Annexure-1

Key Concerns on DoT Guidelines

Implementation of Green Technologies in Telecom Sector

Some of the key concerns noted by the industry with regards to the DoTs Guidelines on the
Implementation of Green Technologies for Telecom sector are listed below :-

1. Telecom Industry accounts for a fraction of the carbon footprint, should not be
singled out; Policy should encompass all sectors for a worthwhile result:

It is first submitted that service providers are in the business of providing public
telecommunication services which is essential to meet the connectivity objectives of the
country and also give multiple allied benefits of improved productivity and enhanced
economic growth. To meet these objectives, operators need assured reliable grid power. In
the absence of this basic assurance/requirement, it is unjust and unfair to additionally
impose on operators the onus of complying with green energy requirements.

We also believe that the responsibility for creating a greener environment spans across
industries, and any green guidelines covering just the Telecom Industry will not only be
discriminatory, but will also be an exercise that will greatly fall short of the result that the
nation as a whole desires for.

It is also important to note that the share of ICT in the total carbon footprint is minimal
and has been constant over the years. Globally ICT accounted for only 0.83% of the
carbon footprint in 2007 and this will increase marginally to 1.43% of the total carbon
footprint by 2020.

1.43% of overall
emission by ICT in
2020

0.83% of overall
emission by ICT in 2007

Smart 2020: Enabling the low carbon economy in the information age. Report by the climate group

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 Further, Indias share in the Global ICT footprint is much lesser in the 1.43% slice of ICT
likely in 2020 as is evident from the graph below:

Other
Industrialised
OECD Europe
countries
12%
7% US & Canada
EIT 14%
10%

RoW
China
27%
30%

Smart 2020: Enabling the low carbon economy in the information age. Report by the climate group

India is included in RoW with other countries, with the average share being only 27%
of 1.43%, which amounts to only 0.38% of the global ICT carbon emissions.

It may also be noted that the CO2 emissions from the Indian telecom sector are negligible
as the sector is already on the Green Track. It is in fact sectors such as agriculture,
Electricity, Transport and Cement which account for 70% of CO2 emissions in India
whilst telecom which is included in Other Industry has a share of just 9%.
Waste
Agriculture 3%
18% Electricity
38%

Other Industry
9%

Iron & Steel

6% Transport
Cement
Other Energy 7%
7% Residential
5% 7%
Source: INCCA India GHG Emission, 2007 - MOEF

It may be appreciated that given that telecom is a part of Other Industry which contributes
just 9% of CO2 emission in India, and the fact that Globally, ICT will account for only 1.43%
of the total footprint by 2020, we believe that the telecom sector is being unfairly targeted
and submit that even if telecom sector was to become green overnight, the overall impact on
the carbon footprint will be negligible.

Recommendation 1 - We therefore submit that it is imperative that the Go-Green

initiative first targets the sectors that are responsible for a significant percentage of
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 the carbon emissions or at the very least ensure that the go-Green guidelines are
non-discriminatory and encompass all sectors for a worthwhile end result.

2. Use of Diesel is a compulsion not a choice; Guidelines for Green Telecom must take
into account ground realities:

It may first be appreciated that Mobile Infrastructure Companies use diesel as an option
of last resort, as besides the obvious concern about pollution, diesel is an expensive
fuel, which entails high costs for both carriage from one location to another as well as
storage.

Given the choice, it makes eminent commercial sense for Mobile Infrastructure companies
to use a cleaner and more affordable fuel alternative. However, the experience with
thousands of standalone solar solutions deployments confirms that the assumptions about
the life cycle of solar PV systems and batteries are overly optimistic. The extremely high
upfront costs and the accompanying technology risks have deterred solar roll-outs on a
large scale as these are simply not sustainable.

The lack of sustainability of alternate energy solutions is also evident from the fact that
Bharat Sanchar Nigam Limited (BSNL) at a recent workshop organized by TRAI has
admitted that their experience of 20 sites where they have deployed alternative energy
solutions shows that they would need considerable subsidy to scale up this project.

