Well Organised Emergency Communications Capabilities

The recent events in Uttarakhand, India where floods have wreaked havoc destroying thousands of  lives and livelihoods, sweeping away whole villages, roads and mobile towers leaving thousands people stranded and in need of rescue, highlights the importance of preparedness, mitigation and meticulous planning for disaster management (DM). One aspect of this planning is emergency communications.

India is now beginning to take cognizance of  areas like single emergency number and priority call routing. However,  instead of a piecemeal approach, a more holistic approach would be far more effective.

Lets examine the issue of Priority Call Routing first. Please also see my previous blog at http://ictsforall.blogspot.in/2013/06/universal-access-to-emergency-services.html

Telecom Regulatory Authority of India's (TRAI) analysis as seen from its consultation paper  was as follows;

 TRAI’s reasons for the need for priority call routing during disasters include inter alia: 

• The wide variety of radio equipment used by various public safety organisations is frequently incompatible, preventing communication between responders.
• In extreme circumstances, official public safety systems may fail.
• Civil networks often provide greater capability for data communications than their public safety counterparts. The latter are often provided with very limited transmission capacity which is not upgraded as quickly as civil networks.
• NGOs and private sector responders play a critical role in response but may not have access to public safety networks. Often during disasters the civilian telephone networks are not so much destroyed as congested into uselessness. This can paralyze official response during disasters.

Based upon on the above premises, the consultation paper focuses primarily on network congestion issue and attempts to find ways and means to ensure that network congestion bottlenecks are eased for official and unofficial agencies involved in response and recovery.

Solutions suggested by TRAI: TRAI has suggested that one possible solution is network dimensioning (core network, POI circuits) in a manner that facilitates handling of increased volume of traffic during disasters. Needless to say, while telecommunication networks are dimensioned to meet mandated quality of service (QoS) standards keeping in view normal estimates of peak traffic, dimensioning to handle disasters would involve extra costs which telecom service providers may be reluctant to bear. The second option the TRAI has suggested is priority call routing for personnel involved in response and recovery. 

TRAI's analysis accepts that a  resilient telecommunication networks  (so as to cater to communications during disasters/ emergencies), would include (a) proper network  dimensioning, (b) emergency communication alternatives like satellite radio, ham radios and (c) a comprehensive strategy to rebuild or repair lost infrastructure. This is however considered to be a time consuming and costly exercise and hence priority call routing is suggested as an immediately implementable and less costly solution. 

TRAI goes on to describe:

a) The United States Government’s emergency phone service for the National Security for emergency preparedness community to communicate over the existing public switched telephone network (PSTN) with a high likelihood of call completion even during network congestion or disruption with the help of enhancements based upon existing commercial technology. This is called   Government Emergency Telecommunication Service (GETS) in case of landline systems. A similar system for wireless networks is the Wireless Priority Service (WPS). GETS and WPS are authentication based priority call routing systems but do not pre-empt on-going calls or preclude public use of the civilian network. 

b) Canada too has a WPS system similar to that of USA.

c) U.K’s Mobile Telecommunication Privileged Access Scheme (MTPAS). This system restricts civilian access to cellular phone networks during emergencies. It actively prevents civilian use from congesting the cellular networks, thus allowing emergency services personnel priority for communications. Entitled users are provided with special SIMs to enable communications, while normal users will receive a beep indicating that the network has been reserved for MPTAS –aware phones.

d) Certain other models of priority calling such as that based upon a mobile virtual network operator (MVNO) concept or enhanced multilevel precedence and pre-emption (eMLPP) have also been discussed. While the former would entail dedication of part network resources to the virtual emergency operator during crisis, the latter pre-empts radio resources based on assigned priority. 

My Comments are as follows:

Regarding TRAI’s assumptions about present shortcoming of DM communications systems and remedies thereof: 

(i) Ministry of Home Affairs (MHA) and National Disaster Management Authority (NDMA) are already making efforts to expeditiously establish and enhance disaster communications networks by way of National Disaster Communications Network , National Emergency Communications Plan Phase I and II schemes. This is to be  backed by Disaster Management (DM) information systems such as National Database for Emergency Management (NDEM)and National Disaster Management Informatics System (NDMIS) (with inbuilt Vulnerability Analysis & Risk Assessment and Decision Support  tools). 

(ii) Given the existence of the above mentioned  schemes, the establishment of a high capacity, resilient, comprehensive and inter-operable (compatible) DM communications network cannot be assumed to be time consuming and beyond immediate financial capability of the Government. However, due care must be taken to ensure inter-operability of networks and devices.

(iii) It may be noted that these schemes provide for communications facilities for District authorities National Disaster Response Force personnel and other field level functionaries who are the first responders. It is felt that all government agencies expected to be involved in emergency/disaster relief must mandatorily use/have access to inter-operable NDCN elements and post disaster, they must switch over to this system to free up the public telecommunications network to others. Further, reliance should be placed on pre-planned network augmentation and ad hoc networks as already provided in NDCN, rather than planning for preemption of the PSTN.(I discuss this further below)

(iv) In the light of the above, it would be appropriate for NDMA, MHA and TRAI etc.to align their respective approaches to Disaster related communications. It would be advisable to prioritize the expeditious roll out of these schemes ensuring adequate capacity and inter-operability, rather than to plan for procedures to take over public communications which are critical means of alerting normal citizens/potential victims of disaster and can greatly aid in rescue and relief operations.

Regarding the importance of public networks for victims of disasters and hence need for a holistic approach

(i) The overall teledensity in India is 79.58% (July 2012). Urban teledensity is 169% and rural teledensity is 40%. Internet/broadband penetration though not high (23 million internet and 14.57 million broadband subscribers), is increasing rapidly (18% growth of broadband subscribers over previous year). Along with availability and affordability of telecommunications services, basic mobile usage literacy and e-literacy is on the rise among Indians no matter which economic strata they belong to. Ordinary citizens either as victims or others are the first to be present on the scene of the disaster. Needless to say, communications are critical to their survival as it becomes a lifeline to obtain help. Modern technology also enables caller location facilities which are invaluable for rescue and relief workers to locate injured/trapped individuals.

