Yesterday, the Telecom Regulatory Authority of India (TRAI) proposed allocating an additional 5 MHz spectrum in the 700 MHz band to Indian Railways, intended for safety and security applications. Currently, this band is partially utilized by Reliance Jio (RJIO) for standalone 5G services. The history of the 700 MHz band in India has been marked by controversies since its valuation in 2012, when TRAI set its price at four times the value of the 1800 MHz band. This valuation, made prematurely, disregarded the lack of global adoption and an established band plan—essential prerequisites for effective spectrum utilization. Moreover, TRAI’s methodology involved substantial calculation errors, driving prices to unrealistic levels. These missteps were detailed in my earlier articles, notably on April 19, 2016, and February 9, 2024.
In 2016, TRAI compounded the issue by revisiting its 2012 recommendations without conducting a fresh, ground-up valuation, leaving the 700 MHz band unsold in multiple auctions. It was only in 2022 that RJIO acquired 10 MHz of this spectrum. Meanwhile, Bharti Airtel, despite extolling the benefits of the 700 MHz band in its 2021–22 annual report, chose not to purchase it during the same auction when 30 MHz was on offer. Airtel later publicly stated that its 5G network could operate reliably without this band.
With TRAI now recommending the allocation of the remaining 5 MHz in this band to Indian Railways, this article delves into the implications for stakeholders, particularly RJIO and Airtel, as the remaining spectrum in the 700 MHz band becomes unavailable for commercial use.
Balancing Public Interest: Railway Safety vs. 5G Development
The 700 MHz band, whether allocated to Indian Railways or telecom operators, ultimately serves the public interest, as both would leverage it to deliver benefits to consumers. However, the key question is not simply who uses the spectrum but which application maximizes value for India’s economic and consumer needs. A thorough benefit analysis should guide this decision, weighing the relative importance of railway safety against the critical need for a robust 5G network.
While enhancing railway safety is undoubtedly vital, it is equally important to ensure that India’s 5G infrastructure can fully unlock its capabilities. Without sufficient spectrum in the 700 MHz band—a crucial frequency for wide-area coverage and efficient connectivity—the full potential of 5G to revolutionize industries and empower consumers may remain unrealized. Moreover, as India aspires to be a global leader in next-generation technologies like 6G, the implications of exhausting this spectrum must be carefully considered. TRAI’s current recommendation overlooks a crucial aspect: how the lack of additional spectrum in the 700 MHz band could hinder India’s ambitions for digital transformation in both 5G and 6G, potentially undermining its global competitiveness.
How the Lack of 700 MHz Spectrum Will Limit RJIO’s Ability to Unlock the Full Capabilities of 5G
India currently has four telecom players contributing to the rollout of 5G services. For these players to fully unlock 5G’s potential, they require adequate and contiguous spectrum in the sub-GHz band (frequencies below 1 GHz). Both “adequate” and “contiguous” are key. By “adequate,” we mean at least 20 MHz of spectrum, while “contiguous” refers to this 20 MHz being assigned within a single band, not fragmented across different bands or divided into multiple non-adjacent blocks.
The need for 20 MHz of sub-GHz spectrum arises because higher-frequency bands such as 1800, 2100, 2300, 2500, and 3500 MHz lack effective indoor penetration for homes and offices. While indoor Wi-Fi can complement 5G networks, but quite unlike 4G, it (WiFi) cannot replace their (5G) capabilities. Therefore, a contiguous 20 MHz block in the sub-GHz spectrum is essential, especially for operators with large customer bases. This would ensure that advanced 5G services, such as handset-level slicing, can be delivered without congestion. A mere 10 MHz block is insufficient. Not only does it limit capacity, but reserving even half of this spectrum for network slicing leaves minimal bandwidth for best-effort services, leading to network bottlenecks.
Moreover, operators cannot aggregate spectrum across disparate bands, such as 700 MHz and 800 MHz, to create a larger block. Carrier aggregation between closely spaced low frequency bands suffers from inefficiencies due to diplexer losses, which reduce combined network coverage by up to approximately 40%. This fact has been explained in my article dated 5th Sept 2023 – Why the Operators Need to Choose a Specific Sub GHz Band for 5G?. As a result, RJIO, which currently holds only 10 MHz in the 700 MHz band, finds itself unable to expand its footprint within this critical spectrum. Without a pathway to grow in this band or effectively combine it with its 800 MHz holdings, RJIO’s ability to deliver high-quality 5G services, particularly handset-level network slicing, is severely undermined.
This limitation likely explains why RJIO strongly opposed allocating the additional 5 MHz of 700 MHz spectrum to Indian Railways during TRAI’s consultation process, as highlighted in their response. Their stance underscores the importance of retaining sufficient commercial spectrum in this band to ensure the success of India’s 5G ecosystem.
How the Allocation of 700 MHz to Railways Impacts Bharti Airtel
Interestingly, the assignment of 700 MHz spectrum to Indian Railways aligns with Bharti Airtel’s business interests—a fact that might surprise readers. Here’s why. As discussed earlier in this note, Bharti chose not to purchase any 700 MHz spectrum during the 2022 auction, even though 30 MHz was available. This decision, in my view, was largely influenced by the Supreme Court’s AGR judgment, which significantly strained Bharti’s cash flow, costing the operator approximately ₹50,000 crore. For additional context, refer to my earlier article, “DoT AGR Demand – Operator Impact.”
The high cost of 10 MHz in the 700 MHz band—around ₹40,000 crore—was likely a major deterrent for Bharti. With no current footprint in this band, Bharti benefits indirectly from the Railways’ allocation, as it limits further expansion opportunities for its competitors in the 700 MHz spectrum. Attentive readers may note this subtle alignment in Bharti’s submissions to TRAI, where the focus was not on opposing the allocation to Railways but on ensuring that Railways cannot commercially exploit the spectrum, such as offering WiFi services to passengers.
