Training Methodology

1. SatyaspeakLirneAsia - Broadband Policy and RegulationBSTTM,IIT Delhi - 17th December, 2016 Broadband Policy–Enter VNO Regime in India, “Too late-Too Little”Satya N. GuptaJt. Secy. General, ITU-APT Foundation IndiaHon. Secy General, NGN Forum IndiaVice- President, PTC India Foundation

2. Training Methodology • Objective: • “To learn all you wanted to know about Broadband Policy and Regulatory environment in India” • Philosphy: • If I Listen- I Forget • If I See- I Remember • If I Interact- I Understand • “ Learning through Knowledge-Exchange” • Moral: • For next few hours, you should Eat, Drink ,Think and Talk Broadband Policy- Sleep not an option- There is a reverse-Quiz and Prize to be won.

3. Agenda • Introduction- Broadband Definition • Facilitating Regulation for Broadband • Roadblocks for Broadband • Govt’s Role in promoting Broadband • Enabling Regulation for Broadband • National Broadband Policy –Technology-Neutrality • National Broadband Plans –Developed and Emerging Markets • Broadband Commission for Digital Development (BCDD) • Salient Features of NTP-2012 • Creating NBP India – NOFN ( Bharatnet) Implementation Strategy • New initiatives-Digital India, UL, VNO, Active Sharing, EOT • Recommendations for Road Ahead • Reality Check-State of Broadband Services and ISPs in India

4. Introduction Broadband- Broad Definition • Generally, Broadband describes high speed, high capacity data communication making use of DSL, Cable Modem, Ethernet, Fixed Wireless Access, Optical Fiber, W-LAN, V-SAT etc. • There is no specific international definition for the Broadband though there is a common understanding among developed and developing countries that it should be more than 2MBPS. • As per Broadband Policy 2004, Broadband in India was defined as: • “Always-On’ data connection that is able to support various interactive services including Internet access having the capacity of a minimum download speed of 256 Kbps to an individual subscriber form the Point of Presence of the service provider.” (This definition has already started showing up its limitations and has been upwardly revised to 512 KBPS(2015) and further to 2MBPS and may be 4MBPS in future(2017), in line with best international practices)

5. Targets for Internet & Broadband Penetration in India(Broadband Policy 2004 and NTP 2012)

6. Roadblocks for Broadband-India 1. Price • Price for broadband access @ INR 250 (USD 4) per month – still unaffordable to masses ( > 3% of monthly per capita income) 2. Access to the customer • Lack of access to the incumbent’s copper loop for DSL by competitors. • Low quality of cable TV infrastructure and lack of industry organization. • High costs for VSAT based access. • High spectrum costs making BWA unaffordable to masses. • Cumbersome and expensive processes for Right Of Way (ROW). 3. Cost of connectivity • Lack of effective competition in the “within city”/ last mile access networks • High cost of Upstream Bandwidth • Absence of National Broadband Network (NBN), NOFN 4. Fiscal policies • High taxes and duties, and lack of fiscal incentives for faster Broadband growth 5. Content and applications • Lack of locally relevant content and absence of “Killer Applications” to drive growth

7. Govt’s Role in Promoting Broadband • Creating the right policy environment by having a National Broadband Plan (NBP) and including Broadband in Universal Service/Access definition- NTP,12 • Creating National Broadband Network infrastructure with Open Access- NOFN ( Bharatnet) • Establishing and empowering Internet Exchange in the country- NIXI • Permitting Service Based Competition/Class licencing for Broadband- VNO • Allowing International players to have operation in the country-FDI, 100% • Supporting community/local investment in Broadband in uneconomic remote rural areas through PPP mode and Viability Gap Funding- USOF • Leveraging Govt’s own demand and setting example by being on-line leader through delivery of e-governance services- NeGP, CSC • Extending special tax concessions for equipments, access devices, content & services used for Broadband- exemption from GST, licence fees

8. Enabling Regulation for Broadband • Permitting infrastructure sharing among different service providers including LLU and FS for optimum utilization and cost reduction- Active infrastructure sharing. • Allowing captive infrastructure of utilities (Rail-roads, Power grids, Highways, Pipelines) to be used for Broadband services- IP1, NLDO. • Reducing the bottleneck in last-mile access by facilitating deployment of alternative technologies like Cable TV network, Fiber, Wireless, Broadband over Power lines, through easy access- Draft ROW Policy • Reducing the cost of bandwidth for domestic and international Internet connectivity- DLC,IPLC tarrif orders • Allocation of suitable Radio Spectrum for Broadband services at reasonable price and making more spectrum unlicenced- Digital Dividend, 5.1-5.3 Ghz , White Spaces • Permitting broadcast infrastructure like DTH to be used for Broadband access. • Allowing service-agnosticness over broadband without any restrictions for VOIP, IPTV, OTT etc.