(ii) Rather than restricting public access to critical communications facilities, congestion on networks can be avoided by having efficient and reliable disaster warning and information systems including internet based message boards which the public would rely on rather than relying on interpersonal communications to make (anxiety) calls.  We should also be considering early warning systems like IPAWS as an integral part of emergency communications .

(Please also see my previous post on this issue at http://ictsforall.blogspot.in/2013/06/communications-imperatives-in-disaster.html)

(iii) Government should plan to make effective use of TV and radio and internet enabled social media forums and message boards to this end. service providerss can play a critical role through message boards and SMS broadcasts. Community education is also an important facet. 

(iv) TRAI can play a critical role in recommending/mandating the specific duties and overall cooperation of service providers in this regard. TRAI has not analysed the Telecommunications Service Priority (TSP)  programme under USA's Office of Emergency Communication's for emergency communications. This needs to be put in place as a part of licensing conditions of service providers. 

(iv) Relief and rescue agencies should be able to receive emergency calls from public on the public network but should use dedicated communications resources to interface with each other.

Thus some concrete measures for the present would be:

(i) While most telecommunications infrastructure is necessarily designed to withstand normal climatic conditions of an area, TRAI could carry out an analysis of specific area-wise vulnerabilities in conjunction with NDMA and DoT, and accordingly mandate special technical standards for network resilience and dimensioning of telecommunication networks in highly vulnerable areas. DoT’s Telecom Engineering Centre has already prepared draft guidelines in this regard which could be used/refined. The additional cost borne for retrofitting or supplementing existing network elements could be borne by the Government. All future infrastructure, networks and services after a specified cut off date would however mandatorily comply with revised technical specifications.

ii. The Universal Service Obligation Fund of India is administered by an USOF Administrator and functions as an attached office of Department of Telecommunications.  As USOF is mandated to provide telecommunications services to the people in rural and remote areas at reasonable and affordable prices, it follows that the existence of robust and disaster resilient networks falls within USOF’s mandate. Thus a USOF scheme could be designed for one time upgrading of existing networks in such vulnerable rural areas. 

iii. TRAI should take into cognizance the fact that world over, increasing importance is being give to universal access to emergency services (across platforms, including IP networks) and caller location services are being mandated. 

iv. The availability and accessibility of emergency communications to the aged and disabled is also something that even developing countries are according increasing priority to. These fall in the purview of Universal Service in most countries and TRAI may recommend necessary action to DoT. 

v. It may be noted that the USOF Administration is funding a nationwide rural optic fibre network (NOFN) (through an SPV namely, Bharat Broadband Network Ltd) to connect 2.5 lakh village panchyats (local self government offices). NOFN can serve as a valuable backbone in times of disasters/emergencies. With a view to provide high capacity DM related connectivity, NOFN can provide fibre in the last mile to critical rural structures such as schools, hospitals apart from local administration. While redundancy is most likely an inbuilt design feature for NOFN, it should be specially ensured that NOFN has the necessary disaster resilience to extent possible. 

vi. TRAI may consider making recommendations to DoT on a national Disaster Management Plan for Telecommunications Infrastructure and Services. This is mandated under Section 37 of the Disaster Management Act 2005. This would cover every stage of the Disaster Management cycle from mitigation to relief and early recovery. Business Continuity Planning for service providers should be a part of the same.

vii. Finally a holistic approach may be adopted rather than picking up only one segement of international best practices for emergency communications

Innovation is the key to Universal Service-Use of Low Power Base Stations in Africa

One of the biggest bottlenecks to provision of mobile services in rural areas in developing countries is the non availability of power. In India diesel generators are used in rural areas. This  implies  interruption in service in case of disruption in diesel supply-a common problem in remote areas and environmental pollution. While renewable energy solutions like solar panels are being deployed, these are costly especially when serving conventional mobile towers and base stations.

The deployment of low power base stations  is a good solution in such cases. One such device is being used in Zambia as reported by David Talbot of Communications News at

http://www.technologyreview.com/news/515346/a-tiny-cell-phone-transmitter-takes-root-in-rural-africa/#comments

A related article on Ushahidi, a device for crisis communications may also be of interest particularly from an Emergency Communications view point.

National Broadband Networks-Easier Said Than Done

While many nations have rightly put in place national broadband plans to ensure full participation of their citizens in information society, ambitious state aided  national broadband plans do face many difficulties.

Australia's NBN being rolled out by its incumbent operator TELSTRA appears to face in addition to technological issues, problems with competition regulation and uncertainty of political backing  as may be seen here: 

http://www.telegeography.com/products/commsupdate/articles/2013/06/21/accc-report-confirms-telstra-breached-competition-safeguards/

Singapore which adopted a successful market driven strategy has problems too, but on the demand side. Please see http://www.totaltele.com/view.aspx?ID=481850.

I continue to believe that the incumbent driven model of network roll out while it appears easier and quicker in the short run creates a regulatory burden/obligations akin to regulation of  monopoly wire line providers of the past. This also means substitution of network competition with service competition which again demands effective regulation. At least developing countries are perhaps not well equipped to deal with this requirement. Please see my previous posts on this issue at 

http://ictsforall.blogspot.in/search/label/Broadband%20networks

USA's National Broadband plan-The Connect America Fund

A part of United States’ 2009 recovery and reinvestment effort was the development of a $7.2 billion National Broadband Plan. According to this Plan,

Government can influence the broadband ecosystem in four ways: 

1. Design policies to ensure robust competition and, as a result maximize consumer welfare, innovation and investment.

2. Ensure efficient allocation and management of assets government controls or influences, such as spectrum, poles, and rights-of-way, to encourage network upgrades and competitive entry.

3. Reform current universal service mechanisms to support deployment of broadband and voice in high-cost areas; and ensure that low-income Americans can afford broadband; and in addition, support efforts to boost adoption and utilization.

4. Reform laws, policies, standards and incentives to maximize the benefits of broadband in sectors government influences significantly, such as public education, health care and government operations

To provide universal access to broadband a Connect America Fund was to be created ‘to support the provision of affordable broadband and voice with at least 4 Mbps actual download speeds and shift up to $15.5 billion over the next decade from the existing Universal Service Fund (USF) program to support broadband.’

