India’s Telecom Bill Magnifies NTN and TN Spectrum Tensions

India has been making waves throughout the telecommunications industry with its recently draft Indian Telecommunications Bill and National Frequency Allocation Plan 2022, which contains major policy reforms aiming to guide the country’s telecom infrastructure transformation and management for years to come. Emphasis on these reforms has been the consolidation and amendment of laws governing the operation and provision of telecommunications services, spectrum allocation, and making them ready for the future, especially regarding 5G and satellite communications. A point of contention with this set of reforms has been the lack of distinction between satellite and terrestrial spectrum, a practice which could make satellite spectrum (in the 1-40 GHz range) susceptible to auction. The administrative allocation or auction of the 27.5-28.5 GHz spectrum, part of the Ka-band used commonly for satellite broadband, has been one of the core issues driving this debate and remains one of the fixations for both India’s space and telecom industries.

While the Indian Space Research Organization (ISRO) chairman and the Satellite Industry Association (SIA) of India have already voiced their concerns about distinguishing and reserving spectrum for satellite communications, the Department of Telecommunications (DoT) of India has released a new wave of SatCom-related procedural reforms. These positive changes include:

• Not requiring permission to mount very-small-aperture-terminals (VSATs) on any mobile vehicle
• Enabling self-certification of antennas without prior clearance from the government
• Streamlining the Network Operation and Control Center (NOCC) process that reduced timelines from eight months to six weeks
• Elimination of satellite antennae performance verification testing

With these freshly announced process improvements and policy changes, India is signaling an escalating effort to establish a robust satellite infrastructure for wireless communications throughout the country, but is it the right approach? What the country decides in the coming months for wireless spectrum regulation will have a critical impact on its communications industries, and potentially disrupt the expanding satellite broadband segment and future growth of the space industry.

Following the wave of increased enthusiasm to transform communications infrastructure and close the digital divide around the world with terrestrial and non-terrestrial network (NTN) integration, there growing friction about reserving, allocating, and repurposing spectrum for these networks. For the terrestrial network (TN) operators, the move into the 3.5 GHz and mmWave spectrum has been driven by the transition to 5G and the increasing number of mobile network users, especially in densely populated areas. By moving from millions of hertz or megahertz (MHz) to billions of hertz or gigahertz (GHz) of bandwidth, Communication Service Providers (CSPs) will be able to satisfy the data rates and bandwidth of many more users. The interest culminated with the auctioning of the L, S, C, and Ka-band for commercial deployment in the United States, South Korea, Japan, and the EU, with trials moving forward in several other regions throughout the world.

Hence, India’s interest in auctioning spectrum within the 28 GHz band is not unfounded. The decision to auction this spectrum off so that satellite and terrestrial companies can compete, however, would go against the current international standard that exclusively reserves the 28 GHz band for satellite players despite its efficiency for 5G services. There are several reasons for this distinction of band assignment, of which is the crucial fact that 5G signals running on the same band will increase the chances of radio frequency interference (RFI) between terrestrial network equipment, earth stations, and satellites. Even terrestrial signals adjacent to a satellite radio frequency (RF) band can create problems by raising the signal-to-noise ratio (SNR) or by spilling over into the satellite band.

The growing need for spectrum is not unique to TNs however, as NTNs’ user base and deployments are also requiring more resources. Satellite deployments for the Internet of Things (IoT), satellite-to-mobile (NTN mobile), consumer broadband, maritime, and aeronautical markets are driving growth throughout the industry, which ABI Research estimates will culminate in over 53.3 million subscribers by 2030, accounting for a compound annual growth rate (CAGR) of 17.4% (MD-SATCC-101). While new space companies in the NTN mobile space, such as Lynk, AST Space Mobile, Omnispace, and recently Starlink, have been partnering with telecoms that own spectrum to work with frequencies that are useful for cellular data applications, these services ultimately mean repurposing or sharing terrestrial spectrum for space-based networks. While from a regulatory standpoint this is very much a grey zone, especially in the eyes of the Federal Communications Commission (FCC), from a business perspective, this ultimately means that these companies do not have to commit time, money, and energy to things that aren’t building the network and focus on the engineering challenges: turning distractions into competitive advantages.

While the increasing customer base and spectrum demands of TNs and NTNs have created more friction for both industries, this development does not mean a path without compromise, coexistence, and integration. The Indian Space Association (IspA) has already promoted its stance that in the 24-27.5Ghz band there would be the adequate capacity (800 MHz) for each of the four major Mobile Network Operators (MNOs) in India. Hence, retaining the 27.5-28.5 GHz for satellite networks would not inhibit the propagation of 5G throughout the country. Furthermore, mmWave is heavily reliant on the availability of fiber on-site and requires a significant amount of small cell base stations due to its limited range (around 500 meters). The cost of deployment, small coverage footprint, and susceptibility to signal attenuation by obstructions makes mmWave ideal for limited-range deployments (indoors, private networks).

While India’s new telecom reforms could become a model for acknowledging the growing issue of spectrum interference and enacting industry-specific policy to reduce the harmful effects it can have on TNs and NTNs, a final decision has yet to be rendered. In this respect, satellite communications can provide connectivity to rural and underserved communities where terrestrial networks have difficulty reaching, as well as provide services like telemedicine and medical support services, education, and employment opportunities. In India alone, nearly 75% of the rural population lives without broadband, reflecting an untapped market of 71.4 million people. For India and many countries around the world, SatCom is showing its criticality for everyday life and can provide critical support and connectivity for defense, security, humanitarian, emergency response, and diplomatic communications.

To this effect, regulatory evolution for supporting TNs and NTNs should consider many aspects, critical of which are:

• Defining the kind of interference that is acceptable with sharing bands and implementing standards for receivers and assignment of radio frequencies in specific use cases
• Evaluating spectrum requirements of 5G TNs and NTNs, enacting industry-specific policy, and assigning separate radio frequencies
• Enforcing Low Earth Orbit (LEO) mega-constellation coordination with Medium Earth Orbit (MEO), Geostationary Equatorial Orbit (GEO), and TNs, especially when leveraging Ku and Ka bands
• Support the development of technologies for interference mitigation  
• Enforce specific and time-sensitive space sustainability, registration, and disposal requirements so that orbits remain usable and ecosystem players maintain accountability
• Support MNO adoption of multi-band strategies and a plurality of wireless infrastructure solutions (TN and NTN) to build out 5G networks and optimize infrastructure investment and inclusivity