Centre for Internet and Society

The Free Basics debate: Trai has a point in imposing temporary ban on net neutrality

sunil — 2015-12-25T14:58:30Z

The argument against net neutrality in India is simple. Regulation cannot be based on dogma – evidence of harm must be provided before you can advocate for rules for ISPs and telecom operators.

The article was published in FirstPost on December 24, 2015.

But net neutrality regardless of your preferred definition is a very complex regulatory question and there is no global or even national consensus on what counts as relevant evidence. To demonstrate the chain of causality between network neutrality violations and a variety of potential harms - expertise in a wide variety of fields such as economics, competition law, telecom policy, spectrum allocation, communications engineering and traffic management is required. Even with a very large research budget and a multidisciplinary team it would be impossible to predict with confidence what the impact of a particular regulatory option will be on the digital divide or innovation. And therefore the advocates of forbearance say that the Indian telecom regulator — Trai — should not regulate unprecedented technical and business model innovations like Facebook's Free Basics since we don't understand them.

Till recently I agreed with this empirical line of argument. But increasingly I am less convinced that scientific experiment and evidence is the only basis for regulation. Perhaps there is a small but necessary role for principles or ideology. Like the subtitle of Nassim Nicholas Taleb's book, we need to ask: How to Live in a World We Don't Understand. Let us take another area of technological regulation – cyber security. Do we really need to build a centralised database containing the passwords of all netizens and perform scientific experiments on it to establish that it can be compromised? A 100 percent centralised system has a single point of failure and therefore from a security perspective centralisation is almost always a bad idea. How are we so sure that such a system will be compromised at some date? To quote Sherlock Holmes: “Once you eliminate the impossible, whatever remains, no matter how improbable, must be the truth.” Decentralisation eliminates the possibility of a single point of failure thereby growing resilience. The Internet is perhaps the most famous example. It is not necessarily true that all decentralized systems are more secure than all centralised system of a decentralized network but it is usually the case. In other words, the principle of decentralisation in cyber security does not require repeated experimental confirmation across
markets and technologies.

To complicate matters, the most optimal solutions developed using economics and engineering may not be acceptable to most stakeholders. Professor Vishal Misra has provided a Shapley Value solution using cooperative game theory in the multi-sided market to determine how surplus should be divided between three types of ISPs [eyeball, transit and content] and Internet companies using transparent paid transit arrangements. But a migration from the current opaque arrangement to the Misra solution may never happen because Internet companies will resist such proposals and are increasingly getting into access provision themselves through projects like Google Fibre and Loom. Walter Brown from South African Communications Forum proposes that billing by minutes for phone calls and billing by message for SMSes should be prohibited because on 4G networks voice and text messages are carried as data and price is the best signal to consumers to ensure optimum use of network resources. This according to Walter Brown will eliminate the incentive for telcos to throttle or block or charge differently for VOIP traffic. Again this solution will not be adopted by any regulator because regulators prefer incremental changes with the least amount of disruption.

So given that we only have numbers that we can't trust - what should be some of the principles that form the bedrock of our net neutrality policy? To begin with there is the obvious principle of non-discrimination. The premise is simple – anyone who has gate-keeping powers might abuse it. Therefore we need to eliminate the possibility through regulation. Non-exclusivity is the result of non-discrimination and transparency is its precondition. That can also be considered as a principle and now we have three core principles to work with. Maybe that is sufficient since we should keep principles to the bare minimum to keep regulation and compliance with regulation simple. Some net
neutrality experts have also identified fairness and proportionality as additional principles. How do we settle this? Through transparent and participatory policy development as has been the case so far. Once we have principles articulated in law - how can we apply them to a specific case such as Facebook's Free Basics? Through the office of the appropriate regulator. As Chris Marsden advocates, net neutrality regulations should ideally be positive and forward looking. Positive in the sense that there should be more positive obligations and incentives than prohibitions and punitive measures. Forward looking in the sense that that the regulations should not retard or block technological and business model innovations. For example zero-rated walled gardens could be regulated by requiring that promoters such as Facebook also provide 50Mb of data per day to all users of Free Basics and also by requiring that Reliance provides the very same free service to other parties that want to compete with Facebook with similar offerings. Alternatively, users of Free Basics should get access to the whole Internet every other hour. All these proposal ensure that Facebook and it business partners have a incentive to innovate but at the same time ensures that resultant harms are mitigated.

Just to be absolutely clear, my defense of principle based regulation does not mean that I see no role for evidence and research. As regulation gets under way – further regulation or forbearance should be informed by evidence. But lack of evidence of harm is not an excuse for regulatory forbearance. India is the last market on the planet where the walled garden can be bigger than the Internet – and Facebook is sure giving it its very best shot. Fortunately for us Trai has acted and acted appropriately by issuing a temporary prohibition till regulation has been finalised. Like the US, coming up with stable regulation may take 10 years and we cannot let Facebook shape the market till then.

For more details visit https://cis-india.org/telecom/blog/the-free-basics-debate-trai-has-a-point-in-imposing-temporary-ban-on-net-neutrality

The Coming Telecom Monopoly

Shyam Ponappa — 2012-05-24T07:36:55Z

The 2G judgment and Trai spectrum pricing recommendations have led to a policy that makes sense for only one survivor.

Shyam Ponappa's column was published in the Business Standard on May 3, 2012

The Telecom Regulatory Authority of India, or Trai, has delivered a stunning blow to the telecom sector in the form of its spectrum pricing and refarming recommendations. The sector was already reeling from scandals and misgovernance, and staggered by a confused Supreme Court judgment based on inappropriate assumptions (for details, see “Time for a review”, March 1, 2012, and “Open access is the future,” March 4, 2012). This will cripple an erstwhile sunrise sector that drove (and still can) India’s prosperity through productivity, enabling many factors to converge positively — such as its economic momentum, enterprise, resilience and, most important, a demographic bulge that could become a blessing or a curse. This convergence was (and is) possible because of the enabling ability of telecom and broadband to provide access to education, vocational training and continuing education; health care and other public services; and commerce, including the delivery of individual output, within easy reach. All this is stalled, as we deliberately disembowel ourselves, as it were.

If Trai’s recommendations are implemented, they will ensure that a lone survivor dominates the sector, annihilating all significant competitors – Bharti, Vodafone, Idea, Tata, and newcomers like Telenor and Sistema – through their having to pay exorbitant fees just to keep their current business going, even without expansion. That is, provided the lawsuits that are likely to follow don’t obliterate everything for the next 10 years.

Are these setbacks happenstance, heaven-sent, or acts of man? Analysing the components shows that much is attributable to the machinations of men, although rendered by different individuals or groups under varying compulsions. The afflictions that began with cronyism and misgovernance have been aggravated by a judgment based on misapprehensions regarding: (a) spectrum technology; (b) the economics of auctions and; (c) competition in network economies.

In trying to get at the corrupt nexus of corporations, politicians, bureaucrats, and just plain crooked people, indiscriminate zealotry is destroying legitimate enterprise. The judgment lumps the guilty with the circumstantially proximate. Coupled with defining auctions as best for the public interest, this set the stage for what has followed. The furore over corruption and the Anna Hazare movement ensure that any objective recommendation would come under fire, with a mobocracy baying for revenge.

Is being deprived of ubiquitous, reasonably-priced broadband so devastating? Yes, because of broadband’s great potential in India’s vastness for enabling people at relatively low cost, compared with, say, fixing energy supply, or sanitation and water, or roads, or growing food. All these are necessary; but broadband is much easier to achieve, at lower cost, and would bring it all more easily within our grasp, especially in rural areas.

Performance

Some question the beneficial effect of revenue sharing from the National Telecom Policy, 1999, (NTP-99) suggesting the sector might have done as well or better without the change. Pakistan is cited as an example for growth with auctions. Consider the performance of the sector in both countries.

Chart 1 - Mobile Subscriptions (Millions) 2003-2010

(The third line shows India’s numbers reduced to 70 per cent, reflecting an estimate of live subscriptions.)

Chart 2 shows the percentage of population served. Pakistan’s coverage grew

Chart 2: Percent Population Covered

Sources: India – TRAI; PIB; http://en.wikipedia.org/wiki/Telecommunications_Statistics_in_India
Pakistan - http://www.pta.gov.pk/index.php

rapidly until about 60 per cent, then tapered off. India started more gradually before accelerating to 60 per cent a couple of years later, and kept going. In March 2011, both were around 70 per cent. At the end of December 2011, India was at 76.86 per cent.

However, there are two major differences. One is the scale of India’s operations. Sheer magnitude makes for much greater complexity, and the achievement is therefore remarkable. The second is the significantly higher government levies in India. India’s telecom sector is perhaps the world’s most heavily burdened, with government collections higher than in Pakistan by 15 to 24 per cent of revenues.* (Compared with China,where government charges are only 3.5 per cent, India’s levies are even more grossly out of line.) Had Indian enterprises not had this burden, it’s conceivable they might have had the capacity and stomach to effectively address rural coverage, especially with the right incentives.

Achieving Ubiquitous Broadband

Now consider what needs doing for countrywide access to broadband, and what odds have to be overcome. First, there’s the addition necessary to rural and semi-urban networks, where almost three times the existing coverage is needed. Much of this needs wireless access. This is why spectrum pricing critically affects outcomes. Many people in India harp on a litany of sunk-costs-not-affecting-tariffs, oblivious to the vast deficiency in network coverage, ie, areas and people without access. It’s like arguing over pricing without any production plant or products. Without capital investments in network coverage, there can be no services, nor any tariffs, high or low. There is little doubt of the effects of high spectrum and licence fees: these needs remain unmet. Hence the low rural teledensity of under 39 per cent at the end of February 2012, with urban coverage at nearly 170 per cent, and overall teledensity at 78 per cent. Separately, there’s the issue of inadequate incentives for broadband delivery.

Statements from Trai and the Department of Telecommunications about the spectrum pricing recommendations being reasonable because of the revenue potential simply don’t add up. Their projections are based on a fantasy of booming growth (like the Budget projection of 7.6 per cent GDP growth, but even more exaggerated). Whereas the combined effect of the scam and its fallout, sentiment, momentum, and misguided efforts at tax-gouging will ensure that telecom revenue growth is no more than a stunted five to seven per cent, at best. No bank will lend seven-year funds in such uncertain circumstances to what was once a sunrise sector — but is now like heavy infrastructure, with a need for 20-year financing. Add the costs and difficulty of refarming the 900 MHz spectrum, and one has to wonder: who is going to bid, and why? It makes sense only for one survivor. All this is aside from the extension of subsidised non-performance at the PSUs, instead of transforming them into anchors of an open-access national network.

For more details visit https://cis-india.org/telecom/coming-telecom-monopoly

The Challenges of Direct Democracy

Shyam Ponappa — 2012-01-30T12:51:10Z

India must weigh the pros and cons of various approaches to direct democracy and develop one of its own.

Direct democracy is alluring. The dangers to our society and economy from reckless governance as well as confrontational activists, however, are the undermining of institutions, and the unintended consequences.

Our governments have a carry-over of feudal and colonial attitudes and do not communicate unless they must. Change is accepted only under duress, and is not initiated through leadership. Mismanagement is tolerated, resulting in various scams such as the 2G spectrum scam and associated problems.

The current anti-corruption drive by Anna Hazare et al and their well-intentioned cohorts uses tactics that echo a righteous, anti-authoritarian and non-collaborative pattern of “us” versus “them”, combined with an insistence on their way alone. Yet, collaboration is essential for solutions that lead to an equilibrium, recognising the legitimacy of all stakeholders – the government and civil society – as well as the criticality of credible institutions and processes.

