Dear Sir/Madam,

    I have read the CP on OTT and I propose below plan:

TSPs' still have an opportunity of pure revenue in existing model without affecting existing OTT operations.
This can be achieved by reducing price and displaying commercials to 3g / 4g users.

Please do not confuse this with zero-rating, which is a different model.

I have decribed the plan for ad-supported internet as follows:

User installs an adware APP designed/customized and provided by TSP in the user's phone which shall always run in background. The TSP shall periodically feed ads which will show up in the user's phone.
Two data streams will be generated by the TSP app. a) User data stream & b) TSP sponsor advertisement stream.
If the TSP server is unable to feed ad stream to the user's phone, then user data flow also will stop. The ads can also be semi-interactive to ensure and log user participation.
But TSP advertisement data stream should have limited bandwidth which could be fixed by TRAI to avoid interference with customer bandwidth.
"ad-free" service users need not install the TSP's app.

Of-course this idea is similar to the successful OTT & television revenue making model.
TSPs' can demand very high revenue on these ads because, there is very high hit rate even more than Television. TSPs' and advertiser contract should not be allowed to make any discrimination on services used by customer. But they may discriminate on ads stream alone. Should be similar to TV ads model.
TSP's may have three models:
a) Free internet with most ads (will benifit first-time/extreme-budget users and also TSPs' - ads in intervals of minutes). This way minimum bandwidth requirement can also be met by the TSP's. This will also positively impact rural usage of internet.
b) Paid low cost subsidised (budget users - hourly ads). Pricing has to be lesser than existing tarrif.
c) No-ad service (users who don't want advertisement interference). Pricing can be slightly higher, but should not be higher than 10% of current tariff because existing tariff already pays for TSP infra also.
The efforts required from TSPs' for implementing this model are app development, and minor changes in TSP server software and marketing management.
This model will allow the OTTs' to operate independantly from TSPs', while TSPs' also will have their profits. I hope this will solve the major issue that initiated this consultation paper.

Same model can also be capitalized by other ISPs' like wired & datacard based broadband providers.


Below are some points I have collected supporting the above plan:

1) Independance & neutrality is the life and purpose of internet.
2) We cannot afford to preserve a technology just because it was used widely once upon a time.
I don't think TSPs' will agree to pay royalty to postal department, just because SMS has choked telegram business.
Rather they will have to learn from postal department to accept changes and adopt their strategies and investments.
For example, if sms and phone calls have reduced because of internet, they may optimize their infrastructure investments more on data and less on phone-sms infra in urban areas.
In these days, these optimizations can easily be done by capitalizing on big-data which most of the big companies already have.
If 2G and 3G infra are one and the same, there is no need to have this whole debate anyway. Its win-win for the TSPs'.
3) The game has changed, TSPs' have to create apps too, and compete with OTTs as this is the way forward.
for example, some TSPs' are already into wired-broadband, landline, dish-tv. OTT is just another line of business.
At the time of this writing, I don't see anyone stopping TSPs' from participating in OTT business.
4) Putting leash on OTT market by TSP's is crossing the line of democracy and entering the likes of antitrust issues.
5) At any point, winning and losing of business should be based on intuitively capitalizing on needs of customers (must also benifit customers, or plan will fail). Not by setting controls.
6) The OTT's which are alleged to be so called "competition to TSPs" are the ones which are the reason for the data usage revenue of the TSP's.
The OTTs' are reason for heavy bandwidth requirement and in return revenue for TSPs'. Without these OTT's people really don't need 3G or 4G.
7) If OTT way of communicating internationally is the cheap way, there is no justification to prohibit it.
Cost-effective ways of doing things, that will benifit the human race should always be encourage, not discouraged. If we don't embrace the latest technologies, another nation may jump at the opportunity and progress faster than us.
As matter of fact, TSPs' can jump into the OTT business with their advantage of mastery and better integration and infra in this field.
8) Apart from model described intitially in this mail, there is one more which is described in the Consultation Paper, give customers choice and internet packs classified as OTT (without any OTT discrimination) enabled, and OTT disabled packs, with different prices. But this or any kind of Access-tiering, may be less feasible in market.
9) Security should be handled separately without impacting cost.
10) "Zero-rating" - the Non-priced and unaccounted discrimination of services should be banned.


Please reply with you feedback on my suggestion.

Thanks & Regards,
Wesley