Here is an internet user's perspective on the Regulation for OTT services whitepaper.

Thank you for publishing the whitepaper and inviting end-users to participate. It is a sign of a healthy democracy and very appreciated.

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. 

-- It is always better to build general guiding principles very early on so that they can be selectively modified in case of new developments. In any case, we have seen enough developments and directions taken by countries who have been on the same path. In a way we can build a robust policy framework and guiding principles that should last us for the next 10 years.

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. 

-- Players who strive to offer services in India must ultimately be beholden to the law as it exists in India. We must be careful that we have robust laws that do not allow individuals / politicians / malevolent actors to harass providers who might not be directly responsible for content flowing through. Standard safe-harbor provisions need to be extended to TSPs or other communication providers and aggregators. 

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. 

-- TSPs are seeing tremendous growth in data volumes and this is going to increase with time. OTT services are a global phenomenon and as such TSPs need to redefine the core sector that they serve. Today, many people take a landline just to get an address proof.

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.

-- As a consumer, I pay for bandwidth. What lies inside the bandwidth is not for my TSP to evaluate. The fact that they are in competing businesses is incidental. This is especially more so given the fact that we have many corporate business houses who own parts of many utility businesses. Let us take an example: tomorrow, if Airtel owns a food franchise, should it be to Airtel to let me order food only from a particular website? My using WhatsApp and order pizza are two examples of the same pie,

Question 5: Do you agree that imbalances exist in the regulatory environment in the operation of OTT players? If so, what should be the framework to address these issues? How can the prevailing laws and regulations be applied to OTT players (who operate in the 114 virtual world) and compliance enforced? What could be the impact on the economy? Please comment with justifications. 

-- Ultimately, all OTTs that service consumers in India have to comply with the laws of the land. I believe offering safe-harbor and net neutrality provisions will offer them a level playing field. Innovation in OTT services should not be dependent on a few providers as that ultimately leads to an oligopoly -- lack of innovation and reduced consumer surplus.

Question 6: How should the security concerns be addressed with regard to OTT players providing communication services? What security conditions such as maintaining data records, logs etc. need to be mandated for such OTT players? And, how can compliance with these conditions be ensured if the applications of such OTT players reside outside the country? Please comment with justifications. 

-- OTT players that reside outside the country are ultimately bound by the laws of the local geography they service. Ultimately, the regulator should intervene if it believes there is significant threat to security that outweighs the benefits to many. A simple example is that while it is relatively painless for one person to mandate 'Shoes must be removed during flight check-in screening', it causes millions of man-hours to be lost in waiting time. Every extra bit of security theater is painless for a few but painful for many. Similarly, a reduction in the profits made by one player are ultimately shared by billions of consumers who benefit a small amount each.

Question 7: How should the OTT players offering app services ensure security, safety and privacy of the consumer? How should they ensure protection of consumer interest? Please comment with justifications. 

-- OTT players should enjoy the benefit of safe-harbor and 3rd party distance from possible adverse effects. No-one expects MTNL to compensate them if their data link is used to hack into a bank account.

Question 8: In what manner can the proposals for a regulatory framework for OTTs in India draw from those of ETNO, referred to in para 4.23 or the best practices summarised in para 4.29? And, what practices should be proscribed by regulatory fiat? Please comment with justifications.

-- I do not believe I have enough background to answer this question.