We in India are not alone in being drawn to direct democracy. Switzerland’s success in citizen participation combined with its federal structure is the epitome of a workable system. But this model cannot simply be transplanted without regard to cultural contexts. Consider the sobering example of California.

California's Predicament

California has been in a state of financial crisis for several years. In 30 years, the Golden State’s credit rating fell from among the best of the 50 states to the worst. Despite everything from Silicon Valley to agriculture, defence, aerospace, biotechnology and Hollywood, why can this state not manage itself? Why does The Economist quote labels like “dysfunctional”, “ungovernable”, even “failed” for this El Dorado (April 20)? To understand what happened in California, we must start with its direct democracy model imported from Switzerland.

The Swiss Model

Since the 14th century, Switzerland has had a tradition of citizens participating in assemblies. Coordination among different sets of delegates, e.g. for building roads and bridges across different valleys, had to be approved by respective assemblies. On this canvas, Switzerland grafted America’s Constitution in 1848. It worked and still works because of its design, and Switzerland’s collaborative approach. Constitutional amendments require a referendum as well as a majority of votes by the cantons (states) in the legislature.

Thus, over half the cantons can overrule the popular majority in a referendum, because of the rule taken from America of two votes per state, even if they represent a minority of voters. After being approved in a referendum, the amendments go back to the legislature for redrafting. This enforces George Washington’s principle of “cool” debate outlined at the time of drafting the US Constitution, and embodied in Senate deliberations for dispassionate lawmaking. Initiatives for new laws by direct democracy go through the same process, but the legislature has the option to draft a counter-proposal. This process of engagement and negotiation is designed to avoid extreme outcomes and promote dispassionate solutions. As with America’s Constitution, this prevents two kinds of abuse: James Madison’s1 concerns regarding minority factions and their “swing vote” capturing outcomes (as in India, where minority factions become king makers), or a tyranny by the majority.

The California Variant

About 100 years ago, the Progressives in California brought in direct democracy from Switzerland. As in India today, the purpose then was to attack corruption, specifically, “The Octopus” of the Southern Pacific Railroad with its tentacles everywhere. California’s direct democracy was designed to achieve the opposite of the Swiss model. Switzerland emphasises compromise and consensus; California encourages confrontation, and the winners impose their will. Starting new initiatives (“propositions”) is easy; calling referendums on existing laws is difficult. In effect, California’s propositions are irreversible, because a retraction or reversal needs a two-thirds majority, which is virtually impossible because of minority factions and special interests.

For over half a century, there were no major problems. Then, in 1978, the anti-tax proponents initiated a property tax cap, Proposition 13. It limited state revenues (placing a ceiling on all property taxes at one per cent of the 1975 value, which could grow at no more than two per cent annually unless sold, thereby establishing a new value). There are contradictory views on the benefits of Proposition 13, with the defenders blaming opportunistic individuals, not the system, for problems. It is the old divide between tax-and-spend liberals versus cut taxes-and-services conservatives. The outcome, however, is that California went from being a liberal showcase with excellent infrastructure and services to a bankrupt state, cutting back on both.

What India Can Learn

India’s polity (at central, state, and local levels), at least now, must start creating systems that harness participation through all means available, so that the voice of popular assemblies is heard within the framework of our representative democracy, and acted upon.

The government needs to move away from the paradigm of “The Administration” against “The People”. Instead, the government must lead a process of collaborative stakeholder engagement for equitable resolution, like the one based on a lifeboat concept of shared interests and survival. As individuals, we need to move away from blaming routines (the government/everyone else is at fault, and I am a victim) to accepting the responsibility and discipline of institution building and processes.

What India Requires

Discarding feudal/colonial notions of the durbar in political parties, among politicians and in government.
Channeling righteous public anger into the constitutional process with competence and discipline. Currently, there seems to be no effective way of demonstrating dissatisfaction except by taking to the streets.

We need institutionalised incentives and penalties to steer towards these effective means, and to abandon arbitrary and angry ways.

Technology allows this on an unprecedented scale, with perhaps 100 million Internet users in India already. To harness and channel this capacity, systems need to be developed on the lines of the Obama campaign2, vastly extended with the expertise and support staff to inform citizens and channel their participation constructively within an institutional framework. These systems will need to cover everything, from issue-based analysis and presentation to spelling out responsible choices with the foreseeable consequences, and collating individual inputs and preferences. If executed with vision, imagination and commitment, this could reduce the instances of people taking to the streets.

This article by Shyam Ponappa was published in the Business Standard on July 7, 2011. Read the original here

For more details visit https://cis-india.org/telecom/blog/challenges-of-direct-democracy

The Centrality of Cash Flows

Shyam Ponappa — 2015-08-25T16:27:22Z

Greece's experience tells us that cash flows are crucial to economic outcomes. No matter how far-reaching the vision, ambition, and slogans, the effects of cash flows are profound and inevitable.

The article was originally published by Business Standard on July 1 and also mirrored in Organizing India Blogspot on July 2.

Many of our politicians and bureaucrats and a large proportion of the public seem oblivious to how cash flows affect our political economy. This apparent absence of understanding (or flouting of fundamentals by opportunists who understand them but act in their own interests) shows up in many ways among all political parties in their approach to the basics: the provision and pricing of essential services such as security and law-and-order, electricity, broadband communications, transport, water, sanitation, and waste disposal. Without an understanding and acceptance of how essential cash flows are for providing these services, we can't realistically aspire to better living conditions. No matter how well or wealthy you may be, you still have to pick your way gingerly through the mess and the stench of your environs when you step out.

Cash flows are at the crux of the problems our governments face at the Centre and states, and that society is up against. They include all the legacy issues mentioned above of the inadequate infrastructure services that we endure, and extend even to problems such as the defence services pensions. While the National Democratic Alliance is not blameless, there are egregious instances among other political parties, such as the Aam Aadmi Party's (AAP's) actions on waste management and electricity supply in Delhi. The essential sticking points have been delayed (obstructed) cash flows, whether in paying sanitation workers or electricity distributors. These instances are mentioned only as indicative examples, as their processes hark back to the habitual practice of governments at the Centre and the states of delaying payments, whether it is fertiliser subsidies to manufacturers (a central government "habit" for decades), or setting realistic tariffs and making prompt payments to electricity distribution companies, as in the case of state governments running Delhi. Various parties - the Congress until 2014 and the AAP thereafter - have themselves been victims of the structural constraints of electricity generation plants with antiquated, inefficient equipment, as in the old coal-based plant at Badarpur, or efficient, modern plants using gas caught in an upward price spiral with domestic gas not being available, such as at Bawana.

In the communications sector,constrained cash flows limit services. One rough estimate is that cumulative charges for spectrum amount to about Rs 1.8 lakh-crore ($30 billion), roughly equal to the total amount invested in networks and equipment. In other words, operators could have invested double the amount in networks and equipment if it had not been paid in government charges. Operators had to take on significant debt for prior payments, thereby hampering their ability to invest in extending and upgrading their networks.The operators' financial constraints constitute one major reason that a market hungry for data services is starved. (Another major reason is the technology constraint of narrow, noncontiguous bands of spectrum, but that is another tale).

The situation in electricity supply is much worse, because of the high and still growing level of stressed assets of the state electricity boards. Press reports estimate that as much as Rs 53,000 crore may possibly become non-performing assets (NPAs) by the end of September.

There is a view that stressed assets and NPAs need not be a problem, because they can be readily sold to new owners who could reorganise the undertakings, which could succeed or go out of business if they fail. While this is theoretically possible, in practice, this is quite difficult and impractical to carry out, especially in hard times. Banks typically are not equipped to take over a number of non-performing businesses and run them until they can dispose of them. Secondly, considering the problems of being profitable in bad times combined with generating cash for operations in downbeat markets, it is unlikely that there will be acceptable buyers willing to pay reasonable prices for loss-making assets.

One difficulty in addressing such issues is that the basic concepts - of cash flows, of numbers from operations in the profit-and-loss statement in tightly coupled lockstep with the balance sheet, which leads to the cash flow statement, require a level of effort to understand that many are unwilling to put in. Cash flows are measurements of flow, whereas profit-and-loss and balance-sheet items are accumulated over specified periods such as a month or quarter, i.e., statements of stock,with no easily discernable relationship to actual cash movements in those periods. There are additional complexities in delving deeper, e.g., in considering the similarities with the flow of liquids. As cash flows are in some ways comparable to liquid flows, there is research from the perspectives of fluid dynamics that requires an understanding of more complex mathematics, physics, or engineering. For those interested in exploring these aspects, further readings are suggested here.

Put intuitively, the key is in setting up and/or taking corrective action to facilitate smooth flows, with the recognition that disruptions create turbulence. Smooth flows are laminar, as the layers or lamina of fluid move easily without mixing (see diagram). Once turbulence sets in, it takes time and often additional effort (resources) to revert to smooth flows, because the obstacles have to be removed or worked around, and the vortices and eddies created by disruptions have to be stabilised and smoothed out.

For more details visit https://cis-india.org/telecom/blog/business-standard-op-ed-july-2-2015-shyam-ponappa-centrality-of-cash-flows

The Buzz Around TV White Space

Shyam Ponappa — 2015-12-16T02:21:19Z

Large blocks of underused spectrum lie tantalizingly out of reach, waiting for enabling regulation, administration, and to some extent technology, to accelerate our move towards Digital India.

The article published in the Business Standard on November 4, 2015 was mirrored in Organizing India Blogspot on November 5, 2015.

One such category is unused/underused TV spectrum or "TV White Space" (TVWS). Despite growing demand, operators face bleak prospects as they struggle to deliver, starved of spectrum and infrastructure. Their dilemma is how to extend delivery capability without choking on buying spectrum so precious it's like an albatross around their necks, leaving little capital for densifying and extending their networks.

There's a war brewing around wireless broadband trials using TVWS in India, years after completion in other countries. These frequencies are most effective for long-range broadband. Mobile operators are watchful of developments such as Microsoft getting preferential access, triggered by announcements of its partnership with the Education and Research Network (ERNET) for countrywide rural broadband. Equipment suppliers also seem apprehensive of developments that could lead to swathes of spectrum being "unlicensed", reducing markets for their established products for licensed spectrum.

This article aims to clear some of the misinformation to facilitate policies for Digital India.

What is "TV White Space"?

There's confusion and disinformation about what TVWS is. Quite simply, TVWS is unused TV spectrum, or TV bands devoid of TV signals. The meaning derives from the areas on a page without print or pictures. Microsoft calls [the technology developed for] it "White-Fi", while some call [the technology developed for] it "super Wi-Fi".

Even bands broadcasting TV programs can have underutilised sections that can carry broadband, as pioneered by researchers at Rice University in Houston, Texas. Rice has a system that uses TV bands for both broadcasting as well as broadband.1 According to researchers, although the 400 to 700MHz band is used for broadcasting TV in many US cities, its capacity is largely underutilised because of alternative ways of accessing TV signals, such as through cable, satellite, or Internet TV. Therefore, incorporating Rice's technology in TV sets or remote equipment could significantly expand the urban reach of "super Wi-Fi", and not restrict it to rural areas.

Is there any TVWS in India? Some say there isn't!

Studies across the country show that over most of it, unused TV spectrum (white space) amounts to 85 to 95 per cent of TV spectrum.2,3,4 Studies excluding northern India show that in over a third of the area, a large band -- 470 to 585 MHz -- is available for alternate use.2,4

An odd controversy has been created about whether this is "white space" or not, precisely because the spectrum is largely unused.5 The convoluted semantics are mystifying, because white space is by definition unused broadcast spectrum. The National Frequency Allocation Plan already designates this band for fixed or mobile wireless, in addition to TV. In other words, without changes in allocation, operators can share TV spectrum on a secondary basis, as in the USA, the UK, and Singapore.

