IAMAI Respon TRAI Consultatio Proliferation of Throug Public Wi

IAMAI Respon TRAI Consultatio Proliferation of Throug Public Wi
IAMAI Response to the
TRAI Consultation paper on
Proliferation of Broadband
Public Wi-Fi Networks
August, 2016
IAMAI would like to assert its support to the underlying objective of the consultation paper – expanding
Internet access by examining the need to encourage public Wi-Fi networks in the country and address
the issues pertaining to the proliferation of public Wi-Fi networks. This is a commendable initiative by
the Authority as we have seen that even with moderate expansion in access to data, there has been an
explosion in websites, applications and platforms that has had a dramatically positive impact on
employment and the country’s GDP growth.
India needs to unlock, explore and experiment with different types of technologies viz., Cable, Loons,
Drones, VoLTE, VOIP, Satellite technology with the prime focus on Whitespaces and Wi-Fi technologies
as the next best frontier for innovation, competition and connectivity. In particular, proliferation of
Public Wi-Fi as middle and last mile connectivity and a supportive ecosystem to promote it is a major
need of the hour.
Overview of Public Wi-Fi Ecosystem Globally
There has been an unprecedented growth in public Wi-Fi hotspot deployments globally. The computed
aggregate growth rate has been predicted to increase by 13.23% in 2013-18.1 There are nearly 9 million
public hotspots in the world so far [Fig 4.1] which includes public Wi-Fi hotspots deployed by mobile and
fixed-line carriers as well as third-party Wi-Fi service providers and excludes community Wi-Fi. APAC
with more than 6 million hotspots constitutes 68% of the global hotspots2 followed by LATAM and
Europe. Among the BRIC nations China and Brazil have the highest number of public Wi-Fi hotspots.
India at present has 30,000 hotspots across the country. Recent years have not only seen a significant
expansion in the build out of public hotspots but also addition of new capabilities to previous/existing
public Wi-Fi generations. The next phase of public Wi-Fi is characterized by a huge expansion of services
and revenue streams, and of the variety of service providers. The key technical and market
developments in various advanced nations have enabled new business models for existing and new
service providers.
Some of the Key Drivers for Global Adaptation of Wi-Fi are:
Increased Traffic: Worldwide, the overall data traffic is set to increase 12 times between 2013
and 20183, and mobile data traffic is set to rise at an even higher rate, to reach
11.9exabytes/month by 2017.
Increased speeds and reduced latency – Wi-Fi can provide better speed equivalent to 3G speed
as shown in the illustration below depending on the technology in use.
Improved quality of service – as voice and video move to IP, and always-on broadband
connectivity becomes vital to ways of living and working, QoS expectations rise and operators
need to meet these expectations in order to attract and retain customers.
Increased mobility – behavior patterns are shifting so more people are using broadband from
mobile devices to stay connected at all times.
Network Congestion- As more and more people use wireless broadband, networks come under
pressure. Wi-Fi can help offload data in crowded areas.
In most of the countries the operators have initiated Wi-Fi hotspots at various locations as there is
business clarity. In India operators have recently joined the race to provide Wi-Fi under the concept of
freemium [Free Premium]. Most of the business models today are highly successful due to such models.
The economic logic behind the freemium model is: when supply of a product increases, the demand for
its complimentary products also increase. The free product drives the revenue generation by creating
demand for not just the other products but also by increasing the number of customers/users. The
Success of such models depends on the number of people it attracts to use it.
Following are some of the best case business models adopted worldwide in well established and
emerging markets.
Best case Business Models adopted Worldwide
Well Established
Business Models
Time-Based Model
Free access driving
other services
Wholesale access
Bundled Wi-Fi
Advertising and
Managed services
(venues and
Cellular offload
(user driven)
Growing Rapidly
Cellular Offload
[Carrier Driven]
Community Wi-Fi
Monetization Options
Pay –as-you-go Access
The operator offers hourly and daily passes for access
to its Wi-Fi network
Wi-Fi as another way to deliver providers’ own
content, including TV programmes, games and news.
TSP/ISP Forming partnerships with venue owners so
they could propose Wi-Fi networks with a paid or free
model to the end customers. The operator shares the
investment costs and revenue with the venue
Added value for broadband
Bundles Wi-Fi access in all its mobile data
broadband tariffs. Single Account gives millions of
connection viz., Roaming packs.
Revenue from ads and
Teaming up with the consumer product brands,
sponsors subsidizes the cost
where Ads display on the landing page.
of access to consumers
Offers managed service for public locations that
want to provide Wi-Fi to their customers and
employees (e.g., coffee shops, hotels, airports,
stadiums, railway stations).
