31st May, 2005: Publication on May 13th, 2005 by the Telecom Regulatory Authority of India (TRAI), of its recommendations on spectrum related issues, which followed 12 months of consultation and intensive study, is welcomed in most aspects by GSA and the whole communications industry. The detailed recommendations and their timing underline the importance of 3G/IMT-2000 mobile services and spectrum to key developing markets.

TRAI has signaled that India needs more spectrum for mobile communications and will now embrace 3G technologies, having observed the sharply accelerating demand for mobile communications in its major cities and nationally. Officials appreciate the contribution that mobile technologies make to delivering on the country's teledensity targets. As government is targeting 200 million mobile subscribers by 2007 (there were 50 million mobile subscribers in India at end March 2005, of which 80% are using GSM), it is easy to see that the allocation of more spectrum is absolutely crucial. Adopting 3G technologies such as WCDMA, the preferred 3G evolution path for GSM operators globally and also several 2G CDMA operators (including in Korea), ensures access to mature technology, multi-sourced supply to open standards, the most spectrally-efficient 3G solution, and lower costs for the industry, underpinned by GSM's economies of scale.

GSA has been deeply involved in discussions with TRAI and government officials during the period of consultation, presenting facts and information to assist policy-making. The GSA India Chapter, based in New Delhi, provided a key channel for dialogue with all the key industry players. GSA additionally participated in all three Open House Discussions organized by TRAI, and at additional expert meetings with their representatives. It is gratifying that TRAI fully recognized and accepted the arguments for alignment with the IMT-2000/WARC-92 band plan for 3G services. Europe and most countries outside North America have adopted the WARC-92 bands to support first implementations of IMT-2000/3G services. Brazil and China are also planning in favour of the IMT-2000 /WARC-92 band plan. The World Radio Administrative Conference in 1992 (WARC-92) identified frequency bands 1885-2025 MHz and 2110-2200 MHz for use by IMT-2000 systems. From this decision, the bands 1885-1980 MHz, 2010-2025 MHz and 2110-2170 MHz are identified for terrestrial IMT-2000. The recommendation by TRAI provides for full alignment with these bands.

In reaching their conclusions, TRAI considered claims from the CDMA operators in India that their 2G systems should be allowed to operate in part of the IMT-2000 spectrum (the so-called PCS 1900 band as deployed in North America), and that their systems could co-exist with new 3G systems. The scientific evidence which was put forward to, and considered by TRAI, demonstrated that this was not the case, and showed that interference would result, and that there are no mitigation techniques such as either the use of additional filtering or use of guard bands, which would be of practical use. The mixed-band allocation PCS1900/IMT-2000 scenario has not been implemented by any country, and is also rejected by TRAI.

The repercussions of this decision will also be seen in any countries still considering deployment of the 'mixed-band' as there is unanimous consensus that it is unworkable. It is also a strong signal to other Administrations to ensure that they are able to allocate IMT-2000 spectrum for 3G/IMT-2000 services without the risk of interference from non-3G/IMT-2000 services and applications, such as WLL, for which solutions are available in other frequency bands.

GSA also welcomes these other key TRAI's recommendations:

the subscriber-based approach criteria for determining additional spectrum assignments for operators to continue

spectrum trading is not considered at this time, however it may be considered later following further consultation

reduction of spectrum charge limit from 6% Annual Gross Revenue 'AGR' to 4%

assignment of minimum threshold spectrum, as per international practices, to be ensured to be given to each GSM/CDMA service provider, at the earliest, for better and economic planning

However, GSA expresses a serious worry about the market and competitive imbalance which would arise from unequal treatment on the timing and amount of spectrum allocation of spectrum for 3G services. Another recommendation by TRAI favours CDMA operators by supporting granting early additional spectrum in the 800MHz band, allowing first mover advantage to deploy 3G services using CDMA 1x EV-DO technology while at the same time, not guaranteeing a timetable or allocations for IMT-2000 spectrum which the GSM players need for deploying their WCDMA-enabled 3G services. This clearly would not provide a level playing field for all operators, and is an important question to be resolved by the government in reaching its final policy decision.

An additional concern is that there should be a minimum of 2 x 10 MHz paired spectrum allocated in the IMT-2000 band for each 3G/WCDMA operator in order to ensure a reasonable operating environment. TRAI's recommendations propose only the availability of 2 x 5 MHz in the IMT-2000 band to each existing mobile operator provider who demands it, which is inadequate.

GSA, with the support of the GSA India Chapter, looks forward to continued dialogue and information exchange with senior representatives of TRAI, government officials and other key industry players to assist development of the best environment for mobile communications investments and developments in India.