A recent news item in this regard can be seen a thttp://www.bna.com/fcc-finalizes-effort-n17179874752/

The idea is to incentivise operators to serve areas where availability of broadband at benchmark speeds is currently lacking.

USA’s US programme is perhaps the oldest in the world. Perhaps because of this long history it appears to be rather large, unwieldy and demanding in terms of   effort  toward regulation, administration,  monitoring and  implementation. 

Innovation is the Key to Universal Service-Google's Loon Project

This project is interesting as it firstly offers solutions for rural areas which may be very useful for low population density  pockets-this  may seen from the link Google to Provide Internet Access Remotely and secondly it offers a possibility of quick deployment of a post disaster communications network as is detailed in Google's Loon Project Puts Balloon Technology in Spotlight

Global Symposium for Regulators-Discussions on Competition and Universal Service

The theme for this year’s Global Symposium for Regulators being held in Poland from 3-5 July, 2013  is ‘4th-Generation Regulation: driving digital communications ahead.’The consultation process focuses on 3 areas:

• Regulation 4.0: Innovative and smart regulatory approaches fostering equal treatment of market players, stimulating services uptake and access to online services and applications without putting extra burden on operators and service providers (co-regulation, self-regulation, smart incentives, etc.);

• The evolving role of the regulator: the regulator as a partner for development and social inclusion;

• The need to adapt the structure and institutional design of the regulator to develop future regulation.

Regulation 4 mentions many important areas including those bearing on competition vis-à-vis broadband networks and flexible approach required for digital inclusion and universal service as discussed in my previous posts. In my view significant observations are the following:

Competitive provision of broadband networks:

‘We acknowledge that when adopting a regulatory framework that eliminates barriers to new entrants, ensuring the inclusion of competitive   provisions  that guarantee healthy relationship between all players  (operators,  Internet providers,  OTT providers, etc.),   is one of    ways  to promote the deployment of next -generation broadband networks and access to online applications and services.’

‘Regulators also need to review existing competition laws to determine whether measures  

based on regulation or competition law are already in place and whether they adequately address the issues that tend to impact net neutrality.’  

‘We acknowledge the importance for regulators to understand all parameters at play in a digital environment to ensure not only affordability of access but also the need to guarantee a certain level of quality of service (in particular for  communications that are sensitiv e to time delay), the need for interoperability,  without putting extra burden on operators and service providers.’

‘We notably recognize that encouraging operators  and service providers   to propose and implement ways in which they can develop the sector may  stimulate innovation and provide for   a win-win solution   for both  the state and the industry .  Regulation should ensure  the  sustainable development of the ICT  sector that is essential  to attracting the investments  needed in  a  global  digital environment.’

On Regulation for Universal Access and Digital Inclusion:

‘We recognize that stimulation of service uptake and access to online services and applications  requires flexible regulatory approaches.    We acknowledge that understanding people’s n eeds and  how they can  benefit from using ICTs  is  key to innovation , as both business and individual   consumers  are providers of  incentive s  for innovation .  We encourage governments  to work  collaboratively with all stakeholders and in particular the industry and  regulators to   facilitate   and  support  the  development of  infrastructure and  provision of services, particularly in rural, unserved  and underserved areas .  From  the  supply   side ,  predictable and stable   regulations are needed   to   maintain effective  competition and drive the development of  innovative services.  From  the  demand side, measures such as deferring  heavy or special  taxes on ICT equipment and   services,   encouraging research and development, endorsing special programs to stimulate e-literacy, will result in higher penetration, increased demand ,    better social inclusion  and contribute to national economic growth.  Governments  and regulator s  have a key role  to play in promoting and increasing  awareness on  the  use  and benefits of ICTs.’

‘Regulators  can  also   act as a partner for ICT development and social inclusion, by facilitating (and sometimes creating ) partnerships, such as private-public-partnerships (PPP), with aid-donors, governments, ministries and other NGOs ,  in particular to meet universal access goals to ICTs for rural ,  remote   and unserved   areas  and people with special needs. Regulators can further extend partnerships with schools and local communities through projects  for improving the connectivity of schools  and communities to  enhance use of ICT applications in addition to providing access to technology  and promote economic development.   We also  encourage partnerships with  other public agencies  to offer a   coordinated approach   for  the benefit of the government and  the community, as a whole.  The regulator may further provide advisory and educational assistance  to local communities .’

During this symposium, the session on Universal Service will focus on “Maximizing the Potential of Universal Service Funds through Successful Administration and Management – Addressing the Missing Link” The discussion paper for this session is a study on Universal Service Funds which is summarized in a presentation by Lynne.A.Dorward.

It is remarkable how much convergence there is on best practices,  lessons learned and way forward. Significantly, the presentation highlights that we must look beyond mere connectivity to also look into special needs of persons with disabilities, women, indigenous people etc and focus on providing access to ICTs in a conducive and culturally  acceptable manner. The recommendations for Universal Service Funds rightly focus on a comprehensive approach which takes into account tapping into linkages between all types of stakeholders including other public agencies and funding sources to provide a comprehensive solution to ensure digital inclusion.

I think this is pretty much on the same lines as what I have been trying to communicate through my previous posts. Once again I am happy and proud that the Indian USOF has been praised for high level of transparency, visibility and accountability to all stakeholders.

In my view the way forward for USOF could be captured pictorially as follows:

Communications Imperatives in Disaster Situations

It is heartening to note that Indian Telecommunications Companies are coming forward to assist in post disaster communications in the flood ravaged state of Uttarakhand. Today's Economic Times carries an article titled Telcos help track last call records of victims which explains how major service providers are setting up free help lines for tracking last calls made by victims and free public calling offices (PCOs), topping up prepaid balances for free and setting up portable base stations etc. 

While these efforts are laudable there is a pressing need to have a standard operating procedure for such situations so that many of these measures kick-in automatically. Telecommunications are the life line of relief and rescue work. The Department of Telecommunications (DoT) needs to enforce the license provisions relating to location based services. This would appear to be a precondition for the effectiveness of emergency number services in dealing with disaster/emergency related calls as envisaged in TRAI's consultation paper on Emergency Communications and Response Systems.

