IAFI supports allocation for NGSO spectrum in Ku/Ka, auction for D2D

The ITU-APT Foundation of India (IAFI), strongly supports TRAI’s initiatives to establish an equitable, transparent framework for spectrum allocation, aligning with the rising significance of satellite-based communication systems in India’s national connectivity and socio-economic landscape. With their capacity to provide coverage in remote and underserved areas, satellite systems are a vital part of India’s digital infrastructure roadmap.

A significant advocate for innovation and digital transformation in India’s telecommunications sector, IAFI has just released a detailed response to the TRAI Consultation Paper on “Terms and Conditions for the Assignment of Spectrum for Certain Satellite-Based Commercial Communication Services.”

IAFI’s response emphasizes the role of both Non-Geostationary Satellite Orbit (NGSO) and Geostationary Satellite Orbit (GSO) constellations in delivering essential high-speed broadband, mobile services, and disaster-resilient connectivity. Such services are especially needed in areas where traditional terrestrial networks struggle to reach due to geographical constraints. Below are the key aspects of IAFI’s response to the TRAI consultation.

Key Recommendations from IAFI
Spectrum Assignment Framework: Prioritizing Fairness and Efficiency
IAFI supports an administrative approach to spectrum allocation for Fixed Satellite Services (FSS), especially where critical applications like defense and disaster resilience are concerned. However, in cases where exclusive spectrum is essential—such as with direct to device satellite services using IMT bands—a selective market-based mechanism may be appropriate.

To prevent predatory pricing practices and support fair competition in the satellite market, IAFI advocates for carefully structured spectrum pricing models, particularly in segments where satellite services compete directly with terrestrial networks such as with direct to device satellite services using IMT bands. This ensures that spectrum policies foster a level playing field across both public and private stakeholders, meeting strategic and national security requirements while stimulating healthy market competition. IAFI also encourages a regulatory approach that avoids unnecessary market concentration and promotes a diversity of operators across NGSO and GSO platforms.

Adaptive Spectrum Charging for Diverse Use Cases
IAFI calls for a flexible, tiered spectrum charging model that considers the different operational contexts for satellite-based services. Recognizing the unique public benefit of satellite systems, IAFI suggests a nominal or even zero-charge approach for traditional applications, such as government, defense, and rural connectivity, which are essential to national infrastructure. By contrast, fees for more commercially oriented uses could reflect their potential for revenue generation. This structure would enable service expansion in underserved regions without imposing excessive financial burdens on providers.

For NGSO systems, flexible pricing is essential, and IAFI emphasizes parity between GSO and NGSO spectrum fees to avoid arbitrary pricing differences based on orbit type. IAFI endorses an Adjusted Gross Revenue (AGR) based fee model for NGSO operations, recommending a cap of 1% to maintain a fair spectrum valuation. This approach aligns with India’s regulatory objectives and supports efficient use of shared satellite and terrestrial resources.

License Validity and Satellite Access Authorization
In IAFI’s view, a 20-year spectrum license term is necessary for supporting the stable, long-term investment commitments required by satellite operators. This extended validity aligns with the operational lifecycles of most satellite constellations and provides a secure regulatory environment conducive to sustainable growth and innovation. Recognizing the dynamic nature of this sector, however, IAFI also supports shorter validity options, such as a three-year initial term, which could facilitate faster rollouts for emerging satellite technologies.

To streamline authorization, IAFI proposes a specific Satellite-based Access Authorization for NGSO Mobile Satellite Services (MSS), setting them apart from traditional VSAT licensing.

Optimal Frequency Band Utilization for Gateways and User Links
IAFI highlights the importance of globally harmonized frequency bands for efficient satellite communication. The Ka and Ku bands are deemed optimal for NGSO Fixed Satellite Services (FSS), offering a balanced combination of high-speed data rates and low latency. These bands are particularly suited to NGSO systems like Starlink, Telesat, and OneWeb, which operate in environments that require both high capacity and reliability.
BCS Bureau