9. Broadband Policy, 2004- India Service Providers can choose any technology(Tech-neutral) • Over existing infrastructure • DSL/ ADSL/VDSL over Copper loop • Cable Modem over Cable TV network • Power Line Broadband Access • Over new Cable Infrastructure • Fiber To The Curb (FTTC) • Fiber To The Home (FTTH) • Hybrid Fiber Coaxial (HFC) • Metro Ethernet over Fiber ( MEF) • Over Wireless Infrastructure • Fixed Wireless Broadband Access ( FWBA) ( WiMax 802.16d) • Wireless LAN (Wi-Fi) (802.11a/ b/ g) • Satellite (V-SAT, DTH) • High speed WLL (GPRS, EDGE, CDMA, CorDect) • 3G Cellular Mobile System (WCDMA, EVDO, IMT2000) • IMT-advanced Technologies (Wimax, LTE)

10. Broadband Access in India- Technology-Neutrality (Making use of existing and new infrastructure ) VSAT HOME SHOPPING SERVER (E-COMM) INTERNET KIOSK/ HOME Ethernet VIDEO SERVER FTTC >24 Mbps 512 Kbps- 2 Mbps 256 Kbps- 24 Mbps FTTH ADSL Cordect E-COMM SERVER INTERNET (CONNECTIONLESS) PSTN (Connection oriented) 70 Kbps SWITCHED TELEPHONE/DATA SERVICE ROUTED (TCP/IP) WLL CDMA 144 Kbps – 2 Mbps M-COMM SERVER Cellular Mobile Cable TV Network (Shared) Hotspots Network (WISP) 3 G PLMN EVDO/WCDMA BUSINESS VOICE, DATA & VIDEO ON SAME PLATFORM 384 Kbps- 2 Mbps 128 Kbps- 1.5 Mbps WAP ENABLED/ GPRS/ EDGE CM Broadband through Cable TV Wireless Broadband Access (Wi-Fi, Wi-Max) 64-384 Kbps Broadband through DTH HANDSET

11. Satellite based DTH Services offer alternate for the Broadband via Receive Only Internet Service (ROIS) • Broadband Policy 2004 • DTH provider with ISP license allowed to offer internet services • ISP licenses permitted to allow customers for downloading data through DTH • DTH providers permitted to provide both way Internet service after obtaining VSAT and ISP license • Deployment of DTH for TV has begun, but internet access through this was not permitted • While internet data is downloaded from the satellite, the uplink connection to the ISP is through another channel • Since DTH (or receive-only VSAT) dish is only receiving, should not require SACFA clearance or NOCC fee for uplink monitoring • New technology permits DTH to be used for bi-directional internet access, though costs are high because of required hardware

12. Broadband using DTH for Receive-only Internet CUSTOMER PREMISES EQUIPMENT BROADCAST RECEIVE ONLY SIGNAL CHANNEL OUTWARD DIALUP EQUIPMENT Inbound CUSTOMERS RECIVING SET DTH PROVIDERS TRANSMITTER 2 MBPS OUTBOUND COMBINED SIGNAL Outbound Channel 64 – 128 kbps (Radio, ISDN, Dial up etc.) - Internet Service DTH Service International Provider Provider Internet Hub Cloud Speed of outbound channel is generally between 10 to 20% of inbound channel

13. VSAT has the potential for significant impact on Broadband Penetration in Remote Areas • Advantages of VSAT for remote geographies, high reliability, multi-casting and disaster recovery applications are well-known • VSAT operators face increased costs due to special regulations & restrictions because of its CUG category • Policy makers have some concerns that can be addressed in changing current rules • To bridge last mile, VSAT license could be permitted to be used as access media for Broadband • Broadband Policy 2004 • Open Sky policy for VSAT to be pursued by DOT • Minimum dish size of 1 m for KU-band permitted • Throughput restricted upto 2 Mbps • VSAT service providers permitted to provide Internet services by obtaining ISP license