Cost savings with effective
Offloads cellular data traffic to Wi-Fi to help
Network management. Free
alleviate network congestion, lower network
Wi-Fi as a customer retention
operating costs, and reduce (or defer) 3G and 4G
capital expense (CapEx) investments.
The amount of data used will
be billed with the existing
data plan or bill.
Customer Retention and
reduction in subscriber churn
Heavy offloading strategy in
congested areas. This is a
partitioning model.
Sells Wi-Fi network access to mobile operators on
a per-user or per-MB basis.
Wi-Fi connections at home hubs by enabling users
to share their Wi-Fi signals with others.
Hotspots managed
by Venues and
Wi-Fi Roaming
Freemium Models
Wi-Fi roaming in partnership
with other operators on a
bilateral basis. Connecting to
Wi-Fi networks while
travelling is crucial to enable
operators to monetize actual
and latent demand for mobile
broadband access.
There is a demand for Wi-Fi roaming among a
broad base of consumers, including those who
don’t use data at all while roaming for fear of bill
TV everywhere
It is driven by high quality
video, which is dependent on
good bandwidth and QoS for
premium customers.
TV Everywhere (also sometimes known as
authenticated streaming or authenticated video
on-demand) refers to a business model which
enables customers to watch TV on mobile devices
or laptop when they are not at home.
Availability and use of consumer data in real time
for promotion, spot discount and mobile ads is
captured with relevance.
Big Data analytics
Economics of Unlicensed Spectrum
Radio spectrum is used for different radio communication services based on the level of frequency,
coverage/range and use.4 A part of this radio spectrum is sold or licensed to operators and dedicated
for defence purpose and rest fall under unlicensed spectrum. Most of the spectrum which is allocated
for mobile communication use and TV broadcast consists of bands that do not have interference issues.
Unlicensed spectrum on the other hand is open to use by any certified device/router which is easy and
cheap compared to licensing. Unlicensed spectrum maximises productive output in a world where last
mile access network can easily interact with sophisticated and popular devices viz., Wi-Fi and Bluetooth.
Wi-Fi service uses unlicensed spectrum in 2.4 GHz and 5GHz bands. Other than these traditional bands,
many countries use TV white space for Wi-Fi, aka white-fi which operates under 802.11af standard.
Consumers rely on Wi-Fi these days utilizing it seamlessly while they are outside or on the go.
Furthermore, unlicensed spectrum will play an important role in proliferation of IoT and smart cities.
Seoul, the Korean Capital has almost universal Wi-Fi which is twice the speed of Wi-Fi in the US,
whereas, in India, Wi-Fi technology is a highly underused asset. The opportunity cost to use unlicensed
spectrum as a gap-filler5 is missed out. While unlicensed spectrum can be a great opportunity to
maximize the use of spectrum, offering up limited bands is futile.
The regulators all over the world are worried about the interference problem that can arise due to these
unlicensed bands if put to use. There are many services that use unlicensed spectrum viz., Wi-Fi,
cordless phones, home security solutions, Car entry systems etc. The regulators should note that the
marginal overhead cost involved in designing the operating rights to minimize the interference is
outweighed by the considerable economic value of the unlicensed spectrum.
Radio Spectrum is divided into nine bands, each band performing similar tasks as per the ITU Radio Regulations.
to fill guard bands with low-power devices
Unlicensed spectrum can play a great role in country like India which has 80% unconnected citizens. In
India fixed broadband penetration in rural and difficult geographical locations is dismal. Operators too
hesitate due to heavy capex and opex. In such conditions unlicensed spectrum is the best substitute. In
many countries unlicensed spectrum has provided tremendous economic value. In the US it has
provided economic value over $220 Billion6 in 2014-15. Spectrum lying idle and the bands that are not
allocated or lying unused are causing not only economic loss but also wastage of scarce resources.
Spectrum is a peculiar resource which is infinitely renewable, divisible in 6 to 8 dimensions, and unused
spectrum is a lost opportunity that can never be recaptured.7
Wi-Fi Infrastructure Cost Model
Wi-Fi technology helps two or more devices [computer or mobile] to communicate with each other
without the help of any land cable or fixed line. To build a Wi-Fi infrastructure is less complex than
building traditional telecom infrastructure and is as efficient in terms of performance and cost to the
consumers. Internet hotspot gives internet access over a WLAN through the use of a router connected
to a link to an ISP. WAP [Wireless access point] is the device that allows wireless devices to connect to a
wired network using Wi-Fi. It is different from hotspot which is the physical location.
Existing infrastructure such as electricity poles and bus shelters can be used to mount routers and other
equipment. This will reduce the operating cost and required investment for a city wide deployment
strategy. The initiatives like smart cities and M2M/IoT proliferation would not be possible with only
licensed spectrum. For these models to work in India, major change in outlook is necessary for the policy
and regulatory bodies.