Mobile Infrastructure Companies on their part prefer rechargeable batteries to diesel as

rechargeable batteries despite being expensive, are less polluting and convenient.
However, use of rechargeable batteries is largely dependent on electricity supply from the
grid which unfortunately is very inadequate and erratic, especially in rural areas. It may thus
be appreciated that most often, companies have no choice but to depend on diesel supplies
in order to ensure un-interrupted service to consumers.

It is thus submitted that all efforts to introduce Green Telecom would fail if the
measures prescribed are not implementable.

Recommendation 2 - We believe that the DoT while laying down guidelines for Green
Telecom must take into account these ground realities and ensure that the measures
required to be undertaken are sustainable and targets which are laid down are
achievable in order to meet required end objectives.

3. Sub-optimal spectrum allocations lead to more sites & higher diesel consumption; a
spectrum policy that ensures adequate spectrum can overcome this constraint:

It is further submitted that one of the key reasons for higher use of diesel and the
consequent higher carbon emissions is the very sub optimal allocations of spectrum to the
Indian operators, that has resulted in the setting up of a far higher number of sites for
providing capacity and coverage than would have otherwise been required. It has been
estimated that the fragmented spectrum allocations is costing the nation upto 15 million
additional tonnes of diesel consumption per year.

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 A spectrum policy that ensures optimal and adequate spectrum is absolutely
essential to overcome this constraint, which in turn, can lead to a significant
reduction in carbon emissions.

4. Targets for deploying Renewable Energy Technologies are very stringent in the initial
period; DoT may prescribe more reasonable gradation:

It may be appreciated that from the point of view of solution identification, developing
technology/vendor eco systems and implementation, the initial years are the toughest ones
and therefore, it would be both logical as well as desirable to have more reasonable and
practically achievable targets in the initial years, followed by a high ramp-up in later years.

Existing Proposed
80% 80%
60% 60% Urban
40% Urban 40%
Rural
20% 20%
0% Rural 0%

Also, one blanket measure across India may not be appropriate as the conditions in
various geographies are very different.

Recommendation 3 - In light of the above DOT is requested to re-look at this target taking
into account technical feasibility and other factors.

5. Lower capacity factor of Solar will deter site sharing; proper study is required to strike the
right balance for use of solar cells for powering the BTSs:

As you may be aware, due to space and other techno-economic constraints, the typical
capacity of a Solar Power System is about 2-3 KW, which is only suitable for the sites with
single tenancy. Thus, in the event that a Solar Power System is deployed for a site, that
particular site would NOT be capable of being shared with other operators, which would be
an extremely retrograde step in an environment where sharing is not only encouraged but
has also been actively implemented by all operators.

It may thus be appreciated that the mandatory application of the direction to have 50% and
20% of the sites for the rural and urban areas respectively, powered by using Grid Power
and RET would result in significant reduction in the number of sites which can be shared,
this would eventually result in deployment of higher number of tower sites and hence higher
carbon emissions, which would lead to the exact opposite of the intended objective to
achieve lower carbon emissions.

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 Recommendation 4 - We also believe that rather than having differential targets
stipulated for rural and urban areas which would be difficult to monitor, there should
be a consolidated uniform target covering all possible sites.

We also submit that abundant caution needs to be exercised in seeking to eliminate diesel
generators and instead use solar power for electricity requirement of BTSs (carbon emission
reduction) as this will result in a three-fold higher use of battery capacity. Given the fact that
nearly half the country has 14 hours long nights in winters and the fact that battery life is
directly dependent on charge-discharge cycle (which is just 200-400 cycles only for
maintenance free batteries being used in telecom industry) elimination of diesel generators
will require daily charging of batteries for at least 14 -15 hours whereas normally a back-up
of not more than 4-6 hours is required, thus reducing life of batteries (from 2 to 3 years to
less than 1 year). It is further stated that manufacturing process as well disposal or recycle
of life expired batteries produces more toxins which is more damaging to environment.

Recommendation 5 - We therefore submit that a proper study is required to strike the

right balance for use of solar cells for powering the BTSs.

6. Target for Carbon emission should be prescribed on a per unit of traffic basis to
cover both voice and data:

We believe that as we go forward, the increase in the number of subscribers is likely to lead
to increasing energy consumption resulting from an increase in both voice and data usage.
Thus, it would be more logical if the Carbon emission targets were to be based on a per
unit of traffic carried in the network as opposed to per subscriber basis.

