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BIF Recommendations on Satcom for NTP NTP-2018: BIF SUBMISSION ON SATCOM ( Pt. of Capsule 5 ) Anchor Principle: Enhance the role of satellite communications for accelerating “ Broadband to All “ Preamble It costs ten to twenty times more to connect the last 10-20% population of any country, including India. Satellite communication helps connect this last 10-20% population in a very cost-effective way. The satellite service providers licensed by the Department of Telecom have an installed base of more than 250,000 terminals. They serve as the communication backbone to the banking industry, large distributed enterprises, small and medium businesses who are dependent on the internet for conducting their business (including filing of GST returns), other telecom service providers who use satellite as a backhaul medium to expand their coverage to the rural and difficult terrain areas and lastly the Government itself for the rollout of various social initiatives. Another tens of thousands of small and medium businesses are waiting to get on to the internet and want cost-effective and reliable communication. This number would grow several-fold if satellite broadband can be a cost-effective medium for the consumers (similar to countries like US, Australia, Brazil). The Government can do its bit to un-lock this potential by tweaking its policy and provide the much-needed impetus to the sector. Broadband India Forum (BIF) has been working for the cause of proliferation of broadband and sees immense potential in the use of satellite as a medium for broadband and for acceleration of Government’s Digital India program. After an elaborate consultation with its esteemed members who range from satellite providers to licensed service providers and equipment 1

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BIF Recommendations on Satcom for NTP

NTP-2018: BIF SUBMISSION ON SATCOM( Pt. of Capsule 5 )

Anchor Principle: Enhance the role of satellite communications for accelerating “ Broadband to All “

Preamble

It costs ten to twenty times more to connect the last 10-20% population of any country, including India. Satellite communication helps connect this last 10-20% population in a very cost-effective way. The satellite service providers licensed by the Department of Telecom have an installed base of more than 250,000 terminals. They serve as the communication backbone to the banking industry, large distributed enterprises, small and medium businesses who are dependent on the internet for conducting their business (including filing of GST returns), other telecom service providers who use satellite as a backhaul medium to expand their coverage to the rural and difficult terrain areas and lastly the Government itself for the rollout of various social initiatives. Another tens of thousands of small and medium businesses are waiting to get on to the internet and want cost-effective and reliable communication. This number would grow several-fold if satellite broadband can be a cost-effective medium for the consumers (similar to countries like US, Australia, Brazil). The Government can do its bit to un-lock this potential by tweaking its policy and provide the much-needed impetus to the sector.

Broadband India Forum (BIF) has been working for the cause of proliferation of broadband and sees immense potential in the use of satellite as a medium for broadband and for acceleration of Government’s Digital India program. After an elaborate consultation with its esteemed members who range from satellite providers to licensed service providers and equipment manufacturers, BIF has come up with some key recommendations that can help its cause and also help the industry grow.

Key Recommendations

1. Open the supply of satellite capacity from private players aimed to ease the way of doing business and making the latest and innovative technology available to all at an affordable cost. Like in all other sectors, the Government should be involved in facilitating the growth and development of the sector rather than playing the role of an operator or an intermediary in artificially controlling the sector dynamics. Free market forces should be permitted to ensure optimal outcomes as regards procurement of capacity similar to that of the broadcast sector where the service providers are free to choose satellite capacity supplier of their choice.

2. Remove all ‘artificial’ barriers that are impeding the growth of the industry.

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BIF Recommendations on Satcom for NTP

Today the license restricts the speed of broadband to 2 Mbps per VSAT terminal. Also, other regulations that prohibit the use of different new bands and newer technologies like the LEO/MEO and smaller flat panel antennas etc. Similarly, satellite can very effectively address a variety of applications such as multicast file transfers, connected cars, maritime broadband communication, in-flight connectivity & broadband on trains. Technology should be the only limiting factor for the provision of a satellite broadband service.

3. Allow VSAT Services to be provided without any restrictions and in any combination across India, regardless of whether the service is - to extend voice and broadband services to consumers and businesses in remote areas, and/or to provide backhaul services to Telecom Service Providers or ISPs, and/or part of a larger hybrid telecom network service provided to an enterprise through a Telecom Service Provider.

4. De-license the VSAT terminals so that the import/local manufacture and sale of terminals can be freely done. Simplify the SACFA/WPC compliance by making it a self-certification. For the gateways, provide a time bound and single window clearance not exceeding 60 days from the date of application. This will result in a much faster roll out of the service and reduction of costs which will help bring down the cost of the service.

