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Allocation of Spectrum Resources for Residential and Enterprise Intra-telecommunication Requirements/ Cordless Telecommunication Systems (CTS)

KTMT Response to Issues for Consultation
1. Whether the current allocation of spectrum for CTS is sufficient tomeet the requirements? If not, then how to meet the demand ofcordless telephony spectrum requirements?

The current allocation of spectrum in the band 1880-1900 MHz appears to be sufficient for voice services. For data and video services, the CTS spectrum is likely to fall short when NOFN in the back bone and in cities under the NBP comes up by 2014-2015. NBP has left the edge and access networks upon the private players to bring up. Private players have hardly invested in edge and access networks built around FTTB or FTTP since 1994. Even if they see good ROI in high speed high capacity FTTB/FTTP access networks, this is going to take a long time due to ROW/PROW issues. CTS with CAT iQ for data and video can be ideal for residential clusters, SOHO, SMEs, corporates, factories, plants etc. Thus, it is a good idea to keep another 10 MHz spectrum in 1900 MHz other than the current 20 MHz in 1880-1900 MHZ band.

2. In view of the availability of cellular mobile services in the countryand possibility of Fixed Mobile Convergence (FMC), is there any needto have DECT Phones?

Cellular phones are quite ubiquitous and some of them are also used in CUG in the enterprise segments. Femto cells are likely to be deployed as and when these become affordable. These would offer cellular phone service while being back hauled through a fixed broadband. However, the capacity of femto cells is really limited to not more than 3, 5, 7 lines and so on. High capacity femto cells are not viable as they become costly and have hand-off and interference issues. This deficiency of capacity of femto cells in the enterprise segment needs to be made up. Ubiquitous use of cell phones in enterprise segment, urban and dense urban areas would cause congestion. It is here that CTS spectrum employed as part of DECT for voice, video and data would come handy. There is a very good possibility of affordable multi mode cell phones having GSM, Wi-Fi and DECT coming up to serve the need for efficient voice, data and video services using one hand set.

3. Is there any requirement of allocating spectrum for digital CTS, inview of similar solutions being available in already de-licensed band 2.4 & 5.8 GHz?

The de-licensed bands really need to be coordinated for interference free service. Wi-Fi data service has shot up in popularity in a very big way. However, being uncontrolled, it suffers from interference and security where the deployment is huge and usage very high. We are not likely to see a big wired last mile in future. Thus, to cater for interference free and secure last 100 meter access for scaled up CTS voice and video service, the de-licensed bands of 2.4 and 5.8 GHz would not meet the requirement.

4. Whether de-licensing of the spectrum for digital CTS applications will be the right path?

We have had cases of licensed spectrum being used for WiMAX services for BWA. The spectrum fee even for the WiMAX CPE has become a barrier in the mass deployment of this BWA technology. The cable dry areas require BWA but spectrum charges make the service cost prohibitive and carriers do not even bother to offer this in those areas. Live example in Delhi itself is the area of Wazirabad. MTNL is not present with its wire line. Carriers have not deployed many BTSs for EVDO or 3G due to capex constraint. GPRS/EDGE does not meet the requirements. BWA through WiMAX is a very good option but carriers find it cost prohibitive. Only low grade Internet service available is through LCOs LAN based infrastructure having no OSS/BSS/CRM. Internet service through the current method of LCOs arrangements can never pass the QoS standards and would be dumped first the moment carrier grade service is available. This is the case in Delhi. Rest of the peripheral areas in the country even around good cities would have similar situation. To make CTS viable as a scaled up technology for last 100 meters, the spectrum should not be charged.

5. Do you agree that the 1880-1900 or 1910-1920 MHz band (TDDMode) be allocated for digital CTS applications? If yes, what shouldbe the limits of emitted power (EIRP), power flux density (pfd), and antenna gain etc?

We should follow the ETSI standards in this regard which the EU has adopted successfully.

6. Do you see any coexistence issues between existing cellular systemsusing adjacent band with low power CTS allocations in 1880-1900 or1910-1920 MHz band?

The ETSI limits for CTS enable very smooth co-existence between GSM and CTS in EU. India can take a cue from there.

7. Whether the de-licensing of either 1880-1900 MHz or 1910-1920MHz band for low power CTS applications will result in loss ofrevenue to the government?

India has 1 million wired EPABXs. Assuming each EPABX has around 25 lines on an average, there are minimum 25 million EPABX lines in the country. We can assume another 25 million local lines coming up for high residential, SOHO, SMEs, enterprise, corporate, factories segments. Assume another 25 million local lines for normal residential segment, thus, 50 million more lines can come up by 2016. If de-licensed CTS are available for deployment, the period may be shortened to 2015 even. The loss of revenue due to de-licensing would be off set by quicker and scaled up proliferation of voice, data and video services which if left up to wired or BWA technologies alone would take much longer, less number of people would subscribe to the service and apart from delay, the revenue share for the government would also reduce. No loss of revenue is foreseen due to de-licensing of the band.