There are other related issues such as the DoT having a Disaster Management Plan as required under the Disater Management Act, 2005. This would include resilience and redundancy of communications especially in vulnerable areas, SOPs entailing setting up ad hoc networks and mandatory  time bound restoration of communications post disaster etc. It would also entail laying down the protocol and methodology for coordination between service providers and local authorities and list obligations on both their parts. An article BSNL's attempts to restore infrastructure points to the need for such planning and coordination. Such a plan would also lead to corresponding regulations and  amendments to licenses. There would be financial implications which would need to be taken care of. There are also underlying issues regarding Universal Service Obligations which normally  include free access to emergency services. Please see my previous blog titled Universal Access to Emergency Services

The states and districts also need to have well equipped and functional State and District level Emergency Operations Centres (SEOCs and DEOCs) with robust communications networks that can handle the sudden surge in traffic as demanded by disaster/emergency situations. This is mandatory under the DM Act.

There are innovative solutions that can be permanently made part of emergency communications services. See for example Google Person Finder's services for this disaster.

Mobile communications are also important for timely dissemination of emergency alerts and SMS broadcast of location specific disaster prevention/mitigation or relief related information.

Eventually the issue of long term restoration of communications infrastructure arises. In this case suggestions have been to consider mandating insurance towards reconstruction for critical infrastructure like telecommunications.  

Special Initiatives-ICTs for PwDs

The other special initiative of USOF was the one for persons with disabilities (PwDs) in rural areas. 

India is home to one of the largest disabled population in the world. As per census 2001, 21.9 million Indians suffer from some form of disability. Seventy five per cent of persons with disabilities live in rural areas. A good percentage of these would either be unemployed and/or illiterate. Information and Communication Technologies (ICTs) can play an important role in facilitating the socio-economic and political inclusion and mainstreaming of Persons with Disabilities (“PwDs”) as ICTs can enable them to access various services (health, education, government services etc.), information, employment opportunities etc. and most importantly, to communicate effectively in spite of their particular disability. In recognition of the significance of ICTs in improving the daily lives of PwDs, enhancing their well-being and productivity and enabling their active participation in society, a scheme of Pilot Projects for access to ICT facilities combined with ATs for PwDs in rural India was launched.

A presentation on the scheme can be seen here.http://www.usof.gov.in/usof-cms/Stakeholder-Meeting%2007.09.11/USOF-India-Scheme_PwDs_A.G.Gulati.pdf

USOF  was heedful of the advise of disabled persons organisations (DPOs) and went through a fairly elaborate consultation process to evolve its scheme and float an Expression of Interest (EoI) with four project categories: 

• Setting up of ICT centres equipped with appropriate ATs for PwDs in educational/rehabilitation/vocational training institutions in rural areas

• Provision of special handsets with/without access to bundled content for PwDs in rural areas

• Public access to ICT facilities with ATs in villages or in/near rural institutions dealing with PwDs

The anticipated outcomes are explained in the diagram below:

To facilitate partnerships, all information about stakeholders including contact details and their feedback was placed in the public domain. Appropriately, evaluation was to be based on a combination of qualitative and quantitative factors. The EoI was however structured and had an outer date for application.

In this case service providers had to be lead bidders with proof of partnership with NGOs/DPOs and other relevant stakeholders depending on the category of project. The project submission dead line was extended several times but even so USOF received only two incomplete applications from non-service providers.

This would suggest that the more informal and flexible approach of Sanchar Shakti would have worked better in this case as clearly there was a lot of interest from technology providers and NGOs/DPOs. In hindsight, it would seem that USOF could have helped in collaborations between partners and in development and design of projects rather than following the more rigid EoI route with fixed deadlines etc.

Details of this initiative are available at http://www.usof.gov.in/usof-cms/disabled.htm

A SWOT analysis of the bidding vs consultative approach (like Sanchar Shakti) can be seen below:

Source: Archana.G.Gulati

Special Initiatives-ICTs for Rural women

In my very first post I had mentioned that USFs need to devise schemes to meet needs of specially disadvantaged groups and address demand side gaps.  I had alluded to USOF, India's special initiatives by way of pilot programmes to bring the benefits of ICTs to rural  women and the disabled. Today I will cover the former.

We in USOF labelled our project for women Sanchar Shakti. This name signifies the synergies to be achieved by empowering  women with  communications while recognizing the inherent importance and power of women. This scheme  aims to provide a highly customized bundle of relevant information and mobile value added services (mVAS ) to the rural SHGs to suit their unique cultural and socio-economic context.

Given the capacity of telecommunications services to deliver valuable information, impart education, connect with markets and supply essential citizen services, while transcending economic, social, cultural, physical and literacy barriers it is apparent that ICTs can make a significant contribution to the lives of rural women. From the very beginning, we were clear about our objectives. We wanted our projects to empower rural women in a manner that would enrich their personal lives while bringing about a sustainable change in their economic position.  

Our early discussions with stakeholders made it clear that given the strength of the Self Help Group (SHG) based model for positive interventions; our efforts must focus on rural women’s SHGs in rural India. We strove to educate ourselves and our project applicants about the needs of our target beneficiaries and thus the correct design for our projects so as to best address their requirements. In this journey we were competently assisted by NGOs dealing with women’s SHGs, gender experts from U.N Women (now UNIFEM) and telecommunications service providers. They helped us decide the broad contours of the scheme which were later refined to a project application template. The scheme was however kept open and flexible allowing plenty of scope for innovation and customisation. We went through a very lengthy process of shortlisting and refining the project proposals we received in collaboration with stakeholders with USOF playing a patient, supportive role of active facilitation role.

It is felt that the huge amount of time and effort that we put into multiple rounds of meetings and thorough proof of concept (PoC) roll outs has eventually resulted in four genuinely valuable projects that will have a positive and permanent impact on the gender equity and ICTs scenario in the covered rural areas. The four projects cover about 10,000 SHG members in 10 districts in the states of Maharashtra, Rajasthan, Uttarakhand and Andhra Pradesh Other projects may follow. These four projects focus on breaking the dependence on intermediaries when it comes to access to input and final product markets for SHGs engaged in cottage industries. The SHGs themselves are engaged in multifarious activities ranging from  handicrafts to agricultural/livestock rearing. Information on weather, crop/livestock diseases, markets and market prices, training courses, raw material /inputs etc. are covered in these mobile VAS bundles. Also covered are inputs on literacy, child and maternal health, pertinent government programmes, social issues such as domestic violence, child marriage, dowry etc. It is hoped that our initiatives will encourage the greater use of mVAS/ICTs in the delivery women-specific government services and influence the private sector to look beyond voice services for rural India. 