5. As already provided in the Indian Telegraph Act , policy and regulation of all telecommunications services via satellite should be under exclusive purview of DoT and TRAI respectively on lines of terrestrial communication services. DOS/ISRO could play a consultative role to identify a list of coordinated satellites and frequencies in line with ITU procedures, to be used for telecom networks.

6. Expand the scope for existing Service Providers so that they can grow the market and proliferate satellite Broadband access across the SAARC countries, without needing an International Long Distance license.

7. All uplink teleports for broadcast services should be permitted to plan for contingencies such as natural disasters by entering into arrangements with similar facilities located in other jurisdictions and transponders on alternate satellites respectively.

8. Inclusion of Broadcasting Satellite Service (BSS) Plan Frequency bands so as to augment the total satellite capacity available over India

9. Security Norms for Satellite Operators should be streamlined and made similar to that of other Unified Licensees

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EXPLANATORY NOTES

1. Open the Supply of Satellite CapacityA. The NTP 99 was a big milestone for the VSAT industry opening up the Ku Band

and allowing foreign satellites to augment the domestic capacity. The NTP 99 recognized the consultative role of DoS in the satellite space. However, this consultative role over time has become a canalizing role for DoS/Antrix in providing capacity. This has led to a number of issues that are impeding the growth of the satellite broadband industry.

B. The Government’s (DoS) role of being a sole supplier of capacity has led to many hurdles in doing business (much against the Government’s intent to bring about ease of doing business across all sectors including telecom). Added to this, DoS is a licensor, regulator and service provider, which leads to many conflicts of interest.

C. Any sale of capacity by DoS effectively becomes an allocation of a national resource, thus leading to many complications in pricing and contracting.

D. Free market forces should be permitted to ensure optimal outcomes as regards procurement of capacity similar to that of the broadcast sector where the service providers are free to choose satellite capacity supplier of their choice. So long as the Satellite is coordinated with Indian Administration under the ITU guidelines, the broadcaster/teleport operator can negotiate and enter into a contract with the

satellite operator

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Communication Satellites –Primary Growth Driver

A.B.C.D.E. World over, Communication Satellites are the Primary Growth Driver for the

satellite industry and form more than 50% of the entire satellite market, considering communications satellites and the ones used for Civil/Military communications. The Governments across the globe have taken a number of initiatives to liberalize the commercial satellite space, while retaining control over the remaining. In the Asia-Pacific region, except China, all of the countries have adopted an “Open Sky” policy as they recognize that satellite communications is an effective medium in reaching out to the last 10-20% of the population.

F. Despite having a share of a sixth of the global population, our share in the communication satellite market stands at less than 2% of the global communication satellite population. Thus India, the target focus of the “Next Billion in Broadband” has less than 3% of the total global satellite population (41 as against 1381). This clearly establishes that India is far below global norms on satellite communications.

G. Globally Low Earth Orbit (LEO) and Medium Earth Orbit (MEO) networks are being developed, which are expected to bring about an exponential increase in capacity and at the same time bringing the cost of capacity by factor of 100. India’s ambition to be a global power in the satellite launch space and reaching out to the moon and mars should not cloud the benefits that affordable satellite communications can bring about for the masses.

H. High Throughput Satellites (HTS) are used effectively in most of the countries, leading to large capacities and reduction in costs and allowing many more applications to be deployed using satellite communication. In India HTS is still not freely available although there are HTS footprints covering the country.

2. Remove artificial barriers that are impeding the growth of the industry

A. The TEC IR Document (TEC/IR/SCB-08/03.Oct 2013) restricts the speed of broadband via satellite to 2 Mbps. These licensing barriers are artificial in nature especially when satellites world over can deliver upwards of 25 Mbps to a subscriber. . The same document allows a much higher limit for a broadcast network or a transmission network. This clearly goes to show that this limit is not driven by a technology limit. Similarly, a transportable VSAT is allowed for the broadcast sector in the form of SNG/DSNG terminals, but not allowed for satellite broadband or mobile ATMs for banks. Ideally, the ground network should be allowed to optimally use the satellite resources to maximize the utility for the end-users.

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B. Similarly, the licensing conditions need to be agnostic to bands and satellite orbital locations. All bands that are permitted by the ITU for India should automatically be adopted for satellite broadband.

C. New technologies like HTS, steerable beams, frequency re-use on HTS, flat panel antennas, and NGSO Satellite constellations can bring in benefits of lower cost broadband delivery as well as support for newer applications like IFC and Maritime (ESIMs – Earth Station in motion), Connected Cars, Disaster Recovery etc. These technologies along with the ITU regulations for such services should be adopted in a timely manner so as to encourage early adoption of the same by the Indian industry.

