[cr-india] TRAI Open House in Delhi - first impressions

[Vickram Crishna]

Thanks Sajan.

Now let's look at their brief, and the reality. This is a pretty long 
mail, the first part being a discussion of the SACFA guidelines, the 
middle part specific suggestions for inclusion in a recommendation 
paper for TRAI, and the last being a recompiled list of 
recommendations incorporating all these. I have put several line 
spaces to separate these three parts, to make it easier to scroll 
down. When commenting please only copy the relevant portion and not 
the whole mail.

Both Arun and I, among others, have advocated over the years that it 
should not be the role of the government to adjudicate between 
different technologies, but only with their application. 
Unfortunately the trend to omniscience continues, with TRAI mandated 
to rule on carriage instead of content, and in this case, 
specifically for FM, rather than public service. In fact, on this 
list and at the various Open Houses we all have more or less accepted 
that the broadcast code used by AIR is good enough to continue for 
all. However, the real threat to use of the Code is the technical 
obfuscation and cumbersome procedures adopted for no good purpose.

Although we do not believe that this process is the most effective 
way to go about things, we do not refuse to participate, rather we 
hope that our inputs will add value to the extent possible, in 
generation of good policy.

At 1:35 PM +0000 10/25/04, sajan venniyoor wrote:
>SACFA has given fairly extensive guidelines on siting procedure for 
>wireless stations on their website 
>(www.dotindia.com/wpcc/spectrum-home.htm). Apparently, local 
>building laws apply (and mast height clearance is exempted from 
>SACFA clearance) only if the mast and antenna are installed on a 
>rooftop and their height is less than 3 metres (see below).

Exactly. They already have some kind of guideline that was clearly 
intended to ease their work, but which seems to have been, in the 
typical bureaucratic way, been expanded to include everything but the 
kitchen sink - and even that, if it is over 3 meters high. Easier 
work ends up taking two years and more to clear a simple matter like 
an application to broadcast low power FM. There must be a better way.

>Stand alone transmitter towers are covered by other norms. And any 
>radio station with a 100+ watt transmitter comes under the 'Full 
>Siting Category', which sounds quite dire.
>.....
>The  technical evaluation is done primarily for-
>
>a)      Aviation hazards.
>b)      Obstruction to line of site of existing/planned networks     
>c)      Interference (Electro Magnetic Interference (EMI)/Electro 
>Magnetic Compatibility (EMC)) to existing and proposed networks.

a) Aviation hazards are covered, please note, in a manner that is 
surely inadequate by today's aviation norms. I would like to know 
what kind of commercial jets normally flies off short runways? 3 km 
is the runway length alone, for most large bodied commercial jet 
aircraft, the type used in India, and for practically all land-based 
fighter aircraft. Surely they have the right to expect 
interference-free communications for more than that length after 
take-off? My point being that there is a case to believe that the 
departments are not concerned with effective governance, but only in 
status quo and maintenance of power.

If the techies within SACFA (would this be the civil aviation 
ministry experts?) know how to avoid interference for low flying 
aircraft, and conversely, how to use low power radio signals to mess 
up communications for low flying aircraft, especially in landing and 
take-off, this ought to be public knowledge, to avoid mishap in the 
future. Only terrorists and governments hoard information.

b) Existing/planned networks! And who on earth do they think is doing 
the planning? This sounds like a perfect Catch-22.  The same reaction 
hit me when I looked at the next point, which refers to proposed 
networks, without any hint of when such networks are expected to be 
implemented.

Still, this is in a sense nitpicking, and if one could be lucky 
enough to find non-venal or dedicated officers filling the steering 
seats in SACFA, the guidelines should not, theoretically, pose a 
hindrance to speedy clearance of new applications. Since this is not 
a given, with the current level of dedication obvious among 
government officers (evidenced by the extraordinary rapidity with 
which last year's applications have been disposed), there is no harm 
in asking TRAI to make things a bit clearer, either by sticking to my 
original suggestion, or by appointing a special low-power wireless 
frequency clearance committee that overrides SACFA's brief for the 
specified FM band.

I have discussed these two scenarios once again below, plus added a 
suggestion for conflict resolution on EMI/EMC interference.