Key Wi-Fi Technology Trends and Best Practices Globally
The Wi-Fi platform is evolving rapidly with new best in class technologies emerging and revolutionizing
the market. These technologies define the scale, range, coverage, capacity and throughput. The key
technological trends seen in the Wi-Fi market are, Hotspot 2.0, 802.11ac, emergence of 11ad and 11ax,
White-Fi, VoWi-Fi, 802.11n, Google Fi, Wi-Fi aware , WiGig ,Wi-Fi direct etc. These technologies will
create new revenue models and more players in the market providing greater access that can transform
the internet economy.
Snapshot of various Wi-Fi Technologies existing and upcoming [Best Practices]
[Hotspot 2.0]
2.4/5 GHz
Mobile Phones automatically connect to
the Wi-Fi network once they are in range.
60 GHz
5 GHz
Sim Based Technology 8
based on the protocols of
Multi –gigabit speed
wireless communication
Faster Data Rates [at
least 500 Mbps @ 5 GHz
on a single link and 1gbps
for multi-station
7GBPS speed. Short distance and high
volume data transfers.
802.11ac is a supercharged version of
802.11n works exclusively in the 5GHz
presence/in use
in India
sub-1 GHz
2.4/5 GHz
60 GHz
45/60 GHz
470-590 MHz
Project Loon
2.4 and 5.8 GHz
ISM Bands
Project- Fi
Wi-Fi aware
Uses light
waves from LED
light bulbs
Stamp Chip)
Wi-Fi chip that
can uses TV
White Space
protocol/standard that
gives at least 100 Kbps @
sub-1 GHz
Low energy/power consumption. It will
allow low rate 802.11 wireless stations to
be used in sub-gigahertz spectrum.
This standard is
finalized. [Draft
Upcoming technologies which can provide a speed of 10gbps and will support technology
like MU-NIMO[Multi-user multiple input/multiple output]
This technology allows
WLAN operation in TV
whitespace/UHF bands.
High altitude balloon
network operating in
stratosphere aka floating
cell towers
connects to the fastest
Wi-Fi or LTE network in
an area.
A new technology that
allows multiple Wi-Fi
devices to communicate
with other nearby devices
The technology is called
Optical Wireless
Communication [OWC]
It has a better range over the other bands
i.e., 2.4 and 5 GHz
It is a reliable and cost effective way to beam
internet service from sky to ground antennas.
The tests to
soon begin.
The technology will use solar and wind to
power the electronic equipment.
It can connect to two 4G towers at the same
time and allow customers to automatically
switch between the networks.
This can resolve the call drop issues.
Most importantly this technology helps you
refund the unused data unlike in the current
system where the operators charge you in
advance for data packs and do not refund or
allow carry forward.
OWC which uses visible light communication
[VLC] or light waves instead of Radio
frequencies [RF]. It is proved capable of
sending data at speeds of upto 1GBPS, 100
times faster than most Wi-Fi.
All the advantages of TV whitespace Wi-Fi
has been listed in the next section under Key
Suggestions [Unused Spectrum and TV
Source: Indian Express and Bulls-eye Telecom
A timely intervention in terms of a robust policy framework for public wi-fi will enable India to cash on
these innovations and bolster Digital Empowerment in the country. The new advanced technology
Require less equipment to produce the same quality service as a DSL or cable.
Help in faster data speed
Require seamless authentication
Wider Roaming
Low Capex and Opex
Lead to improved QoS and Security
Key Ares of Focus in India
Following are some of the key bottlenecks that need to be cleared:
1. Lack of Public sector participation and Right of Ways [ROWs]
Lack of Public sector participation, issues of Right of Ways [ROWs] for the private sector, heavy
infrastructural investment for the TSPs, lack of government initiative to incentivize the Telcos and
private sectors to invest in uneconomical region, uneven broadband roll out and underutilization of the
already laid out cable TV networks etc are some of the glaring issues for unsuccessful fiber penetration
in the country. There are 55,000 villages in India where the mobile operators cannot reach.
2. Backhaul is Essential
Government’s focus on Fixed Broadband is essential. For the Wi-Fi technology to work as the last mile
connectivity, or as data offload strategy, the government has to seriously think of providing fixed line
and optical fibre network to homes or be able to take the connectivity at least to the base station.
Otherwise Spectrum assigned will remain underutilized. It has been seen that in most of the cases where
optic fiber network has been provided, due to lack of middle and last mile connectivity, the internet has
not reached the user.
3. Healthier Play of Licensed and Unlicensed Spectrum is Necessary
The gap between the fiber points to the users can be filled by the use of Wi-Fi technology. The country
has plenty of idle and unused spectrum that can be used for affordable middle and last mile connectivity
and for connecting Wi-Fi clusters. These bands can be brought under unlicensed spectrum or lightly
licensed as is the case in many developed and emerging economies.