Many constellations are being developed in the LEO/MEO orbits for high throughput and cost-effective delivery of capacity. It would be impossible for India to be self-sufficient in this area without permitting such new technologies and for the private sector to augment the DOS built capacity.

D. These developments have a big bearing on the growth of the industry and in the provision of affordable broadband to the masses in the underserved and un-served areas. The telecom policy should take cognizance of these developments and make the rules and regulations that are technology neutral.

E. When it comes to applications, satellite communications can provide the much needed convergence. More and more media networks are also

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converting to IP. A VSAT provider should be able to carry any IP traffic regardless of the application. The applications that satellite can effectively address are:

a. File transfers for the purpose of education , local information, weather bulletins, agricultural mandis & low cost entertainment to rural areas;

b. Connected cars for traffic management, insurance and security purposes; convergence broadband and media services;

c. Inflight Communications( IFC ) and Maritime Communications d. Data Multicasting & Caching for ultra-low cost based transfer of files e. Hybrid solutions consisting of data multicast with return channel over

terrestrial solutionsf. Broadband for planes/trains/shipsg. Broadband for Commuters h. Mobile Backhauling for 2G/3G/4G/5Gi. Smart Cities for M2Mj. Emergency services to reduce car accident casualtiesk. Low cost entertainment distribution l. Auto Car Software upgrades/updatesm. Disaster Management Terminals

3. Allow VSAT Services to be provided without any restrictions and in any combination across India, irrespective of whether the service is - to extend voice and broadband services to consumers and businesses in remote areas, and/or to provide backhaul services to Telecom Service Providers or ISPs, and/or part of a larger hybrid telecom network service provided to an enterprise through a Telecom Service Provider

A. Satellite broadband effectively complements other forms of broadband and backhaul technology. In the Indian context, satellite communication is used by large enterprises, small and medium businesses, telecom service providers as a part of a larger network. Most of these networks are delivered by access providers and the VSAT service is one part of the larger service being offered. In this context, it is imperative that the VSAT service be allowed for the access provider to carry in their portfolio. For the customer, it makes prudent business sense to buy this as a bundled offering. The access providers should be able to buy this service and re-sell the same to their customers.

B. In many geographies satellite is effectively used as a backhaul to deliver either a cellular service or a wi-fi broadband service. The VSAT service providers should be allowed to offer backhaul services to the other Telecom Service Providers without the need for a separate NLD license and set-up.

C. At the same time, a satellite based communication service can cost-effectively deliver broadband along with voice to a small or medium business

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in the underserved or un-served areas. Such a service should be allowed on VSATs.

4. De-license the VSAT terminals so that the import/local manufacturing and sale of terminals can be easily done.

A. The biggest inflection point for the growth of mobiles came in when the Government decided to de-license the mobile handset. Imagine, having to obtain a license for a mobile handset. It would have severely restricted the growth of the mobile industry. Today, satellite is yet another wireless alternative. In many countries, satellite terminals are in homes, very similar to a DSL/Cable/FTTH modem/equipment. This sort of a revolution is only possible when the Government de-licenses the terminal itself. This means, the terminal can be easily imported and deployed. Also going forward, local manufacturing should be facilitated in the area of VSAT terminals also.

B. This does not mean that the service provider has any less accountability to the regulations. Like in most countries, the terminals are installed on a self-certification and information basis. Audits are conducted and if the audit finds out that the terminal does not comply to the regulations, severe penalties are imposed. The VSAT terminals would still be imported through the respective VSAT service providers and directly by the users of the Captive VSAT Hubs

C. Similarly, on the gateway side, it takes a long time and often more than nine months to get the regulatory approvals. In some exceptional cases, it has taken more than two years to obtain all the regulatory permissions. The satellite operators including ISRO charge the VSAT service provider even during this period of inability-to-use. Not only does the Service Provider pay without generating any revenues, the Government also loses revenue (in the form of license fee and spectrum usage charges) when the network is not put-to-use. In order to avoid this, the Government should adopt a single-window approach and a time bound approval should be provided within a window not exceeding sixty days. Moreover the window should be available for the operators to apply for the necessary approvals any time depending on their business requirements and not be restricted to apply only during specified periods during the year.

5. As provided in the Indian Telegraph Act, policy and regulation of all telecommunications services via satellite should be under exclusive purview of DoT and TRAI respectively on lines of terrestrial communication services

A. The telecom industry has reached a great deal of maturity when it comes to policy formulation. The Department of Telecom (DoT) plays the role of a

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making appropriate and forward looking policies while the TRAI is entrusted with the role of adopting a consultative approach & enabling regulatory recommendations & guidelines which go into making the Policy for the sector.

