Hi,

I read the Consultation Paper on “Regulatory Framework for OTT Services”.

I have three opinions from three view

1)      General Observation

2)      From view of consumer

3)      From view of TSP (Telecom Service Provider)

4)      From view of Innovator (Application Developer) of Facebook/Skype/WhatsApp

1) General Observation:

Applications providing messaing communicate (text/voice) kept coming and going. People starts crazy and sometime after even people do not remember their names. I am using messaging apps since long. First I used Yahoo Messenger (really first popular messenger service) which later unveiled voice communication too. At time it was part of daily life of many people (mine too) but now nobody even remembers or suggest to download it. Yahoo messenger was replaced first by GTalk (Google Talk) even this service got obsolete by google itself and providing it’s migration path to Google Hangout. TRAI and other people involved in framework can check even though so much successful messaging app at one time that everybody moved from Yahoo to GTalk and even owned by google and very tight coupling other many google applications hangout’s usage statistics did never took off.

In my view this framework started to take place when Airtel and other TSPs feel themselves threat by hearing Voice Calling by WhatsApp by understanding that voice calling revenues will go down.

It’s almost a month WhatsApp rolled out voice calling checkout how many people tried using it .. (Ha ha ha). One can try to think why not.. Internet bandwidth is not that cheap.. Rs.250 approx for 1 GB. On a regular usage it does not leave much and using whatsapp voice calling consume bandwidth at ends of call.

Finally a short note, I am also a developer in IT and play role of a Technical Architect. Adding burden or complex world of internet usage or charges will ultimately hurt morals of Application Developer and Innovation. TSPs will not get benefit while national GDP will get that hit ultimately because lack of innovation. One small application developer who wants to try Innovation will not be knowing all rules and remain afraid about uncertainty for what he is liable.

2) From View of Consumer:

Consumer should pay to service provider for what services he is using from provider. If user is consuming internet he should only be paying for internet regardless for what purpose he is consuming that internet bandwidth.

If user has to pay for a messenger application for making a call to a land line or to another person using that application then bandwidth used for such application should never be charged and should be available at the highest speed available to make efficient service. If TSP can ensure that even if a mobile is on 2G and making a voice call using an application which requires a 512KBPS for a better call (from app to app / landline/mobile) then such application will surely get that speed then app and TSP can have their agreement for revenue sharing and consumer will only pay to app for usage. Bandwidth used by this app should never be chargeable and it’s TSP responsibility to ensure best quality of service for such app.

3) From view of TSP:

TSP can always think of entry of another TSP or another technology can hit their revenue. TSP can always try to demand revenue sharing from such apps. But that revenue sharing from service provider.

TSP should never expect to create a complex charge structure for end consumer. In past (early 20xx) we have seen telecom companies provide many ways to offer service (like sms, voice calls for subscription) and end user are not many literate and cause problems for consumers for higher charges or bills and ultimately it becomes dispute between TSP and consumer and TRAI needs to take care of this aspect.

If TSP thinks they are getting affected.. TSP should know that they have license for providing internet. Govt has right to block/unblock any particular service which govt might seem as threat for security of nation or individual (in terms of information / financial / other).

4) From view of Innovator (Application Developer) of Facebook/Skype/WhatsApp

As of now many application providers are not from india. I believe in coming years there will be good innovators from India to provide very good applications across world. PayTM seems one of them. Creating a favourable environment for application developers (Innovators) will soon give India few multibillion dollar companies and open a large domestic and foreign revenue earners. Same is the reason why many innovating companies comes from US. Because they have net-neutrality TSP should only charge for bandwidth. Consumer is using bandwidth for what purpose is upto the user.

TRAI wants to keep track of calls being carried using VOIP, how these calls should be treated

1)      National Security agencies should have access to all calls made using such apps.

2)      App to App calls should be considered equals to calls within network of TSP (AirTel to AirTel in same circle)

3)      App to landline calls should have inter-connection charge to protect TSP. and inter-connection charge should be payable to service provider at the receiving end of Call, because Originating end of provider is getting paid for internet.

A suggestion:

Make favourable environment for india’s growth. If we want to see 100 indian companies part of fortune 500. Net-neutrality is the basis of growth of US.

If we do not want net-neutral then first compensate Post-Office first for obsolete feature of Telegram then BSNL for eroded revenue and burden of Pension because most users moved to new TSP for landline and mobile.

Thanks & Regards

Vikas Parikh

Hi Honorable Minister,
Department of Telecommunications.

It has come to our attention today that Airtel has decided to start charging for VOIP data traffic on all Subscribed Internet Plans.

Quoting it, from their terms and conditions page:

“All Internet/data packs or plans (through which customer can avail discounted rate) shall only be valid for Internet browsing and will exclude VoIP (Both incoming/ Outgoing). VoIP over data connectivity would be charged at standard data rates of 4p / 10 KB (3G service) and 10p / 10 KB (2G service). “

This is a gross violation of the principles of Net Neutrality. As the Internet is essentially seen as a utility, promoting such a misstep is only going to further impede the government’s vision of providing cheap and affordable Internet to all its citizens.

Being providers of utility services, an ISP should not be able to control or alter the terms of access to such services according to their whims and fantasies. This is going to set a dangerous precedent where ISP’s will have the ability to dictate the terms for all internet companies, unless they are paid first.

This is similar to how monopolies act, and the government should be more proactive in trying to discourage such business practices.

We would also like to bring to your notice that failing to prevent such malpractices will lead to further collusion and cartel-like behavior among the Indian ISPs.

We have already seen enough instances of such behavior, where some of these same ISP’s have colluded against the interests of the consumer and the exchequer. Therefore, we believe that it is time the government took notice of this issue.

India is a growing economy with a nascent Internet Industry. Failure to prevent the spread of such practices will further discourage Internet startups from working and/or coming to India, leading to fewer businesses and reduced employments in the future.

We ask for your help, in keeping the Internet open and available to all the citizens of India. We sincerely believe it is the most powerful medium of communication that humanity has ever created, and a failure to act today, might endanger this nascent tool from achieving its greatness.

A concerned citizen.
Vikas Parikh