BharatNet meeting 230625,000 villages are being connected with fiber by the remarkable Bharatnet, on track to complete in 2019. One to five Wi-Fi hotspots in each area (GP) will offer services including banking and e-gov for eight cents (U.S.) per day to $1.50/month. These "Common services centres" will often be run by "Village level entrepreneurs," perhaps as many as 100,000.

DOT's goal is 500,000 deployed in 2018 under a light licensing procedure. 43,000 are already in place and 300,000 more on the way. Some will be solar-powered.

This is the largest Internet access program on earth, originally conceived by Sam Pitroda in the government of  Dr. Mammohan Singh. It is a credit to the government building it.* Telcos are also connecting; Bharti has 30,000 cells planned. Reliance Jio, now with 4G to 96% of Indians, will raise that to 99%. Jio has better coverage than most of the major Europeans, all state of the art 4G LTE.

The big four telcos now are demanding a delay and a huge increase in costs.  "Establishing public WiFi networks without licence will be illegal being in violation of the Indian Telegraph Act 1885."

COAI, which represents Bharti, Vodafone, and Jio, believes that, "Would give unfair advantage to unlicensed entities and would thus lead to a loss of revenue to Licensed Operators who are providing services legitimately under the licensing framework and are already going through a phase of severe financial stress, It would thus lead to a loss of revenue to the exchequer. Further, it will have serious national security implications in case unlicensed entity is allowed to offer the internet access services." (letter below.)

Simply getting the license would cost more than setting up and running the Wi-Fi network, if Indian procedures are similar to those in other countries. If the Indian telcos need higher profits, the country has many ways to support them other than slowing rural deployment. 

India is doing more to reach the rural unconnected than any other country on earth. The heart of the plan was BharatNet, fiber to the 625,000 villages. Local Wi-Fi is usually the best way to connect villages. Jio has proven it can profitably bring 4G LTE to 96% of India, a far from rich country. 4G is so much more efficient it has a much lower cost per bit. Deploying anything less is almost always a mistake today. Ghana and other Africans adding 3G aren't aware of the current technology choices.

The Government of India and its goals have changed since 1885.

* For the record, I am not a supporter of most rightwing governments, including India. I can respect their achievements, however. As always, I report as close to the truth as I can.

Gopal Vittal, Chief Executive Officer of Bharti Airtel said, “Access to broadband is a key enabler of inclusive economic growth and social well-being of rural inhabitants. We are pleased to support the commendable initiatives by the DoT to ensure broadband access for every Indian and in particular building the infrastructure backbone under BharatNet.” 

OCR Version of the COAI letter

Smt. Aruna Sundararajan,

Secretary (Telecom),

Department of Telecommunications,
Ministry of Communications & IT.
Sanchar Bhawan, Ashoka Road,
New Delhi 110 001

Subiect: TRAI Recommendations on “Proliferation of Broadband through Public Wi-Fi
Networks" issued on March 9, 2017

Reference: i) Joint Industry letter bearing reference number JAC12017I016 dated April 12,

ii) COAI letter bearing reference number RSMICOAII2017I138 dated July 24,

Dear Madam,

This is with reference to our above mentioned letter dated April 12, 2017 vlde which we had

submitted our views on the above highlighted Recommendations on Proliferation of Broadband
through Public Wi-Fi Networks, as stated below:

A. Licensing and Level Playing Field:

1. The Industry supports the use of Wi-Fi technology as a mean to provide Internet
services. However, Internet Access through Wi—Fi or through any access technology is
permitted under a licensing structure since ‘lnternet Access’ is a licensed service. As per
the provisions of the Indian Telegraph Act 1885, the activity of establishing, maintaining
and working of telegraphs requires a license from the Government. In fact, as per the
extant license conditions. any entity which intends to provide Internet services using

delicensed spectrum is also required to obtain a license under Section 4 of the Indian
Telegraph Act.

2. Internet is a network which supports communication between two end points. Internet
works over various types of medium such as wireline, wireless etc. Since Internet

services are covered under the definition of telegraph it can be provided under license
only which conforms to the provisions of the Act.

14, Bhai Veer Singh Marg, New Delhi ~110 001
lelz+91~1l~23349275 fax:+91-11~23349276 email:This email address is being protected from spambots. You need JavaScript enabled to view it.



Under the current licensing structure, Internet Access is provided under UL(Access
Authon‘zation/ ISP Authorization), UASL. ISP or UL—VNO license. Further. any entity
wants to resell the Telecommunication services should obtain a VNO license.

It is worthwhile to mention that under VNO licensing conditions, the entry fee for ISP
category-‘C’ license is Rs, 10,000/- which is sufficiently low for any entity to pay for
providing Public Wi-Fi services in smaller scale.

Contrary to the well-established Licensing structure, TRAI is in its recommendation has
suggested that Public Data Office Aggregators (PDOAs) and Public Data Office (PDOS)
be allowed to provide Internet Access through Wi-Fi technology under a Registration.
Any such service will be in conflict with the existing licensing framework that allows

provision of internet services within the existing UL/UASL/ISP Licensing framework and
reselling through UL(VNO).

The said recommendations of TRAI, if implemented, will also adversely affect the Level
Playing Field. Licensed operators operating under a License, have to pay levies and
ensure adherence to various Regulatory and security related requirements in the interest
of the country. Allowing the same activity to be performed by an unlicensed entity would
tilt the Level Playing field, as the same would give unfair advantage to unlicensed
entities and would thus lead to a loss of revenue to Licensed Operators who are

providing services legitimately under the licensing framework. It would thus lead to a loss
of revenue to exchequer and would pose security risks as well.