Regarding spectrum usage charges, as with any infrastructure, it is much more beneficial in the public interest to provide affordable services first and to collect government fees and taxes later, than to front-load auction fees and have no services at all (imagine road systems if up-front charges had to be paid for the right to build them). Overall benefits from Digital India, which is impossible in the foreseeable future without low-cost wireless broadband connections to the NOFN and other backbone networks like ERNET, will far exceed cash collections from auctions.

Proponents of auctions suggest that TVWS be reallocated as cellular spectrum and auctioned. Their reasons: (a) The transfer of public property to private operators; (b) Transparency and fairness; and (c) Government collections. This reasoning is false and misleading, because: (a) No transfer is required, as all operators can get secondary access equitably through a consortium approach; (b) This ensures transparency and fairness; and (c) Government collections from productive use will far exceed any auction collections, as evidenced by licence fees: in 2005, estimated auction fees lost until March 2007 were Rs 20,000 crore, whereas actual collections were double, at Rs 40,000 crore; collections by March 2010 were Rs 80,000 crore, in addition to the public benefits of better services.

Should TVWS be used only for 3G & 4G?

Another negative argument is the insistence that TVWS should be auctioned for 3G and 4G. Whereas Digital India needs low-cost wireless broadband, especially for long-distance links in rural India, because of the high cost and difficulty of building and maintaining fibre or wired networks in difficult terrain, and/or in sparsely populated areas. Therefore, access to TVWS needs to be bundled with the National Optic Fibre Network/BharatNet, and other shared backbone networks like ERNET. Policies should permit different network design scenarios including transmission power and purpose. Point-to-point links are needed over long distances in place of fibre or microwave, and broad coverage is needed for contiguous areas like industrial developments, campuses, commercial complexes, or rural communities. At the user end, TVWS could interface through cellular (3G or 4G) or Wi-Fi transceivers.

TVWS does need tight radio filters (unlike Wi-Fi) to minimise interference, the underlying consideration that drives spectrum management. There's also need for varying power specifications depending on the network design and purpose as described above, and policies for unlicensed sharing using geolocation databases, as defined by the US FCC (Federal Communications Commission).

To be most beneficial, it is not important to extract the maximum carrying capacity from TVWS in every location, as in the misplaced number-of-subscribers-linked spectrum policy some years ago. Rather, the objective for Digital India is to use this technology in combination with others for the purposes people need, namely, for affordable broadband wherever they are, while mitigating radiation hazards. This is essential for India to get its basic communications infrastructure.

Shyam (no space) Ponappa at gmail dot com

1. http://news.rice.edu/2015/07/13/rice-tests-wireless-data-delivery-over-active-tv-channels-2/, Jade Boyd, September 5, 2014.
2. IIT-Hyderabad studied TVWS in southern India from 2009, shared findings with the government/other IITs from 2011, and published in 2014:http://link.springer.com/chapter/10.1007/978-3-319-08747-4_3#, Kalpana Naidu et al.
3. http://www.cse.iitd.ernet.in/~vinay/papers/coral13.pdf, Pradeep Kumar et al, June 2013, IIT-Delhi.
4. arXiv:1310.8540v1 [cs.IT], Gaurang Naik et al, 31 October 2013, IIT-Bombay.
5. https://www.linkedin.com/pulse/tv-whitespaces-how-white-spaces-parag-kar;http://www.financialexpress.com/article/fe-columnist/editorial-beware-the-white-spaces/146355/

For more details visit https://cis-india.org/telecom/blog/business-standard-november-4-2015-buzz-around-tv-white-space

The 2G Supreme Court Judgment

Shyam Ponappa — 2012-03-13T08:21:49Z

The Business Standard published Shyam Ponappa's two-part article deconstructing the assumptions in the Supreme Court's 2G judgment, and suggesting possible ways forward. The first one was published on March 1, 2012, and the second on March 4, 2012.

The 2G Supreme Court Judgment - 1

Time for a review [Flawed assumptions: auctions]

The judgment cancelling 2G licences was based on demonstrably incorrect assumptions about auctions, writes Shyam Ponappa in an article published in the Business Standard on March 1, 2012. This first of two articles starts out with identifying the false premises of the judgment, particularly relating to the consequences of auctions.

The Supreme Court judgment of February 2, 2012, cancelling 122 2G licences needs a detailed review. This is because it is based on faulty premises relating to economics, finance and technology. If the Supreme Court entertains review petitions on this judgment, it is imperative that the judges be aware of these false premises, and that they be correctly informed regarding these issues. This article gives a few instances of such errors and explores the logic of auctions.

First, as an example of an error, the judgment states, “Spectrum has been internationally accepted as a … renewable natural resource which is susceptible to degradation in case of inefficient utilisation.”

The fact is that spectrum is not renewable, nor is it degraded. Spectrum is completely unaffected by use, unlike the degradation of land or water through use. However, use of a particular range of frequencies in a given space and time can block another user’s effective access to the same spectrum in that space and time — hence the need for considering efficient societal use.

Second, the judgment states that “the Government of India has already taken a decision to ... allot the same [spectrum] by auction”, quoting Telecom Minister Kapil Sibal. The fact is that the government had not announced such a policy decision before the judgment.

Third, the judgment prescribes auctions as being in the public interest. Are they?

The assumption that auctions are in the public interest warrants a detailed review. Amidst a cacophony of confused opinion based on little knowledge and less understanding, here is the evidence:

a) Maximum public revenues: auctions or revenue share?

Assume for a moment that public revenues are indeed the appropriate measure in the public interest. What does the evidence show? An estimate from the Telecom Regulatory Authority of India (TRAI) in 2005, of auction fees foregone after the transition to revenue-sharing, was Rs 19,314 crore from March 1999 to March 2007. In fact, actual revenue-share collections by March 2007 amounted to double that number, or Rs 40,000 crore. Further, the amount collected by March 2010 was Rs 80,000 crore.

Sources: Auctions - TRAI, 2005:
http://www.trai.gov.in/trai/upload/StudyPapers/2/ir30june.pdf
Revenue Share: CAG, 2010: http://cag.gov.in/html/reports/civil/2010-11_19PA/Telecommunication%20Report.pdf

These data demonstrate that over seven and 10 years, revenue-share collections far exceeded auction fees foregone. Over the entire life-cycle (20 years or more with extensions?), the revenue-share collections will overwhelm even the Comptroller and Auditor General’s (CAG’s) imaginary lost revenues.

b) Public interest: revenues, or access and usage?

What is really in the public interest — revenue collections or the benefits of usage? The CAG report and the clamour for auctions assume that revenue collections reflect the public interest. However, the draft National Telecom Policy 2011 (NTP-2011) states as its first objective: “Provide high quality, affordable and secure telecommunication services to all citizens.” It states that revenue generation will be secondary.

In other words, the policy objective is to provide the benefits of accessible, affordable services to users, not to maximise revenues collected. This was the first time the government unequivocally stated an objective that appeared emphatically in the public interest. The Supreme Court has thus far seen it differently, although this has nothing to do with upholding the law.

The confusion is made worse because the preponderance of literature is by “auction experts” focusing on high fees — and not at all on the services that should have followed but didn’t, because the capital went into the auctions instead of building service capability. A notable exception is a more balanced study of spectrum auctions worldwide that considers social gains as well as fees — which estimates social gains at an overwhelming 240:1 (“What really matters in spectrum allocation design”, Thomas W Hazlett and Roberto E Munoz, April 9, 2010: http://ideas.repec.org/p/reg/wpaper/372.html).

c) Are auctions in the public interest?

There was one successful auction in India in 2001 – because the market was dead – for a fourth mobile operator per circle. Other auctions in India and abroad resulted in the failure of network rollout and services, but were hailed as successes because of high auction fees. For cases of “operation successful, but patient dead”, read on.

Auction failures

US, 1994: The first US auction netted huge bids. Soon after, a number of “successful” bidders declared bankruptcy. This was repeated in the 1995-1996 “C”-Block auctions.

India, 1994: This auction in 1994 was followed by chaos from overbidding and default. The sector recovered only after many years, when the bids were set aside in favour of revenue-sharing with NTP-99. It took almost a decade before a reduction in revenue share (lower fees) and tariffs (calling party pays) led to explosive growth in mobile telephony from mid-2003.
UK, 2000/European Union, 2001 (3G): Considered a spectacular success, netting about $35 billion in the UK, followed by high bids in Austria, Germany and Italy that netted over $100 billion, these auctions raised about ten times the amount expected. The markets collapsed thereafter, and the bidders couldn’t service the debts incurred. Companies have taken a decade to recover, moving cautiously even now on 4G.
India, 2010 (3G and broadband wireless access): Hailed as a success, with over Rs 1,00,000 crore bid, lacklustre performance has followed, as companies struggle with the “winner’s curse” of paying too much to corner spectrum.

Auction experts have written disparagingly of “failures” (low fees) in countries like the Netherlands, Switzerland, Sweden, and non-auction countries like South Korea, Japan and Finland (until 2009). However, these disparaged countries have the best broadband services, according to a 2010 study by Saïd Business School at Oxford (http://www.sbs.ox.ac.uk/newsandevents/releases/PublishingImages/3 - Broadband quality ranking - by economic development.jpg). That is not surprising, considering that the capital was invested in service delivery, instead of in vying for spectrum.

Read the original from the Business Standard

The 2G Supreme Court Judgment - 2

Open access is the future [Flawed assumptions re technology; way forward?]

This article addresses erroneous technological assumptions, and explores possible ways forward.

The first part of this article (‘Time for a review’, BS, March 1) dealt with erroneous assumptions, especially regarding auctions. This part covers misplaced assumptions about technology, and explores constructive alternatives going forward.

Errors in technical assumptions
An assumption underlying the prescription of auctions is that spectrum must be assigned to operators for their exclusive use. This was how wireless evolved during the first half of the 20th century, when radio frequency interference was the predominant problem in wireless communications.

With developments in technology, some advocate open spectrum predicated on the use of “cognitive radio” or “software-defined radio”, by which user equipment avoids interference by sensing unused channels automatically. In this model, open-access spectrum is a commons.

Another approach is to use a database-driven open-access model, whereby devices register with a database, and are dynamically assigned spectrum as needed. If this were possible in 1959, when Ronald Coase first recommended auctions, it would not have been necessary to parcel out spectrum. Even in America’s developed economy, the first auction was in 1994, and it failed.[1]

Now, technological developments enable spectrum sharing and dynamic assignment. America’s FCC has appointed 10 database administrators for dynamic spectrum allocation, with Spectrum Bridge being the first — in operation from January 2012.

America restricts this approach to unused spectrum in the TV bands, and a portion of the 700 MHz band, called “TV white spaces” (TVWS). The UK’s Ofcom is taking similar steps, with implementation planned for 2013. While all licensed frequencies could be pooled, sharing is restricted to TVWS because of conventions and legacies, and operators’ and governments’ preference for auctions. This judgment rules out sharing, blocking other technologies if the spectrum were available.[1]

The lure of auctions

For markets like India, there is every reason from a technology perspective to share not only TVWS and 700 MHz, but all commercially licensed spectrum. There is a technological basis for pooled spectrum, without exclusive assignment and auctions. Yet people love auctions: liberals, because business must pay its way, and governments get revenues; conservatives, because market mechanisms substitute for government controls.[2] Operators prefer exclusive assignment to the uncertainties of open access and compensation for their holdings. Governments want auction revenues. So neither governments, nor big operators, nor the uninformed public, see incentives for pursuing what is in the public interest: shared spectrum.

