Dear Patrons,

India needs encouraging policies that will lead to flexible spectrum use to allow evolution of all services and technologies bringing benefits to consumers and the economy. Allocating the required frequencies must be in a manner that facilitates entry of new technologies and competitors into the market, encouraging and promoting innovation.

A change in the broadband penetration strategy to allow satellite technology for providing ubiquitous connectivity is urgently required for India. More than 50% of rural India is still not digitally connected. As per a report by the Telecom Regulatory Authority of India (TRAI) the broadband penetration is a mere 29.3% in rural India and approximately 55% in the country.

Fixed broadband penetration in India is among the lowest in the world at only 1.69 per hundred inhabitants. This suggests that terrestrial technologies alone cannot achieve any significant change in the statistics. A right mix of technology policy is urgent and imperative.

Source: OECD statistics for June 2020, TRAI Recommendations on Roadmap to Promote Broadband Connectivity and speed 31.08.2021

In terms of quality, India ranks very low at 131 out of 140 nations on Global Index for mobile broadband speeds as of March 2021 as per TRAI Recommendations on 'Roadmap to Promote Broadband Connectivity and Speed' August 2021. The average mobile broadband download speed in the country was 12.15 Mbps during March 2021 while the average upload speed was registered at 4.8 Mbps for the same period.

Source: OECD statistics for June 2020, TRAI Dec2020

With the advancement of satellite technologies in HTS & UTHS, large parts of the Indian terrain can be connected via satellite without any delay. The number of satellite and mega constellations of LEO/MEO are promising efficient and affordable broadband services. In short, satellites can bring 5G like speed and quality consistently to any terrain. Which is why large investments have gone into launching of the satellites planned to cover the entire globe; most of the countries follow the ITU directives for using Ka-bands. A total of 17.25 GHz of spectrum was identified for IMT services to support 5G at WRC-19. The 28 GHz band (27.5-29.5 GHz) is allocated for fixed satellite services (FSS). Only a small number of countries have gone against this practice and have assigned (or partially assigned) this band for IMT.

Ka-band can contribute to economic benefits including
• High speed Broadband connectivity for unserved and underserved areas
• Improved service quality for underserved locations
• Wider choice of broadband and pricing options
• New applications and connectivity services
• Aeronautical and maritime services.



SIA-India in its Counter Response to the TRAI Consultation Paper "Auction of Spectrum in frequency bands identified for IMT/5G" stresses on adopting a technology neutral spectrum policy. If mmWave spectrum from satellite is allocated to 5G it will :

• Widen the existing digital divide in India
• Significantly increase costs of providing broadband access to the unconnected.
• Lead to a Lopsided spectrum allocation policy favouring one technology will harm investments.
• Offer excessive spectrum leading to wastage and hoarding

These outcomes will result in costly regulatory failure for India through loss of substantial overall economic opportunities [estimated GDP Loss of $184.6 b by 2030] with the Indian citizens being denied the benefits of advanced satellite broadband services and benefits of employment generation.

The impact of the loss of C-band spectrum in the 3.6-3.67 GHz band alone will be felt across the entire INR 700 Bn Indian broadcasting industry which provides direct and indirect employment to 1.83 M people.

The association also commented upon the issue of Satellite Spectrum Auctions calling it a distraction to the core issue of identification of spectrum for 5G/IMT. Subject matter related to Satellite Spectrum Allocation Method is currently not within the scope of consultation process and the case of auction of satellite spectrum has often been inserted under other vital issues for consultation that TRAI engages the industry with irrespective of its relevance to the subject under discussion.

SIA India goes on to assert that propositions such as "same service, same rules" do not apply to satellite services as the terrestrial concept of exclusivity does not apply to them and auctioning therefore is not applicable. Satellite spectrum has international encumbrances. Competition Commission of India (CCI) has debunked the argument of "same service, same rules", and legal precedent exists that not all communication services in India are considered "same services".

India needs to avoid the pitfalls that would place it on the wrong path for achieving cost-effective national connectivity, thereby widening the existing digital divide. There is a need for a pragmatic and more balanced approach, recognising the benefits of satellite technology. The detailed submission by SIA-India can be accessed at https://bit.ly/3ueWNlY

• Artificial Intelligence, Geospatial Systems and Drones, Semiconductor and its eco-system, Space Economy have immense potential to assist sustainable development at scale and modernize the country. They provide employment opportunities for youth, and make Indian industry more efficient and competitive.
• Supportive policies, light-touch regulations, facilitative actions to build domestic capacities, and promotion of research & development will guide the government's approach.
• For R&D in these sunrise opportunities, in addition to efforts of collaboration among academia, industry and public institutions, government contribution will be provided.

• Tax incentive Period extended by one more Year up to 31st March 2023: Eligible start-ups established before 31.3.2022 had been provided a tax incentive for three consecutive years out of ten years from incorporation. It has been extended by one more year from the period of incorporation of the eligible start-up up to 31.03.2023 for providing such tax incentive.
• Incentives for newly incorporated manufacturing entities under concessional tax regime: A concessional tax regime of 15 per cent tax introduced earlier for newly incorporated domestic manufacturing companies has been extended by one year i.e. from 31st March, 2023 to 31st March, 2024.
• Fund raised under the co-investment model, will be facilitated through NABARD to finance start-ups for agriculture and rural enterprise relevant for farm produce value chain. The activities for these start-ups will include technology including IT-based support.
• Promote new age companies by facilitating 'Drone Shakti' through varied applications and for Drone-As-A-Service (DrAAS). In select ITIs, in all states, the required courses for skilling will be started.
• Defence R&D will open up for start-ups and academia with 25% of defence R&D budget earmarked.
• Credit Guarantee Trust for Micro and Small Enterprises (CGTMSE) scheme will be revamped with required infusion of funds. This will facilitate additional credit of 2 lakh crore for Micro and Small Enterprises and expand employment opportunities
• Raising and Accelerating MSME Performance (RAMP) programme with outlay of 6,000 crore over 5 years will be rolled out. This will help the MSME sector become more resilient, competitive and efficient.

• The Circular Economy transition is expected to help in productivity enhancement as well as creating large opportunities for new businesses and jobs. The action plans must also include 'Space Debris Cleaning' sector under the sectors identified such as electronic waste, end-of-life vehicles, used oil waste, and toxic & hazardous industrial waste are ready.

• World-class foreign universities and institutions will be allowed in the GIFT City to offer courses in Science, Technology, Engineering- free from domestic regulations, except those by IFSCA to facilitate availability of high-end human resources for financial services and technology.

As part of its commitment to capacity building and academia outreach, SIA-India has signed an MOU with the Society for Space Education, Research and Development (SSERD) to collaborate on elevating and fostering Space Education and Research in India. SSERD is an international organization dedicated to promoting Space Science among the community and creating awareness about the current inventions and innovations happening in this sector.

The Event discussed key issues being faced by TV and Broadcasting Industry including possible ramifications of the 5G launch on the broadcasters and distributors.

Mr Rajeev Gambhir, Sr Director Technology and Policy, SIA-India participated in the event and moderated a session on the Topic- The 5G Opportunity. The discussion included the following topics:

• Current pace of 5G roll-out in India
• Impact of 5G in Digital media distribution
• Role of Satellite in video delivery
• Balancing the effective spectrum usage between Wi-Fi, terrestrial and Satellites

Mr Rajeev Gambhir, Sr Director Technology and Policy, SIA-India participated in an on-air panel discussion on Channel "India Ahead" discussing the impact of 5G rollout using the C-band spectrum on aviation safety and broadcasters.