The five-judge apex court bench headed by Chief Justice S.H. Kapadia in 2012 said auction could be a
better option where the aim is maximisation of revenue. The principle that the State owned natural
resources should be allocated only by a process of auction is not a principle applicable universally and is
so clarified by this Court in Natural Resources Allocation.10 The court was answering a presidential
reference seeking its opinion on whether auction was the only method of allocating natural resources
across the board.
Hence, as auction could not be the sole method of dispersing natural resources the government should
allow a healthier play of licensed and unlicensed spectrum of certain bands.
For instance, the TV whitespace band or the UHF band was regulated to operate under unlicensed or
lightly licensed ways in many countries to provide a platform for innovation in the wireless industry. This
helped create methods to provide future broadband wireless services and applications to people at a
lower cost. The UHF band is globally used for high power terrestrial TV broadcasting. This band is
perfectly suited for Wi-Fi technology. This option has been tested in many developing countries like
Kenya, Tanzania, South Africa and the Philippines where internet penetration is low due to geographical
issues and expensive fiber.
The Indian Government should periodically re-evaluate spectrum allocation to identify underused or
unused spectrum and reallocate it to ensure efficient use of spectrum in each market.
4. Resolve the Interference Issue with facilitating technology
In Re, Special Reference No.1 of 2012, (2012) 10 SCC 1
Technically it was observed that for transmitting an unlicensed spectrum one needs to keep the level of
the frequencies low to prevent the signals from colliding. But such interference concerns to licensed
users, the predominant reason behind the limited allocation of unlicensed spectrum, have greatly
diminished with the advent of facilitating technology. Interference-free spectrum use by multiple
operators is enabled by some of the best technology Wireless Local Area Network (WLAN), Ultra Wide
Band (UWB), Radio Frequency Identification (RFID), Near-Field Communication (NFC)systems, and
others supporting cost-efficient and flexible spectrum usage of unlicensed spectrum.
5. Encryption and Privacy
An effective Wi-Fi encryption and privacy protection can give confidence to individuals and businesses to
use Wi-Fi technology. In many countries haphazard encryption regulations have affected the growth of
Wi-Fi. In India too, regulatory uncertainty surrounding adoption of Wi-Fi technology will undermine the
competitiveness of the market by discouraging the internet users. WEP is old standard and has serious
security weakness and therefore WPA protocols should be used. WPA2 has come in with even higher
secured technology which is based on IEEE 802.11i and provides 128-bit AES based encryption. Fake WiFi hotspots and snooping issues need to be checked with a strong encryption protocol in India. IT
administrators deploy technologies where their network is set up in such a way that each user has a
separate encryption. Such technologies are available and can be seamlessly deployed at each location or
access point.
IAMAI Position on Public Wi-Fi Propagation
Given the abovementioned background, the Association responds to the consultations with the
following broad principals in mind:
Each and every individual should get fair, equal, high quality, high speed and affordable access
to the Internet. Open and free access to the Internet should be provided through these
networks in a manner that conforms to all principles of net neutrality and the current rules.
Subject to conformity to all principles of net neutrality and current rules, market forces should
determine the relationships between ISPs/TSPs, content providers and other parties active in
the digital environment to foster innovation, creativity and the development of hyper
competitive yet nascent content industry. No overbearing regulations should impose any
burdens on deployment of Wi-Fi networks.
TRAI should also consider working with the industry and the DoT to identify a roadmap for
unbundling the local loop as has been done in the US. This is imperative as in the times to come
cable companies will also be at the forefront to drive broadband penetration in India alongside
telcos owing to the ongoing digitalization of cable television operations. Given that last mile
cable connectivity in India is in a chaotic state and local cable operations in India are largely
unorganized, it is important that the regulator, industry as well as the government focus on
cable operations to drive broadband through two way interactivity and mandate suitable
principles and standards taking a leaf from international best practices to that effect.
Additional measures over and above as provided in the consultation paper may also be taken to expand
Internet access to consumers:
Free access for rural consumers: Creating a public subsidy program to enable TSPs to provide free
Internet access to rural consumers, along the lines of other national social security programs currently
used by the country.
Time based models: Allowing TSPs to provide free Internet access to all consumers at certain time
periods when the network utilization is low.
Introductory models: Allowing TSPs to provide free Internet access to new consumers (those who are
new to Internet or are using data on the TSPs network for the first time).
Public or community networks: Building access points around the country geographically selected to
provide access to those consumers who cannot afford to buy private services.
Income Targeting: Enabling TSPs to provide free Internet access to consumers below a certain income
Responses to Issues for Consulation
Q1. Are there any regulatory issues, licensing restrictions or other factors that are hampering the
growth of public Wi­Fi services in the country?
