US : The CDMA Development Group (CDG) feels that if what is being widely reported in the Media becomes the 3G spectrum Policy, the reach of Telephone & Internet Access will be limited without the full assignment of the 450 MHz and the 1900 MHz Frequency bands. Assigning 3G spectrum in the 800 MHz frequency band for the CDMA Operators is welcome but the allocation of just one carrier each of 2 x 1.25 MHz is highly inadequate compared to the 10 MHz allocation in the 2100 MHz band.  The CDG feels that not including the 450 MHz and 1900 MHz bands is unfair to the CDMA industry.  CDMA2000® equipment is readily available and widely deployed in these frequency bands around the world providing for large economies of scale. 

450 MHz:  The ITU-R Study Group 8 approved its Report on the feasibility of having IMT-2000 systems share frequencies within and adjacent to the 450-470 MHz band – an important step towards having the World Radio Conference (WRC-07) identify the 450 MHz band as an IMT-2000 band for 3G services.  By not allocating and assigning the 450 MHz band in India, telecom growth will be limited, especially in the rural areas of India.

1900 MHz:  The decision to reject the mixed 1900 MHz band allocation, if true, would have been made without considering the full facts, most specifically testing the feasibility of sharing the spectrum between CDMA2000 and WCDMA systems.  The CDG recommends allocating and assigning more carriers in the 800 MHz band to India’s CDMA operators to mitigate the significant disadvantage this decision will create and to compensate for the previous unfair assignment of more 2G spectrum to GSM operators than to CDMA operators.

The CDG agrees with the recommended principles of using spectrum efficiently, ensuring technology and service neutrality, and establishing a level playing field through auctioning with a reserve price for allocation of 3G spectrum.  These universally accepted principles should be applied to both 2G and 3G spectrum allocations and assignments in India. Particularly, 2G spectrum allocated in excess of the contracted amount of 4.4 MHz & 6.2 MHz to GSM players must be made chargeable and all further allocation of 2G Spectrum should be auctioned considering the fact that demand far outstrips availability. Subscriber-linked criteria must be done away with.

“CDMA has played an important role in the expansion of telephony and Internet penetration in India.  We urge the Indian government to continue to stimulate innovation, competition and further investments by bringing balance and fairness to the allocation of its scarce national resources,” said Perry LaForge, executive director, CDG.

The CDG urges the DoT and Indian government to address imbalances within the 2G spectrum bands to increase fair competition. By allocating 2G spectrum on an incremental basis based on an operator’s reported subscriber numbers and dated spectrum efficiency analysis, the government has constrained CDMA2000 operators to only half of the amount of spectrum available to GSM operators.  The CDG recommends that this unfair policy be rectified and made consistent with the proposed 3G spectrum policy which places all players on a level playing field.  This will ensure India’s valuable spectrum is used more efficiently and that all technologies and services are treated equally.  India’s businesses and consumers will be the ultimate benefactors of a fair and prudent policy.