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Appendix
REPLY TO DOT REFERENCE ON NATIONAL BROADBAND PLAN
TRAI RECOMMENDATIONS
5.65 SOFA
will
undertake
the
reinstatement work itself or will
pay the reinstatement charges to
the concerned agency.
DOT REMARKS
Creation of SOFA for each state
would not be practicable. The
Executive
Agency
will
be
responsible for establishment,
management & operation of
NOFN.
The
tripartite
MOU
amongst DOT, Concerned state
and Executive Agency would take
care of various issues related to
Right of Way permission and
Right of Way Charges.
The capacity of the proposed
NOFN for providing Broadband is
scalable depending on the CPE
and backhaul capacity. The
download speed is achievable
depending on the deployment of
suitable CPE and availability of
required backhaul bandwidth
capability.
TRAIS COMMENTS
The Authority's views regarding
SOFA may kindly be seen at
Annexure - D.
Accepted
No Comment.
Accepted
No Comment.
Accepted
No Comment.
No Comment
No Comment.
No Comment.
contained in Annexure A
7.16 The
objective
of
national
broadband Network is to provide
fibre to home in 63 cities covered
under JLNRU, Fibre to curb in
all other cities (0.5 Km from any
residence).
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Annexure - A
11
Singapore
Malaysia
Sweden
United
Kingdom
United
States
nationwide
broadband
including
rural
areas.
Government to provide USD 11.6 billion under various
broadband programs.
Further USD 2.5 billion is made available for grants
loan and loan guarantees.
9. The optic fibre network in all habitations serves the advantage of the
telecom services being subject to the market forces whereas the Rural
Wireless Broadband Scheme can induce and sustain an anti-competitive
behaviour either vis--vis the other service providers or the consumers.
10. Having bid for the spectrum, either for 3G or BWA services, it is the
responsibility of the service providers to go to the rural areas. The rural
wireless broadband scheme effectively subsidises the telecom service
providers and that too only two of them. Considering that the costs of
the scheme have not been finalised and given the possibility of
additional investment from time to time, effectively it means
underwriting the cost of these two service providers in serving the rural
areas. This has the potential of the cost of the scheme being a
significant portion of or even exceeding the revenues that have been
realised from the auction of 3G and BWA spectrum.
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Annexure B
Provision of optical fibre network in the urban areas
1. Optical Fibre network in the cities is primarily used for meeting the
backhaul requirements. Even though the Optical Fibre network in
aggregation layer is available in many cases, the Optical fibre has not
reached the homes. Today out of 11.47 million Broadband connections,
only 0.28 million are working on Fibre. Therefore, it is desirable that
Fibre is extended to homes at least in 63 cities where bandwidth
requirement is high.
2. With increasing growth in the economy, and a globalised world, the need
for increased bandwidth cannot be overemphasised. Many cities in the
world are already working towards provision of speeds of 100 Mbps.
Such high speeds are better provided through optic fibre network rather
than wireless broadband. It should also be noted that currently, the
world over, 65% of the bandwidth consumption is indoors, either at
home or in office. This being the case, using only wireless broadband
spectrum also constitutes a waste of precious spectrum. Yet another
feature is the growing trend towards multi dwelling units in the metros
and large cities, rendering the provision of broadband easier. It is
therefore necessary for the large cities to be provided with a ubiquitous
and efficient broadband network capable of delivering high speeds. This
should be an inherent aspect of the urban development process in our
country.
3. Currently, growth of broadband in urban areas is low due to nonavailability of fibre both in the aggregation and access networks. Wireless
in access network may provide wider coverage but lacks high capacity
bandwidth support. Scarcity of spectrum and required number of BTS to
support the increasing demand is a key constraint. It is difficult to
provide high speed broadband with good quality of service using only
wireless technology.
4. Futuristic networks can only be created by deploying the deeper fibre
networks within the close proximity of the users. The robustness of any
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Annexure- C
Rationale for Creating National Optic Fibre Agency
(NOFA)
1. Creation of an optical fibre network in the country requires a
dedicated agency for planning, operation and provision of required
bandwidths to its users. In the remarks against paragraph 7.05
and 7.06, the DOT have stated that during the deliberations in the
Department, it was felt that the creation of NOFA merits serious
consideration. Yet, the scheme that is formulated does not make
any provision for this. Instead, the institutional mechanism for the
National Optic Fibre Network (NOFN) envisages the setting up of a
high-level committee as well as an advisory body with BSNL being
the executing agency. It is only at stage two, the timing of which is
to be decided subsequently, that an SPV is proposed to be formed.
