*Cellular Operators Association of India (COAI) on ‘Proposal for Direct Allocation of Spectrum to Private Networks* “COAI believes that direct spectrum allocation to enterprises is not tenable in India because of various reasons pertaining to India’s telecom ecosystem, the national revenue as well as security architecture. While some industry bodies have, in their own interests, drawn parallels with countries such as the US, Finland, Germany, UK, etc. where private networks have been deployed, this comparison ignores a crucial contextual difference of such industries being located in remote or geographically secluded areas with limited public network coverage. In India, however, most industrial corridors and enterprise zones are already well-served by telecom operators, thereby leaving no coverage deficit. It is further misleading to state that setting up private networks independently would be cheaper for enterprises as in reality, deploying a private 5G network entails significant capital expenditure on equipment, spectrum management, security, network maintenance and skilled personnel. Unlike TSPs, most enterprises do not have the expertise or scale to manage telecom infrastructure efficiently. What appears cheaper on paper could turn out to be more expensive and operationally burdensome in practice. Moreover, with continuous upgrades and evolution of both the technology as well as the ecosystem, there would be need for continuous upgradations to the network components in the private network, which the TSPs would be in the most favorable position to know and deploy suitably. It is also misleading to claim that telcos would not be technically equipped to provide for the private networks, as with the provisions of 5G, knowledge of the requisite SLAs and the provision of Network Slicing put together, the telcos are in a better position to provide the services along with the knowledge and experience required to run the same on a long-term basis. It may also be noted that radio frequencies cannot be geographically or physically contained and hence, RF signals from private networks can spill over beyond the intended premises, leading to interference with public mobile networks operated by licensed TSPs, creating risks in network reliability, service quality and user experience on both sides. This could be well managed by a TSP. Besides, one must also consider the significant loss to the government exchequer in case of private networks as the national auction of spectrum generated ₹1.5 lakh crore in 2022 alone. Moreover, it would create an uneven playing field between TSPs and private entities who enjoy infrastructure benefits without comparable regulatory or financial obligations. Above all, COAI firmly believes that the private networks managed by unlicensed or foreign entities raise serious national security concerns as these players are not bound by the same compliance, interception and regulatory obligations as TSPs. Without a clear regulatory framework, there would be no accountability in case of misuse, breach or attack. Such an arrangement would also dilute the State’s ability to ensure lawful interception, user traceability and emergency response coordination. Without robust domestic oversight, this could expose India to cybersecurity, surveillance and diplomatic risks and set a dangerous precedent of allowing private service delivery without appropriate safeguards, investments or responsibilities. COAI strongly believes that all enterprise 5G needs must be fulfilled through licensed Telecom Service Providers via spectrum leasing or network slicing as this would ensure national security, revenue protection and regulatory parity in this rapidly evolving ecosystem. The future of India's digital economy must be built on secure, inclusive and accountable networks and Indian Telecom Service Providers stand ready to deliver private 5G solutions under appropriate regulatory supervision.” Lt. Gen. Dr. S.P. Kochhar, Director General, COAI