Satellite spectrum refers to a unique range of radio frequencies that enable satellite communication (satcom), providing high speed internet access even in remote areas where terrestrial networks may fall short. Unlike terrestrial spectrum, which supports mobile communications within national boundaries, satellite spectrum is inherently international, governed by the International Telecommunications Union (ITU).

In India, there are two main authorisations for satellite-based commercial communication services under the unified licensing framework: the global mobile personal communication by satellite (GMPCS) service authorisation and the commercial very small aperture terminal (VSAT) closed user group (CUG) service authorisation. However, recently, the Telecom Regulatory Authority of India (TRAI) put forward recommendations to merge the GMPCS and commercial VSAT CUG service authorisations into a single authorisation, the “Satellite-based Telecommunication Service Authorisation”, under the Telecommunications Act, 2023.

The allocation of satellite spectrum has long been a critical and debated topic among industry stakeholders. To address this, TRAI has released a consultation paper titled “Terms and Conditions for the Assignment of Spectrum for Certain Satellite-Based Commercial Communication Services”. This paper aims to explore the methodology and pricing for assigning spectrum to satellite companies to facilitate calling, messaging, broadband and other services across India.

Key issues raised in the consultation paper

Frequency bands for satellite-based communication services

Satellite-based communication services rely on two types of links – user links and gateway links. The user link connects the satellite to user terminals, requiring frequency spectrum for both uplink and downlink operations. The gateway link connects the satellite to the satellite earth station gateway and similarly requires spectrum for uplink and downlink functions. While a range of frequency bands are available for satcom services, the popular frequency bands used for providing satcom services are L-band (1-2 GHz), S-band (2- 4 GHz), C-band (4-8 GHz), Ku-band (10-15 GHz) and Ka-band (17-31 GHz).

In this regard, TRAI has sought inputs on which frequency bands or ranges should be considered for spectrum assignment to NGSO-based fixed satellite services (FSS) and GSO/NGSO-based mobile satellite services (MSS) for providing voice, text, data and internet services.

Interference-related challenges and coordination issues

To control interference, the ITU provides an elaborate framework for allocation, coordination, power limits and regulatory protection. However, TRAI has highlighted concerns regarding the interference-free operation of NGSO satellite systems. Thus, TRAI is seeking views on whether the current ITU Radio Regulations (ITU-RR) sufficiently address the interference and coordination challenges. If not, what additional measures should be implemented when assigning frequency spectrum for NGSO-based FSS for data communication and internet, as well as GSO/NGSO-based MSS for voice, text, data and internet.

TRAI also raised questions about whether protection measures, such as prescribed distances, are needed to prevent interference between satellite earth station gateways operating in the same frequency range – specifically between GSO and NGSO system gateways, and among different NGSO system gateways.

Furthermore, TRAI has sought stakeholder inputs on the necessary protection criteria and conditions for spectrum assignments to satellite gateways and user links to prevent interference with terrestrial networks.

Scarcity of satellite gateway sites

A satellite earth station gateway serves as the critical interface between the space-based communication network and terrestrial networks. The number of gateways a satellite system requires depends on factors like its intended use, geographic coverage, capacity and quality of service. While a single gateway can be sufficient for conventional GSO satellites covering a region, high-throughput satellites and NGSO systems need multiple gateways to ensure effective operation. TRAI has therefore sought inputs on whether specific conditions should be established to mitigate the risk of a scarcity of satellite gateway sites.

Roll-out obligations for assigned spectrum

Currently, for commercial VSAT CUG service authorisation, licensees must roll out their networks by installing and commissioning a hub station for star network configurations or at least two VSAT terminals for mesh network configurations within 12 months of the frequency allotment by the Wireless Planning and Coordination (WPC) wing of the Ministry of Communications. Similarly, for GMPCS service authorisation, licensees are required to commission a land earth station gateway switch for GMPCS service provision within 12 months of frequency allotment by the WPC.

