaware that the consequences of interest rate hikes since February 2010 would (a) not control inflation (short of an economic collapse), and (b) lead to a severe curtailing of growth. To be fair, some economists aided and abetted with remarks that interest rates must be raised because of high inflation.

By contrast, the accompanying charts for China and Germany (euro zone) show their negative real interest rates.

What we have to do is reduce interest rates, with selective credit controls to ensure that credit for speculation is constrained and costs are high, e.g., in certain real estate, commodities, stocks and derivatives. Implementation, likewise, has to be “intelligent”, with online tracking by exception, and not cumbersome or voluminous weekly or fortnightly reports that are manually compiled and/or analysed, filtered and then presented to committees for decisions.

Airlines

The structural anomalies in India’s taxes on aviation turbine fuel (ATF) and airport charges defy logic. For a decade, there has been talk of cuts in central and state taxes on ATF, but the problems continue. Consider the missed opportunity: India has a large domestic market and is well positioned for airlines to use this for establishing global leadership, as well as ubiquitous domestic services. Instead, the sector is bled for short-term government revenues, giving foreign airlines the advantage. ATF charges in India for international flights cost 16 per cent more than they do abroad, and local airlines pay over 50 per cent more because of taxes and additional charges. Consider the ludicrous stipulation that foreign airlines cannot invest in India, and the irrationality defies imagination. Add the illogic of a government-funded, loss-making airline undercutting private airlines, and we have the mess we are in.

Globally, airlines suffer from gratuitous free-market philosophies, the exceptions being airlines from strategically focused countries, e.g., in West Asia, Southeast Asia (Singapore, Malaysia, Thailand) and, of course, China. Wake up! Surely no one doubts that aviation is an integral aspect of logistics and transportation? The government needs to recognise this and build capacity, with policies like uniform, low state taxes. Also, as in telecommunications, aviation requires an oligopolistic structure with limited competition, which if ignored brings chaos and grief, because nothing else is sustainable.

Telecom & Broadband

The draft National Telecom Policy 2011 promises good things. Yet, like India’s potential, the promise will be realised only with convergent action. This iconic sector, which changed the way the country functions and is perceived, is on the verge of being ruined by dysfunctional intervention. For instance, the regulator and the government seem bent on applying retrospective charges for “excess spectrum”, taking the bottom out of the market. Worse, 3G services are hamstrung by government attempts to restrict services, while operators threaten litigation. Meanwhile, the bastions of “free market”, the US and the UK, are initiating shared spectrum policies. What good are our brilliant objective statements about excellent, affordable services if the government acts to achieve the opposite? And is it beneficial for India to hound solid companies like Telenor and Qualcomm (unless they commit transgressions), instead of taking a problem-solving approach?

If the confused doublespeak – of punitive charges, restrictive practices, PSUs building state-of-the-art networks, auctions and spectrum sharing, all in the same breath – continues, we may lose a decade or more because of instability and irrational policies. It is time for decisions on pay-for-use, open-access spectrum and networks. Incumbent network companies can be compensated along a downward-sloping power curve to give up their competitive advantage. We must start being reasonable and do things that make sense.

This article by Shyam Ponappa was published in Business Standard on 1 December 2011. Read the article at Organizing India Blogspot

For more details visit https://cis-india.org/telecom/healing-self-inflicted-wounds

Recapturing the Commons

Shyam Ponappa — 2019-04-03T01:44:54Z

Regulations that facilitate infrastructure with appropriate public resource use will enhance productivity.

The article was published in Business Standard on March 7, 2019 and in Organizing India Blogspot on March 8, 2019.

Growth in the third quarter was disappointing, but there are signs of a cyclical recovery, with a Purchasing Managers Index for manufacturing at a 14-month high. For a significant upward shift of our growth curve, however, apart from lower interest rates, policy-makers have to be constructive. What might we wish for? Here are some suggestions.

Accept the reality that investible funds in India are insufficient for our needs. These include our stock and net inflow of capital, and profits available for investment. We can try to increase our productive capacity or choose business-as-usual, thereby staying below our potential. Why? Because our activities aren’t profitable enough to induce and sustain investment. We need investment —in hard infrastructure, such as transportation and logistics, electricity, water and sewerage, and communications, and in second-order infrastructure, such as security and law and order, health care, education and training, banking, finance and insurance. There’s also the need for reorganisation of markets and practices, e.g., in agriculture, infrastructure, and government procurement.

There’s little doubt that digital connectivity is invaluable for all these. While the imperative is clear, the question is how to orchestrate achieving the desired results.

The telecom operators, alas, have low profitability, inadequate network coverage, and too much debt. Continuing as before means subpar access and productivity for all. We are all hamstrung, and even more so in rural areas. Because of the expanse an7d scattered users there, connectivity entails much higher costs with lower revenue potential.

