Offering excessive spectrum resources in the upcoming 5G auction will result in Indian citizens being denied the benefits of high-demand, advanced satellite broadband services and risk lost GDP increases per annum to India’s economy of up to USD 184.6 billion by 2030 and associated FDI and employment generation benefits.
The impact of the loss of C-band spectrum in the 3.6-3.67 GHz band alone will be felt across the entire INR 700 Bn Indian broadcasting industry carrying 900+ registered channels to 21 Cr Households in urban and rural India through ~1730+ digital platform operators and 50000+ cable operators, provides direct and indirect employment to 1.83 M people.
It is important to note that 5G advances are not unique to terrestrial networks. Satellite broadband is already using many of these advances and has been doing so for many years. The ability of satellite-based services to provide connectivity to unserved and many other underserved areas is demonstrated amply, and the solutions are available now instead of IMT alternatives with a multi-year rollout period.
The international best practice for rationally planning spectrum use for different applications examines alternative uses to identify which use maximises the value of that spectrum. Anil Prakash, Director General SIA-India said, “We consider it important to recognise the current situation in terms of spectrum supply and demand and to adopt a more balanced approach in auctioning of the spectrum bands, taking into consideration the needs of various sectors as well as to ensure efficient take-up whilst generating a reasonable value to the Government.”
Given that more than 120 countries expressed their intention to follow the ITU decisions and preserve the 27.5-31 GHz and 17.7-21.2 GHz bands for satellite broadband services, this global consensus reaffirmed maintaining the 27.5 GHz and above for FSS. Europe’s “5G Roadmap” re-affirms this determination, recognizing the critical nature of this spectrum for satellite broadband, and explicitly stating its policy: “Signal clearly that Europe has harmonised the 27.5-29.5 GHz band for broadband satellite and is supportive of the worldwide use of this band for ESIM. This band is therefore not available for 5G”
SIA-India, in their submission, has urged TRAI to limit the inclusion of mm Wave spectrum in any 5G/IMT auction to the internationally harmonized 24.25-27.5 GHz spectrum. The 3.25 GHz of spectrum available is more than adequate to meet any of the nascent, still uncertain 5G/IMT requirements for mm Wave spectrum. The 300 MHz of spectrum in the 3.3-3.6 GHz band identified in the NFAP 2018 provides enough spectrum to satisfy India’s mid-band 5G requirements while ensuring a competitive auction. With three private mobile network operators (MNOs) accounting for 90% of the market, each of them would be able to secure 80-90 MHz while leaving 30-60 MHz for the state-owned MNOs that account for the remainder of the market.
It is important to ensure that the 5G operations do not interfere, impact or hamper the existing operations of satellite services. Mitigation measures like band pass filters are NOT a standalone solution and are effective only when applied with a suitable guard band and emission limits on the high levels of 5G transmissions compared to the earth station receive signals.
Providing excessive spectrum for 5G poses the risks of the spectrum being unsold or, even worse, underutilised by terrestrial players at the expense of other players such as Satellite Operators. These outcomes will result in a costly regulatory failure for India through loss of substantial overall economic opportunities. The time has come when the regulatory framework needs to support deployment of satellite services in adequate and efficient manner vis-à-vis other services, for India’s space sector to grow and citizens benefit with multiple service options.