However, following the merger of GMPCS and commercial VSAT CUG, it is evident that roll-out obligations primarily pertain to the operationalisation of satellite earth station gateways, specifically the feeder link frequency spectrum. No separate roll-out obligations have been stipulated for the spectrum assigned to user links. Given that next-generation satellite systems, including NGSO-based systems, require substantial amounts of frequency spectrum, it could be argued that there is a need to introduce additional roll-out obligations to ensure efficient use of the spectrum allocated for satellite-based telecommunications services.

TRAI is therefore seeking inputs on whether additional roll-out obligations should be imposed for spectrum assignments beyond the existing conditions recommended. In particular, TRAI is requesting feedback on whether new roll-out requirements are required for FSS and MSS.

Surrender of assigned spectrum

Entities authorised to provide satellite-based telecommunication services rely on satellite operators for resources. Situations may arise where these entities need to transition to a different satellite system due to the end of life of their current system or more favourable commercial options. As a result, even when spectrum is assigned for a specific validity period, an authorised entity might wish to surrender it before the term ends. This raises the question of whether a provision should allow early spectrum surrender and, if so, under what terms and conditions. TRAI has sought inputs on the need for such a provision for NGSO-based FSS and GSO/NGSO-based MSS. In addition, TRAI is interested in views on the process and conditions, including minimum holding periods, required notice, surrender fees and other relevant terms to ensure fair and efficient management.

Other key issues

Typically, GSO satellites have a lifespan of 15-20 years, while LEO satellites last between 5 and 10 years. As satellite services continue to evolve and new satellite systems are being deployed, a key question arises regarding the optimal duration for frequency spectrum assignments. TRAI has sought inputs on what the maximum assignment period should be for NGSO-based FSS, and GSO and NGSO-based MSS to provide voice, text, data and internet services.

In addition to these, TRAI has sought views on whether there should be defined timelines for processing applications related to the assignment of frequency spectrum. The aim is to assess whether standardising timelines could enhance efficiency and predictability in the spectrum assignment process.

Spectrum charging mechanism

The Indian satellite broadband industry is currently at a nascent stage. Therefore, the current pricing strategy should incorporate an intertemporal analysis that takes into account the present status of the satellite industry while also offering predictive insights into its future development.

At present, spectrum allocation for space-based communication services is conducted through an administrative mechanism. This includes a mix of formula-based charges for certain services and charges based on a percentage of adjusted gross revenue (AGR) for others. For commercial VSAT services, spectrum charges are applied as a percentage of AGR, determined by the data rate range as outlined by the Department of Telecommunications.

A key argument for AGR-based spectrum charges is that they align the financial burden of spectrum costs with an operator’s revenue performance. Higher revenues lead to higher spectrum charges, while lower revenues reduce the financial burden, creating a flexible model that reflects the operator’s ability to pay. In addition, this approach promotes a level playing field by ensuring that smaller operators with lower revenues contribute less, while larger, more profitable operators pay more. However, a potential drawback of AGR-based charging is that it does not directly link charges to the quantity of spectrum held. This could incentivise operators to hoard spectrum without fully utilising it. To mitigate this risk, one solution could be to implement a minimum spectrum charge based on the amount of spectrum held by the service provider.

In this context, TRAI is seeking inputs on whether spectrum charges for NGSO-based FSS, and GSO and NGSO-based MSS should be imposed on a per MHz basis, calculated as a percentage of AGR, or determined through an alternative methodology.

It further raises questions on the appropriate percentage of AGR, minimum spectrum charge and the methodology to be used to determine the amount of the minimum spectrum charge.

Industry response

Reliance Jio has urged TRAI to issue a revised consultation paper on spectrum allocation for satcom, arguing that the current version overlooks a critical aspect: ensuring a level playing field between satellite and terrestrial services. According to Jio, the absence of this key point prevents stakeholders from effectively considering and providing relevant inputs, potentially compromising the fairness of TRAI’s recommendations and the government’s objective of fostering balanced competition.