Bharti now has alternative avenues for growth. It can explore acquiring spectrum in the 600 MHz band, where 30 MHz of contiguous spectrum is available, or consolidate its holdings in the 900 MHz band, especially in circles where Indian Railways must vacate 1.6 MHz of its spectrum in lieu of 700 MHz as per the TRAI’s current recommendation. This vacated spectrum would allow Bharti to create larger, more efficient blocks suitable for deploying 5G services in the future.
The following illustration highlights Bharti’s potential spectrum landscape, showcasing opportunities unlocked in the 900 MHz band through unsold spectrum and the spectrum vacated by Railways in key circles.
The above diagram highlights that in 8 out of the 22 circles, Bharti, after combining its existing holdings with the vacant spectrum (marked in pink on the chart) and the spectrum vacated by Railways, will have less than 10 MHz in the 900 MHz band. However, in the remaining 14 circles, Bharti will possess 10 MHz or more, and in three of these 14 circles, its holdings will exceed 15 MHz. Interestingly, in most of the 14 circles where Bharti has more than 10 MHz in the 900 MHz band, it leads in revenue market share, as illustrated in the chart below. Also refer to my previous article for more reference about this table below.
This analysis suggests that Bharti is well-positioned—arguably on par with Reliance Jio, which holds 10 MHz in all circles—for future 5G deployment in the 900 MHz band, provided it strategically leverages this spectrum. On the other hand, acquiring spectrum in the 600 MHz band is not a viable option for RJIO. With 10 MHz each in the 700 and 800 MHz bands, opening a new band like 600 MHz would not align with its interests, as it cannot combine the newly acquired 600 MHz spectrum with its existing 700 MHz holdings to form a larger, contiguous block of 20 MHz without loss of overall coverage as explained earlier.
In contrast, Bharti enjoys greater flexibility. It can selectively acquire 600 MHz spectrum in circles where its current 900 MHz holdings are insufficient for standalone 5G deployment. This strategic advantage positions Bharti better than RJIO, giving it more options to optimize its spectrum portfolio for the future.
How Consumers Fare Under TRAI’s Recommendation
Setting aside the business interests of telecom operators, the central question is: how well does TRAI’s recommendation serve consumers and India’s broader interests? In my view, TRAI has missed the mark by failing to optimize the use of sub-GHz spectrum. The recommendation lacks a holistic analysis of the overall scenario, particularly the critical role of low-frequency bands in extending coverage inside buildings and offices—areas where higher-frequency bands are ineffective. Moreover, WiFi cannot substitute the capabilities of next-generation technologies like 5G and 6G in such settings.
It is crucial to understand that 5G and 6G are not just about faster speeds; they are about unlocking advanced slicing services indoors, where high-frequency bands fail to penetrate effectively. This makes strategic planning for the allocation and use of sub-GHz spectrum essential, especially given its scarcity and its harmonization with global standards. Such harmonization ensures affordable devices, a critical factor in a price-sensitive market like India.
When it comes to entities like Railways or PSUs, which do not operate in the consumer service domain, device affordability is less of a concern. These organizations primarily use spectrum for internal purposes, where end-device costs are not a significant factor. Allocating globally harmonized IMT spectrum, which is vital for 5G and 6G, to such non-commercial uses in large chunks is shortsighted and undermines national interest. Such spectrum should be reserved for commercial applications to offer widespread 5G and 6G services.
Thus, TRAI’s current recommendation does not align with the larger consumer interest or India’s overall goal of efficiently utilizing scarce spectrum. It also fails to account for the fact that vast portions of this spectrum, outside railway corridors, will remain unused and wasted. This lack of foresight is a missed opportunity to position India as a leader in the global digital economy.
Conclusion: A Call for Strategic Spectrum Allocation
TRAI’s handling of the 700 MHz band reflects a recurring pattern of missteps that continue to undermine India’s telecom and consumer interests. From the inflated valuation in 2012, compounded by subsequent flawed recommendations, to the current proposal favoring non-commercial usage by Railways, the spectrum’s potential remains largely untapped. This is particularly alarming given the critical role of sub-GHz spectrum in enabling robust indoor 5G and 6G services, which are pivotal for India’s digital future.
The 700 MHz band, globally recognized for its harmonized IMT usage, is essential not only for expanding 5G coverage but also for fostering affordability in a price-sensitive market like India. Allocating such valuable spectrum for limited, non-commercial use by Railways and PSUs—entities that do not rely on consumer-grade devices—represents a misalignment of national priorities. The resulting underutilization of this scarce resource outside railway corridors risks leaving vast swathes of spectrum wasted, a significant opportunity cost for a country striving to lead in next-generation technologies.
Furthermore, TRAI’s recommendation neglects to consider the broader implications for operators like RJIO and Bharti. While Bharti may emerge with strategic flexibility to optimize its holdings in the 600 MHz and 900 MHz bands, RJIO faces limitations that hinder its ability to enhance 5G services. More importantly, consumers, the ultimate stakeholders, stand to lose the most, as these decisions fail to maximize the potential of advanced slicing services and seamless indoor connectivity that 5G and 6G promise.
India deserves a forward-looking spectrum policy that prioritizes efficient utilization, aligns with global standards, and meets the dual goals of economic advancement and consumer empowerment. The current recommendation, however, falls short on all fronts, risking not only immediate inefficiencies but also India’s long-term competitiveness in the global digital landscape. It is imperative for policymakers to revisit this approach, ensuring that spectrum allocation serves the nation’s larger strategic interests while truly benefiting the end consumers.