The Association recognizes the following regulatory challenges that need to be resolved.
1. Unavailability of adequate unlicensed spectrum: Commercially significant frequency bands
which have been de­licensed completely (outdoor and indoor) in many countries are still
licensed or partially licensed in India. This severely limits the capabilities of businesses to
deploy the latest technologies and expand service in India.
5150­5350 MHz
5725­5875 MHz
60 GHz (‘WiGig’/ V­Band)
71­76 / 81­86 GHz (E­Band)
Further, limitations on EIRP and power spectral density and inconsistencies in these
limitations across bands hinder proliferation and enhance the cost of deploying access
Additionally, TV whitespace band is the most suited to provide broadband in rural areas as an
efficient backhaul media. The lack of enabling regulation for using this band is a major
hindrance in enhancing connectivity.
Inadequate backhaul capacity: Backhaul is critical to internet service. Acquiring Right of
Way permissions from various authorities has long been highlighted as a cumbersome
process and a barrier for setting up the telecom infrastructure need to invest in more
internet backhaul. It is appreciated that the government is already working on bringing a
legislation to ‘rationalise Right of Way procedures and charges for laying of telecom
infrastructure — currently varying widely across states’ 11.
3. Lack of Wi­Fi infrastructure best practices: The present Wi­Fi ecosystem in the country is
highly fragmented. Lack of flexibility to innovate and scalable best practices have hampered
expansion and investment. Areas of most concern are interoperability, common Know Your
Customer (KYC) compliance, authentication, accounting and localization requirements.
Currently regulations appear to discourage the utilization of resilient and distributed
datacenters in which virtual machines can efficiently monitor, manage, process and
secure Wi­Fi services. Restrictions exist in the form of requirements for localised billing and
customer information within India, onerous KYC regulations, and unclear internet transit
requirements. Datacenters (known in the industry as “cloud” technology) are typically large
capital investments co­located with appropriate power and other technology. In addition, for
reliability, data can be replicated across multiple locations. Removing these barriers would
vastly reduce costs and will accelerate expansion of the Wi­Fi sector.
4. Prescriptive security requirements: The existing security requirements governing public Wi­Fi
networks are prescriptive and adversely impact user experience and convenience.
Such requirements discourage users to sign­on to public Wi­Fi services. With new
technologies and standards available, providers should be able to address legitimate
security concerns without hindering user experience.
5. Lack of participation of smaller entities and individuals: Currently reselling of Internet data
is not permitted. This restriction prevents small entities and individuals to participate in
the Wi­Fi ecosystem and expand Wi­Fi services in neighbourhood, villages, and other areas.
To provide Wi­Fi services one needs to take franchisee or become agent of an Internet
Service Provider (ISP), which may discourage participation of smaller entities.
Mobile data offload: Lack of policy clarity on offloading of mobile data by a telecom
operator onto the Wi­Fi network operated by another provider is one of the constraints
limiting offloading of mobile data on Wi­Fi networks.
Q2. What regulatory/licensing or policy measures are required to encourage the deployment of
commercial models for ubiquitous city­wide Wi­Fi networks as well as expansion of Wi­Fi
networks in remote or rural areas?
1. De­licensing spectrum: The following frequency bands need to be de­licensed completely
for indoor and outdoor use in accordance with international best practices and
5150­5350 MHz
5725­5875 MHz
60 GHz (‘WiGig’/ V­Band)
71­76 / 81­86 GHz (E­Band)
http://articles.economictimes.indiatimes.com/2015- 07- 29
/news/64996753_1_telecom- infrastructure- digital- in
dia- telecom- service- providers
Specifically for E­Band, a lightweight registration process may be used to ensure that
point­to­point E­Band links do not interfere with existing links.
The limitations on EIRP and power spectral density and inconsistencies in these limitations
across bands need to be reviewed and aligned with international best practices and
developments. For instance, EIRP levels should be increased to provide parity of coverage
between 2.4 GHz and 5GHz.
The TVWS band should also be delicensed as a large number of countries have already
2. Increasing backhaul capacity: The process of enacting the legislation to rationalize Right of
Way procedures and fee for laying of telecom infrastructure across states needs to be expedited.
Any such legislation/policy should be premised on permitting deployment of Wi-Fi infrastructure
on government buildings/ electricity poles free of cost or at very low cost.