Hence, we submit that the current method of providing Internet Services only under a
License in conformation to Indian Telegraph Act is necessary to maintain
Regulatory stability and consistency. Allowing a service like Internet to be resold
under a Registration would be against the very basic foundation of Unified
Licensing Regime and would tilt the Level Playing Field and impact the financial
health of operators who are already reeling under severe financial strain.

. TRAI Recommendation of delicensing of 5.725 - 5.825 GHz spectrum band for outdoor



The spectrum is a scarce resource; the same is required to be used judiciously in the
interest of the nation. Additional delicensing of spectrum would be an inefficient

utilization of this scarce national resource and would cause a loss of revenue to the

2. TRAI has recommended the delicensing of 5.725 - 5.825 GHz spectrum band for

outdoor usage. The availability of unlicensed spectrum is not an impediment for the
spread of Broadband, as 483.5 MHz of unlicensed spectrum is already available which is

under-utilized. In contrast to this, around 300 MHz of Licensed spectrum is serving over
a billion cellular customers in the country.



3. Furthermore, reuse of Wi-Fi frequencies is better owing to it being deployed as low

power higher frequencies, thereby allowing the operators to deploy greater capacities.
Despite these facts. Wi-Fi frequencies are under-utllized at present. Thus, we do not
recommend de—licensing of any additional spectrum band for Wi-Fi services until the
current unlicensed spectrum is fully utilized. This is to ensure that there is no wastage of
precious spectrum in any manner.

The licensed TSPs acquire spectrum through auction process. This has resulted in very
high spectrum acquisition costs mainly due to the lack of supply of spectrum in all the
previous auctions. Affordability of spectrum still remains a challenge in lndia. TSPs have
already committed Rs. 3, 27,000 crores since 2010 for acquiring spectrum till now. TSPs

additionally pay spectrum usage charges and other levies on the acquired spectrum to
the exchequer.

In view of the above we believe that there is no need to de-license 5.725 - 5.825
GHz spectrum band for outdoor usage at this stage. Further, we submit that

affordability and supply of licensed spectrum should be the priority going

C. Introduction of Aggregators and Subscriber Verification


TRAI has recommended that Authentication through e-KYC, e-CAF and other electronic
modes be allowed for the purposes of KYC obligations cast upon PDOAs. We submit
that there is a flaw in the recommendation inasmuch as TRAI suggests that the activity
be carried out by the PDOs /PDOAs under a Registration.

Subscriber verification is a critical activity for telecom services which is performed by
licensed operators as it is directly linked to security aspects. OTP based login methods
deployed by various TSPs to provide Wi-Fi services at various places provide easy
access to Wi-Fi at various places, which has been formulated by DOT after discussion
with Ministry of Home Affairs.

While the overall objective has been stated as to facilitate affordability and ease of
access of broadband services but the solution offered is by the introduction of

Aggregators. Any sort of introduction of Aggregators or ‘third parties' in the value chain
increases the cost of providing the services.

In view of the above, we believe that there is no requirement of any Aggregators in the
system. Introduction of Aggregators and that too under a Registration would create
distortions in the market leading to non-level playing field as also cause issues such as
loss of revenue to exchequer and security problems. It will introduce players that are not

subject to the existing licensing and regulatory framework and have the potential to
transform into gatekeepers.


D. Our Requests:


In light of the above, our requests are as under:

1. The current method of providing Internet Services (through any technology)
only under a License is necessary to maintain stability and consistency in
Licensing and Regulatory framework and the same should be continued.

2. Allowing a service like Internet to be resold under a Registration would be
against the very basic foundation of Unified Licensing Regime and would tilt
the Level Playing Field. This should be allowed only through a UL (VNO)

3. Currently, there is no need to de-license 5.725 - 5.825 GHz band for outdoor
usage as existing unlicensed spectrum is under-utilized; on the other hand
there is a need to increase affordability and supply of licensed spectrum.

4. There is no need to introduce Aggregators in the system as the same is not
required; any introduction of Aggregators would lead to security gaps, loss of

revenue to exchequer and would potentially introduce gatekeepers in the

 We hope that our above requests will merit your kind consideration and support.

With Regards,

You rs faithfully,

‘3‘“ 5- 7-3134

Rajan S. Mathews
Director General

 An early government outline of the plan by Notan Roy and Pravin R. Chandekar of the Ministry of Electronics & Information Technology is worth readin. Connecting everyone is worthwhile although the claim here it has a major impact of the economy is unsupported 


Ubiquitous access to the net connectivity and its impact on the national GDP growth are widely recognized at all level. 'Always On' data connection irrespective of the geographical variations has a greater significance in respect of enabling the users to remain in touch with the competitive world for greater contributions on the emerging market facing technological innovation & digitization for efficiency & inclusion- financial & social both. There has been an increasing demand by individuals and organizations that the high speed uninterrupted data services should be made available at all the time at an affordable & cheaper rate. Presently, contribution of mobile network like 3G/4G for data services has led to a greater benefit to the society. But, due to the rapidly increased mobile data overload fulfillment of users' demands are often compromised at the cost of unwanted network latency leading to declining the satisfaction level of the consumers. It has been a research proven outcome that an wide spread network of Public Wi-Fi service can greatly improve this scenario as a complementary service in such a way that mobile data can be dynamically offloaded / shared to get rid of unwanted break in packet transmission. It has been a constant endeavor of the Government to take remedial steps for improving the telecom grade of service (GoS) in accordance with the technological evolution and its consumption for emerging national growth