What has been truly heartening is the tremendous increase in self-confidence of the beneficiaries as observed during the three to six month period that they were in touch with USOF during the Proof of Concept stage. There is no doubt that these women are truly hard working and contribute greatly to family income and well-being through their dedicated hard work including entrepreneurial activities. The Sanchar Shakti project gave them a source of information, a voice with which to express their aspirations and a hope to enhance their knowledge, contribution and self-worth as earning members of society. They quickly mastered the use of the mobile device and interacted enthusiastically with USOF, NGOs and Service Providers to demand the particular information and services that they needed. They demonstrated an amazing capacity to use data and knowledge to enhance their skills and incomes even in the short span of a month in which the projects were test run to prove concept.

The approach adopted for the Sanchar Shakti Scheme is very different from the usual competitive bidding model of PPPs. The legal framework of USOF allows pilot projects to be exempt from the mandatory bidding process for selection of service providers. This proved to be important in the case of Sanchar Shakti as it enabled USOF to allow diverse stakeholders  much needed time to find each other to partner in these projects. In fact USOF Administration played an important role by transparently placing information on interested parties on their website to allow mVAS providers, Equipment Manufacturers, Service Providers and NGOs to approach each other. In particular NGOs dealing with rural SHGs and the former three stakeholders are not natural partners and without USOF intervention it is doubtful if they would have found each other. As mentioned earlier, each project went through a lengthy design phase wherein USOF and U.N Women assisted the  private partners in development of gender appropriately VAS packages to deliver content identified by NGO partners in consultation with SHG members. Given that Sanchar Shakti’s consultative and iterative methodology was very different from traditional bidding, due care was taken to maintain complete transparency by placing details of all meetings and stages of consultation/project formulation on the USOF website. In the absence of the same it may have been difficult to pass muster as far as the government’s legal and financial vetting and approval processes are concerned. 

It is felt that for delivery of public services aimed at disadvantaged groups such as rural women, the consultative, collaborative, bottom up PPP approach of Sanchar Shakti is very valuable. It is not possible to carry out such schemes in a rigid, structured top down manner. For one thing the stakeholders involved are multiple and diverse and for another such programmes demand intensive customization and localisation. Sanchar Shakti’s success can be emulated for similar efforts towards other segments of society such as the disabled in rural India. In fact a USOF attempt to follow bidding for schemes for disabled did not meet with much success for exactly these reasons. 

It is added that Sanchar Shakti is subject to systematic reporting and monitoring & evaluation requirements as in case of other USOF OBA projects.

Details of the Scheme can be seen at  http://www.usof.gov.in/usof-cms/gender.htm

Ensuring Affordability of USF Supported Services

A query from an esteemed telecom expert and colleague made me feel that this may be a good topic to cover today.

Part of the reason for the Actual Access Gap referred in my previous post is the non-affordability of services for certain segments of the population. This could be because they have lower than average paying capacity in absolute terms (say the urban poor) and/or relative to cost of provision of the services (on account of geography/ own disability etc.). In developing countries, the bulk of the population in rural areas could easily fulfil both the absolute and relative criteria making it essential to provide services not only at par with urban tariff rates but at times below urban rates in spite of higher costs of provision.

The underlying rationale of many an output based aid (OBA) USF project is that if  subsidy can be provided to help the USP break even and cover CAPEX and OPEX for a finite period, demand will eventually pick up enough to make services profitable (even at a lower tariff rate.) In any case ideally in an OBA based USF project, once the USF contract comes to an end, the USP should be  free to revise traiffs as per market conditions and other (non USF related) regulatory restrictions. In the  interest of  protecting its investment the USP would not like to drive away customers by charging unreasonable tariffs.

In India, the USOF mostly follows the OBA route. USOF projects are bid out. Reverse bids are floated  with a maximum permissible subsidy level based on a detailed benchmarking exercise. Tariffs in India are regulated by the Telecom Regulatory Authority (TRAI) and beyond the jurisdiction of USF. Thus, USF may in its tenders/contracts refer to TRAI regulations on say fixed line tariffs in rural areas and require rental and call charges to be at par or lower than the same. Alternatively, as explained in my previous blog titled "Broadband Networks through the Infrastructure Sharing Route" the USOF tender/contract may require that during the contract period the USP offers subsidized infrastructure/services at a discounted rate with reference to TRAI's ceiling rates. In USOF's mobile infrastructure and services scheme, the static infrastructure was required to be offered rent free by the wining infrastructure provider to the three winning mobile service providers who would share the towers. However, mobile services themselves could be offered at any rate to end users. With their rentals costs being nullified and given the competition between three players it could be assumed that they would vie with each other to provide attractive tariff plans to the served rural population. In fact my own experience with monitoring of this scheme has shown that in this case it was customer services (such as regular supply of recharge vouchers for pre-paid connections and QoS  which distinguished the more successful USPs from the laggards). In USOF's Wire line Broadband Scheme a couple of very affordable entry level broadband tariff plans were arrived in consultation with the USP (selected by nomination in this case on account of incumbent owning 99.9% of rural wire lines). These were required to be offered along with any other tariff plans (as per USPs choice) to rural customers being served through subsidized infrastructure. (Broadband tariff is on forbearance). Significantly, and as predicted when the broadband scheme was first introduced, the entry level tariff plans formed the bulk of the uptake but over time, the higher value tariff plans offered by the USP in parallel gained popularity. As on April 2012, entry level packages constituted 32% of the total broadband subscriptions under the scheme whereas initially their share was up to 90%. Thus, the decision to discount tariffs is always a considered one based on the characteristics of the market and the gap that we need to address.

In each USOF scheme, the benchmark subsidy is modeled on the basis of projections of CAPEX, OPEX, estimated demand and paying capacity of subscribers separately for each bidding unit. This could be a state, selected individual districts, group of districts etc.The tariff assumptions/prescriptions form part of the subsidy model and benchmarking exercise.

