Connectivity is one of the most significant components of a low-bit-rate internet of things (IoT) ecosystem. An IoT ecosystem ne­e­ds ubiquitous, re­silient and seamless connections at all times to run efficiently. Satellites have the unique advantage of providing such connectivity even in the remo­te­st parts of the country, helping to achieve an unprecedented level of connectivity and stability that terrestrial networks alone are not capable of delivering.

Keeping in mind the unique role that satellite can play in terms of providing con­nectivity for IoT applications, the Tele­com Regulatory Authority of India (TRAI) re­cently came out with its recommendations on the licensing framework for satellite-based connectivity for low-bit-rate applications. TRAI has recommended all satellite frequency bands to be used for providing satellite-based low-bit-rate connectivity, as part of the licensing framework for satellite connectivity applications.

TRAI has recommended that relevant service licensees may provide connectivity as per the scope of their authorisation for any kind of network topology model including hybrid model, aggregator model and direct-to-satellite model. Further, all types of satellites, that is, geostationary orbit (GSO) and non-GSO (NGSO) satellites, should be permitted for use in providing satellite-based low-bit-rate connectivity. Furthermore, service providers should be allowed to use any of the permitted sa­tellite frequency bands for providing satellite-based low-bit-rate connectivity. To this end, the relevant existing authorisations un­der the unified licence framework may be suitably amended for enabling sa­tellite-based low-bit-rate connectivity.

Meanwhile, TRAI has suggested that service licensees should be mandated to establish their earth station in India, corresponding to the chosen foreign satellite system following security purposes. It has also recommended that the Department of Telecommunications (DoT) should put in place a comprehensive, simplified, integrated, end-to-end coordinated, single-window online common portal for all the agencies involved in granting approvals/permissions.

TRAI has suggested that DoT can consider closing INSAT MSS-R service authorisation. The scope of INSAT MSS-R service authorisation involves providing the INSAT mobile satellite system reporting service, which is a one-way satellite-based me­­­ssaging service available through INSAT. TRAI is of the view that since the service is not in operation and many technological developments have taken place in the field of satellite communications, DoT may consider closing this authorisation.

Following is a brief summary of the recommendations.

Amending the scope of GMPCS service provision

The GMPCS service authorisation under unified licence permits the licensee to provide voice and non-voice messages and data services. Under the scope of data services, the licensee may provide satellite-based data connectivity to SIM-based IoT/ aggregator devices. TRAI has recommended that the scope of GMPCS service authorisation under unified licence may be suitably amended to include the provision of satellite-based low-bit-rate connectivity for IoT devices. Further, the regulatory body has suggested replacing the existing formula-based mechanism and is of the view that spectrum usage charges for using satellite frequencies under the GMPCS service authorisation should be prescribed as 1 per cent of AGR. These charges would cover the entire spectrum charges for handsets/ user devices as well as for earth stations.

Amending the scope of commercial VSAT CUG service

The commercial VSAT CUG service authorisation under unified licence permits the licensee to provide data connectivity bet­ween various sites scattered within In­dia. Under its scope, the licensee may be permitted to provide data connectivity for IoT devices also through satellite. TRAI has recommended that the scope of commercial VSAT CUG service authorisation under unified licence can be suitably expanded to include provision of satellite-based low-bit-rate connectivity for IoT devices. Further, TRAI is of the view that commercial VSAT CUG service providers should be permitted to use any technology conforming to the TEC IR/GR to provide the service. TEC IR/GR, in turn, may be modified to include the specifications re­garding “user terminal station on moving platform” for VSAT services. In respect of SUC for a commercial VSAT CUG service licence, the authority reiterated that the SUC should be 1 per cent of AGR, irrespective of the data rate.

Amending the scope of captive VSAT CUG service

The scope of captive VSAT CUG service licence involves providing data connectivity between various sites scattered throughout India, using VSATs. Under the scope, the licensee may be permitted to use data connectivity for IoT devices also, through satellite. TRAI has recommended an amendment in the scope of a captive VSAT CUG service licence to include provision of satellite-based low-bit-rate connectivity for IoT devices to be used only for internal communication and non-commercial purposes, that is, for captive use only.