B. Department of Space (DoS) on the other hand formulates space policies and provides their valued advise on the strategic aspects .

C. All policy with respect to satellite broadband service (VSAT service) should be holistically addressed by DoT and TRAI.

D. For effective administration of the INSAT/GSAT capacity, it would be desirable to have a commercial arm like ANTRIX to sell capacity with well laid out contracting principles that are distanced from a Government allocation of a national resource. This is the only way, the Indian capacity can become competitive and be at par with foreign capacity in terms of the ease of doing business.

6. Expand the scope for existing Service Providers so that they can grow the market and proliferate satellite Broadband access across the SAARC countries

A. The Hon’ble Prime Minister has a great vision to donate a satellite developed by India to the SAARC countries. This gives a tremendous opportunity for the VSAT service providers to reach out to the various customers in the SARRC countries to provide a VSAT service.

B. With a gateway in India, VSAT service providers can expand their scope by providing services to customers in the SAARC countries without the need for an International Long Distance license.

C. The SAARC countries have problems similar to that of ours and a satellite broadband service will effectively complement their terrestrial infrastructure. This service can help reach broadband to the unserved and underserved areas of the respective countries.

7. All uplink teleports for broadcast services should be permitted to plan for contingencies such as natural disasters by entering into arrangements with similar facilities located in other jurisdictions and transponders on alternate satellites respectively.

It’s a universally accepted fact that satellite based communications services including broadcast can be very effective medium to transmit useful information to large populations in case of any natural disaster/emergencies.

8. Inclusion of Broadcasting Satellite Service (BSS) Plan Frequency bands so as to augment the total satellite capacity available over India

Back in early-2000s, there was no available satellite capacity in the planned Broadcasting Satellite Service (BSS) frequency bands (11.7 – 12.2 GHz for down-link

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and 14.5-14.8 GHz/ 17.3 – 18.1 GHz for up-link, in the GSO (Geostationary satellite Orbit) arc of interest (40 deg. E to 120 deg. E).

Satellite capacity that could cover India was however, available in the FSS (Fixed Satellite Service) Ku frequency bands: 10.95 – 11.2 GHz; 11.45 – 11.7 GHz; 12.2 – 12.75 GHz in the down-link and 13.75 – 14.5 GHz in the up-link.

These FSS frequency bands were therefore used in all guidelines.

Situation has changed since then and the frequency bands that were planned in 1977 (at the ITU) for BSS can now be used since a number of satellites within the GSO (Geostationary Satellite Orbit) arc are available or in the process of being made available, that can provide services over India.

Therefore inclusion of Plan BSS frequency bands for use over India will be a win-win situation because:

1.     BSS Plan bands that have been languishing without use in India (spectrum is wasted when not used) will be put to use for a purpose (DTH or broadcast as an example), for which they were allocated (India was very active at the ITU for this process in 1977).

2.     This will reduce the pressure on the FSS frequency bands, presently used for DTH rather than for communications (these were NOT meant for TV broadcasting but had to be used for DTH since satellite capacity was not available in BSS Plan bands in 2001 when DTH guidelines were made) and gradually make them available for broadband – high capacity - backhaul communication in India for which there is a great demand.

CONCLUSION/SUMMARY

Commercial Communications through satellite needs to be maximized for Digital India for bridging the Rural/Urban Digital Divide. Opening the skies would bring the much-needed ease of doing business in this sector in addition to bringing the latest technology that is available today and in the future.

The licensing and regulation needs to be an enabler and not a dampener. All artificial barriers restricting use of new technologies from being deployed in the country should be done away with. Availability of technology should be the only limiting factor. This will pave way for lower cost satellite broadband that will be affordable for all.

A VSAT service is a gap-filler and a great backhaul option for Telecom Operators particularly for the remote locations. At the same time, it is an ideal solution for bringing broadband within reach of consumers in the remotest part of the country. It needs to be to be given due merit.

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The success of the mobile revolution can be repeated with satellite and this can be achieved by de-licensing of the terminal equipment and timely provision of approvals for gateways.

The telecom industry has come a long way and is at a very high level of maturity. This has been made possible due to the effective structure that has been put in place – DoT making appropriate & forward looking policies & TRAI in a consultative approach & for making enabling regulations for Policy formulation has helped the industry achieve a great amount of growth. This same model needs to be successfully adopted for the satellite broadband industry as well where Department of Space’s valued advise may be taken on matters of strategic interests while the commercial interests be handled by DOT long with TRAI.

In-line with the vision of the Hon’ble Prime Minister, VSAT service providers should be allowed to set up networks that expand across the borders and reach out to consumers in the neighboring SAARC countries.

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