Response to TRAI Consultation Paper on Auction of Spectrum in frequency bands identified for IMT/5G (CP)

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Response to TRAI Consultation Paper on Auction of Spectrum in frequency bands identified for IMT/5G (CP)

Deepak Arora

@deepakarora

January 21, 2022

Public Policy

318

We recently submitted our feedback on the TRAI Consultation Paper Auction of Spectrum in frequency bands identified for IMT/5G (available here). Our response to the paper was largely focussed on the aspects dealing with the deployment of 5G/LTE NPNs (Non-Public Networks) and its licensing framework. In the paper, TRAI has broadly recognized two high-level approaches for enabling the deployment of 5G/LTE NPNs viz.,

Meeting the Demand for 5G/LTE NPNs through Licensed TSPs: Under this model the TRAI envisages: (i) the provision of NPN ‘as a service’ by existing TSPs, (ii) TSPs deploying NPN infrastructure to utilize portions of their existing spectrum holdings, or (iii) TSPs sub-leasing their spectrum holdings for the creation of NPNs.
Utilizing Unlicensed Spectrum or Earmarking of Licensed Spectrum for NPNs: Under this model the TRAI envisages the utilization of unlicensed spectrum by enterprises for the deployment of NPNs, or the earmarking of bandwidths in licensed spectrum bands, specifically for the deployment of NPNs.

NPN as a Service provided by TSPs

We mentioned that investments in NPN infrastructure and spectrum is likely to be a viable strategy for select industries. Therefore, the first approach of enabling TSPs to serve the existing demand for NPNs, by providing NPN as a service, is likely to serve wider sections of the industry, who may not have the resources or know-how to deploy and manage NPNs.

Currently, there is nothing in the extant regulatory and licensing framework that prevent TSPs from designing and offering services that they believe will address enterprise requirements. Therefore, the extant licensing framework is adequate for enabling TSPs to utilize spectrum licensed to them to offer managed NPN services through techniques such as “network slicing.” However, it would be unrealistic to expect that this approach alone, can serve the entire demand for enterprise NPNs for enabling Industry 4.0 use-cases in India. Accordingly, we suggested that the TRAI should consider a combination of all the approaches considered in the CP, with a special emphasis on direct licensing of earmarked spectrum to enterprises.

Sub-Leasing of Spectrum

We mentioned that given the simultaneous demand for consumer 5G applications, the pool of spectrum bands available for sub-leasing to enterprises for NPN deployments is likely to be limited. Moreover, given that sub-leasing is likely to be limited to Licensed Service Areas (LSAs) where the TSP holds spectrum utilisation rights, enterprises that are national in scale may need to lease spectrum from multiple TSPs. Even if reasonable leases could be negotiated enterprises may be left working with a patchwork of spectrum band with multiple TSPs, thereby adding additional complexities in the process of enterprise level network integration. We therefore suggested, TRAI should consider adopting a light-touch approach enabling TSPs to negotiate sub-leasing arrangements with enterprises and as such, there should not be any prior approval requirements.

Earmarking of Spectrum for NPNs

Greater control over network design and spectrum management are crucial enablers for the success of NPNs across a diverse and constantly evolving set of end-use requirements. Therefore, direct licensing of earmarked spectrum, is likely to enable greater number of use-cases for NPNs, while also providing certainty to enterprises on the availability spectrum access for the duration of the licenses.

By enabling enterprises to directly obtain licenses for spectrum use, spectrum usage can be tailored to enterprise-specific needs over a delimited geographic footprint that corresponds to their business premises. Further, and as rightly acknowledged by the TRAI, this approach is also likely to enhance spectrum utilization by promoting shared usage amongst enterprises. Therefore, and given the limitations of the other two approaches, and the competing requirements for consumer applications over public networks, and enterprise applications over NPNs, the earmarking for dedicated frequencies in the mmWave and mid-Band spectrum is likely to be the best suited strategy for accelerating the deployment of NPNs.

Copy of submission is enclosed. Kindly write to deepak@nasscom.in, for any questions/ clarifications.

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