Subject: Consultation Paper No: 2/2015
From: Krishnandu Sarkar
Date: 01-Apr-15 12:02 AM
To: advqos@trai.gov.in

Question 1: Is it too early to establish a regulatory framework for

OTT services, since internet penetration is still evolving, access

speeds are generally low and there is limited coverage of high-speed

broadband in the country? Or, should some beginning be made now

with a regulatory framework that could be adapted to changes in the

future? Please comment with justifications.

Answer: These type of regulatory framework is just conflicting with Net Neutrality and these type of regulatory framework should never be introduced. Instead TRAI should focus on improving the speed. Even the countries like Norway, Uruguay, Finland etc. has more average speed ranking than India as per Akamai 2014 Rankings. Whereas we are still trying to connect with the world in 512 Kbps. 3G speed never reach 21Mbps. TRAI should focus on these issues instead of trying to restrict things.

Reference : http://en.wikipedia.org/wiki/List_of_countries_by_Internet_connection_speeds

 

Question 2: Should the OTT players offering communication

services (voice, messaging and video call services) through

applications (resident either in the country or outside) be brought

under the licensing regime? Please comment with justifications.

Answer: No. The so called OTT Players are just using Internet to provide their services without contradicting any Law. If TSP / ISP are not able to sell their product this simply means they are not providing better option. It’s not due to OTT, but because, OTT players are providing much better service than these TSP’s and ISP’s.

 

Question 3: Is the growth of OTT impacting the traditional revenue

stream of TSPs? If so, is the increase in data revenues of the TSPs

sufficient to compensate for this impact? Please comment with

reasons.

Answer : It’s a rule of business, the smarter and better one survives. If TSP’s are not able to make revenue, it’s because of their poor pricing, nothing else. Every business have some competition, they have to go through it. Why would people give INR 1/- for a 1 minute conversation where he/she can talk for 30 Minutes in Skype for the same value?

 

 

 

Question 4: Should the OTT players pay for use of the TSPs network

over and above data charges paid by consumers? If yes, what pricing

options can be adopted? Could such options include prices based on

bandwidth consumption? Can prices be used as a means of

product/service differentiation? Please comment with justifications.

Answer: Again, implementing any kind of restrictions is just contradicting with Net Neutrality theory. Consumers pay for bandwidth, what he does with that should not matter to TSP’s. Nowadays, most of the TSP’s have FUP (Fixed Usage Policy) in their Broadband Plans. Most of the consumers use the whole limit and most of them don’t. So does this mean TSP’s will price according to the usage? So they are making their revenue on unused bandwidth.

And OTT players are just providing service over internet and there’s no reason for a TSP to charge OTT players for providing the service. They are already charging for the bandwidth from the customer. So are TSP’s looking for double revenue by charging for the same Bandwidth to Customer and OTT Players?


Thanks and Regards,
Krishnandu Sarkar