For Technology leaders in OECD markets, shared spectrum was not a priority, because more spectrum was available to fewer operators. For instance, in 2010, operators in many US cities had 55-90 MHz according to gigaom.com, and AT&T was using only about half its available spectrum, whereas in Delhi and Mumbai, operators had only 10 MHz.

First-come-first-served

Can the FCFS policy be abrogated on the basis of unconstitutionality? If so, the induced turmoil and far-reaching changes in procedures required for everything from tickets for railways or airlines, state-owned assets such as land, mining concessions, even government housing (including for judges?!), and all previous licences granted by FCFS procedures, defy imagination. This urgently needs review by the Supreme Court in the public interest.

Irregularities, outcomes, contracts and cancellation

The same 11 companies whose licences were cancelled qualified according to the FCFS principle, except that their sequence was changed, apparently through procedural irregularities. In other words, without malfeasance, the same companies would have got the licences, except for S Tel getting Delhi and someone else not. Malfeasance deserves penalisation. However, as changes resulting from irregularities are limited in the sense that the same candidates would have won, must all licences be cancelled? Is there a judicial option of annulling the award, and placing the issue before the executive for equitable resolution in the public interest? After all, it is against the public interest to induce turmoil in markets and development capabilities, which the present ruling is likely to do not only in telecom, but in other sectors like energy, mining, manufacturing and transportation. Also, if foreign companies acquired legitimate stakes in licence holders, can these contracts be nullified without proof of their malfeasance? Or could erring parties be penalised, while legitimate parties are enabled to reconstitute their position as required by law?

The way forward
Unfortunately, it is for our discredited and dispirited government to pick itself up and dig us out of this hole. Focused, goal-oriented action on the following lines would help.

First, review petitions: A first step is structured review petitions to the Supreme Court seeking relief, without grandstanding, bluster, or abdication of responsibility.

Second, an alternative to spectrum auctions exists in open access with payment. Both public revenues as well as public usage can be well served by treating access to spectrum as an open-access right-of-way. India’s policy makers need to consider the US and the UK’s shared spectrum approach. Spectrum can be paid for as it is used, as are oil pipelines, roads, or airports and ports.

Open access could create tremendous opportunities in India, including for other technologies, e.g., a revival of WiMAX, if Intel grasps the nettle.

Third, on the cancelled licences. This has different problem sets. One set comprises parties who abused the system, punishable under due process of law. If there are parties in a second set that did no wrong, they should suffer no penalty.

What of a subset of the first, in which a foreign partner invested legitimately and built out, provided they were within the law? If these investors acted in good faith, perhaps a legal recourse could be to place their cases before the government for resolution and rehabilitation in the public interest conforming with the laws, if need be by a dispensation from the court, or even by fresh legislation. After all, good faith investors have contractual rights. Possible solutions might be (a) to penalise the guilty partner, while absolving the innocent, or (b) cancelling the licences of the guilty, while allowing the innocent to reconstitute as required by the law.

Above all, there is need for problem-solving that is systematic, transparent and participative, with expert inputs in domains and processes, to place the sector on a firm footing.

Read the original published in the Business Standard

[1].http://www.benkler.org/Open_Wireless_V_Licensed_Spectrum_Market_Adoption_current.pdf

[2].Paraphrasing Eli Noam: http://www.citi.columbia.edu/elinoam/articles/beyond_auctions.htm

[3].For details, see: http://organizing india.blogspot.com/2011/06/ntp-2011-objective-broadband.html

For more details visit https://cis-india.org/telecom/2-g-supreme-court-judgement-1

The 2G Judgment of December 2017: What Was It About?

Shyam Ponappa — 2018-01-18T14:40:50Z

The judgment provides a critique of how no proper evidence was presented on existence of an FCFS policy and its improper implementation.

Originally published in Business Standard on January 3, 2018 and also published in Organizing India Blogspot on January 4, 2018.

The recent 2G judgment raises perplexing questions about the case, with pointers in the judgment to issues of concern that we need to address going forward. This preliminary analysis highlights questions that arise from select issues covered in the judgment of over a thousand pages: Can government policy itself be prosecuted as alleged wrongdoing, as the charge sheet apparently tried to do? The judgment states that the FIR alleged in item 1 that the licence fee in 2008 was Rs 16.58 billion as in 2001, and licences were issued on a first come, first served (FCFS) basis without competitive bidding.¹

These are factual statements in accord with prevailing policies, and licences could be applied for at the fee set in 2001. The charges question the appropriateness of the policies as there was no competitive bidding or auction.² Arguments for changing the policy to adopt auctions, or to increase fees, appear unconnected with proving wrongdoing.
Regarding the FCFS policy, the charges are twofold. One is whether or not there was in fact an established FCFS policy. Another is alleged malfeasance in policy implementation.

Was there an FCFS policy?

The judgment finds that the FCFS policy has been misrepresented in the claim that only one application was processed at a time.3 This is analysed and contradicted in detail. The judgment gives several contrary examples provided by the defence, such as later applicants being processed earlier when there was a problem with compliance by the earlier applicant, of successive applicants given letters of intent (LOIs) on the same day, and applicants with LOIs seeking repeated extensions before letting them lapse. The judgment states that no evidence was presented of a systematic FCFS process for the issue of LOIs and spectrum allocation/assignment in the case of 51 prior licences issued. The finding is that because there was a single applicant at a time earlier, a sequential process was followed, but that this was not a conscious policy. Also, that the evidence from the Wireless Planning and Coordination Wing (WPC) is that priority for spectrum allocation was from the date of application for spectrum, and not from the application for the unified access services (UAS) licence (LOI). The judgment concludes that there was no evidence to prove that there was an FCFS policy in the form as alleged in the charge sheet. The sense one has from the instances cited is that there was a loose policy with no standard operating procedure.

Possible malfeasance & evidence

Another allegation in the charge sheet is that the FCFS policy, such as it was, was implemented in a manner that resulted in wrongful gains. From press reports at the time, one expects that this statement of possible malfeasance is the sort for which evidence might be available and presented. So, was such evidence presented?

The FCFS process changed from the date of application for a licence in the order in which it was received to actual compliance with terms of LOI. This meant submitting all requisite information, documentation and clearances together with bank drafts and guarantees. Earlier, the FCFS criterion was the completed application (as in the instance of a later complete application being processed before an earlier incomplete application). The judgment records that consideration of the proposed change to LOI compliance was publicly known well beforehand and was even published in the press.

The counter is that because of a large number of applicants, the criterion was established for serious applicants who complied with the conditions of LOIs, including all clearances and payments. All applicants were apparently well informed of impending developments at the Department of Telecommunications (DoT). The judgment notes: “Everything was leaking in DoT. There was no secrecy or sanctity… In such a situation, no blame can be cast on any of the accused alone.” However, one is left with a sense that this area has not been conclusively explored.

Some questions remain
A broad question: Is there a way to deliver justice while avoiding the infructuous path of dealing with the several hundred thousand pages of documents over seven years and the opportunity cost so far for all involved in just this case? If so, how do we change course going forward? The charges appear to have conflated the questioning of policy with allegations of improper implementation and culpability. Might separating the questioning of policy from establishing wrongful implementation and culpability be more constructive? Could defining narrower culpable allegations, focused on evidentiary material, obtain conclusions beyond reasonable doubt?

The judgment provides a scathing critique of how no proper evidence was presented on the existence of an FCFS policy. What is the explanation for a weak case by the prosecution?
The charges sought to prove that there was a conspiracy of all the 17 accused, and that the first indication of it was the letter from the DoT to the solicitor general regarding LOIs for pending applications. Could the charges have targeted other events and activities based on likely availability of evidence, and if so, what might they have found? Examples: Bringing forward the deadline for applications from October 1, 2007 to September 25, 2007, or the lack of orderly standard operating procedures adopted in changing the priority of applicants from the date/time of application to LOI compliance.
Regarding wrongful gains, there is no indication if forensic methods were used in tracking transactions and if so, what the methods and findings were.
What explains the rough-and-tumble process that applicants had to go through in complying with LOIs related to the case?

For the New Telecom Policy in 2018, we must hope to learn from and avoid such adverse situations. One way is to facilitate collaborative and transparent implementation.

Delhi District Court judgment: Cbi vs . (1) A. Raja (A1); on 21 December, 2017.pdf https://indiankanoon.org/doc/17920655/
The Trai (Telecom Regulatory Authority of India) recommended auctions in August 2007 for all spectrum except “2G bands”, but not for licensing. Acceptance by the DoT would have made this the policy, but this recommendation was not accepted.
(Ibid) Page 524, Paragraph 753

For more details visit https://cis-india.org/telecom/blog/business-standard-shyam-ponappa-january-3-2018-2g-judgment-of-december-2017

Television Standards

Srividya Vaidyanathan — 2012-10-03T10:16:53Z

There are a number of TV Standards worldwide. Not all television sets in the world are alike. Countries use one of the three main video standards – PAL, NTSC or SECAM. What this means is that a video from a PAL country will not play in a country that uses the NTSC standard.

Frames

Before we dive deep into the various TV Standards we shall take a look at a few basics of TV transmission. A television transmission consists of a set of rapidly changing pictures to provide an illusion of continuous moving picture to the viewer. The pictures need to come at a rate of 20 pictures per second to create this illusion. Each of these "rapidly changing" pictures is a frame. A typical TV transmission is at 25-30 frames per second (fps).

Lines

Each frame consists of several closely spaced lines. The lines are scanned from left to right and from top to left. A typical TV picture consists of 525 to 625 lines. Considering this large number of lines, if all were to be written one after another the picture would begin to fade at the top by the time the last line is written. To avoid this, the first frame carries the odd numbered lines and the next frame carries the even numbered lines. This provides uniformity in the picture and this is called interlacing.

Timing

TV receivers require a source to time the rapid succession of frames on the screen. Designers decided to use the Mains power supply frequency as this source for two good reasons. The first was that with the older type of power supply, you would get rolling hum bars on the TV picture if the mains supply and power source were not at exactly the same frequency. The second was that the TV studio lights or for that matter all fluorescent, non incandescent lights flicker at the mains frequency. Since this flicker is much higher than 16 times per second the eye does not detect it. However this flicker could evolve into an extremely pronounced low frequency flicker on TV screens due to a "beat" frequency generated between the light flicker and the mains frequency. This would have made programmes un-viewable particularly in the early days of development of TV receivers.

The two mains power frequencies worldwide are 50Hz and 60Hz. This meant that there was an immediate division in the TV standards - the one with 25 frames per second (50 Hz) and 30 frames per second (60 Hz). Most of the compatibility problems between TV standards across the world stem from this basic difference in frequencies.

NTSC (National Television Standards Committee)

The majority of 60Hz based countries use a technique known as NTSC originally developed in the United States by a focus committee called the National Television Standards Committee. NTSC (often funnily referred to as Never Twice the Same Colour) works perfectly in a video or closed circuit environment but can exhibit problems of varying colour when used in a broadcast environment.

PAL (Phase Alternate Lines)

This hue change problem is caused by shifts in the colour sub-carrier phase of the signal. A modified version of NTSC soon appeared which differed mainly in that the sub-carrier phase was reversed on each second line; this is known as PAL, standing for Phase Alternate Lines (it has a wide range of funny acronyms including Pictures At Last, Pay for Added Luxury etc). PAL has been adopted by a few 60Hz countries, most notably Brazil.

