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.
Comment: Without a regulatory framework, customers stand to loose out
on comfort. TRAI has till date been on the customer's side and hope it
continues to do so.
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.
Comment: internet should be open for all at the least affordable price
only that can ensure telephone penetration in India.
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.
Comment: With continuous change in technology, the market is always
dynamic. Business with foresight and planning will benefit from these
changes and the ones that don't will fade away. It is not right on
TSPs part to steal away the benefits of new technologies from
customers just because their existing revenue streams will deminish.
They should reinvent themselves.
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 product/service
differentiation? Please comment with justifications.
Comment: TSPs should not charge additionally, it will not be a level
playing field for OTT players and in turn will effect innovation in
the industry.
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 virtual
world) and compliance enforced? What could be the impact on the
economy? Please comment with justifications.
Comment: OTT players shouldn't be charged anything additional. TRAI
should ensure that all OTTs have level playing field so that the
market forces will function to the benefit of customers.
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.
Comment: It should be made mandatory for all OTT players to have their
data servers in India so that they fall under the countries
jurisdiction and our right to privacy is ensured.
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.
Comment: all data of OTT players should be encrypted using the best
industry standard and a regulatory framework has to be put in place to
ensure user privacy.
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.
Comment: -
Question 9: What are your views on net-neutrality in the Indian
context? How should the various principles discussed in para 5.47 be
dealt with? Please comment with justifications.
Comments: net neutrality will help a lot of young entrepreneurs in
thus country and give them a chance against established foreign
multinationals with deep pockets.
Question 10: What forms of discrimination or traffic management
practices are reasonable and consistent with a pragmatic approach?
What should or can be permitted? Please comment with justifications.
Comments: There should be absolutely no discrimination. Only the
govt/emergency services should be allowed a free/better access.
Question 11: Should the TSPs be mandated to publish various traffic
management techniques used for different OTT applications? Is this a
sufficient condition to ensure transparency and a fair regulatory
regime?
Yes, along with that a strict regulatory framework has to be set to
ensure net neutrality.
Question 12: How should a conducive and balanced environment be
created such that TSPs are able to invest in network infrastructure
and CAPs are able to innovate and grow? Who should bear the network
upgradation costs? Please comment with justifications
Comments: let the market itself come out with the best solution.
Question 13: Should TSPs be allowed to implement non-price based
discrimination of services? If so, under what circumstances are such
practices acceptable? What restrictions, if any, need to be placed so
that such measures are not abused? What measures should be adopted to
ensure transparency to consumers? Please comment with justifications.
Comments: there should be absolutely no discrimination.
Question 14: Is there a justification for allowing differential
pricing for data access and OTT communication services? If so, what
changes need to be brought about in the present tariff and regulatory
framework for telecommunication services in the country? Please
comment with justifications.
There should be no differential pricing.
Question 15: Should OTT communication service players be treated as
Bulk User of Telecom Services (BuTS)? How should the framework be
structured to prevent any discrimination and protect stakeholder
interest? Please comment with justification.
Comments: no idea.
Question 16: What framework should be adopted to encourage
India-specific OTT apps? Please comment with justifications.
Price parity
Question 17: If the OTT communication service players are to be
licensed, should they be categorised as ASP or CSP? If so, what should
be the framework? Please comment with justifications.
No idea.
Question 18: Is there a need to regulate subscription charges for OTT
communication services? Please comment with justifications.
No.
Question 19: What steps should be taken by the Government for
regulation of non-communication OTT players? Please comment with
justifications.
No idea.
Question 20: Are there any other issues that have a bearing on the
subject discussed?
None