Enabling flexible Wi­Fi infrastructure and service standards: Wi­Fi providers should be
permitted to easily obtain hosting, management, and connectivity services from third
parties (Wi­Fi aggregators/hubs) that leverage efficient scalable and resilient datacenters,
i.e., cloud technology. Cloud­based Wi­Fi solutions can efficiently provide user
authentication, KYC & other compliance, and accounting at scale across millions of users
and hundreds of ISPs. Such services will enable all ISPs and Wi­Fi providers to achieve
interoperability and economies of scale. The ability to outsource these services to a
cloud­based solution will eliminate barriers to entry for new Wi­Fi infrastructure, facilitate
expansion in remote and rural regions, and ultimately will reduce costs of Wi­Fi services to
users. However, for cloud­based solutions to develop, the regulatory policy necessarily will
have to remove regulatory hurdles such as in­country restrictions on data management
(since cloud technology relies on pre­existing datacenters in multiple global locations) and
requirements for equipment inspection (since cloud technology uses virtual machines).
Reference should be made to best practices in other jurisdictions such as in the United
States, United Kingdom and Japan by adopting the global standards like hotspot 2.0 and
4. Defining security requirements at a high level: Rather than laying down prescriptive security
requirements including KYC compliance, the government should define the security
requirements at a high level such that the policy emphasizes on outcomes rather than the
process. It should allow industry the flexibility to deploy mechanisms to meet such
requirements including technological and contractual measures. With modern technologies,
Wi­Fi providers should be able to address government’s security concerns in a way that
would not hinder user experience.
Enabling participation of new players including small entities and individuals to provide
Wi­Fi services: Allowing reselling of Internet data and setting up of public Wi­Fi access points
without any legal constraints will go a long way in proliferation of Wi­Fi services. It will allow
efficient bandwidth utilization (for e.g. subscribers who have unused bandwidth can put data
for sale), bring down data prices and generate jobs. Multiple aggregator platforms/hubs
could emerge to provide authentication, metering and payment services. The market forces
should be allowed to mature the ecosystem w i t h innovation and entrepreneurship
without any regulatory intervention. While ISPs continue to be liable for meeting
licensing requirements, the Wi­Fi aggregators/hubs can enable implementation of such
requirements through business agreements with ISPs. This should not be restricted under
the reselling clause of the ISP license. All verification/ authentication and service support can
be handled by the underlying ISP. Also, outright restrictions with regard to the regulatory,
licensing, and legal status of Wi-Fi repeaters, Wi-Fi mesh network devices, and other
equipment which might be used to boost signal on customer premises (collectively, CPE or
Customer Premises Equipment) must be removed.
6. Enabling mobile data offload: The policy should explicitly allow offloading of mobile data by
the telecom service providers (TSPs) to Wi­Fi networks that are operated by other providers
including fixed line ISPs. The TSPs and Wi­Fi providers need to deploy global standards to
enable interoperability.
Mandating Neutral Wi­Fi deployments in public spaces: The policy should mandate
neutral host Wi­Fi deployments in public spaces so that any provider is able to participate by
leveraging the scalable cloud infrastructure solutions and there is no monopoly of a
particular provider in a specific venue.
Incentivizing hotspots in rural and remote areas: Public hotspots in remote and rural
areas may not have commercial viability for established Internet Service Providers (ISPs).
There is a need to incentivize businesses to open Wi­Fi hotspots in such areas. While market
forces may determine such incentives, the government may explore the possibility of
subsidizing such hotspots through the use of Universal Service Obligation Fund (USOF). The
government may also consider reducing the license fee and provide tax exemption for Wi­Fi
services especially in rural/ remote areas.
Q3. What measures are required to encourage interoperability between the Wi­Fi networks of
different service providers, both within the country and internationally?
There are various market driven models (neutral Wi­Fi networks, direct roaming agreements
between ISPs, Wi­Fi hub/aggregator/exchange models) which can allow interoperability between
Wi­Fi networks. The government should not mandate a particular model but instead encourage
various models to emerge. The government should focus on liberalizing the policies which presently
limit the proliferation of Wi­Fi services (such as de­licensing spectrum, simplifying RoW permissions).
The issues related to interoperability will also be addressed by market forces as the proliferation
of public Wi­Fi increases. The industry (including consortiums like WiFi Alliance, WBA) has been
working to develop technologies and standards to enable interoperability and this work needs to be
leveraged to mature the Wi­Fi ecosystem.
Q4. What measures are required to encourage interoperability between cellular and Wi­Fi networks?
The policy should allow offloading of mobile data by the telecom service providers (TSPs) to Wi­Fi
networks that are operated by other providers including fixed line ISPs. The TSPs and Wi­Fi providers
need to deploy global standards (e.g. 3GPP) to enable interoperability.
Q5. Apart from frequency bands already recommended by TRAI to DoT, are there additional bands
which need to be de­licensed in order to expedite the penetration of broadband using Wi­Fi
technology? Please provide international examples, if any, in support of your answer.
Commercially significant frequency bands which have been de­licensed completely (indoor and
outdoor) in many countries are still licensed or partially licensed in India. This severely limits the
capabilities of businesses to deploy latest technologies and expand service in India.