Further, TRAI has suggested that captive VSAT CUG service licensees may be permitted to set up more than one CUG for their own use. Also, as per captive VSAT CUG service licence, the licensee shall pay licence fee annually at Rs 10,000 per annum per VSAT/earth station ins­talled. There should not be any separate li­cen­ce fee for IoT/aggregator devices whi­ch are connected to a VSAT terminal in hybrid model of architecture. Ad­ditionally, for any other model of architecture, in­cluding the direct-to-satellite and aggregator models, IoT devices should not be treated as a user terminal station for the purpose of levy of licence fee and spectrum charges and should not be subjected to licence fee and spectrum charges. The captive VSAT CUG service licensee should be permitted to use any technology conforming to the TEC IR/GR for es­ta­b­lishing its network for captive use. TEC IR/GR, in turn, may be modified to in­clude the specifications regarding the “user terminal station on moving platform” for captive VSATs.

Amending the scope of NLD service authorisation

The NLD service authorisation under unified licence permits the licensee to inter alia provide leased circuit services using wireline/wireless media, including satellite media. As per TRAI, the scope of NLD service authorisation may be suitably amended to include provision of satellite-based low-bit-rate connectivity for IoT devices. Earlier, in 2020 TRAI had made a similar recommendation on this subject. TRAI’s recommendations re­gar­ding amending the scope of NLD service authorisation includes:

  • Replacing the existing formula-based me­chanism. SUC for using satellite frequencies under the NLD service licence should be prescribed as 1 per cent of AGR excluding the revenue from the li­censed services other than satellite-based services.
  • NLD service licensees should be asked to do the accounting separation and ma­in­tain the revenues accruing from satellite-based services and other licen­sed services separately.

Allowing service licensees to obtain satellite bandwidth from foreign satellites

The satellite communications space is be­ing liberalised by the government for participation of non-government private entities. However, it will take time to have adequate satellite capacity available in India through domestic satellites. There­fore, TRAI has recommended that service lice­nsees should be permitted to obtain satellite bandwidth from foreign satellites in all the permitted satellite bands in order to provide satellite-based services. To this end, TRAI has made the following suggestions:

  • The government may publish a list of approved foreign satellites/satellite systems based on their technical and security evaluation, from whom service licen­sees may procure satellite capacities. Ser­vice licensees should be permitted to choose the foreign satellite/ satellite system from the approved list and to lease the satellite capacity directly from the chosen foreign satellite/ satellite system.
  • Service licensees should be mandated to establish the earth station in India, corresponding to the chosen foreign satellite/satellite system, prior to using the leased capacities.
  • The current practice of permitting the hiring of foreign capacity for a limited period of three to five years should be removed and service licensees should be permitted to hire foreign satellite capacities for a longer period as per need.
  • Service licensees should not be levied any kind of facilitation charges by the government when hiring foreign ca­pacities from the approved list of foreign satellites/satellite systems.
  • The government may come out with a road map detailing the schedule of launch of communication satellites and availability of domestic satellite capacities in India to facilitate service licensees to plan and optimise their capacity procurement.

TRAI has also recommended that the government should consider doing away with NOCC charges. The spectrum charges paid by service licensee should cover all the administrative, operational and testing charges.

Setting up of single-window online portal

TRAI has recommended that DoT should put in place a comprehensive, simplified, integrated, end-to-end coordinated, single-window online common portal for all the agencies involved in grant of various approvals. This portal should have inter-departmental linkages for transfer of applications and information for parallel processing, wherein service licensees can place their request and the agencies res­pond on­line in a transparent and time-bound ma­nner.  Further, all guidelines, ap­p­lication forms, fee details, processes, timelines and application status should be made available on the portal. TRAI has suggested that the National Single Win­dow System portal established by the Depart­ment for Promo­tion of Industry and Inter­nal Trade can include the De­part­ment of Space (DoS) as well, as service licensees are required to apply to the DoS for satellite transponder bandwidth.

Diksha Sharma