Satcom disruption-The LEO players are buzzing

Christopher McLaughlin
Chief of Government, Regulatory Affairs and Engagement
OneWeb Communications Ltd
“OneWeb believes a new licensing framework is required especially for reflecting the latest technological advances made in the Non-Geo Stationary Orbits satellites Non-Geostationary (NGSO) Satellite systems. Currently spectrum for gateway are licensed per antenna, such an approach has impeded the development of NGSO systems owing to the imposition of onerous fees on the operation of the multiple antennas required for certain NGSO ground systems such as gateways. Licensing earth stations that comprise a structured array of antennas as a single antenna would be more aligned with the opportunity cost of spectrum, for which a co-located array of antennas, using the same frequencies, does not deny more spectrum from other users than a single antenna would. This gateway licensing approach has been adopted in many countries around the world. For example, the US considers that

Multiple antennas in an NGSO FSS gateway earth station complex located within an area bounded by one second of latitude and one second of longitude may be regarded as a single earth station for purposes of coordination with terrestrial services.

We would also like to see a provision for generic or blanket licensing for VSAT and ESIM within the FSS for satellite applications. An adoption of national regulatory regimes that consider generic or blanket licensing would greatly simplify the administrative burdens of government, operators, service providers, and users alike. European administrations for example, through several ECC Decisions, have adopted a set of technical and operational principles for blanket licensing that eliminate the need for individual licensing of two-way earth stations, whether for fixed or mobile applications”.

Praveen Sharma
VP & Regulatory Affairs
Tata Communications Limited
“The Indian service providers, licensed by DoT and MIB, should be allowed to contract directly with foreign satellite providers, without any inhibitions, for promoting ease of doing business. This is particularly in context of new satellite technologies like LEO and MEO, which can be crucial in proliferation of broadband as well as low bit rate applications like IoT, which is a subject matter of this consultation.

We also appreciate that TRAI in this consultation paper has also focused on reduction of charges payable by way of levies, which has inhibited the service providers from using the satellite communication technologies. We fully support that the levies should be collected from service providers only up to the extent of recovering administrative costs; these should not be treated as a source of revenue for the exchequer.

For creating a conducive regulatory framework, a single window system should be created for granting approvals for using the satellite bandwidth by the licensed telecom service providers, so that they do not have to approach multiple departments for securing approvals.”

“All of the satellite services should be covered under a single authorization. As the satellite services authorization can provide backhauls to access service providers, it is of little relevance to permit NLD service providers to deploy satellite networks under the NLD authorization. Suitable time should be given for existing service providers using the NLD authorization to migrate satellite networks into the satellite services authorization. So the choice available to service providers are satellite Services authorization if no public switched voice is to be provided and GMPCS authorization if a public switched voice is to be provided. Similarly, the access service authorization can also be dealt in the same way as in the satellite context LSAs do not make any sense.” Hughes

Rahul Vatts
Chief Regulatory Officer
Bharti Airtel Limited
“We also strongly believe that the time has come for the TRAI and DoT to recommend bold reforms by bringing clarity on licensing, procedures, gateway/earth stations, reduction in costs. It is also important since the TRAI paper recognises that in some of the existing licenses for satellite services, there have been hardly any players in last two decades. This makes it imperative to identify bottlenecks and allow growth of services.

In this background, we submit that:
• There is a need to simplify licensing for satellite connectivity based services specially in wake of opening of space sector for private participation.
• The GMPCS license is the most suitable national authorisation under the Unified License (UL)that has a fully relevant scope. Its current scope permits all types of voice, text and data services that means it includes low-bit rate applications.
• The NLD license is also a suitable license to offer satellite based low bit rate applications. Wherever necessary, further clarity may be provided in scope of other such licenses as well.
• LEO constellations hold one of most promising potential for connectivity solutions through higher throughput and low latency.
• The Hybrid (LPWAN + Satellite) model offers best opportunity for ecosystem to flourish.
• Satellite providers should have flexibility to offer bandwidth and work with Telecom (Mobile/Fixed) operators on aggregating the sites traffic and carry data over backhaul wherever feasible on mutual commercial basis.
• Restricting the scope of Satellite based services to a specific data service like ‘IoT services’ will be inefficient application. This should be left with service providers. As regards existing licenses, the GMPCS covers data services as well so that would include low-bit rate services • Contiguous and harmonised spectrum in sufficient quantity be made available as per national frequency allocation plans. The system of advance publication, coordination and notification under the ITU Radio Regulations should be followed. The DoT and DoS should introduce a mechanism involving flexibility to seek information in order to ensure that the project for which the applicant has applied is real and progressing to bring into use the assignments in the national ITU filings.
• The entire process for approval of satellite based licensing should be online with a single window clearance (all ministries and departments) and within a defined timeframe. This must include license and clearance for gateway and land earth stations preferably 60 days).
• To reduce the cost of bandwidth, the multiple charges (NOCC, SACFA and other WPC charges) should be unified and made to recover only administrative cost of license. We believe that the Authority should consider these inputs while making its recommendations on the subject.”

“To keep up its position in the global market, India needs participation in the satcom space both from the public as well as from the private sector. In fact, it is believed that vigorous private competition is needed here similar to that in the telecom sector, where it enabled huge customer benefits, market growth and drastic reduction in prices (much below the global benchmarks).

Another important issue is the lack of freedom for free market forces to operate, which will ensure direct negotiation between the buyer and seller (from approved/authorised satellites). This will enable healthy competition and better choice for the buyer, thereby helping bring down the prices and also improve quality of service.

The sector also suffers from the high price of satellite capacity which primarily stems from lack of adequate competition and lack of sufficient use of latest technologies viz. Ka band, High Throughput Satellites (HTS) as well as use of latest technologies like NGSO (Non-Geo Satellites viz. LEO/MEO/HEO, etc.) Technologies, flexible payloads, flat panel antennas, etc.

Many benefits can accrue to the satcom sector if policy liberalisation, permission of interplay of market forces between buyer and seller, ease of doing business, simplification of licensing framework and rules and permission for infra sharing between the VSAT CUG services and the NLD services particularly in rural, remote and geographically challenging terrains are permitted.

It is necessary that DoT sets out a clear time frame for issuance of license and clearance for gateway and land earth stations. Currently these approvals take inordinately long time. In order to promote ease of doing business, it is urged that DoT and ISRO be asked to work together and specify a clear time frame of say 60 to 90 days for final clearance.

Reduction of NOCC charges, Spectrum Usage Charges and other levies too need to be reviewed. BIF has several times during earlier consultations, recommended that SUC may be brought down to cover the cost of administration which barely amounts to 0.1 or 0.2 percent of the AGR.” Broadband India Forum