ITU's ICTs Regulation Toolkit explains this approach in terms of 'Smart Subsidy':


‘A  smart subsidy is the term used to describe an initial subsidy (usually given on a once-only basis) that is designed to be results-oriented, does not distort the market, and encourages cost minimization and growth of the market. It helps to kick start a project or service, with the ultimate objective of the programme becoming commercially viable, whereas without the subsidy investors might otherwise have been reluctant to invest. Investors’ reluctance could be due to perceived risk or general lack of capital for the kind of service opportunities that are considered by government to be essential for socio-economic development. The important element of the smart subsidy zone is that an initial subsidy to private sector providers will make the project commercially viable on an ongoing basis by filling the financial gap with a one-time subsidy, which increases the operator’s rate of return and reduces his risk. No further subsidies are needed if the service targets are set realistically, with medium term commercial viability in view. Targeted interventions are usually implemented using a Universal Access and Service Fund (UASF).’

National Broadband Networks: Regulation, Universal Service, Competition and Monopolies

One of the fundamental principles of Universal Service (US) is that it should complement and supplement effective regulation, liberalization and competition rather than replace these measures as a means of achieving greater telecommunications penetration. In fact, Universal Access (UA)/ US as obligations or policy instruments should ideally come into play when these measures have failed to address what is known as the actual access gap. This gap may arise on account of geographical or socio-economic reasons etc.

Source: WDRP 432(2002) as modified by Archana.G.Gulati 

With this in view, legal   definitions of Universal Service (as in the EU and USA ) often have an explicit references to competitive neutrality. However, while The European Union’s Universal Service Directive adopts a meticulous approach whereby market distortions are consciously  avoided at every step be it the  scope of US,  choice of technology, choice of Universal Service Providers(USPs), source of funding US etc. USA’s approach is not so rigorous. Similarly the Indian USOF legal framework lacks any such explicit reference or obligation to carry out an ex ante analysis to establish market failure or ensure competitive neutrality of US interventions.

Over the past two decades dramatic progress has been made in telecommunications penetration, particularly in mobile voice segment. This has been possible on account of technological innovations and competition which drives service providers to innovate, improve quality and meet customers’ demand at affordable prices. In a monopoly environment as persisted before the onset of mobile services, the regulatory burden of ensuring affordable services was much higher as the incumbent operator/operators were subject to various tariff restrictions and interconnection regulations to prevent misuse of monopoly /oligopoly situation. Non discrimination and transparency of information as well as consumer protection, while they are regulatory concerns even in competitive markets become far more acute in case of monopolies.

Given the importance of high speed broadband and the fact that roll out in certain markets would not be economical, governments across the world are funding OFC based broadband networks.The rationale for/criticism for focusing on OFC in backahul  or access services would merit a separate discussion, but is definitely a key issue as it impinges on technological neutrality which is a subset of competitive neutrality.

While most of these these public/US funded OFC networks are slated to be open access networks, care should be taken to avoid displacing private investment and initiative which may have been forthcoming with the right regulatory environment or incentives. Use of public funds/universal service funds should ideally be restricted to areas where markets have failed and logically the best course is to bid out such network provision to allow a level playing field between private and public operators. This may lead to a more fragmented approach than one integrated network but contractual obligations can ensure seamless connectivity between and non-discriminatory open access to backbone networks owned by various entities.  (see previous blog post) Such a PPP approach rather than publicly/incumbent owned networks may prove to be more competition and growth friendly in the long run even if it entails more effort in the short term. The use of public funding in pockets where no operator will venture or where effective competition is unlikely in spite of effective regulation (akin to European Commissions white or grey areas) is however justifiable. 

ITU's Trends in Telecommunications Reform 2013, has made a pertinent observation:

   'Developing countries in particular face challenges in promoting growth of Internet assets that will   support the widespread availability and adoption of broadband. These differences are based in part on geography, distance, and scale, but are also highly sensitive to competitive conditions within each country and to related choices by governments with respect to liberalization.'

It is seen that Australia’s NBN which is to be rolled out by the incumbent TELSTRA, is subject to overview by the Australian Competition and Consumer Commission (ACCC) and will be a purely wholesale network. Obligations of structural separation have been imposed on TELSTRA through a structural separation undertaking (SSU) to prevent conflict of interest and ensure a level playing field in downstream markets. The Indian NOFN may need to consider similar precautions vide a suitable regulatory framework.

I found some though provoking comments for and against on NBN at
http://nbnconcerns.wordpress.com/. and
http://www.malcolmturnbull.com.au/media/speeches/three-years-of-nbn-2-0-what-have-we-learnt/.      
A comparison with New Zealand and Singapore has been blogged here
 http://www.zdnet.com/nbn-how-aust-compares-to-singapore-and-nz-7000007426/.

A comparison with South Korea is blogged at http://www.computerworld.com.au/article/426682/nbn_vs_world_korean_experience/. What is distinctive about South Korea's success is the tackling of the entire broadband value chain and retention of competition as a means to spur growth. 

As the close of this entry I reproduce an extract from the Conclusion of the ITU Report on State of Broadband 2012.

 Broadband networks and services are more than simple infrastructure – they represent a set of transformative technologies that promise to change the way we communicate, work, play and do business.  It is essential that every country  takes  broadband  policy  into account to shape its future social and economic development and prosperity, emphasizing both the supply and demand sides of the market. Further, it is crucial to adequately evaluate the potential alternatives to be implemented in order to encourage private sector investment. A “one size fits all” policy to broadband roll-out could have negative implications for the ICT market. Finally, a detailed cost-benefit approach should be adopted when evaluating different public policies and regulatory options to promote the growth and development of broadband in different countries around the world.

Broadband Networks through the Infrastructure Sharing Route

I had mentioned earlier that we should perhaps be concerned about the current trend of state funding for broadband roll outs. It is often presumed that private sector will not roll out high capacity Optic Fibre Cable (OFC) networks at the speed or with the spread required for desired levels of broadband penetration.

It is true that private sector may need various incentives or even subsidies to venture into less lucrative markets or uneconomical areas. However, in my view, a variety of measures can be taken  that still fall short of state funding or state ownership.