SECAM

Amongst the countries based on 50Hz systems, PAL has been the most widely adopted. PAL is not the only colour system in widespread use with 50Hz; the French designed a system of their own -primarily for political reasons to protect their domestic manufacturing companies - which is known as SECAM, standing for Sequential Couleur Avec Memoire. The most common facetious acronym is System Essentially Contrary to American Method.

SECAM ON PAL

Some Satellite TV transmissions (usually Russian) that are available over India, are in SECAM Since the field (25 frames /sec) and scan rates are identical, a SECAM signal will replay in B&W on a PAL TV and vice versa. However, transmission frequencies and encoding differences make equipment incompatible from a broadcast viewpoint. For the same reason, system converters between PAL and SECAM, while often difficult to find, are reasonably cheap. In Europe, a few Direct Satellite Broadcasting services use a system called D-MAC. Its use is not wide-spread at present and it is trans-coded to PAL or SECAM to permit video recording of its signals. It includes features for 16:9 (widescreen) aspect ratio transmissions and an eventual migration path to Europe's proposed HDTV standard. There are other MAC-based standards in use around the world including B-MAC in Australia and B-MAC60 on some private networks in the USA. There is also a second European variant called D2-MAC which supports additional audio channels making transmitted signals incompatible, but not baseband signals.[1]

Quick Facts:

NTSC and PAL are video standards that are recorded on the cassette. These videos send and electronic signal to the television, then only it can be viewed.
In, India, PAL video format is supported.
NTSC is the video standard commonly used in North America and most of South America.
PAL is the video standard which is popular in most of the European and Asian countries.
The difference between NTSC and PAL is the transmission of number of frames per second. In NTSC, 30 frames are transmitted per second. Each frame is constituted up of 525 scan lines.
In PAL, 25 frames are transmitted per second. Each frame consists of 625 scan lines.
Second, the power frequency used in NTSC is 60 Hz. While in PAL, the power frequency is 50 HZ.

Telecom Path-Breaker?

Shyam Ponappa — 2011-11-18T05:42:00Z

Does the draft National Telecom Policy-2011 reflect true brilliance or smoke-and-mirrors? It will be a game-changer if a shared network is implemented effectively, writes Shyam Ponappa in this article published in the Business Standard on November 3, 2011.

There’s much to criticise the government about for not initiating systematic reforms. Yet, the draft National Telecom Policy 2011 (NTP-2011), announced three weeks ago, is a stunner.[1] It begins with a solid, integrated-systems preamble to IT, Communications and Electronics, followed by an excellent vision statement: “[to provide] secure, reliable, affordable and high quality... telecommunication services anytime, anywhere.” A sound beginning, although open-ended in terms of how the details could evolve.

There are potential problems with such high-level pronouncements, of course. A number of commentators castigate the motherhoods in the draft. With a lofty perspective and few details, much depends on how the open-ended possibilities develop, including the difficulties of execution in dealing with ground realities and obstacles.

An Assessment

NTP-2011 addresses six major areas: spectrum, licensing, broadband, convergence, roaming, and manufacturing. Focusing on the first two, there are sweeping proposals:

licences will not be linked to spectrum; and
spectrum sharing will be permitted.

Some view the separation of licences and spectrum as retrograde, because spectrum is essential for service delivery. Others suggest that transgressions that led to the scams are now being inducted as new policies, e.g., operators accessing networks they do not own, which is characterised as being against the public interest. Some heap opprobrium, alleging that like the previous policy, NTP-99, which they call retrograde (although it led to the phenomenal growth in mobile telephony), its main purpose is to allow companies to avoid paying licence/auction fees to the government.

The last expostulation is the most ludicrous, because revenue collections after NTP-99 far exceeded estimated fees foregone: Rs 20,000 crore estimated “loss” by March 2007, but Rs 40,000 crore actually collected, and Rs 80,000 crore collected by March 2010.[2]Add tax collections on exponential growth with increased profits, and the result is even higher total government revenues.
Opposing operator access to networks arises from confused objectives; blocking access is like cutting off one’s nose to spite one’s face. The purpose of the sector is to provide services and access to users for legitimate activities. The public interest lies in facilitating access on appropriate terms.
To evaluate licensing and spectrum, begin with the premise of shared spectrum. Spectrum is essential for effective service provision, particularly in the rural and semi-urban areas with about 70 per cent of the population. An aspect not commonly known is that larger bands of spectrum enable more efficient throughput. For example, 1 MHz of a 12 MHz band carries 50 per cent more traffic than 1 MHz of a 6 MHz band. An estimate of the benefit to Indian operators of more bandwidth at international norms is a reduction of 20 per cent in operating costs.

Spectrum Occupancy

In practice, assigned spectrum is idle much of the time, except during the busy hours in India’s heavy-traffic metros, for extraneous reasons: too many operators, with too little spectrum, in too- narrow bands. This aspect becomes clear from spectrum utilisation or occupancy studies. For instance, the chart shows spectrum occupancy in Bangalore, Edinburgh and Stony Brook (New York) sometime in 2011.

The low readings (250 to 850 MHz in Bangalore, 600 to 950 MHz in Edinburgh, and 500 to 850 MHz in Stony Brook, NY) indicate available “white spaces” that can be better utilised.

High-traffic cities like Delhi and Mumbai have much higher utilisation than cities elsewhere in the world. It comes at increased costs to operators, because of advanced equipment and the closer spacing of towers, as well as having negative environmental effects. If a system with on-demand access to centralised, more efficient spectrum bandwidth were available, the capacity would be much higher, while operators would gain tremendous savings.

Another aspect has to do with the structuring and pricing of shared spectrum. One scenario for sharing is to enable operators to share assigned bands on mutually acceptable terms, leaving the onus of structuring and deployment on the respective operators, as for mobile telephony towers. As with the towers, there are likely to be coalitions of operators/independent entities who are able to work out arrangements among themselves, while not attaining the ultimate efficiency of unified coordination. For instance, participants who share towers in India share passive but not active infrastructure, and a critical element of active infrastructure is spectrum.

An alternative scenario would be mandated spectrum sharing. Spectrum on demand could be made available to any operator/counterparties for the duration of every communication “transaction”. This would need a database-driven Dynamic Spectrum Assignment facility, as deployed by Spectrum Bridge in the US. The more efficient throughput would mean higher traffic capacity for a given investment through better utilisation.

The distributed processing alternative through cognitive radio in every user device is (a) much less efficient, and (b) far more expensive. The market consolidation-through-acquisition approach, with more auctions, is the least efficient and most expensive.

Common-Access Networks

There would be further efficiencies if the entire network (and not just the spectrum) were accessed on-demand for payment per use. Another benefit from a public perspective would be much lower collective investment in resources, because of better utilisation. A third benefit would be the reduced environmental impact because of a lower carbon footprint and radiation from two or three common-access national networks (assuming competition is essential for effectiveness and efficiency).

In other words, database-driven, shared spectrum and networks have to be organised and managed as a coordinated unit if the potential benefits are to be realised. America is doing this with TV white spaces/the digital dividend, through the appointment of 10 database administrators (including Spectrum Bridge, Google and Microsoft). This should elicit our interest.

Once the government and stakeholders accept these concepts, the next major task is structuring the networks as consortiums to align the interests of operators and network providers, with state-of-the-art lead partners. In this process, incorporating and reorienting BSNL and MTNL as guardians of national interests with oversight by an adequately empowered regulator will be the remaining major tasks.

[1].http://www.dot.gov.in/NTP-2011/NTP2011.htm

[2].TRAI, 2005: http://www.trai.gov.in/trai/upload/StudyPapers/2/ir30june.pdf
CAG: http://cag.gov.in/html/reports/civil/2010-11_19PA/Telecommunication%20Report.pdf

Shyam's article was originally published in the Business Standard. It can be read here

For more details visit https://cis-india.org/telecom/telecom-path-breaker

Tech Talk: Landscape of Wireless Communications & Electromagnetic Spectrum

praskrishna — 2014-05-07T08:12:54Z

The Centre for Internet and Society (CIS) welcomes you to a talk by A. Radha Krishna on April 28, 2014, 2 p.m. to 5 p.m. at its office in Bangalore.

Radha Krishna's talk will focus on:

The various wireless communication technologies like Bluetooth, Zigbee, Zwave, WiFi, IoT, HomeRF, RFid, NFC, RuBee, connected car, V2V, V2I, V2R, 2G, 3G, 4G, x10, Insteon, JenNetIP, Wireless USB, microwave communication, satellite communication, Iridium, ameture radio, DVB-T, H/NGH, SH, AM, FM, NTSC, TV-Band Devices, cordless phones, RC toys, remote door lock of cars, etc.
Touch upon lasers and fiber optic communications.
Discuss licensed/unlicensed/reserved bands of electromagnetic spectrum.
Some of the challenges to use other frequencies of electromagnetic spectrum.

A. Radha Krishna

A. Radha Krishna is an Architect working in Alcatel-Lucent with 15 years of experience in embedded, consumer electronics, and telecom domains. He is also a long time Wikimedian and acted as Wikimedia Bangalore SIG chair for about 1.5 years. He is also part of NASSCOM initiative to reduce the gap of skills of Engineering students to Industry need. He is working on a Telecom course which could be part of curriculum in Engineering colleges all over India from 2015.

Presentation Material

View more presentations by Radha Krishna here.

Snacks and high tea will be served at 5.00 p.m.

For more details visit https://cis-india.org/events/tech-talk-landscape-of-wireless-communications-and-electromagnetic-spectrum

Take 'Model T' for Telecom

Shyam Ponappa — 2012-05-10T10:16:54Z

We need an initiative coordinated by the PMO that optimises both services and government revenues, says Shyam Ponappa in his article published in the Business Standard on 2 December 2010.

The 2G spectrum troubles give India an opportunity for clear thinking and purposive action for a significant impact on people’s lives. We (all stakeholders: operators, central and state governments and agencies, the media, opposition parties, PSUs and private corporations, and citizens) need to recognise that there are two distinct aspects to the wrangle: legacy problems and the way forward. The 2G controversy has to do with the truth and consequences of legacy actions. The way forward concerns our fundamental purpose, i.e. the delivery of effective and efficient communications services. What then must we do?

1. Past problems: Follow due process
Many commentators and sections of the public take a shotgun approach, demanding the cancellation of licences and auctioning confiscated spectrum. This is outside the purview of the law and will destabilise the sector and the economy, as will any arbitrary government action.

In a democratic society, there is a proper way to address these problems: through the due process of law, not summary judgements ending in figurative lynchings. There are contracts with operators, and we have to learn to respect and enforce the law. Use harsh penalties by all means, but only after (a) going through due process in establishing the facts, (b) provided there is evidence of culpable wrongdoing, and (c) the law calls for harsh penalties. If the law calls for a slap on the wrist, we need to change our laws for serious crimes, not resort to mob violence in the guise of righteous outrage.

2. Present and future needs: Approach needs with a sense of purpose
A different aspect of the predicament relates to how we can achieve improved communications infrastructure and services in India. This includes broadband Internet, voice telephony, TV and radio. We need a constructive approach encompassing services, hardware and software, instead of being mired in outmoded practices based on exclusive spectrum allocation, for example. Our focus has to be on our purposes/needs: ubiquitous access at a reasonable price. We need broadband for every household. How do we get it? (Click for graph)

Capitalising on the low-margin model
The growth of mobile telephony provides a workable model. The graph above shows the rise in subscriptions with declining prices after the shift to revenue sharing in NTP ’99, together with reductions in revenue share percentages for licence and spectrum fees, and in the access deficit charge.

