Cut to the present and TRAI’s recent recommendations on 2G spectrum pricing and consolidation have been met with overwhelmingly critical responses by all and sundry in telecom. “For the first time I’m seeing TRAI regulations that are meaningless. It’s almost as if a smaller player said that M&A norms should be anti large players or almost as if they are targeted at big GSM players like Bharti and Vodafone,” says Sridhar Pai, the founder of telecom consulting company, Tonse Telecom.
The other stunning recommendation from TRAI is a sneaky one. It recommends that any further allocation of frequency from the old stock of spectrum [2G] be made at the prices at which companies have won their share in the new stock [3G] spectrum.
“Yes, the incumbent operators took it free of cost and enjoyed it; they should have paid for it. But asking them to pay 3G market determined price in 2010 is a little unfair. The 3G auctions story would have been different if companies were told beforehand that 2G prices would be linked to 3G prices,” says Shetty.
Not surprisingly, operators have chosen to question TRAI’s recommendations. Airtel and Vodafone both wrote to the Communications minister A. Raja, the former calling the recommendations “shocking, arbitrary and retrograde”. The two, along with Idea, then challenged the recommendations before the TDSAT, which told them the difference between recommendations and orders.
Radio spectrum is a scarce resource all around the world, in India it is much scarcer simply because there are more operators among whom it is divided. But if TRAI’s goal in slicing ever smaller pieces of the spectrum pie to more players was to increase competition, the net result might be the exact opposite.
According to a study commissioned by the GSM Association in December 2008, the average Indian operator with 5.5 MHz spectrum has one quarter the 22 MHz spectrum available to operators around the world.
That means successful operators like Airtel or Vodafone reach the spectrum limits the fastest and then suffer the consequences of network congestion: Losing customers to smaller competitors. That isn’t better competition; it’s government-enforced socialism of market share. Better competition would be if those customers left them for lower prices or better services. No wonder then that operators like Airtel and Vodafone plan to deploy a significant majority of the 3G spectrum they bought to provide “defensive voice relief”, meaning use 3G for voice calls so your best customers don’t leave you for better voice quality.
Older players have also been hit by a slew of other TRAI recommendations — licence renewal fee, 2G spectrum charges, 900 MHz re-farming, cap on consolidation — and they are not allowed to share spectrum. Newer players come in with a reduction in licence fee, a government-given market value for their spectrum (never mind subscribers), spectrum sharing has been allowed for them.
“Net effect of TRAI recommendations is that incumbents have been put at greater risk: Lesser spectrum, 900 MHz advantage being taken away, lesser M&A options,” says Mahesh Uppal, a telecom policy consultant.
Now why should it be like that?
The only reason is that Indian regulators are fascinated with the idea of “large” and “vibrant” markets and a desire to constantly level the playing field to make sure that new operators feel at home. But if there is freedom to enter the industry there must be freedom to exit it as well. And that’s why the M&A recommendations that TRAI has suggested make so little economic sense.
Consider some proposals. A merged entity cannot have more than 30 percent market share nationally. The total spectrum held by a merged entity cannot exceed a certain point, which is not very high. “How can you decide on 30 percent? It is just not comprehensible. And if I have to return spectrum then why should I merge?” asks a telecom industry veteran.
In most telecom markets across the world, generally there are four to five players. The top two make money, the third makes just enough to keep body and soul together and the number four and five sell out getting newer guys into the game who think they can rock the boat. Since in India there are very few incentives to merge, the number of competitors will not come down by a lot.
“If policy enables, we should get down to 6-7 players in two-three years — the top four big guys and younger/more agile competitors (with foreign funding) and BSNL/MTNL. I see a decent role for six-seven operators but not 15,” says Kunal Bajaj of Analysys Mason, another telecom consulting firm.
Sachin Gupta, a financial analyst with Nomura agrees and says you need to burn serious to find out whether you can. “Very few can exist profitably, perhaps five-six. More than consolidation there might be elimination, forcing some to pack up and go. Smaller players must spend $0.5-1 billion to get more clarity to see if they can survive and make money,” he says.