Recommendation 6 - Since the networks today carry substantial amount of data apart from
voice, the best approach would be to base the measurement on per MB of traffic. Voice
minutes carried in the network can be converted into an equivalent MB so that both voice
and data can be factored into this equation.

7. Baseline needs to be set as year 2012-13, Measurements should be as declared by

CEA & Reporting should commence after a period of two years:

Recommendation 7 - As the Green guidelines have only just been released by DoT, the
baseline needs to be set as year 2012-13, due to the non-availability of historical data.
In many of the shared sites, there is no provision to apportion individual consumption.

Also, the formula proposed by TRAI for calculating Carbon footprint is very complex and it is
applicable for maximum throughput applications (where there is continuous full load).
Whereas the loading pattern of DG sets in telecom is very dynamic and varies widely from
25 to 85%. However, since the proposed formula uses the loading factor as a constant at
100%, it would lead to erroneous carbon footprint values.

Recommendation 8 - We therefore suggest that the measurement methodology,

declared by Central Electricity Authority, Ministry of Power & vetted by UNFCC which
is simple and widely used, should be adopted.
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 Recommendation 9 - Further, since the measurement of Carbon Footprint is a complex
issue and there is no policy framework in place, we request that at least two years should
be given to the service providers from the date of issue of the letter to start declaring
their carbon footprint.

We are also not aware of any industry/sector that is required to declare its carbon footprint
twice a year. As submitted above, we believe that green norms should be sector agnostic
and should apply to all sectors using fuel. Recommendation 10 - We therefore request
that reporting should be done once a year.

8. Green Passport [GP] by 2015, to be harmonized with international standards; DoT to

facilitate meeting with TEC to begin work on Green Passport norms

As you are aware, power expenses account for the major part for the operators expenses
and thus, it is a business imperative as well as a corporate social responsibility for operators
to adopt energy efficient technologies.

Mobile operators and telecom equipment manufacturers are continuously upgrading their
network infrastructure to use green technologies.

The standards/certification such as the Green Passport [GP] need to be harmonized with
ongoing international / other standardization procedures. It would be imperative to take into
consideration the same before adopting or framing guidelines on the standards/certification
such as the Green Passport [GP]

Recommendation 11 - DoT is requested to facilitate a meeting with the TEC to begin work
on formulating the Green Passport norms/ standards in consonance with international
standards.

It may also be appreciated that Telecom Operators / Licensees have absolutely no control
on R&D carried out by Telecom Equipment Manufacturers. Telecom Licensees can procure
and deploy Green Passport Certified equipment strictly based on the availability of such
equipments which in turn depends on the equipment manufacturers.

9. Voluntary Code of Practice:

In view of the above it is evident that there are many issues that need to be clarified by the
DOT. The Voluntary Code of practice can only be formulated once we receive the
clarifications from the DOT. Recommendation 12 - The submission of this is therefore kept
pending until we receive a response on the above points from the DOT.

10. Other Issues

We respectfully submit that the targets laid down for rural towers discriminate against
operators who have already taken the lead to go into the rural areas to increase tele-density
and service in rural areas. Operators with a larger rural footprint will have a steeper target.

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 Similarly, operators who already have taken several initiatives for significant energy savings
in network & operations will have a tougher task to reduce even further from a lower base.

We submit that such operators will be disadvantaged and face a greater burden of these
green targets now being introduced.

The guidelines need to take this aspect into consideration to ensure fair and equitable
treatment of all operators.

The DoT guidelines also need to factor in the fact that different technologies 2G, 3G, 4G
are playing here at different levels of maturity and would have a bearing on the
achievements possible in green Telecom.

WAY FORWARD

In view of or above submissions and in order to ensure an effective adoption and

implementation of green telecom guidelines by the Telecom operators, we suggest following
approach:

I. Adoption of Renewable Energy Supply Companies (RESCOS) Model to fuel Telecom

Towers:

Telecom operators are most willing and committed to deploy clean energy solutions if these are
available at an affordable cost. While this is not currently possible, this can be expedited if
telecom players work closely with Renewable Energy Service Companies (RESCOs).