This is a good instance of Henry Ford’s low-margin, high-volume strategy for the Model T. To sustain low tariffs extending to broadband, we need to reduce extraneous levies. A Trai study of 2005 showed government levies on telecommunications in India were far in excess of China, Sri Lanka and Pakistan.*

The study also showed that licence fees from the original auctions would have amounted to Rs 19,314 crore through 2006-07. According to the CAG report, licence and spectrum fees with reduced levies actually amounted to Rs 40,169 crore by 2006-07, i.e. double the auctions; by March 2010, the figure was nearly Rs 80,000 crore.** Over a long period, reduced revenue share for licence and spectrum fees has resulted in explosive growth as well as higher government collections than auctions and high fees.

Initiative by ministry or PMO?
Why can’t the communications ministry, the DoT and Trai effect this transformation? Recall the scope of NTP ’99 and the role of the Prime Minister’s Office (PMO) for these reasons:

First, reduced short-term government revenues. In the long term, the revenue sharing in a vibrant sector far exceeds the auction take, as shown above. Recall that the primary motivation for the licence auctions of the 1990s and the spectrum auctions was collecting government revenues. Hence, the first criterion is the stance of the finance ministry and the government on revenue collection.

A second criterion at the state level is also financial, for rights of way charges.

Third is India’s approach to spectrum management. Spectrum use can be structured like road or rail networks, or oil pipelines, instead of being treated as exclusive property or usage rights. The difference in costs and benefits to society is staggering. It’s like the right to use daylight or the air we breathe. Visible light is a part of the same electromagnetic radiation, so if there is a charge for radio frequency spectrum, why not for visible light and/or the atmosphere? Rentiers might see this as an opportunity for revenues, but democracies surely must consider it against the public interest.

Existing networks of various government undertakings, including PSU operators BSNL and MTNL, PowerGrid, Gail as well as private operators, could be managed as national assets, as described above for spectrum on payment for usage. This need not mean government control and administration, as there could be a consortium with government participation. There are compelling economic reasons for public access to spectrum and networks because of the drastic reductions in investment, with higher asset utilisation, environmental benefits from less redundancy, and reduced radiation from towers, as in one highway network instead of many.

The opportunity
Even as the law takes its course on wrongdoings, we need a new “New Telecom Policy” on the lines of NTP ’99. This is essential for transformational changes in communications services, clearing up confused policies that are at cross-purposes, and extending to boundary domains in ICT. We should aim for “Model T” pricing with access for everyone. We need an across-the-board initiative to replicate the successful aspects of mobile telephony for broadband and other forms of communication (TV, radio). The PMO could orchestrate a workout with all stakeholders that builds in the benefits of shared network resources, including spectrum, with efficient, low-frequency spectrum for rural communications with much less capital investment.

* Study Paper on “Indicators for Telecom Growth”, Trai, 2005: http://www.trai.gov.in/trai/upload/StudyPapers/2/ir30june.pdf

** “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 in Business Standard here

For more details visit https://cis-india.org/telecom/blog/model-t-telecom

Super WiFi & Shared Spectrum: A Time to Start Sharing

Shyam Ponappa — 2012-11-08T07:00:53Z

Look into sharing spectrum and 'Super Wi-Fi', instead of auctions, refarming and exclusive allocation.

Shyam Ponappa's article was published in Organizing India Blogspot on November 3, 2012 and earlier in the Business Standard on November 1, 2012.

Amidst our preoccupation with internal problems of misgovernance, we’re losing track of long-term technical developments elsewhere. For instance, there’s a buzz about “Super Wi-Fi” technology in other countries that's missing in India. Yet this could make spectrum abundant, while avoiding the problems of private allocation. Here’s why India with its floundering, beleaguered telecommunications sector should stay abreast.

Super Wi-Fi using TVWS

The technology for unused TV spectrum bands, or TV White Spaces (TVWS), is referred to as “Super Wi-Fi”, although it doesn’t conform to earlier Wi-Fi standards, nor does it use the 2.4 GHz or 5 GHz licence-exempt spectrum. Super Wi-Fi has its own standards (IEEE 802.22 and 802.11 af) using 470-810 MHz, the “digital dividend” after conversion from analogue broadcast TV. It can be used for long-range rural broadband, and to improve short-range coverage. In the US, where it was pioneered, access is available without a licence to devices registered with a proximate geolocational database. Like regular Wi-Fi, Super Wi-Fi expands the use of available spectrum by sharing access.

The US is also permitting exploration of shared use in defence and security bands from 1755-1850 MHz, extending the potential for sharing spectrum.[1]

TVWS trials

Earlier this month, Singapore’s Infocomm Development Authority organised a workshop on TVWS with government and private entities. Organisers included the Institute for Infocomm Research (IR) and other local participants, with presentations from companies from the US, Europe, Asia, and Africa, including Microsoft, Google, Spectrum Bridge, Adaptrum, Ericsson subsidiary Telcordia, Neul, Japan’s NCIT, and so on.[2] Completed or ongoing trials are shown in the diagram below.

Super WiFi Trials


Source: http://www.microsoft.com/en-us/download/details.aspx?id=29678

TVWS and shared spectrum vs refarming

These developments should be of vital interest in India to policy makers, operators and users — not only for TVWS as a shared resource, but as an approach that could be extended to other bands, so that limited spectrum availability doesn’t constrain reasonably priced, high-speed data services. This is a serious limitation in India, unlike in other countries where a few operators have sufficient spectrum; in this sense, the need to share spectrum is much greater in India. For example, sharing could provide a better alternative to refarming of the 900 MHz band, allowing for both 4G and legacy uses.

One difficulty is that dominant operators may oppose sharing because their spectrum holdings provide a competitive advantage: possibly Bharti, Reliance, or an aspirant like Vodafone with access to inexpensive offshore funding. Our collective interests here, however, are likely to be best served not by constraining access through limited, exclusive spectrum, but by making spectrum abundant through sharing, allowing for wide bands (2x20 MHz or 2x40 MHz) that can be aggregated for much higher throughput for data, not just for voice.

For this to happen, (a) the government has to explore spectrum sharing in TVWS as well as in other bands, and (b) stakeholders must be receptive, to co-operate effectively on a workable plan on the lines of revenue sharing after NTP-99, extending to broadband delivery. Everyone will gain: users will get better access, operators can thrive, and the government will collect much more revenue over time. However, dominant operators will need to give up their spectrum for the greater common interest including their own, and for this, they will need compensation — as in production-sharing agreements in the oil sector.

The advantages of spectrum sharing

There are a number of advantages of sharing spectrum. First, and important, it can be non-discriminatory. Second, it avoids private allocation; shared spectrum can be accessed without allocation to private parties. Then there is the fact that capital cost is reduced. There is no deadweight loss from capital tied up in auctions, freeing it all for network development and service delivery. Finally, there’s the general misinformation about auctions, which become academic if spectrum is shared. If spectrum is instead auctioned, the public interest – of users, operators and producers – will be adversely affected. (On producers, while local manufacturing is currently insignificant, there is considerable scope if it is set up right, as telecommunications equipment imports are expected to exceed energy imports in a few years).

The Supreme Court was misinformed about auction fees exceeding revenue-sharing collections, and not informed of its detriments. As evidenced after NTP-99, networks and services proliferated, resulting in much higher collections than auction fees foregone. The Supreme Court’s opinion on the Presidential Reference clarified that auctions were not mandatory for other resources, but not for spectrum, although the reasoning is the same. This needs rectification if spectrum is not shared, because revenue-share collections and tax revenues on profits from more extensive networks and services are likely to far exceed the estimated auction fees of Rs 40,000 crore over three years, quite apart from the major public benefits of access.

Space for constructive decisions

Another requirement for constructive resolution is that policy makers be given the requisite space to frame solutions that are genuinely in the public interest. These solutions can be premised on abundance if it is possible, rather than artificial scarcity and rationing. At present, the Telecom Regulatory Authority of India, the Department of Telecommunications, and other authorities including the Empowered Group of Ministers are under immense pressure to favour aggressive government collections, instead of what might be genuinely beneficial. This is an odd consequence of the government’s increasing loss of credibility, resulting in the rise of populists, “profit haters”, and ignorant-yet-opinionated sceptics. Uninformed attacks on constructive approaches and alternatives need to be presented and seen in a more balanced way by an informed media, press and public, instead of being fuelled by indiscriminate hype.

Also, we have to learn to distinguish between problems of ideological conviction – those that can be solved through political accommodation – and engineering problems, like network design and service delivery at least cost. Resorting to political accommodation for engineering requirements results in malfunction and/or collapse.

A good way to proceed is to ensure sharing solutions are worked out without incurring exorbitant cost — not only for TVWS but also for legacy operations, such as in the 900 MHz band. These can induce new network build-outs for data services in urban as well as underserved rural areas, and broadband service delivery across the country.

[1]. Other bands being considered for sharing in the US are:
1695-1710 MHz & 3550-3650 MHz; Unlicensed: 5350-5470 MHz & 5850-5925 MHz. For details, see: http://news.cnet.com/8301-1035_3-57529959-94/defense-department-pushes-spectrum-sharing-as-solution-to-wireless-crunch/
[2]. http://whitespace.i2r.a-star.edu.sg/TVWS_Workshop/Programme.html

Details on the UK (Cambridge) trials at: http://www.cambridgewireless.co.uk/docs/Cambridge White Spaces Trial - technical findings-with higher res pics.pdf

For more details visit https://cis-india.org/telecom/blog/organizing-india-blogspot-in-2012-nov-3-2012-shyam-ponappa-super-wifi-shared-spectrum

Submission to TRAI Consultation on "Inputs for Formulation of National Telecom Policy - 2018"

pranesh — 2018-01-25T14:46:48Z

Centre for Internet and Society (CIS) made a submission to TRAI Consultation on inputs to the National Telecom Policy.

Preliminary

We welcome the TRAI consultation on the National Telecom Policy 2018.

We believe these should be among the objectives of the next NTP.

To enable inclusion through the provision of telecommunications infrastructure and services that are accessible to all, especially for the most marginalized.
To maximize the utility of telecom networks by increasing their capacity and throughput.
To maximize the socio-economic utility of of spectrum and rationalize the regulatory regime.
To re-energize the telecom sector, and to bring about a shift to a revenue-sharing model of revenue-generation for the exchequer.

NTP-12 does not include any policy mandate for providing accessibility for person with disabilities. The Policy should mandate implementation of systems that would enable better accessibility for persons with disabilities. This could have included formulation of a Code of good practice for manufactures and service providers, conduct surveys and gather statistics on use of telecommunication services by persons with disabilities, etc.

Resource and infrastructure sharing

Resource- and infrastructure-sharing among telecommunications companies and applications is crucial to ensure both eiciency of usage of a limited resource (whether it is cabling in underground ducts, or spectrum, or telecom towers), as well as to lower telecommunications costs (especially capital expenditure cost) and lowering barriers to entry, reducing environmental costs, and to maximize the beneits for consumers.[1]

Eforts must be taken to enable greater sharing of resources and infrastructure, without there being a negative impact on competition.[2]

As a telecom scholar points out, “[O]perators will sometimes share the cost of digging or deploying passive infrastructure, but will lay their own iber lines, which allows them to engage in full, facility-based competition. In these cases, there is no risk of coordination, as networks based on multiple iber lines ensure that access seekers can obtain full control over them. Under such conditions, co-investment agreements are more likely to lead to timelier and more intense competition on the downstream market.”[3]

For this, the separation between infrastructure and service must be maintained, with focus of competition at the service end with infrastructure being largely common. This is managed differently in different countries.[4]

Keeping all this in mind, we suggest that Strategies E(b) and F(c) be reworded to say, "By promoting both passive and active sharing of telecom infrastructure and resources among telecom service providers, while ensuring that doesn’t lead to a decrease in competition, and where appropriate making certain forms of infrastructure sharing mandatory."