14. Fixed Wireless Access- an important access technology • Broadband Policy 2004 • 2.40 – 2.48 GHz spectrum De-licensed for outdoor usage with power restrictions (4W). • 5.15–5.35 & 5.7–5.8 GHz spectrum De-licensed for indoor usage for low power (200 mw) systems. • 5.25 – 5.35 GHz will be De-licensed for outdoor usage in consultation with DOS. • 1880 – 1900 MHz spectrum delinked from access providers allocation and available to ISPs. • Alternate spectrum for broadband services to be identified (2.3-2.4, 2.5.-2.7, 3.3-3.8 Ghz) • 802.11x (Wi-Fi) technologies are widely used international standards. Wi-Max has substantial future potential • 5.1 and 5.7 GHz bands (802.11a, Wi-fi) equally important as 2.4 GHz (802.11b/g, Wi-fi) Unlicensed bands • IMT 2000 bands have been keenly contested world over for 3G • Need to encourage alternative technologies in less congested bands • Need to exploit use of 450 MHz and 700 MHz (Digital Dividend bands) Alternative spectrum

15. Facilitating Radio Spectrum for Broadband Access • ISM Spectrum (2.4 to 2.48 GHz, Wi-Fi) de-licensed for in-campus WLAN using any technology. • De-licensing of this along with 5.7-5.8 GHz for outdoor usage has also been notified with 4W EIRP. • De-licensing of 5.1 to 5.3 spectrum for indoor & in-campus usage has been notified. • Earmarking of 20 MHz (1880 to 1900 MHz) for wireless TDD access systems by ISPs (delinking from mobile licencing). • Time-bound frequency allocation, site clearance & frequency licenses through automation of Spectrum Management System and by setting predetermined standards for WPC.(E-application for SACFA clearance). • E-Auction of 3G spectrum in 2.1 GHz and BWA spectrum in 2.3 to 2.4 Ghz band has been completed and spectrum allocated. • In NFAP-2011, upper half of 700 MHz (Digital Dividend) band has been earmarked for BWA, e-Auction planned for Sept. 2016

16. Fiscal measures to reduce the cost of access devices, infrastructure and broadband service Recommendations • Allow 100% depreciation of PC’s and broadband CPE’s in first year • Give tax benefit for donated PC’s • Remove anti-dumping duty on import of recycled PC’s • Reduce and rationalize import duties • Put local manufacturing on equal footing with imported finished goods • Exempt web hosting from income tax • Exempt ISP’s from service tax • Personal broadband allowance Broadband Policy 2004 • High priority to indigenous manufacture of Broadband related equipments • Package to bring down the cost of broadband services at affordable level to be worked out in consultation with Ministry of Finance and other related departments.

17. Reduction in the cost of connectivity • Cost of connectivity (international & domestic) forms a significant part of Opex for Broadband services. • Tariff for international bandwidth was forborne and left to the market forces. It was considered to be on the higher side in comparison to international benchmarks. • Govt. reduced the license fees for ILDOs, NLDOs and Infrastructure Provider category II (IP-II) from 15% to 6% of AGR and bank guarantee for IP-IIs from Rs. 100 crore (USD 20M) to Rs. 5 crore (USD 1M). • Revised tariff orders reducing the ceiling price for international bandwidth (IPLC) by 35% for E1 and by 70% for DS3 and STM1 capacity became effective from 29.11.2005. • The revised tariff orders reducing the ceiling tariff for domestic leased circuits (DLC) by an extent of 30% for E1 market price and 70% for DS3/ STM1 market price, became effective from 1.5.2005. • Recently regulator has mandated very high reduction in Access Charges at Cable Landing Stations (CLS) to make these cost- based and in line with International levels.

18. National Internet Exchange of India (NIXI) • National Internet Exchange of India (NIXI) has been set up on recommendation of TRAI by DIT, Government of India to ensure that Internet traffic, originating and destined for India, should be routed within India. • Six nodes of NIXI have been setup in metros and about 45 ISPs have already connected to these. • All the ISPs are not still connected to NIXI and also all routes are not announced on NIXI leading to under utilization of the infrastructure. • NIXI is taking appropriate steps for increasing the utilization of its facilities.