># Exemption from Mast Height Clearance:
>Sites for HF/VHF/UHF:
>Those mast height cases which satisfy the following conditions are 
>exempted from mast height clearance:-
>(i)     Antenna mast should be installed on the rooftop of the building.
>(ii)     The height of mast including antenna to be installed on the 
>rooftop should not be more than 3 meters.
>The site should be at least 3 KM away from the nearest airport.

If you have seen photos of cities like Toronto and Stuttgart, one 
very prominent feature of the skyline is the TV tower, a commercial 
building with a large mast on top. This allows the offices, studios 
and antennae of the enterprise to be conveniently situated in one 
building. Unfortunately, we don't have this luxury in any of our 
cities, and negotiating a deal with an existing building owner could 
be as inconvenient or just plain bad business sense (example: imagine 
a special arrangement with a frequency clearance officer for say, one 
year's operations only, next year come back and deal again).

># Full Siting Category:
>        
>The following fixed stations are covered under the full siting category:
>        
>(a)     All HF stations with power output more than 125 watts.
>
>(b)      (i)     All VHF stations below 174 MHz with power output 
>more 50 watts.

Amazing. Can anyone imagine why SACFA was given this life-and-death 
control in the first place? 50 watts! But look at (c) below, and it 
is clear that section b) is *not intended* to cover FM broadcasting 
stations. Whether or not the 50 watt categorisation is justified, it 
does not affect those interested in low power FM broadcasting. It 
does however, impact on the liberalisation of AM (medium wave) 
broadcasting.

>(ii)     All VHF stations in the frequency range 174-230 MHz with 
>power output more than 25 watts.
>(c)     Broadcasting stations in the frequency band 30-230 MHz with 
>power output more than 100 watts.

So it is only FM broadcasting stations with power above 100 watts 
that get covered by the "full siting category" nutcracker. I do not 
understand why low power AM is getting stepmotherly treatment. While 
the medium does not guarantee noise-free audio to the receiver, it 
can work better for hilly areas, which is many important parts of the 
country. I am puzzled by the lack of interest in speedy disposal of 
applications for medium wave broadcasting as well as FM. I think 
discussions on this list have not paid sufficient attention to 
establishing community-focused public service radio in areas where FM 
is not the most suitable choice.

>On Sat, 23 Oct 2004 Vickram Crishna wrote :
>>I endorse the substance of Arun's recommendations, but suggest a 
>>couple of minor additions )interleaved below):
>>At 12:41 PM +0530 10/22/04, Arun Mehta wrote:
>>>My $0.02 -- figures I could live with -- so that we can quickly 
>>>send a response to TRAI..
>>>   > 5.    Antenna height
>>>As allowed by local building laws
>
>  >SACFA to be directed to release a list of forbidden 
>areas/frequencies, so that applicants may self-determine the 
>combination of 5 (antenna height) and 6 (reach) accordingly, without 
>causing nuisance to any existing user. In case the user (who need 
>not be named) is not actually using equipment currently to broadcast 
>in the designated band (87.5-108 MHz) such areas should be 
>de-notified upon receipt of information. TRAI may appoint an 
>independent body to monitor such usage of the broadcast bandwidth.

I hadn't spotted the detailed SACFA guidelines before putting out 
this suggestion, and now feel that it wasn't specific enough to deal 
with the threat of stiflement, with which we are already familiar.

I therefore suggest that TRAI adopt a clear policy for both low power 
medium wave and FM broadcasting, opening up - liberalising licensing 
- of which will create an environment for the production of better 
content than we currently experience, given the expensive luxury of 
stations that constitute the commercial FM bands.





This policy may encompass Arun's suggestions just as posted to this 
list, but with the following modifications (numbering as per Arun's 
original - I have, right at the very end, compiled a complete list 
for ease of reference):

5. Antenna height: Use of antennae for medium wave or FM transmitters 
under 100 watts will be allowed at heights up to 3 meters from the 
topmost point of existing buildings and natural prominences, subject 
to the site being at least 3 km from the runway direction within 45 
degrees to either side, for both ends of the runway. The construction 
of the mast should be in conformance with local building laws, 
wherever applicable.

Explanation: Aircraft communications that can be affected by 
terrestrial broadcasting are only relevant in line with the runway. 
An aircraft that is approaching a runway over 45 degrees from its 
direction is obviously not intending to land, and is also unlikely to 
be low enough that interference with communications could even happen 
in the first place.