5150­5350 MHz
5725­5875 MHz
License exempt outdoor usage
with appropriate power limits
aligned with global best practices
and developments
Existing international equipment
ecosystem. Primary candidate to relieve
Wi­Fi crowding at 2.4 GHz
Existing international equipment
ecosystem. Primary candidate to relieve
Wi­Fi crowding at 2.4 GHz
Last mile fiber alternative for cellular backhaul
and fixed Internet
60 GHz (‘WiGig’/ V­Band)
Last mile fiber alternative for cellular backhaul,
fixed Internet and village connectivity
71­76 / 81­86 GHz
*Specifically for E­Band, a lightweight registration process may be used to ensure that
point­to­point E­Band links do not interfere with existing links.
The widespread deployment of Wi­Fi Access Points introduces a challenge of how to backhaul
them to the nearest high speed internet connection (usually a fiber POP). Given these devices will
be deployed close together and at or near street level, short range, high speed (several hundred
Mbps) wireless data links are needed. The V­Band and E­Band are ideally suited for these short
range, densely deployed, links
The limitations on EIRP and power spectral density and inconsistencies in these limitations across
bands need to be reviewed and aligned with international best practices and developments.
While de­licensing for effectively eliminating spectrum costs is an important step in
facilitating public Wi­Fi deployments, technical spectrum use rules should also be
modified to promote public Wi­Fi deployment and ensure efficient use of
de­licensed spectrum. The international ecosystem for consumer Wi­Fi equipment is
concentrated at 2.4 GHz and 5 GHz. In India, the majority of portable Wi­Fi devices operate
at 2.4 GHz. The penetration of 5 GHz devices is increasing and, with its relatively larger
amount of bandwidth, will be critical to increasing Wi­Fi capacity in the near­to­medium
term. Rules that facilitate the efficient use of 5 GHz are critical. The case of the United
States, where FCC has consistently expanded the unlicensed 5GHz bands, demonstrates
that such delicensing (a) can be performed without creating wide-scale disruptive
interference; and (b) can drive significant economic stimulus.
In particular, EIRP and power spectral density limitations in at least part of the 5 GHz
de­licensed band should be increased so that a 5 GHz access point (AP) can achieve
approximately the same range as a 2.4 GHz AP. Matching of EIRPs among the two
bands would allow operators to cost­effectively deploy APs supporting 2.4 GHz and 5 GHz
(e.g., as opposed to a potentially cost­prohibitive approach with different densities of APs
in the two bands).
GSR 45E dated 28.1.2005 permits unlicensed operations up to 4 W ERP in 2400­2483.5 MHz,
while GSR No 46E dated 28.1.2005 permits unlicensed indoor operations of up to only 200
mW EIRP in 5150­5350 MHz and 5725­5875 MHz.
Note: IND71 to the 2011 National Frequency Allocation Plan already provides that DoT may
permit on a case­by­case basis operation of wireless access systems at up to 4 W ERP in
5725­5875 MHz. We suggest that 4 W ERP in 5725­5875 MHz be permitted broadly on an
unlicensed basis. To achieve 4 W ERP with a Wi­Fi signal, a proportionate increase in the
power spectral density limit is required and also recommended. Operations up to 10 mW EIRP
(equivalent to 6 mW ERP) in any 1 MHz sub­band of 5725 to 5825 MHz are currently
permitted. In order to permit Wi­Fi signals with 20 MHz bandwidths to operate at 4 W
ERP, the power spectral density limit should be increased to 200 mW ERP per 1 MHz of the
5725­5825 MHz band.
Additionally, TVWS frequencies should also be delicensed for meeting the connectivity needs of
remote/ rural areas. International examples of permissive TVWS licensing or outright
delicensing include the United States, Canada, United Kingdom, Singapore, Finland, Malawi,
South Africa, and Ghana. Pre-license pilots have been permitted in Colombia, Bhutan,
Botswana, Brazil, Cote d’Ivoire, Ghana, India, Indonesia, Japan, Kenya, Gabon, Morocco,
Namibia, Nigeria, the Philippines, South Korea, Tanzania, Taiwan, and Uruguay.
Q6. Are there any challenges being faced in the login/authentication procedure for access to Wi­Fi
hotspots? In what ways can the process be simplified to provide frictionless access to public Wi­Fi
hotspots, for domestic users as well as foreign tourists?
The existing regulatory requirements are overly prescriptive discourage users from signing on to
public Wi­Fi services. The government should define the security requirements and allow industry
the flexibility to deploy modern technologies (for example that allow SIM based identification) to
meet those requirements. A number of technologies have been proposed to unify and simply Wi-Fi
roaming and access. In general, we support the approach taken by the 802.11u standard, HotSpot 2.0,
and Passpoint (“Wi-Fi Certified Passpoint) technologies. Such technologies permit online sign-up,
immediate account provisioning, secure registration, adding multiple devices, and the enforcement of
operator-specific policies.