The chief barrier facing RESCOs in providing affordable green energy sources is absence of
sustainable business models that will enable the costs to be recovered in a reasonable time
frame. The biggest challenge in this is the absence of scale.

We believe that the telecom industry can play a key role in improving the economics of
alternative energy production and usage especially in rural areas. As a bulk user of the clean
energy produced by the RESCOs, telecom operators can serve as their anchor clients. This will
not only provide the much needed scale to the RESCOs, but also reduce the cost-price deficit,
possibly removing the deficit altogether in some areas. As a result, the communities around the
RESCO facilities too could receive cheap power.

Industry commits to bring together all IP-I players in a cluster to improve the economics of
supply for particular RESCO. Clubbing demand from these players, RESCOs can deliver
economies of scale for high-cost infrastructure. With a large anchor demand for energy from just
one user viz. local telecom infrastructure players, off-grid distributed renewable energy project
can become viable. Consequently, telecom industry instead of being viewed as a part of the
problem would become an integral part of the solution by improving the economics of electric
supply.

In addition to the above, all the stakeholders including the infrastructure players, telecom
operators, RESCOs and the community should collaborate on building micro power stations.
The Electricity Act allows for this and the experts also recommend such a course.
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It would also be desirable if the Ministry of Non-Conventional and Renewable Energy (MNRE)
can step in to support the RESCOs with suitable subsidies wherever required. This would also
be logical since RESCOs are channel partners of MNRE and get substantial support from
government. However, this support should entail specific rollout commitments on RESCOs to
provide green energy to Telecom Infrastructure Companies at agreed prices and service quality
levels.

We believe that the above proposal/approach has the advantage of providing the right
incentives for all stakeholders. By proposing RESCOs-off Grid solutions for clean energy, it also
reduces the dependence on the resources of the electricity grid and promotes much needed
decentralization. Delivering electricity to surrounding communities will provide lighting and other
emergency support to begin with and has multiplier effects in almost every area of activity in
rural areas.

In contrast to the existing approach, we believe that the above solution/approach is much more
logical and sustainable and thus gives the proposal a higher chance of success.

II. Implementation of this scheme vide the approach suggested by the committee of
stakeholders :

We believe that the responsibility for implementation of this proposal/approach should

vest with the committee of stakeholders that was proposed in the Ministerial Roundtable
on IP-I issues (Held in Jan 2012). A verbatim record of this Round Table is on the DoT
website.

It is important to emphasize that the industry seeks no additional subsidy for this. All it seeks
government support and facilitation to enable the many government and private stakeholders
come together on a common platform to work together to achieve common end objectives.

III. Pilot Projects:

While the industry wholeheartedly shares and supports the overall vision of making Telecom
GREEN we believe that the current guidelines do not fully address the various constraints and
ground realities as explained in the above paras.

We believe that in order to adopt a more practical approach, there is a pressing requirement
to undertake a few Pilot Projects with suitable number of BTS in different geographies to
better understand the implications and technical feasibility for implementation. This Pilot should
include participation by DoT, TEC, MNRE, TRAI, TSPs, IP 1s,RET vendors.

These projects must reflect the diversity of renewable energy solutions and of Indias
geography. Solar, wind, water and other types of energy have their respective strengths and
constraints. In the same way, the needs of hilly regions of North East are quite different from the
coastal Andhra. One-size-fits-all approaches would not be workable and would also lack
adequate redundancy.

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An important role for the committee proposed in the aforesaid Roundtable was to identify
a sufficiently representative set of pilot projects to test the many energy solutions of interest.
Such an approach will not just address the key concerns relating to threat to environment and
health. They would convert the challenge into an opportunity to address the underlying problem
of poor access to power that hurts not telecommunications alone but the country itself. The
observations and outcome of the PILOT may be used to fine tune the Green Telecom targets
and other policy mandates.

IV. Roundtable to discuss issues pertaining to Green Telecom

We suggest that all the above issue may also be discussed at a Round Table Discussion
with all stakeholders so as to clearly frame the issues on which reconsideration is
required.

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