The Universal Service Fund of India (USOF) had initiated two excellent schemes for the remote and relatively backward North Eastern states of Assam,  Meghalaya, Mizoram,  Tripura (N.E I Telecom Circle) and Nagaland, Manipur Arunachal Pradesh (N.E II Telecom Circle) that involve high capacity OFC backbone networks being laid out in rural areas (from district to block level) through Output Based Aid projects. These were bid out (reverse bidding) after a painstaking bench-marking exercise to arrive at the upper limit of subsidy, keeping in view possibility of renting out existing OFC from incumbent operators, apart from laying fresh cable. The resultant network is to be shared by the lowest bidder i.e. designated Universal Service Provider or Host Operator  on non-discriminatory, open access basis with other service providers. The tariff  offered by the USP has to be at a specified rate of discount vis-a-vis the Telecom Regulatory Authority's  (TRAI's) ceiling rates for leasing OFC. Discounts were worked out keeping in view capital cost subsidies, revenue projections and operating cost requirements. The bid for the states of Assam was won by the incumbent fixed line operator BSNL. However interestingly for the N.E states Railtel won the bid even without BSNL's  advantage of ownership of majority of OFC networks. There is a strong possibility that it has relied on back-end agreements for renting OFC from private operators rather than laying fresh cable to achieve its obligations in a cost effective manner. This is permitted by the USOF tender. 

The above Private Public Partnership model could have been successfully replicated for block to village level roll outs too. Given that OFC as a technology/broadband platform is here to stay, adeqaute subsidies on reverse bidding basis could have attracted private capital in many (if not all) bidding units (states/telecom circles). This model was rejected during decision making on the National Optic Fibre Network (NOFN) on the debatable grounds that bench-marking takes too long. Personal experience with the above mentioned schemes tells me that this is not correct and that the benefits of involving a large number of market players in laying of the nation's OFC backhaul far outweigh the effort involved in tendering individual bidding units.  I have mentioned earlier relying on public ownership or funding the incumbent is perhaps more attractive in the short run in terms of  relatively less time and effort required to commence roll outs. However the long term impact of monopoly ownership of even open access networks (on competition and accompanying aspects such as innovation/customer service/technological neutrality) and regulatory burden involved in ensuring open access on continuing basis, merit consideration.

It is interesting to note that Indian telecommunications players are looking at voluntary sharing of OFC networks and setting up joint ventures to invest and manage shared networks as the way forward. This may be happening only in cities and towns at present, but it is a moot point whether this trend would not have been replicated eventually in rural areas if the PPP approach to network roll out had been followed.

As of now 2.5 lakh village panchayats (local government centres) are to be connected through NOFN or the public sector SPV called Bharat Broadband Network Ltd. This roll out would take high speed broadband  to rural India and hopefully revolutionize rural telecommunications. It is hoped that the roll out is achieved on time and  that the resultant network is effectively regulated to ensure open access and a level playing field between participating Public Sector Units (PSUs) and various private entities involved in the broadband eco system. needless to say these supply side initiatives must be accompanied by measures to address other aspects of the rural broadband value chain.   

Another important, not entirely unrelated development is the forthcoming creation of a Telecom Finance Corporation to provide capital to telecom operators in India at internationally competitive rates. This should give a fillip to network and service expansion and will hopefully be used to fund not only infrastructure but also content and capacity building  related projects.

Universal Access/Service for the Disabled

While ICTs can act as a powerful tool for empowerment of the disabled, lack of accessibility to standard means of communications can keep ICTs beyond the reach of persons with disabilities (PwDs). Most nations of the world include accessibility of at least public pay phones, if not individual connections, within the definition of Universal Access/Services. Many provide relay services for hearing and speech impaired persons.

In India Universal Service Obligation  is defined as the obligation to provide access to telecommunications services to people in rural and remote areas at reasonable and affordable prices. Needless to say,  this implies that all categories of rural population should be able to benefit from ICTs regardless of their physical/social/educational or economic status. 

India is also signatory to the United Nations Convention on Rights of Persons with Disabilities and a member of the International Telecommunications Union (ITU). The latter  is committed to implementation  of the Convention.This was reaffirmed through approval of Resolution 70 at the WTSA-12 in Dubai last year. ITU's efforts in this regard are documented at http://itu4u.wordpress.com/2012/12/03/itu-celebrates-the-international-day-of-persons-with-disabilities/

The Indian Universal Service Obligation Fund  had initiated a pilot project scheme for access to ICTs by the disabled in 2012 through a formal Expression of Interest, after due consultation with stakeholders. The scheme details are available at the link below. http://www.usof.gov.in/usof-cms/disabled.htm

Unfortunately, the response to the scheme was not very good. This is partly because USOF can fund only telecom service providers, who in turn were not eager to be the  project lead in such an effort. A more flexible approach allowing NGOs or disabled persons organisation (DPOs) to take the lead with active participation by USOF Administration to facilitate project formulation through collaboration with other stakeholders may have worked better.  An analysis of approach followed by USOF in this case, alternative approaches and advantages and pitfalls thereof can be seen at http://www.itu.int/ITU-D/asp/CMS/Events/2012/Nepal-PwDs/Presentation_GULATI.pdf

 It is hoped that Indian USOF will continue to prioritize access for the disabled. 

USOF India

The funding position of the Indian USOF as on 1.4.2013 is available at http://www.usof.gov.in/usof-cms/usof_fundstatus.htm 

It makes me proud that the website that my USOF team and I created in 2010  has earned USOF praise for transparency in financial reporting. (See 18.6.2013 blog).  The secure embedded software which needs a log in and password allows both subsidy claim settling  field units (Controllers of Communications Accounts) and Universal Service Providers to interact with USOF Headquarters on matters of subsidy authorization and claim settlement, ensuring also that all stakeholders have access to a common MIS which is exhaustive and comprehensive. Apart from that the site is designed to be a one stop shop for information on USOF including legal and implementation aspects.

USOF India is an active Fund as can be seen from articles describing progress of NOFN and the recent Cabinet approval for towers in Left Wing Extremism(LWE) affected villages. What is also needed is a greater focus of demand driven PPPs. These require considerable effort on USOF Admiration's part to consult, collaborate and design innovative programmes /projects and to see them through. However, this is  badly needed if we are to reap the benefits of  USOF's  bigger supply side initiatives. 