Among the resources that require sharing is spectrum. In 2015, DoT guidelines allowed liberalised spectrum to be shared among operators.

Modernizing spectrum management

We are happy to note that the strategy of “ensuring adequate availability of contiguous, broader and globally harmonised spectrum” is listed under Strategy D(u). There are many opportunities for harmonisation of spectrum usage in India vis-a-vis global usage. For instance, currently in India, only 50 MHz of spectrum has been earmarked for unlicenced use outdoors in the 5 GHz band (5.825 GHz to 5.875 GHz). There is no rationale for this distinction between indoor and outdoor use, and this limits the usage of Wi-Fi outdoors. The US has delicensed 580 MHz in the 5GHz band which allows for the IEEE 802.11ac standard to be used on it, whereas India has only delicensed 300 MHz, whereas 1280 MHz is what is dictated by needs.[5] At a minimum 580 MHz (3x160 MHz) ought to be made available for unlicensed used.

Additionally, delicensing the 60 GHz band would bring us in line with global regimes,[6] where at least 19 countries have delicensed the 60 Ghz band for both access as well as backhaul purposes.[7]

The 60GHz band is ideal for delicensing since it there is virtually no interference since due to oxygen absorption and narrow antenna beam width the transmission distances

are short. We also need to liberalize the 70 and 80 GHz bands to enabling lower cost access for these frequencies to extend ibre connectivity where necessary by using other means, including through aerial systems.

While under Strategy D(v), TRAI proposes the “earmarking [of] unlicensed frequency bands periodically for operation of low power devices for public use”, it should instead be “earmarking unused, underused, and unlicensed frequency bands periodically for public use, with licence-exemption and light-licensing where possible, with safeguards to prevent interference”.

Even bands that have been allocated under the NFAP and licensed may lie unused or underused as well. According to a study by IIT-Hyderabad, unused TV spectrum in India amounts to between 85%-95% of the total TV spectrum. A large swath of 115 MHz — from 470 to 585 MHz — lies unused, and is available for alternative uses. Waiting for an ecosystem to develop around the 470- 698 MHz band,[8] is harming the government’s vision of Digital India and an urgent course correction is needed. As we have argued in the past, “[w]hereas Digital India needs low-cost wireless broadband, especially for long-distance links in rural India, because of the high cost and diiculty of building and maintaining ibre or wired networks in diicult terrain, and/or in sparsely populated areas. Therefore, access to TVWS needs to be bundled with BharatNet, and other shared backbone networks like ERNET.

Policies should permit diferent network design scenarios including transmission power and purpose. Point-to-point links are needed over long distances in place of ibre or microwave, and broad coverage is needed for contiguous areas like industrial developments, campuses, commercial complexes, or rural communities … TVWS does need tight radio ilters (unlike Wi-Fi) to minimise interference, the underlying consideration that drives spectrum management. There's also need for varying power speciications depending on the network design and purpose as described above, and policies for unlicensed sharing using geolocation databases, as deined by the US FCC."[9]

Further, following the lead of the FCC in the USA, and Ofcom in the UK, we in India should exempt low-power usage across all spectrum bands. The approach followed by Ofcom (which allows for powers between -90 dBm/MHz to -41 dBm/MHz (and on a sloping gradient from 10.6 GHz onwards), may be recommended. To reflect this, a strategy statement to “explore greater exemptions from licensing requirements where possible, including for low-power spectrum usage”, would be helpful.

The NTP should also lead the way in encouraging the government and the regulator to look to new ways of managing licence-exempt use of spectrum, as has been done, for example, in the UK.[10]

This allows for a movement away from power-oriented regulations to regulation on the basis of interference. For instance, shared spectrum databases may allow for coordinated usage of higher power but without interference. Further, this allows for bands to be categorized not by usage, but by transmit powers and duty cycles.

Accessibility

One of the lacunae in the NTP-12 is its lack of any policy mandate for providing accessibility for person with disabilities.[11] NTP-18 should not make the same mistake. The NTP should mandate implementation of systems that would enable better accessibility for persons with disabilities. This should include formulation of a code of good practice for manufactures and service providers, conducting surveys and gathering statistics on use of telecommunication services by persons with disabilities, etc.

Revenue maximization

We believe that Strategy D(r) (“reviewing the objectives of spectrum management to maximise socio-economic gains”) should explicitly mention that revenue maximization should not itself be a goal, since that may harm the socio-economic gains to be had from optimal usage of spectrum. We believe that it should be made explict that “ensuring revenue maximization for the exchequer will not be the main aim of spectrum management policy”.

Auctions, which ind mention in TRAI’s recommendations, ne — to favour a model of revenue sharing[12] — and at the least they need to be structured in such a manner as to avoid the “winner’s curse”.[13] Revenue-sharing, which was followed after NTP-99, allows for a more sustainable form of revenue generation for the government, while having transparent allocation systems or auctions designed in a manner not oriented towards maximizing the generation of auction proceeds for the government.[14] Just as increasing the USO fund by itself cannot be a goal — ensuring universal service is the goal — similarly, the generation of tax revenue by itself cannot be a goal.

Patents pools, local manufacturing, and cost of devices

Under “Strategies to become net positive in international trade of telecommunication systems and services”, the consultation paper proposes inancial incentives for development of SEPs, as well as “incentivising local manufacturing of network equipment and devices” as strategies. One concrete strategy to incentivise local manufacturing of telecommunications equipment and devices is to create government-controlled patent pools,[15] which can be used to ensure that patent-holders are paid a royalty on SEPs while also lowering the transaction costs and legal uncertainty for local device manufacturers, and ultimately lowering the price of devices for customers.[16]

Private patent pools do not suiciently take care of the legal risks created to manufacturers. If government intervention is not done, then Indian manufacturers will end up embroiled in legal battles as we have seen with Micromax, and others. CIS has provided a very detailed submission on TRAI’s Consultation Paper on Promoting Local Telecom Equipment Manufacturing.[17]

Internet connection and data centres

While under “Strategies to establish India as a global hub for data communication systems and services”, the problem of Internet interconnection is brought up, but the strategies don’t mention what needs to be done. One of the problems facing India currently is a low level of peering interconnection agreements and a high cost of transit interconnection agreements. This results in a higher cost of Internet for everyone. This needn’t be so. The NTP could establish that there should be no licensing required for running an interconnection point. Currently, there is a lack of clarity on the matter, with contrary suggestions having been provided by Trai in the past. Further, the NTP and that existing interconnection exchanges like NIXI should not discriminate between licensed telecom operators and unlicensed content providers, since it is crucial that the latter also be present at interconnection exchanges, and interconnection exchanges will not lourish unless the hurdles put in place, which favour incumbents, are reduced.

It is worrying that TRAI has suggested establishing a “licensing and regulatory framework for cloud service providers” (Strategy H(a)). While cloud service providers are subject to the regulations provided in the IT Act, and other legislations in India, they currently are not subject to any licensing requirements. No rationale has been provided by TRAI for this suggestion, and it would kill innovation in the sector, and would inhibit the emergence of India as a global hub for data communications systems and services. Similarly, while an overarching data protection and security legislation needs to be in place, the suggestion of a “licensing and regulatory framework for IoT/ M2M service providers” (Strategy G(a)) is worrying, and there is no suitable rationale for having licensing in this space, which will only serve to curb innovation without any corresponding or suitable benefit accruing to the public.

Given that telecommunications isn’t an end in itself, but is a means to an end, one of the missions of the NTP could be:

To enable inclusion through the provision of telecommunications infrastructure and services that is accessible for all, especially for the most marginalized, including those who are disabled, those who live in remote areas, those who are illiterate, scheduled castes and scheduled tribes, women, and transgender communities.

Once again, we are grateful to TRAI for having provided this opportunity to comment.

[]. GSMA, “Mobile Infrastructure Sharing,” 2008, https://www.gsma.com/publicpolicy/wpcontent/uploads/2012/09/Mobile-Infrastructure-sharing.pdf.

[]. José Carlos Laguna de Paz, “How Cooperation Between Telecom Firms Can Improve Efficiency,” The Regulatory Review, June 25, 2015, https://www.theregreview.org/2015/06/25/laguna-telecoms-cooperation/.

[]. Ibid.

[]. Jan Markendahl, Amirhossein Ghanbari, and Bengt G. Mölleryd, “Network Cooperation between Mobile Operators : Why and How Competitors Cooperate?,” in DIVA, 2013, http://urn.kb.se/resolve? urn=urn:nbn:se:kth:diva-134358.

[]. Parag Kar, “Response to TRAI’s Consultation Paper on Proliferation of Broadband through Public Wi-Fi Networks” (Qualcomm, August 10, 2016), http://www.trai.gov.in/sites/default/files/201609011022542916621Qualcomm_india_pvt_ltd.pdf.

[]. See ITU-R Report “ITU-R M.2227 (11/2011)” and ITU-R Recommendation “ITU-R M.2003-1 (01/2015)” on “Multiple Gigabit Wireless Systems in frequencies around 60 GHz”.

[]. Broadband India Forum, “V Band - 60 GHz: The Key to Affordable Broadband in India” (Broadband India Forum, 2016), http://www.broadbandindiaforum.com/img/White%20Paper%20on%20V-BAND%20Revised%20Final.pdf.

[]. Varun Aggarwal, “DoT Says No to Releasing TV White Space Spectrum, Clarifies It Is for Experiments,” The Hindu Business Line, June 16, 2016, http://www.thehindubusinessline.com/info-tech/dot-says-no-to-releasing-tvwhite-space-spectrum-clarifies-it-is-for-experiments/article8737575.ece

[]. Shyam Ponappa, “The Buzz around TV White Space,” Business Standard, November 4, 2015, http://www.businessstandard.com/article/opinion/shyam-ponappa-the-buzz-around-tv-white-space-115110401618_1.html.

[]. “Better Managing Licence-Exempt Usage,” Ofcom, October 7, 2016, https://www.ofcom.org.uk/research-anddata/technology/radio-spectrum/exempt.

[]. Snehashish Ghosh, “National Telecom Policy 2012 — Issues and Concerns,” The Centre for Internet and Society, June 30, 2012, https://cis-india.org/telecom/national-telecom-policy-2012.

[]. David E. M. Sappington and Dennis L. Weisman, “Revenue Sharing in Incentive Regulation Plans,” Information Economics and Policy 8, no. 3 (September 1, 1996): 229–48, https://doi.org/10.1016/0167-6245(96)00010-8.

[]. Shyam Ponappa, “Richard Thaler’s Views on Auctions,” Business Standard, November 1, 2017, http://www.business-standard.com/article/opinion/richard-thaler-s-views-on-auctions-117110101558_1.html.

[]. Shyam Ponappa, “Breakthroughs Needed for Digital India,” Business Standard, April 6, 2016, http://www.businessstandard.com/article/opinion/shyam-ponappa-breakthroughs-needed-for-digital-india-116040601241_1.html.

[]. Sunil Abraham, “Letter for Establishment of Patent Pool for Low-Cost Access Devices through Compulsory Licenses,” The Centre for Internet and Society, accessed January 19, 2018, https://cis-india.org/a2k/blogs/letter-forestablishment-of-patent-pool-for-low-cost-access-devices

[]. Nehaa Chaudhari, “Pervasive Technologies: Patent Pools,” The Centre for Internet and Society, accessed January 19, 2018, https://cis-india.org/a2k/blogs/patent-pools

[]. Anubha Sinha, “Comments on TRAI’s Consultation Paper on Promoting Local Telecom Equipment Manufacturing” (Centre for Internet and Society, November 13, 2017), http://www.trai.gov.in/sites/default/files/CentreInternetSocietyIndia_CP_PLTEM.pdf.