Note: I don't know who must have dreamed up the 3 meter restriction, 
but at least one thing is reasonably clear: such a short mast is not 
likely to be a hazard to persons in the vicinity, and even a very 
poorly trained mason or ironworker ought to be able to erect such a 
tower competently and inexpensively.

In rural areas, expect incompetency: the lack of training and skills 
is closely linked to the lack of education and opportunity. This is 
in fact why the need for effective communication is urgently felt.

Although optimal reach is as important in rural areas as in urban, 
and in fact even more so, given the relative paucity of financial 
resources for development, a rule that limits access to simplified 
antenna placement to buildings only is discriminatory: tall trees, 
rocks and hills must also be allowed. Usage restrictions of all kinds 
need to be eased or lifted entirely. Antenna masts should not be 
defined as 'constructions', or else forest dwellers will be denied 
use of their own natural resources.

6. Permissible reach/coverage: As determined by the applicant, taking 
care not to interfere with broadcasting/communications from existing 
wireless networks. In case a new wireless network is already under 
implementation, care should be taken by the newer station to avoid 
interference with the older applicant. Such a condition will only 
apply for eighteen months after start of construction.

Explanation: Low power broadcasting has been determined to be 
irrelevant to high power broadcast signalling quality at the 
recipient side. The reference is the Mitre study, carried out 
independently but taken on board by the US FCC, in determining 
conditions for future licensing of low power wireless broadcasting in 
the USA.

This means that if the new station under implementation is a high 
power station, then the fresh applicant will have to take care not to 
interfere when the station is ready. However, it is not a blanket 
veto handed over to potentially dog-in-the-manger station owners, it 
will be time limited to eighteen months from the start of 
construction of the station. If they delay construction or are 
otherwise delayed in beginning operations, they should not forever 
enjoy early bird benefits.

14. Conflicts: The District Collector should carry the role of 
ombudsman in local interference conflicts, in case any such arise. If 
the conflict cannot be resolved through technical adjustment of 
existing installations, the Collector may be empowered to expedite 
the assistance of technical experts from the relevant ministry to 
recommend a solution.

Explanation: With SACFA and WPC out of the picture, it is important 
to replace them with a more effective local governmental mechanism.






Complete list of recommendations:

1.     License fee
none
2.     Spectrum Usage Fee
none
3.     Bank Guarantee
none
4.     Transmitter power
100W, for more, you have to apply specially.
5.     Antenna height
Use of antennae for medium wave or FM transmitters under 100 watts 
will be allowed at heights up to 3 meters from the topmost point of 
existing buildings and natural prominences, subject to the site being 
at least 3 km from the runway direction within 45 degrees to either 
side, for both ends of the runway. The construction of the mast 
should be in conformance with local building laws, wherever 
applicable.
6.     Permissible coverage area of CR station
To be determined by the applicant, taking care not to interfere with 
broadcasting/communications from existing wireless networks. In case 
a new wireless network is already under implementation, care should 
be taken by the newer station to avoid interference with the older 
applicant. Such a condition will only apply for eighteen months after 
start of construction.
7.     Quantum of advertisements per hour of programming
Ten minutes maximum
8.     Permissible limit of advertisement revenue per CR station
Not more than 25% of total revenue
9.     Number of licenses per CR licensee
One per coverage area, more subject to availability of spectrum. 
Spectrum availability to be publicised, against a review of the 
technical specifications for FM broadcasting prevalent in major 
wireless user countries.
10.     Frequencies to be allotted for CR /Maximum number of CR
stations per location
Three reserved frequencies; if there are more applicants in a given 
region this number may be expanded, subject to availability of 
spectrum. The District Collector will be the Competent Authority for 
allocation of reserved frequencies.
11.     Period of license / period of extension
Same as commercial
12.     Time limit for clearances
3 months
13.     Period for preserving audio logs
Indefinite. Archiving done at central facility created for this 
purpose. Use CDs, and specify compliance with a suitably open format 
(it is inefficient to define the actual format to be used by each 
station, as long as data is exchange-compliant).
14.        Conflicts
The District Collector should carry the role of ombudsman in local 
EMI/EMC interference conflicts, in case any such arise. If the 
conflict cannot be resolved through technical adjustment of existing 
installations, the Collector may be empowered to expedite the 
assistance of technical experts from the relevant ministry to 
recommend a solution.
-- 
Vickram