The Department of Telecommunications (DoT) recently announced that it will release the updated National Frequency Allocation Plan (NFAP) in April, which will outline available spectrum bands and the services for which they can be used. The current NFAP provides a broad regulatory framework under which frequency bands can be allocated for cellular mobile services, Wi-Fi, satellite communications and broadcasting. A mid-band of frequencies in the range of 3.3-3.6 GHz was earmarked for 5G services, under the NFAP 2018. Meanwhile, TV broadcasters use adjacent portions (3.7 – 4.2 GHz) of the C-band of spectrum for distributing their signals, which includes frequencies between 3.4 – 4.2 GHz.
The challenge is that some of India’s 5G frequency rests with the Ministry of Defence, the Indian Space Research Organisation and the Department of Space. Due to this legacy constraint, the DoT is able to offer only 175 MHz of 5G spectrum in the C-band, through 5G auctions for private operators. This is inadequate – for example, an individual operator is generally assigned 100 MHz of spectrum in the mid-band. In order to ensure sufficient allocation, telecom operators are lobbying the DoT to allocate bands even beyond the current upper limit of 3.6 GHz for 5G.
Specifically, telcos are making a beeline for the 3.6 – 3.7 GHZ band, which normally acts as a “guard band” to limit interference between telecom and satellite broadcasting services. Such a move could have serious implications for TV broadcasting, which is already reeling from body blows dealt to it throughout the Covid phase. Cable and satellite services have used the C-band for over two decades, in line with the International Telecommunications Union (ITU’s) Radio Regulations, as well as India’s Downlinking Guidelines, 2011. Over 900 licensed TV channels in India operate within this band. International experience shows that allocation of frequencies beyond 3.6 GHz for 5G services could disrupt satellite services and impact quality of service.
Many studies, including those from the ITU, the Institute for Electric and Electronic Engineers (IEEE) have concluded that telecom and TV broadcasting services cannot co-exist within the same geographical area, in adjacent mid-bands. C-band downlinks are heavily impacted in countries like the EU, US and Singapore, which allocated the 3.4-3.8 GHz band to mobile broadband services. Further, the US has enabled the use of C-band spectrum for 5G services only after compensating cable and satellite operators with millions of dollars. These funds are used to fit ground networks with 5G terrestrial filters, that are expensive technological solves. A study by Hong Kong’s Office of the Communications Authority (OFCA) suggests that such filters may also be impractical to implement.
It is important to note that telecom operators can use other bands, such as mmWave bands to offer their services – and have in fact urged DoT to include these in the 5G spectrum auction. The same substitutability does not hold true for TV broadcasting through satellites. Despite this, telcos prefer the C-band because mmWave bands require a higher number of towers, which will eat future profits. India therefore must follow an approach that upholds the equity and rights of existing market players and consumers, even while it remains cognisant of the need to embrace new technologies. The country can consider taking a cue from the US’ Federal Communications Commission (FCC), and facilitate discussions to determine an acceptable way forward through provision of suitable incentives for orderly market transition.
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