19. Emerging Broadband Services- OTT • High speed Internet access (death of World-Wide-Wait) – Still the killer application for Broadband in India • Video-On Demand, Interactive TV, IPTV, PPV, Time Shifted TV, Videoconferencing (Multimedia over Broadband) • Triple Play (data, voice, video) – By UASP • IP-VPN (low cost connectivity) – By UASP/NLDO • VOIP (permitted only for UASPs) • Interactive Gaming (future killer application) • 4 e’s (e-Governance, e-Learning, e-Health, e-Commerce)

21. International Govt. Initiatives for NBP

22. International Initiatives for NBP (Con.)

23. India-Approach to Estimate Investment for Broadband Access Infrastructure in Each State

24. NBN-Government Owned Model Source: Analysys Mason

25. NBN-State Government or Municipality Owned Source: Analysys Mason

26. NBN-Incumbent Owned, Government Supported SPV Source: Analysys Mason

27. NBN-Jointly Funded and Owned by SPV,Telco Led Source: Analysys Mason

28. NBN-Jointly Funded and Owned by SPV,Government Led Source: Analysys Mason

29. NBN-Government Loan / Subsidies, Private Owned Source: Analysys Mason

30. NBN-Operational Plan for Government Owned Model Source: Analysys Mason

31. NBN-Operational Plan for Incumbent Owned, Government Supported SPV Model Source: Analysys Mason

32. NOFN India-Existing Fiber Infrastructure and Coverage by Various Service Providers Source: Industry Inputs, Analysys Mason

33. NOFN India-Investment Required to Rollout Backhaul Network to Connect 250,000 Gram Panchayats Source: Industry Inputs, Analysys Mason

34. Bharatnet-Potential Investment Models for additional Fiber Deployment Source: Analysys Mason

35. Creating NBP India- Bharatnet Govt. of India (Ministry of Communications & IT, Universal Service Obligation Fund) Advisory Body consisting of Secretaries of the Govt., Chiefs of PSUs, Chairs of Industry bodies led by Infrastructure Advisor to PM High Level Committee led by Infrastructure Advisor to PM including chiefs of 3 Telecom PSUs including incumbent (BSNL), C-DOT & Secretary,T • Objective to connect 2.5 Lacs Grampanchayts (Large Villages) spread over 5000 blocks by Optical Fiber backbone by 2014. • Making use of the existing transmission infrastructure of incumbent BSNL and utility telcos. • Investment of around 4.0 B USD to be funded from USO fund. SPV (USO funded, incumbent owned, participated by other telecom PSUs and utility companies) PPP (Equity participation from private players and industry at a later stage)

36. Establishment and Maintenance of NOFN-I: NOFN Implementation Strategy • In its plan for the NOFN, for extension of the existing optical fiber network to all Panchayats, DoT proposed an Executing Agency (EA) to undertake the work of establishment, management and operation of the NOFN through a transparent bidding process. • Phased institutional mechanism for implementation of NOFN •  Stage I: A High Level Committee (HLC) to steer and coordinate all activities related to the NOFN Project. • An Advisory Body to advise on implementation issues and upstream and downstream integration as well as issues relating to non-discriminatory access. • A Project Implementation Team (PIT) shall look in to preparatory activities such as GIS Mapping, finalisation of network design, formulation of bid package as well as on issues related to establishment of SPV. • Stage II: After approval by the Union Cabinet (End Oct. 2011), action to be taken to establish and operationalised a Special Purpose Vehicle (BBNL). • The management of NOFN would be transferred to the Special Purpose Vehicle (SPV), which will take over the functions and responsibilities of the EA. •  Stage III: Private sector companies will also be inducted into the SPV by equity expansion under PPP mode.

37. Funding Source of NOFN-USO Fund • Establishment and maintenance of the NOFN will be financed solely through the USO (Universal Service Obligation) Fund based upon bids received by the Executing Agency (BBNL). (USD 4.0B for first phase) • Necessary funds will be allocated by the Ministry of Finance (MoF) to USOF within the amounts accrued/accruing to the USOF. No additional liability on the state exchequer outside of USOF is envisaged. • Given the size and scope of USOF Projects, budgetary allocation by MoF towards USOF expenditure to be restored under Non Plan budget to avoid procedural delays and ensure timely allocation of funds. • As on date the funds available are with USOF are approximately INR 18,000 crores ( USD 3.5B) and on an average the annual accruals to the fund would be approximately USD 1.2B. it is expected that the approximate funds available including cumulative accrual of funds over the next three years (upto2014) would be about USD 7.0 B. • At Intermediate stage Private sector will also be encouraged to make matching investments under PPP mode.