Govt needs Rs 13,645 crore to meet rural broadband target

 USOF left with Rs 21,800 crore for rural telecom projects

Universal Access to Emergency Services

A very important aspect of Universal Service is accessibility of services to persons with disabilities (PwDs), the aged and the illiterate. This is essential not only for day to day communications which can help in mainstreaming and empowering people with special needs but also for emergency communications. The majority of  countries include free access to emergency at least vis-a-vis payphones in their UA/US related regulations.
However, while ensuring access to  emergency numbers is critical the reverse communication by way of accessible emergency alerts can also help save many lives in disaster situations. Needless to say these sections of the population are extremely vulnerable during disasters. In this regard it is interesting to read a FEMA report on  Alerting the Whole Community: Removing Barriers to  Alerting Accessibility at http://www.fema.gov/library/viewRecord.do?id=7599. This report also has an interesting observation to the effect that in the U.S text messaging is second the most preferred means of receiving emergency alerts for PwDs. Given the huge contrast between mobile and land line teledensities in India  this trend is a thought provoking one for policy makers and regulators in the area of disaster management and telecommunications.

Also of interest may be the recent Telecom Regulatory Authority of India consultation paper on Universal Single Number Based Integrated Emergency Communication and Response System which asks stakeholders whether SMS may be used for emergency access. The vast majority of stakeholders have agreed that this is important for the disabled.

Questioning the Efficacy of Universal Service Funds: GSMA Calls for Re-evaluation and Reduction of the Universal Service Fund Levy

The importance of ICTs for sustainable and inclusive economic development and the unacceptability of the digital divide on socio-economic, political and ethical considerations are beyond question.

The modern concept of Universal Access (UA) or Universal Service (US) implies that all citizens must be able to benefit from connectivity to Information & Communication Technologies (ICTs) regardless of their socio-economic status or location within a country. Thus US requires universal availability, affordability and accessibility of ICTs.

Governments have always tried to ensure UA/US through various means, at times even before the concept was given legal recognition. Historically in the era of copper based PSTNs, telecommunications was considered a natural monopoly and the incumbent operator was usually allowed to cross-subsidize local access (to individual residents and/or households rural areas)  from higher (monopolistic) earnings derived from the national and international long distance markets. However, with the onset of liberalization and competition, such cross-subsidies were not possible as the competitors began to undercut the incumbent who was forced to lower (monopoly) tariffs & hence profits. The concept of Access Deficit Charges (ADCs) substituted these internal cross-subsidies with inter-operator cross-subsidies as other operators were required to pay fixed/percentage based compensation to the incumbent for affordable local access. Both measures are neither transparent, nor efficient and create market distortions. Most countries have withdrawn these measures and now resort to either rural/remote area roll out obligations as a part of license conditions or rely on Universal Service Funds (USFs). While technically USFs are more transparent, targeted and efficient mechanisms to achieve UA/US and  competition neutrality is often a stated precondition for USF support, in practice their implementation has not measured up to these theoretical advantages. There are considerable variations in regulatory and implementation practices across the world though around 130-140 countries have defined UA/US requirements.

Funding for UA/ US is mostly from either the general budget or levies on operators. Given that it imposes a form of taxation and given that it is expected to meet certain legally, politically and ethically important targets, the subject of US in general and USFs in particular is always under scrutiny and debates on this issue range from questioning the need for US regulation in a competitive  market to arguing in favour/against inclusion of broadband  in its purview. Off late the balance seems to be tilting in favour of USF for funding national broadband plans and nation-wide OFC networks.  Thus discussions range from trashing the concept to seeing it as a vehicle for achieving state of art ICT services.

The April 2013 GSMA Survey and Report available at GSMA Calls for Re-evaluation and Reduction of the Universal Service Fund Levy question the efficacy of USFs as means of  achieving the objectives of US.  As far as India is concerned there is praise for transparency in financial reporting and criticism for " inadequate or misguided articulation of USF objectives and strategy” that have encouraged urban rather than rural roll outs. I feel that the findings of the survey point to the need for better institutional mechanisms that guarantee transparency, accountability and competitive neutrality  while still being tailored to a country’s local context. Further we need to adopt a more innovative and flexible approach to US funding. We need to consider more bottom-up PPPs, more demand-driven projects and also projects that address demand side gaps to penetration of ICTs.

Universal Service (ICTs) -An Evolving Concept

As an opening remark, I would like to say that those familiar with the concept of Universal Service  to ICTs (US) would agree that it has undergone many changes over the past decades. From opaque cross subsidies in the era of monopolistic provision of copper based land line connectivity, through access deficit charges in liberalized regime with growing mobile revenues, to more transparent funding from Universal Service Funds, US as a concept or obligation has always been present, often even before it has gained statutory status, albeit in different avatars.

What is a bit worrisome is the current practice of using Universal Service Funds (USFs) for nationwide roll outs of Optic Fibre Backbones (OFC) without perhaps giving adequate attention to impact on competitive neutrality.  Very often the incumbent operator ends up having a major roll to play in such a scheme by virtue of ownership of the majority of the existing OFC backbone, As somebody wrote, it is as if we are going back to the future. Should we not be wary about supporting such potential monopolies without well though out strategies to avoid re-creation of monopolies, even if in the short run this appears to be the faster or more economical option for  bringing high speed broadband to rural/remote/under served  areas? I will  write more about that later.

The good side of the present avatar of US is the increasing awareness  and use of USFs for addressing the needs of disadvantaged groups such as women and the disabled and for addressing demand side gaps to ICT connectivity. The Indian USF has two such projects to its credit. The first is labeled Sanchar Shakti and is aimed at provision of mobile value added services to rural women. This is a very successful initiative.The other which did not take off is their pilot scheme for access to ICTs for disabled in rural India.
More about this later.

Here is a link about Sanchar Shakti from GSMA's Blog
http://www.gsma.com/mobilefordevelopment/innovative-use-of-universal-service-funds-sanchar-shakti-gaining-strength

Here is a link about EC updates on  National Broadband Plans
http://broadbandtrends.com/blog1/2012/04/09/european-commission-updates-on-national-broadband-plans/