If you can’t exit then companies will stay and compete destructively. TRAI recommendations have given a fresh breath of life to the newer entrants. They can now stay on longer before deciding whether to quit or not. “If you are a Datacom or Etisalat you will like these recommendations. You are compounding your sins, first you added 100s of licensees and now you make consolidation more difficult,” says Uppal.
Remember, scale is what makes or breaks consolidation attempts, typically achieved when larger players merge or acquire each other. “I don’t know what Loop, Datacom bring to the table. If they don’t get acquired, why do they stick around? It is extremely late in the game,” says Pai of Tonse Telecom.
The question is, why would anyone want to acquire them? They have too few subscribers and they can’t be acquired for spectrum as most of it would have to be returned. “What are the benefits from M&A for Airtel? What would it get by, say, buying a new entrant?” asks Shetty.
Now the regulators may think that the small players will band together and form a large entity and go on to compete with the big boys but that’s pipedream, not policy. Those sort of mergers will not happen because one, they are too tough from a managerial point of view and two, even the new entrants want very high valuations. Many of them expect more than $100 per subscriber, regardless of whether she is real or a paper projection.
The reality meanwhile is that many of today’s subscribers will not generate that much during their entire lifecycle. “Valuations are still based from the Hutch acquisition days,” says Shetty. The post 3G valuation has Gupta of Nomura puzzled. “Will they [newer operators] demand 3G prices? Why would a company pay $3-4 billion for 3-4 million subs [subscribers]?” Some are even more drastic. “Subscriber-based valuation should simply be thrown out of the window,” says Barasia of Bain.
Is a Way Out Possible?
There are two or three ways out of this mess. One is to clearly have a market mechanism to price spectrum. Have frequent auctions to sell off whenever it becomes available. The other solution will be to create a spectrum trading market. It works for the electricity sector. The government decides an upper limit to keep speculation down, but no lower limit.
If this was introduced for spectrum it would allow companies that have excess of it to trade it and profit from it. The government can tax that profit if it wants to. If that’s too radical, allow all operators to share spectrum, leaving them and their equipment providers to work out the technical aspects around that?
The second way to make a sector stronger is to do away with the 30 percent market share limit in case of a merger or acquisition. There are many who advocate a pan-India limit of 40 percent and a 30 percent limit in each circle. But why have those caps in the first place. “The government has created the Competition Commission of India. Let it decide if the merged entity is detrimental to consumer interests,” says a senior telecom executive at one of the top three firms.
And lastly, don’t force companies to give away spectrum when they merge. Do two petrochemical companies have to return land when they merge? Do cement companies have to do it? Steel companies don’t shut down one plant facility and return it to the government when they merge. The whole idea is absurd.
And even more absurd is the idea of taking away the 900 MHz spectrum that was allocated 10 years ago and which is anyway a part of the global frequency plan of mobile systems. In any case, taking away the very bedrock on which all Indian mobile networks are based is in all probability legally not enforceable.
The government should try something like the US FCC did when it took an old frequency band in 700 MHz that television had vacated and auctioned it for mobile purposes.
Some of these modifications may come true but will take time. In the meanwhile, telecom companies will have to figure out new business models to compete and last the next 24 months or so.
New Ways to Compete
Consider even the market leader Bharti, India’s largest mobile operator with over 130 million subscribers. The Rs. 12,300 crore it spent on buying 3G spectrum when divided to a more meaningful metric means it paid Rs.1,471 for each of the 84 million subscribers across 13 circles.
Add to that the money it must now spend on upgrading its network to support 3G services — around $750 million say experts — and the cost per subscriber shoots up to Rs. 1,872.

Image: Sunil Mittal by Dinesh Krishnan, Anil Ambani by Sameer Joshi / Fotocorp; Sanjeev Aga by Sameer Joshi / Fotocorp
Which means either each of its subscribers in the 3G circles needs to bring in an additional Rs. 1,872, or a smaller number of higher-value ones even more, over the years for Airtel to just break even on 3G costs alone. Gupta of Nomura thinks it unlikely that in a price-sensitive mass market like India everyone will go in for 3G to begin with. The likely number, he feels, might be 15 percent. If that is the case, then Airtel will need to make an additional Rs. 12,486 from its top 15 percent customers to break even. That’s a lot of additional revenues.