For more details visit https://cis-india.org/telecom/blog/submission-to-trai-consultation-on-inputs-for-formulation-of-national-telecom-policy-2018

Stranded Capacities & Greater Expectations

Shyam Ponappa — 2015-06-22T01:56:34Z

India's infrastructure is in a shambles because of stranded capacities that don't connect with unmet needs. Every aspect of infrastructure, such as electricity or broadband for communications, needs to be designed and executed to flow through from end to end.

The post was published in Organizing India Blogspot on May 8, 2015. It was earlier published on May 6 in the Business Standard.

The remarkable change in expectations from last May that the National Democratic Alliance (NDA) government achieved appears to be giving way to closer scrutiny based on actual performance. Meanwhile, the wait for significant economic reforms is excruciating.

A couple of indicators of uneasiness: foreign institutional investors (FIIs) have turned watchful, with investments in equity and debt slowing after sustained inflows. (See Chart 1).

Also, while some leading businessmen have been saying everything is on track, industry credit growth is slowing relentlessly, as is to be expected when demand is muted, infrastructure is dysfunctional and credit is expensive. (See Chart 2).

The flurry of claims, accusations, rebuttals and counter-claims about earlier growth rates dwell on reclaiming the past, with little evidence of seeking clues to generate momentum and confidence. This may be attributable partly to the curse of our times: a penchant for headline-grabbing or headline-making. There is scarce interest in less flamboyant, fact-based presentation - whether it is politicians, TV and print media, or the audience, the general public. This may also be partly attributable to inept communication, a malady that seems to plague this regime despite its vaunted communication skills as much as it did the United Progressive Alliance (UPA) before it. Perhaps the Web can be better used to not only organise and coordinate within and across ministries, but also to disclose information while building convergence and confidence.

Consider some points that stand out from the clamour. One is that insufficient attention is directed towards cohesive policies, processes and institutions. On the face of it, there do appear to be several efforts at policy reform, for instance, in land and labour legislation, as well as in judicial reforms. There are critiques, however, suggesting that these stand-alone efforts suffer from insufficient resource allocation and ineffective implementation. The implication is that there is an absence of overarching vision and flowing from that, a lack of direction and integration.

Are constructive alternatives possible?

Last week's observations by former NDA minister Arun Shourie highlighted this apparent lack of vision, and how the government seemed to be dealing with the many problems like pieces of a jigsaw puzzle without an appreciation of the big picture. For example, the government's actions relating to coal and spectrum auctions are merely in line with court orders. There is no apparent effort to develop constructive alternatives in the public interest.

From a societal perspective, surely the government, the courts and the public need to ask: for whose benefit and at what cost? For instance, how are upfront government revenues from auctions beneficial to the public if they result in non-delivery or a slowdown of requisite services, compared with much larger collections over time from enterprises that deliver services after criteria-based allocations?

Note: revenue sharing can also be transparent. For transparent allocations, one alternative is to draw up technical and financial shortlists with integrity, followed by a lottery (with equal integrity). Another possibility is merit-based, open criteria judged by individuals with understanding and integrity - as was done to affect a breakthrough for land acquisition for the Calcutta Metro in 1982 and for part of the Bengaluru Metro in 2006. Both were achieved effectively without controversy by officials (or, to use the customary pejorative, "bureaucrats") entrusted with the responsibility. These individuals could be consulted.

Cohesive Leadership

An elephant in the room is the NDA's socially divisive stance. If the goal is high achievement, the need for convergent effort from our diverse, vast population is a no-brainer. Strong leadership resulting in cohesive effort is essential. The misgivings created so far must be addressed and reversed. If not attempted now, it will be a tremendous opportunity squandered.

There will be, of course, many impediments to achieving convergent efforts. And the dissonant legacy structures - such as realigning the judiciary and executive to constructive engagement, a constructive welfare net in place of Mahatma Gandhi National Rural Employment Guarantee Act, formulating truly beneficial policies for our needs instead of aping detrimental auction models - will be difficult to replace.

It is likely that we will continue in our shambolic ways, depriving ourselves of the gains of organisation and productivity. Yet there is the tantalising possibility of great gains if we were to have the right leadership, and if we could ourselves rise to the occasion.

Infrastructure

Another elephant in the room is our atrocious infrastructure. Successive governments and all parties have foundered on this. Empty talk of "second-round" reforms and so on betray a complete lack of understanding of the elements of essential, enabling infrastructure. At the most basic level, electricity, communications, transport and logistics, water and sewerage/waste disposal are fundamental requirements for productive living. These must be the relentless focus of end-to-end delivery systems.

The reforms in power and communications since 1991 were encapsulated sub-processes, as in Chart 3. Each of the boxes is a complex process in itself, and each has its position in the process flow as shown. Electricity reforms relate to fuel, generation, transmission, distribution and cash collection. Unless all steps in the chain are completed, we will be left with stranded capacities in one or more of these "boxes", like stranded generation plants, as we have been so far.

For broadband communications, the areas are the access, aggregation and the core or backbone networks. The most difficult are the last-mile links in access networks. Elements like the National Optical Fibre Network (NOFN) backbone are stranded unless they are connected with aggregation networks that lead to last-mile access, which could be a wireless, cable, telephone wire, or an electricity link. The system must be designed in its entirety to deliver.

What began the information technology services revolution was facilitating every link in the chain from one end to the other, with permissions, incentives and tax cuts, even if it was only a "thin pipe", 64 kbps link that bypassed initial hurdles for a start. The government could consider variants that could work for each infrastructure sector.

For more details visit https://cis-india.org/telecom/blog/business-standard-op-ed-may-6-2015-shyam-ponappa-stranded-capacities-and-greater-expectations

Spectrum reforms - Good & Bad news

Shyam Ponappa — 2012-07-26T10:02:48Z

A good initiative is under way, but needs changes to work out complex issues, writes Shyam Ponappa in this article published in the Business Standard on May 5, 2011.

There’s some good news, and yes, some bad news… The good news is that momentous developments are under way in spectrum and telecom policy:

The Ministry of Communications & Information Technology held consultations with service providers, then posted the transcript on the Department of Telecommunications (DOT) website.
The Wireless Planning & Coordination Wing (WPC) disclosed data on all commercial spectrum allocations – frequencies allotted by geography and service provider or operator – on its website.

Terrific first steps in a constructive approach. There’s more: the ministry’s report of 100 days states: "We will hold consultations with key stakeholders to evolve a clear and transparent regime covering licensing, spectrum allocation, tariffs or pricing, linkage with roll out performance, flexibility within licenses, spectrum sharing, spectrum trading, MVNOs, unlicensed bands, M&A, etc, in a technology agnostic environment after due consideration of Trai recommendations in this regard. Interest of the 'aam aadmi' would be the prime consideration." That’s comprehensive alright, which is good, though the 'aam aadmi' bit is either confused or manipulative. Elected governments should act in the public interest, no more, no less. While the private sector is exhorted not to play games, the government at all levels – politicians, administrators and agencies – must also focus on results, and avoid populism.

Display & Presentation

The presentation of information could be more effective for the patterns and structure to be easily accessible. The WPC display is of voluminous raw data. There is no overview, with the ability to drill down to details, nor to aggregate details by operator or frequency. The full set runs into 32 pages of tables (Figure 1).

Compare this with a display in colour from the US’ National Telecommunications and Information Administration (Figure 2). Similar information from the WPC runs into many pages.

Figure 2: Fragment of Allocation Chart (USA)

Source: http://www.ntia.doc.gov/osmhome/allochrt.pdf

However, the US display contains not as much detail, and has no interactive capabilities (these are possible extensions). For an interactive graphical interface, consider the “market map” by Moneycontrol.com for stocks (Figure 3, left).

One can drill down in any sector by clicking on the rectangle. For example, “Telecommunication”, which opens a map with the listed companies, each colour-coded to reflect more detail (green for gains, red for losses).

Clicking on a company shows its daily price and volume chart (Figure 3, right). In a variant (at Smartmoney.com), it opens a menu with access to details like news, financials and so on. Similar spectrum displays could show, for example, information by operator for network rollout and subscribers by frequency.

Figure 3: Market Map of Stocks (Sectors) Companies

Source: http://www.moneycontrol.com/mcplus/marketmap/nse/marketmap.php

An alternate display format is the “Topics most commented on” on The Economist's website.
When the cursor hovers on a topic, related comments are displayed. Clicking on a topic realigns the clusters based on content around that topic, as for India in Figure 4.

Figure 4:

Source: http://www.economist.com/conversation-cloud?days=30

This would work well for aggregating comments on related issues in the consultation transcripts.

Imagine what such a graphical interface to a relational database could do for effectiveness and transparency in spectrum policy. It could be extended to telecom and broadband next, and, eventually, to all of government.

The Bad News: Process Limitations

Judging from news reports, process inadequacies might render the ministry’s grand intentions unachievable. The following examples show why.

- Spectrum sharing is an obvious solution for high demand with limited supply. The DoT has reportedly considered it for years, but discussions so far have been superficial and on "excess spectrum". Also, the statements of intent on sharing or trading are confusing. "Spectrum trading" implies exclusive rights to spectrum, unless otherwise specified. "Spectrum sharing" means aggregating spectrum for redeployment, with Dynamic Spectrum Allocation. This is analogous to “common carrier access” and “big pipes” for railways, roads, oil pipelines, or airways. Therefore, from a policy perspective, spectrum sharing and spectrum trading are mutually exclusive.

Spectrum and airways or flight paths coexist in the atmosphere. Imagine if airways were auctioned to each airline for its exclusive use, instead of being available to all airlines for similar aircraft through Air Traffic Control. That’s what we have with spectrum auctions in communications. The logic for spectrum auctions is based on old technology with no allowances for improvements in managing interference in the last 60-70 years. Also, allocating spectrum in this way means that aggregate capacity is constrained for two reasons. One is that each operator uses only part of allotted capacity. A study in Singapore in 2008 found that only two bands had a utilisation rate of 50 per cent; the overall utilisation rate for 80-5,850 MHz was about five per cent (Figure 5).

Figure 5: Average Occupancy of Frequency Bands in Singapore

Source:http://goo.gl/qVyBv

Second, a large band provides much greater capacity than the sum of smaller bands.

Our spectrum predicament arises primarily from inappropriate allocation policies. Therefore, forward-looking policies need the incorporation of a technical understanding of spectrum occupancy, of the effects of spectrum aggregation versus fragmentation, and of technologies like multiple antenna effects (multiple-input and multiple-output, or MIMO), which enable more effective spectrum use and improve functional attributes of higher frequencies. A backward-looking audit of historical data will not serve these purposes.

Another damaging effect is the move to extract spectrum from Defence to auction to the private sector. The rationale apparently is the high revenues the government can collect. This cannot be in the public interest, especially since the alternate optical fibre network to have been built by BSNL is still not ready.

Decisions on issues like the desirable number of operators per circle need an objective rationale. No data have been offered contrary to the UK Ofcom’s findings of maximum welfare at three to four operators.

An inherent limitation of the consultation-and-pronouncement approach (as opposed to a collaborative-stakeholder-workout) is that external expertise in technology and process consultation, sorely needed in India, has to be brought in only by the government. This must be done before formulating new policies, because the issues are too complex to resolve without objective expertise.

Read the original blog post here
For article published by Business Standard, click here

For more details visit https://cis-india.org/telecom/blog/spectrum-reforms