8. Will there be any potential security threat using CTS? If yes, how to address the same.

CTS are digital and thus inherently secure. The control of power as per ETSI standards would ensure that to intercept the CTS transmission, the equipment must be very close to the terminal or base station. Such close placement of interception equipment can be easily detected through normal surveillance means. Sensitive government offices may not use the CTS.

9. Amongst the various options of digital technologies available tomeet the cordless telephony requirements, either spectrumallocation can be considered according to technology or theetiquettes/ specifications can be defined for the de-licensedspectrum band. What method of allocation of spectrum for digital CTS applications should be adopted?

In this case, we have clear deployment of CTS complying with ETSI standards in the EU. We should follow those proven methods as we are not doing any new R&D.

10. Any other issue? Yes, how to provide inexpensive internet in the hands of 65 % of people of India who live in the lower economic strata.

DAS HSPs along with LCOs can offer a huge number of Wi-Fi hot spots in the country again enabling early penetration of true broadband.

India has a very large population in the low economic strata. This more than 65 % population even in large cities lives in smaller houses, tenements or huts in congested areas. For example, Mumbai is known to be 65 % slum. Every city in India has large slum areas. If we include rural areas, such population increases phenomenally. The question is how to provide internet in the hands of these consumers.

Presently, the only way consumer internet being provided is through fixed line or as mobile internet like GPRS, EDGE, 3G, 4G, 1xRTT and EVDO. Due to various reasons, internet penetration in the country has been just less than 7 % which is quite shameful in the world. When we meet in seminars, we often hear from foreigners that a country of 1.2 billion has only around 80 m internet users. The masses which have been just left behind, if provided affordable and workable internet can very quickly enhance its penetration giving the much needed boost to the GDP growth. The country therefore, needs an inexpensive mobile internet distribution mechanism for vernacular light browsing apps and e-mails basically to bridge the last 50 to 300 meter gap which is the hardest to build in telecom infrastructure. DECT CATiQ and DECT ULE can be used successfully to distribute such internet service to these people.

Putting a DECT base station, back hauling it through carrier Ethernet (mostly wired and hardly wireless) bringing x mbps of internet band width to this base station and by using dual mode, dual band GSM/DECT voice and data capable handsets, gross 64 kbps of internet service can be given to six handsets which yields a net of 50 kbps per hand set. By channel bundling techniques, one can go up to 300 kbps also from one base station to one hand set. Now concatenating more base stations, more handsets can be served. Such a distribution set up creates an island of internet having radius from 50 to 300 meters which serves a large number of people living in such a cluster of houses, tenements or huts in congested areas. The key is to create multiple such islands of internet.

NOFN has been planned to reach 250,000 village panchayats. NOFN does not address the last mile access which has been left up to the carriers to do the build out. Wire line last mile is cost prohibitive for such areas and while deploying smaller 3G and LTE cells in the last up to 300 meters access network, DECT CATiQ and DECT ULE provides inexpensive supplementary mechanism to bring internet in the hands of the consumers living in that 300 meters.

The opportunity is really huge. Carriers alone can never meet the requirement of such a mass internet service. They can by complemented by the ISPs and MSOs/LCOs who can take the ISP license and provide internet in most inexpensive way. Even carriers can employ MSOs, LCOs and other franchisees to distribute their carrier grade internet service on DECT to such consumers who require light browsing for vernacular weather updates, mandi rates, e-mails, news feed, telemedicine, dictionary service, search and so on.

Let's recall how Japan, first in the world, introduced mobile internet in 1999. Done by NTT Do Como named as i-mode, it was just 9.6 kbps and Japanese farmers used to sell rice on i-mode. This was one of the best innovations the world has ever seen using their own technology, own ecosystem, no GSM, no CDMA but inexpensive stuff, they enabled their people en-mass to do their day to day business in vernacular apps on i-mode. Here, we are able to give minimum 50 kbps and can go even up to 300 kbps in an island of 50 to 300 meters radius. When they are out of range of DECT, they can use the GSM mode and still get their voice and internet.

Actually, carriers’ fear of loss of revenue is a myth. Inexpensive DECT would complement their existing expensive technologies. Internet penetration will gallop and people would pay from 50/- to 100/- willingly. Conventional mobile internet on GPRS, EDGE, 3G and 4G requires data plan whereas no data plan is needed in DECT as base station would mostly be on fixed line carrier Ethernet having x mbps of internet band width. The service would cost less and as such can be priced also low.

If there is one thing which we need to do as of yesterday is to proliferate inexpensive internet service as fast as possible to the masses of India. Here is an opportunity to enable the carriers, ISPs, MSOs/LCSOs and other franchisees to just do it. DECT spectrum needs to be de-licensed. The nation is the real gainer.

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