The optimists say this money can easily come in with a negligible rise in ARPU over the 20 year license period for 3G spectrum. But that’s just a theoretical concept because no one, certainly not Bharti or Vodafone, will want to wait 20 years or even 10 years to recoup their 3G investments.
How long will it take then?
Though most experts agree that five to seven years is what it will take most operators to start breaking even on their 3G investments, the next two-three years will be the military bootcamp where the men get separated from the boys.
While the boys try peddling “minutes” to marginal customers at lower and lower prices, the men will be learning the ropes of the data services game. They will realise, for instance, that subscribers in small town India are just as interested in 3G as in Mumbai or Delhi, provided there is content they desire.
Fifty percent of the users viewing cricket IPL-related videos earlier this year came from “tier-2, tier-3 and tier-4 towns”, says Rajesh Reddy, CEO of mobile software maker, July Systems, which powered the mobile version for the tournament. Most of them used entry-level mobile phones made by the likes of Micromax or Lava, says Reddy based on his analysis of their browser details. And on an average each one watched two videos every day, “That’s higher usage than what we see for viewers of the NBA championships in the US!” he adds.

Image: Arvind Rao by Gireesh G V, Neeraj Roy by Dinesh Krishnan; JS Sharma by Amit Verma; Nandan Nilekani by Mallikarjun Katakol
This means figuring out services that people would want to pay for. With voice, that was a no-brainer. Now companies will have to figure out location-based services. For instance, it could be that when you are in the vicinity of a mall you could be offered an instant time-bound discount through your mobile. “The mobile companies could get a share of revenues from malls or retailers for being a conduit for driving traffic into the outlet,” says a telecom industry executive.
Such content cannot come from operators, not just because they don’t have the money or expertise to build it, but because of the rise of a new class of mobile phones: The smartphones. Smartphones allow users to access a slew of services by either installing third party applications (apps) or through an Internet browser.
The place where mobile users head to check out their favourite apps is the “appstore”, a place where any developer can peddle his wares to any buyer with a phone. Seeing this trend, companies like Airtel, Aircel and OnMobile have launched their own appstores in India, apart from ones from mobile handset makers like Apple, Google Android or Nokia. The customer will have a lot to choose from.
Even the content creators like Hungama, Mauj and Indiagames will get more choice. To reach subscribers, most of them were at the mercy of operators who kept 70 paisa of every rupee they earned. This is the exact opposite of US and Europe where content creators get to keep 70 percent of what the customer pays. “When it comes to normalising their revenue share with content creators, operators will have no choice but to, because consumers will have choice now,” says Reddy.
KPMG’s Shetty says once operators clear the trial-by-fire of the next two-three years, India will be one of the most attractive mobile markets in the world. One of the biggest attractions will be mobile banking which he feels RBI might allow by that time, after testing the waters over the next few years. In addition the UID project will equip between 600-700 million Indians with something that was either missing or hard to prove: Their identity. That will create a new ecosystem of secure mobile transactions in areas like governance, banking and even telemedicine.
Meanwhile operators can, of course, sell the low hanging fruit of 3G dongles that can be plugged into computers to access the Net.
But many experts are sceptical of actual possible speeds through these dongles once a significant chunk of the 5 MHz spectrum — already much lower than the 10-15 MHz that is optimal — is carved away for carrying voice. Nonetheless, more of those will be launched by auction winners. But pricing on that will always be on a downward curve as has been the trend with Net tariffs.
But these things are untested and untried. The Indian consumer is yet to show an inclination to pay for data and data-based services. But a telecom firm really has no choice.
“In the future, telecom firms will have to do much more product development and segment the market according to price and behaviour than they have done before,” says Parida of Vodafone. Tonse Telecom’s Pai is much more blunt: “The days of jumping into the Indian market, adding subscribers and becoming EBITDA positive by the third year are gone for good.”
The Camelot of selling voice calls at high profits is over. The rigours of civilisation lie in wait.
(This story appears in the 18 June, 2010 issue
of Forbes India. To visit our Archives, click here.)