“COAI appreciates the Government’s underlying policy intent to leverage broadcasting capabilities to offload unicast traffic from mobile networks, to deliver video content to the consumers through broadcasting and save bandwidth. However, the draft policy document for the Direct-to-Mobile (D2M) network requires re-evaluation on the aspects of level playing field, spectrum allocation, network integration, and regulatory and cost arbitrage in favour of the proposed PPP model and against the TSPs.
The present proposal on spectrum assignment for a D2M network for broadcasting content delivery to smartphones and other devices needs to be reviewed comprehensively, especially from a level playing field point of view and to ensure that it does not become a source of regulatory arbitrage. The spectrum envisaged for D2M Service (i.e., 526 – 582 MHz) should be allocated to the service providers to use broadcasting capabilities (D2M) as per the market requirements on the spectrum assigned through auctions. It must be noted that TRAI had recommended refarming of existing usage in this band so that it can be made available for IMT and has commercial value.
Building a dedicated D2M network by earmarking spectrum specifically for the broadcasting infrastructure providing competing/complimentary services would lead to breach of level playing field. Offloading cellular networks also requires a close integration of broadcasting capabilities with cellular networks, so that the spectrum and infrastructure can be optimally leveraged for broadcasting and IMT services as per the demand. A dedicated D2M network, built by a third party, will not be able to achieve these aspects optimally.
Recently, the Consultative Committee of TEC for adoption of proposed ATSC 3.0 standards into National Standard has noted several shortcomings in the same. The Committee recommended that Global precedents of the technology, coexistence studies and impact on mobile networks need to be shared by TSDSI. Further, clarification has been sought on the applicability of this standard for commercially available mobile handsets, as none support this standard currently. It also needs to be considered that after adoption, the documents will be allotted TEC document numbers and hosted on the TEC website. ATSC 3.0 being a technology owned by a foreign entity, it is not clear if copyright permission/authorization for the same could be granted by TEC. The other issues include lack of support for NavIC, Digital Rights Management (DRM) and next-generation audio codecs, etc.
Importantly, there seems to be an incorrect assumption that a dedicated D2M network is required for sending alerts during disasters. Cellular networks have been successfully delivering SMS-based disaster alert messages though Common Alerting Protocol (CAP) platform. Recently, trials for Cell Broadcast method have also been conducted.
It is crucial to ensure that any D2M service implementation aligns with national legal and technical standards and does not result in regulatory arbitrage in providing the content services on mobile handsets. For the complete and effective utilization of the 526-582 MHz spectrum band, a transparent auction of spectrum, a technology-neutral approach with a focus on seamless integration into the existing mobile networks is recommended.”
- Lt. Gen. Dr. S.P. Kochhar, Director General, COAI