38. Digital India Mission of Govt. “To create an inclusive knowledge society through proliferation of affordable and high quality Broadband services across the Nation” • NOFN (National optical Fiber Network), named ”Bharatnet” plans to connect 2.5 Lakh Gram Panchayats with 100 Mbps connectivity by Dec. 2016 • 7,500 Gram Panchayats connected up-to June 2016 • Missing link is "Home/Hand Delivery” of Broadband access to Rural Masses

39. Digital Bharat- Challenges and Opportunity • National Telecom Policy (NTP),2012 Targets- • NOFN-2.5 Lakhs Gram Panchayats (GP) to be connected with 100MBPS by Dec.2016 • 175 M by 2017, 600 M by 2020Broadband Subscribers in Country- • Broadband Speeds- 2MBPS by 2017 and 100 Mbps by 2020 • Missing Links- • Only 7500 GPs completed by June,2016 (Just 3%)( OFC Laid upto 32000) • 25 M. only) Broadband Subs. only 150M (Rural • Broadband Speed only 512KBPS ( Available in Urban only) • Connectivity to Rural creating Digital Divide- No Broadband Rural masses • Challenges- • How to treat Rural Broadband Access ie. “Last Mile” as “ First Mile” • How to “Home–deliver” the “Broadband services” to Rural masses • How to enable “Digital-India” to Include “Bharat” ie. Rural • Way Forward- • “Extra Mile” through People-Panchayat-Public-Private Partnership-5Ps Rural Wi-Fi Initiative

40. Institutional Framework for the Indian Telecommunication-Public and Private Actors Parliament of India Act/ Legislation Recommendations Competition Commission of India (CCI) Govt. of India (MOC,MOEIT, MHA) TDSAT TRAI Policy Regulation (Tariff, Interconnection, QOS) Dispute Resolution & Appeal for DOT & TRAI Directives Wireless Planning & Coordination Wing (WPC) Spectrum Management DOT/ Telecom Commission/TERM/ USO Fund/DEITY Policy Implementation, Licensing,Rural, Security Security Agencies Standardization & Technical Inspection Telecom Engineering Centre (TEC) Centre for Development of Telematics (C-DOT) Operators Telecom R&D Service Provision Interface Approval End Usage Manufacturers and System Integrators Equipment and Network Subscribers

41. Licensing evolution in India- Competition in Phases VAS/OTT Fixed Mobile Monopoly 0 Duopoly in Access, Monopoly in Long distance Monopoly in Access, competition in Long distance 1 Duopoly Nation wide Duopoly 3-4 operators 2 Unlimited Open competition Unified Access 3 Unrestricted entry in all segments 4 Unified Licensing/ Authorization (Class licensing) Single service-agnostic license for all telecom services and class license (authorization) for all value added services/OTT

42. National Telecom Policy (NTP) 2012-Salient Features • NTP – 2012 released on 12-06-2012 by the Govt. is a revision of NTP – 1999 to take cognizance of emerging scenario in telecom Technologies, Networks & Services leading towards Convergence and Unification. • Salient focus of policy is delinking of Spectrum from Licensing, facilitation of Unified Licensing Regime, special emphasis for Broadband, encouraging next generation technologies and domestic R & D and Manufecturing & treating telecom as Infrastructure. • This policy is mainly a long – term, forward looking, all – encompassing vision statement of the Govt. to provide requisite policy impetus to take Telecom sector in India to next level and to rural areas to bridge the Digital-Divide, without detailing the implementation strategy & timelines. • Though it is a great initiative, lot of efforts will be required by the executive arms of the Govt. & the Regulator to Operationalise and Impliment it through various legislation amendments, guidelines & regulations.