Self-Organising Infrastructure – A Conceptual Flaw Without Regulatory Support
Meanwhile, there are conceptual flaws in our approach. The National Optical Fibre Network (Bharat Broadband Network Limited or BharatNet) was conceived as a countrywide fibre backbone. The plan was for optical fibre links to 250,000 gram panchayat villages covering India’s approximately 600,000 inhabited villages. A major assumption, however, was that private operators would build access networks to villages and to users. This was unrealistic for a number of reasons. First, there’s the cost of covering sparse users over large expanses with low revenue potential. Second, the supportive regulations for wireless technologies to build the access networks were/are not in place. For example, even for the established 5 GHz WiFi range used globally for WiFi hotspots, restrictive policies meant that 5 GHz equipment could not be used effectively in India in urban or rural installations. This changed with new regulations for 5 GHz, but only four months ago in October 2018 (for details see https://organizing-india.blogspot.com/2018/11/a-great-start-on-wi-fi-reforms.html).

Other wireless technologies for intermediate- and last-mile links are still blocked, and need enabling regulations.

The 700 MHz band: No operators bid for this given its high price, although it is very useful for covering distances of 5-10 km, and can penetrate walls and foliage. This band together with the 500 and 600 MHz bands could be used to connect gram panchayats to nearby villages. A study of inter-site distances in 14 states shows that most villages would be covered with this range (see Chart below).
Study of Inter Site Distances - Gram Panchayats and Villages

Source: https://tsdsi.in/wp-content/uploads/2019/02/Krishna-Ganti-Day-1-5th-Session-1.pdf

The 500 and 600 MHz bands are allocated for TV, and therefore are part of the “tragedy of the unused commons”. Only a small fraction is used for broadcasting in India because of limited free-to-air TV and better alternatives. As they are earmarked for broadcasting, they are not used for telephony either.

The 70-80 GHz band (E-band) is effective for short-range links covering more users at 3-4 km, but not permitted in India, although it is light-licensed in many countries with nominal fees, e.g., the USA, UK, Russia, and Australia. While ideally our regulations should align with global norms, there are exorbitant charges on operators (reportedly 37 per cent, plus corporate taxes), a debt overhang from spectrum auctions, huge investment needs, and relatively low revenue potential. Compelling arguments to let operators use the E-band with unlicensed access, with registry on a geo-location database to manage interference, to be reviewed after some years. The additional traffic will generate revenues from which government collections will increase.

The 60 GHz (V-band for distances up to 1.6 km): the Cellular Operators Association of India (COAI) opposes making it licence-free as in most countries, and wants it assigned to operators for access and backhaul. For the same reasons as for E-band, operators could be allowed unlicensed access, with a review after some years.

Market Structure and Organisation

A larger problem is that legacy structural and organisational issues need concerted efforts to take requisite policy initiatives. This is perhaps a greater, more urgent need for ubiquitous connectivity.

Successive governments have struggled with revival plans for BSNL and MTNL, somewhat analogous to Air India and Indian Airlines in aviation. Governments have not provided sustained support for ambitious connectivity objectives. There is sometimes inadequate understanding of fast-changing, technically complex enterprises, and episodic attention is given to large enterprises that need timely capital- and skill-intensive decisions (and decision-makers in place), and the upgrading of skills and operating practices. BSNL and MTNL are declining, with bailouts, market disruption through price-cutting, and inability to deliver profits. This is a huge opportunity cost on citizens. However, it is conceivable that with appropriate leadership, and organisational and capital backing, these enterprises could contribute effectively to ubiquitous connectivity, rather than being a drag and/or a disruptive factor. This could happen, for instance, if an alliance were possible with private sector operators providing leadership, organisation and capital, while state ownership concentrates on safeguarding the public interest.

Bharti Enterprises’ Chairman Sunil Mittal has suggested an alliance with Vodafone for an optical fibre network. Bharti and Vodafone already have a joint venture, Indus Towers, providing passive infrastructure services to operators. If regulations enabled active infrastructure from a consortium including BSNL and MTNL, it would leverage the infrastructure while reducing the capital requirements, and increase delivery capability. The entire thrust of regulations could be oriented to facilitating service delivery, leveraging capital, equipment and human resources.

The regulatory approach should aim to facilitate access equitably to public resources that belong to citizens, and not to create obstacles.

For more details visit https://cis-india.org/telecom/blog/business-standard-shyam-ponappa-march-7-2019-recapturing-the-commons

BIF conference on “Substitutability of OTT Services with Telecom Services & Regulation of OTT Services

Admin — 2019-04-12T00:52:07Z

Anubha Sinha was a panellist at a BIF conference on “Substitutability of OTT Services with Telecom Services & Regulation of OTT Services” organized by Broadband India Forum on April 5, 2019 at Taj Mahal Hotel, Mansingh Road, New Delhi.

The event was supported by the Department of Telecommunications, Ministry of Communications, Govt. of India, Ministry of Electronics & Information Technology, Govt. of India, NITI Aayog, and Department of Science and Technology. Click to view the agenda.

For more details visit https://cis-india.org/telecom/news/bif-conference-on-201csubstitutability-of-ott-services-with-telecom-services-regulation-of-ott-services