Q7. Are there any challenges being faced in making payments for access to Wi­Fi hotspots? Please
elaborate and suggest a payment arrangement which will offer frictionless and secured payment for
the access of Wi­Fi services.
Payment issue is not specific to public Wi­Fi but needs to be addressed from the larger perspective of
digital economy. Unified Payment Interface (UPI) and mobile wallets are example of free market
dynamics offering various solutions. Government should not mandate any specific platform(s) and
should support emergence of multiple payment solutions. Multiple payment methods should be
allowed for access to Wi-Fi hotspots, such as cash, electronic recharge, paper vouchers, online
payment, etc.
Q8. Is there a need to adopt a hub­based model along the lines suggested by the WBA, where a
central third party AAA (Authentication, Authorization and Accounting) hub will facilitate
interconnection, authentication and payments? Who should own and control the hub? Should the hub
operator be subject to any regulations to ensure service standards, data protection, etc?
There are issues with a central third party AAA hub. Some of the concerns are: such approaches
unnecessarily centralize information, raise innovation barriers, and increase costs of compliance.
Moreover, such an approach would represent a security target for hackers providing a single point of
critical information storage.
Instead, TRAI could adopt a alternatives models like wi-fi Aggregators providing AAA services or other
models oriented at the standardization of AAA APIs which are to be implemented by identity providers
(login providers) wishing to participate such that ISPs can connect to each other on mutually agreed
commercial arrangement to provide intra-operability of the payment instruments/ balance transfer etc.
The regulatory requirement to host data and infrastructure in­country needs to be relaxed to attract
innovation in this area in the Indian market.
Q9. Is there a need for ISPs/ the proposed hub operator to adopt the Unified Payment Interface
(UPI) or other similar payment platforms for easy subscription of Wi­Fi access? Who should own
and control such payment platforms? Please give full details in support of your answer.
Further to our response to Q7, the ISPs/hubs should be allowed to enter into agreement with any
of the payment platforms based on market dynamics. As highlighted earlier, as the proliferation of
Public Wi­Fi increases, issues such as payments will get addressed by the market forces.
Q10. Is it feasible to have an architecture wherein a common grid can be created through which
any small entity can become a data service provider and able to share its available data to any
consumer or user?
The common grid providers might bring the greatest commercial value to the small entities through
aggregation that enables those entities to participate in regional or national commercial offerings. In
parallel, the common grid providers could make it efficient for the commercial operators to deliver
their services over a multitude of small networks. If the end user is allowed to put his own APs /
repeaters to enhance his signal and provide to the surrounding communities commercially then there
should not be any meaningful technical barrier to a common grid architecture. Multiple common grid
players should be allowed to operate, without being regulated, for reasons as highlighted in our
response to Q8.
Q11. What regulatory/licensing measures are required to develop such architecture? Is this a right
time to allow such reselling of data to ensure affordable data tariff to public, ensure ubiquitous
presence of Wi­Fi Network and allow innovation in the market?
Allowing reselling of data and setting up of public Wi­Fi access points without any legal constraints
can go a long way in proliferation of Wi­Fi services by enabling efficient bandwidth utilization (for
e.g. subscribers who have unused bandwidth can put data for sale) and bringing down data prices,
and can also open huge employment opportunity at bottom of the pyramid..
Multiple grids/ aggregator platforms/hubs could emerge to provide authentication, metering and
payment services. Such grid providers can enter into business agreement with ISPs and the
compliance requirements can be negotiated between the two parties based on the respective roles
and responsibilities.
Notably, there should be no legal obligations on the entities and individuals setting up and providing
Wi­Fi services. While ISPs continue to be liable for meeting licensing requirements, the Wi­Fi
aggregators can enable implementation of such requirements through business agreements.
Q12. What measures are required to promote hosting of data of community interest at local level
to reduce cost of data to the consumers?
For urban areas with greater market potential, the market forces will be adequate to create the local
ecosystem. In rural and remote areas, government may have to incentivise the creation of local
For areas where there is inadequate fibre/copper backhaul, refreshing of the data at the local level
can be time consuming and expensive. To overcome this challenge, satellite link can be leveraged for
backhaul. But this would require policy clarity on use of satellite communication for this purpose.
Moreover, TRAI or the Government must encourage “edge caching” by explicitly permitting such
activities without prohibitive regulation or licensing. Such caching benefits both end users by reducing
latency as well as cost and ISPs by reducing upstream bandwidth requirements. Provided there are no
regulatory or legal hurdles imposed, caching thus presents sufficient incentive to both ISPs and their
customers to be driven by market dynamics and there is no need for any regulatory intervention.
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