43. Unified Licencing Framework- UL • In the new licensing framework, spectrum allocation has been delinked from the License and it has been mandated to obtain an UL for any one or more of the services listed below: • Unified License (All Services) • Access Service (Service Area-wise) • Internet Service (Category-A, with All India jurisdiction) • Internet Service ( Category-B with jurisdiction in a Service Area , State) • Internet Service ( Category-C, jurisdiction in a Secondary Area, District) • National Long Distance (NLD) Service • International Long Distance (ILD) Service • Global Mobile Personal Communication by Satellite (GMPCS) Service • Public Mobile Radio Trunking Service (PMRTS)Service • Very Small Aperture Terminal (VSAT) Closed User Group (CUG) Service • INSAT MSS-Reporting (MSS-R) Service. • Resale of International Private Leased Circuit (IPLC) Service

44. Virtual Network Operators ( VNO) – A Service ( Non-Facility) based licencing regime In April,2016 Govt. released licencing guidelines for virtual network operators, opening the doors for new class of players which will act like Value Added Resellers ( VAR) for telecom service providers. A virtual network operator (VNO) is a managed services provider and a network services reseller of other telecommunication service providers VNOs do not own core telecom network infrastructure; however, they provide telecom services by acquiring the required capacity from licenced telecom carriers (NSO). These service providers are classified as virtual because they offer network services to clients without possessing/creating the actual network. VNOs usually lease bandwidth/ infrastructure at agreed wholesale rates from different telecom providers and offer services directly to end-users, under their own brand.

45. Drivers for VNO regime • NSO, which has invested hugely for getting spectrum licenses but has delayed services due to economic factors, can optimize its resources by letting a new VNO utilize them to deliver services in new markets. The NSO will earn a recurring income from the VNO for utilizing these resources. • The reseller model creates opportunities for entrants or helps widen the scope of services offered by existing players. A VNO can be a local telco/ISP, an MSO, Managed Service Provider or even a cable operator who is able to provide the supporting local infrastructure. • Delivery of new telecom services under the infrastructure sharing model will effectively reduce the cost of service delivery. * Proliferation of VNOs can help the Government to address the connectivity concerns in rural concerns in rural areas and help it march towards its goal of Digital India ( Bharat).

46. Why Indian Telecom Sector Require VNOs or “Is it Too-Late”? • In India most of the access service licensees are integrated TSPs providing access, long distance and internet/broadband services. They provide services either by using their own infrastructure or by sharing/leasing infrastructure of other TSPs. • Despite the presence of so many TSPs there is still a wide digital divide between urban and rural India. • Urban tele-density has reached about 149% while rural tele-density is lagging at around 47%. Against a target of achieving 160 million broadband connections by 2014, only 150 million connections have been achieved by June,2016 and that too with the broadband speed (download) definition of 512 kbps. Also in rural only 25M connections. • VNOs can be a solution to achieve targets defined in NTP-2012 for 100% rural tele-density by the year 2020 and also Broadband access in rural areas.

47. Conceptual Diagram of NSO-VNO Inter-play

48. Sharing of Infrastructure between NSO and VNO • Many NSOs, particularly Govt. owned BSNL, MTNL, BBNL, Railtel have wide spread infrastructure and spare bandwidth capacities available with them and are supposed to be willing to share the same. • To increase the penetration of broadband and to reduce the gap between urban and rural tele-density, one solution could be to facilitate enabling provisions to bring in some players in the service delivery segment as VNOs. • They can provide various telecom services using either the infrastructure laid by the existing NSOs (if the same is available) or by creating a part of local,missing link ( last mile) by themselves. • The above can help the existing NSOs to optimally and efficiently utilise their networks by sharing active and passive infrastructure and optimize the returns on their investments (ROI).

49. Sharing of Infrastructure between NSO and VNO(Cont…) • In a VNO type model, the role of the NSO is vested with the existing TSPs. Infrastructure which can be used by VNOs ranges from active and passive infrastructure, backhaul, OFC, towers, power systems, available with the TSPs. • The matter relating to availability of infrastructure for sharing is best left to the NSO and VNO to decide on mutually agreed commercial terms. • By sharing infrastructure, existing NSOs stand to benefit as they get an additional revenue stream and a higher Return on Investment (RoI). With the growing demand for bandwidth for all services, NSOs are continuously increasing their capacities and VNOs can help their cause by utilizing surplus capacities of NSOs. • The majority of stakeholders have suggested that the arrangements between VNOs and NSOs should be settled on purely commercial terms and there is no need for regulatory intervention in these arrangements. Also, the licensing and regulatory framework should allow unrestricted sharing of active and passive infrastructure in all respects across all categories of licenses.

50. Functional Separation – An Ultimate Network Sharing Concept “The Nirvana of VNO”