Feedback on TRAI Consultation Paper on Assignment of Spectrum for Space-based Communication Services

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Feedback on TRAI Consultation Paper on Assignment of Spectrum for Space-based Communication Services

Vertika Misra

@vertika@nasscom.in

June 2, 2023

Public Policy

251

In April 2023, the Telecom Regulatory Authority of India (TRAI) released a Consultation Paper on “Assignment of Spectrum for Space-based Communication Services” (Paper) soliciting feedback from the public on the draft. On June 1, 2023, nasscom submitted the feedback on the Consultation Paper.

It its feedback, nasscom submitted that satellite spectrum unlike terrestrial spectrum can be shared amongst multiple service providers without diminishing what is available to others. Due to its non-exclusive nature, existing well-established administrative route is the most efficient method of allocation.

We stated that there is fundamental technical difference between satellite and terrestrial spectrum that results in satellite spectrum not being exclusively assigned as opposed to terrestrial spectrum. Nasscom in its response to TRAI on the consultation paper on regulating converged digital technologies and services – enabling convergence of carriage of broadcasting and telecommunication services has already submitted this. This has been the prevailing standard for the allocation of satellite spectrum in India and worldwide

Satellite services primarily address connectivity challenges, especially in areas where terrestrial networks have proven economic or technical limitations. Satellite networks complement terrestrial services hence, they should not be considered mutually substitutable. Thus, the spectrum assignment and pricing approach for both must be treated differently.

Globally too, administrative allocation of satellite spectrum is the only approach because:

satellite spectrum is given on a non-exclusive basis; and
being a shared resource, it requires global coordination.

India, along with 192 other countries, is a member of the ITU. Satellite systems must be internationally coordinated as per relevant ITU Regulations to avoid harmful interference to radio services of other countries.

Further, we believe satellite spectrum should be administratively allocated because auction route can impact India’s space sector in the following ways:

Create artificial limitation of the number of satellite operators sharing spectrum and impact services like broadcasting and broadband.
Create entry barriers, and limit participation in the Satcom sector to only a few players. Auctions are expensive and for many small players, making such heavy investments in an auction may not be feasible.
Limiting the entry of players, would also impact competition in the market of space communications.
Hamper innovation, research & development ecosystem which will have an overall adverse effect on the country’s space sector.
Not aligning with the global practice of administrative allocation of satellite spectrum may discourage foreign investments.
Costs for end-consumers may increase and thereby limit the availability of services, especially in remote locations.

Please see the attachment for our detailed submission and recommendations. For more details, please write to Vertika Misra at: vertika@nasscom.in and Sudipto Banerjee at: sudipto@nasscom.in with a copy to policy@nasscom.in.

Satellite Communication Telecommunication Spectrum Auction

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Vertika Misra

Director - Public Policy