The Authority is of the view that the present proposal runs the risk
of being dependent on the release of USO fund by the Government
and therefore being subject to the normal budgetary processes.
There is a possibility that it will be functioning more like a 100%
centrally sponsored scheme. On the other hand, constitution of a
National Optic Fibre Agency (NOFA) has the merit that the Agency
can manage the availability of funds as per need without having to
depend on the government. Besides, it can also cover the urban
areas as mentioned in Annexure B.
of the work involved coupled with the need for overall aggregation
and integration at the national level. This is admittedly a complex
task requiring a day-to-day oversight and can only be done by a
dedicated agency.
4. While NOFA can leverage USO fund to raise the loan for
implementing National Optical Fibre Network, the proposed
scheme of DoT runs the risk that BSNL cost may be offloaded on
NOFN, BSNL being Executing Agency. This will result in high cost
of broadband provisioning to the customers.
5. NOFA will be lean agency and minimize the cost of operation.
6. NOFA can receive fund from leasing the network for further growth
of the optical fibre network whereas all revenue collected by USOF
will go to Government and may not be reinvested in the network.
7. For the above reasons, the Authority strongly reiterates its
recommendation for the creation of the National Optic Fibre
Agency.
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Annexure- D
Creation of State Optical Fibre Agency (SOFA)
1.
2.
3.
Size
Cities with
Population
Above 1 million
Above 1 lakh to 1
million
Above 10000 to 1 lakh
Villages with
population
10000 and below
4.
0.25
0.75
0.25
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Annexure-E
Problem of BSNL as Executing Agency
1. As per clause 3.1.4 of the draft scheme of the DoT, BSNL has been
indicated as the Executing Agency with a dedicated project
implementation team. It would be the vehicle for implementation of the
National optic fibre network at this stage. Significantly, the policy
decisions, supervision and control of BSNL will be carried out by the
HLC/USOF.
2. While the objective appears to realise speedy and efficient execution of
the programme, the Department of telecommunications would need to
consider whether the Public Sector Undertaking, given its autonomous
status, can be controlled in terms of decisions and supervision by the
HLC or USO fund. The possibility of severe criticism in this regard is to
be considered.
3. It is noticed from the composition of the high-level committee given in
paragraph 3.1.1 of the draft scheme that BSNL would be a Member of the
committee. Since crucial decisions -- the scope of work, execution
strategy, funding requirement and timeframe -- would be decided by the
High-level committee, the possibility of a conflict of interest between
BSNL as executing agency and as a member of the HLC needs to be
considered.
4. BSNL is essentially a Telecom service provider. Given the extreme
importance of the project and the close supervision by two high-powered
bodies, it is possible that the energies of the senior management of BSNL
would be diverted away from its core task of managing Telecom services.
Already, BSNL has been registering losses in the last few quarters and
there is need for BSNL to utilise all its energies in restoring the health of
the enterprise.
5. BSNL is currently one of the service providers. If it is the executing
agency including the maintenance of the network, there is a serious
problem of the lack of level playing field vis-a-vis other service providers.
This would be critical since the optic fibre network is envisaged as
providing non-discriminatory access. There is a serious risk of anticompetitive behaviour setting into the network management.
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Annexure F
Other Issues
1. There are certain other issues which seem to be against the statutory
provisions. The user charges are proposed to be fixed by USOF/ DoT.
However, as per the provisions of TRAI Act 1997, TRAI should fix the
charges for provision of various telecom services which includes leasing
of the bandwidth. TRAIs recommendation vide Para 5.64 proposes that
Optical Fibre Capacity may be leased out to service providers on demand
at predetermined rates prescribed by the regulator.
2. Attention is also drawn to Para 2.1.2 of DoT reference, wherein user
charges for the incremental infrastructure would be determined by
USOF/DoT. As explained earlier TRAI Act envisages fixation of charges
for provision of various services by TRAI. The framework may be revised
to strictly conform to the provisions of the TRAI Act.
3. It is noticed that the draft Tender document stipulates QOS parameters.
Since the QOS parameters are determined by TRAI, the QOS parameters
may not be detailed in the tender document except to state that they
shall be in conformity with the parameters laid down by TRAI from time
to time.
4. An analysis of the provisions in the tender document for the Rural
Wireless Broadband Scheme brings out the following concerns:
a. The scheme proposes to provide subsidy support as a percentage
of capital recovery for setting up and management of wireless
broadband network. It does not provide any details for number of
connections to be provided or the time frame to meet the
broadband requirement of various villages. Any effective network
planning is done based on the projected traffic requirement within
certain period. Even with modest target of 100 million connections
by 2014, the bandwidth requirement per village will be
substantially high and will be difficult to be met by wireless
network.
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