Dear TRAI,
Please find the answers to the questions you had posted for discussion regarding Net Neutrality.
Question 1: Is it too early to establish a regulatory framework for Internet/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.
Internet is just starting to evolve in the country.The average speed of internet in the country is also very low.This show how much internet has to develop in this country.As its a budding stage of Internet in the country TRAI should enhance this by providing necessary support to consumers by providing efficient internet and force the operators to provide quality service.Instead of developing the internet in the country putting a regulatory framework for Internet for supporting the operators would surely backfire the development of Internet services in the country.People should be allowed freely to express their views and try out things in the internet instead of putting rules and regulations for each and everything.First try to increase the quality of services and make sure the operators are providing the service correctly for what they are charging the customers.After making these things correct then think about charging OTT services.
Question 2: Should the Internet/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.
No it should not be brought under the licensing regime. We should allow the start up to innovate services like this instead of trying to demotivate them and trying to put charge for each and everything.Only when services like this emerge people start to use these kind of services.First of all what is the reason for services emerging like this.Its because of the lack of quality services provided by the operators and exorbitant charging to customers
Question 3: Is the growth of Internet/OTT impacting the traditional revenue stream of Telecom operators/Telecom operators? If so, is the increase in data revenues of the Telecom Operators sufficient to compensate for this impact? Please comment with reasons.
Growth of internet has only allowed to increase the revenue of Telecom operators.If you look when the revenue of sms services got down by a very slight margin their increase in revenue of data was quite large.If you look at the per person consumption of data 2-3 years ago it was hardly around 100-200 mb , but now the per person data consumption has increased by 200 - 300% which results directly in the increase of revenue of the operators. Telecom operators are just complaining about the loss in their profit margins and not about complete loss in their total revenue.If they try to increase the quality of data services provided again their will be a increase in data consumption rather than arguing for a negligible loss by the growth of OTT.
Question 4: Should the Internet/OTT players pay for use of the Telecom Operators 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.
OTT are just using the data path for providing of the services.Its their innovation that would bring a change to the future world.Instead of promoting these kind of innovation if TRAI start to charge for each and everything against OTT providers no start up companies would dare to innovate in this kind of market.Consumers are paying for the data services they are getting from the operators.Its consumers wish if they should use OTT or not.Why should operators be concerned and and try to loot from OTT providers.If TRAI doesnt support Net neutrality then it would be operators who would be deciding what sites or apps consumers should use , then what is the use of internet if you are putting charges for each and everything.Are TV channels providing charges to radio as they have looted radio's revenue.
Question 5: Do you agree that imbalances exist in the regulatory environment in the operation of Internet/OTT players? If so, what should be the framework to address these issues? How can the prevailing laws and regulations be applied to Internet/OTT players (who operate in the virtual world) and compliance enforced? What could be the impact on the economy? Please comment with justifications.
In today’s world, OTT players do not operate solely in the virtual world but, on the contrary, interact with “REAL” world products and services, and result in creation of innumerable jobs. In an ever more connected world, any law or regulation which breaks this ‘FLAT’ and ‘NEUTRAL’ nature of the Internet would harm economic growth.Rules and regulations should be put on operators to provide quality services and whether they are providing the minimum speed to users
Question 6: How should the security concerns be addressed with regard to Internet/OTT players providing communication services? What security conditions such as maintaining data records, logs etc. need to be mandated for such Internet/OTT players? And, how can compliance with these conditions be ensured if the applications of such Internet/OTT players reside outside the country? Please comment with justifications.
Servers for these OTT can be asked to set up in our country and logs can be requested by TRAI , but that is not a discussion currently when considering Net neutrality.
Question 7: How should the Internet/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 provide adequate encryption methods while transmission and receiving of data.The servers should be non hack-able and necessary firewalls can be provided
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 or the best practices? And, what practices should be proscribed by regulatory fiat? Please comment with justifications.
First of Net neutrality should be there in India.If India can be a democratic country then why are you trying to put condition over consumers freedom.
Question 9: What are your views on net-neutrality in the Indian context? How should the various principles be dealt with? Please comment with justifications.
A FREE and OPEN Internet is a pillar of democracy and our fundamental right. Internet service providers and governments should treat ALL data on the internet EQUALLY, not discriminating or charging differentially by user, content site, platform, application, type of attached equipment, or modes of communication.
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.
No traffic management practices should be there.As per the recent Sec 66A where The Supreme Court has allowed freedom to speech in Internet, traffic management practices violates the rules by putting regulation over user freedom over the internet
Question 11: Should the Telecom Operators 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?
Again, any case by case traffic management of OTT applications, even if it is transparent, violates Net Neutrality. So, this question won’t arise if TRAI ensures Network Neutrality.
Question 12: How should the conducive and balanced environment be created such that Telecom Operators 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.
Operators should bear the network upgradation cost.Anyway operators are charging for data.If they provide quality services and maintain uptime of data all the time gradually the per person consumption of data automatically increases which in turn would increase the revenue for the operators.
Question 13: Should Telecom Operators 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.
Telecom operators should be allowed in any way to provide discrimination of services.Its the right of consumer to do whathever he wants with the amount he had paid for.Consumers are demanding rights only for legal purposes.
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.
No justification can be provided for differential pricing for data access.TRAI ahould encourage these OTT services for their innovation and provide steps for security of data instead of helping the operators to gain more money from consumers
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.
How can be OTT communication service players be treated BuTS.Then in the future Youtube Emails should be treated as BuTS as streaming of data also consumes heavy data and email with heavy attachments , Cloud services etc all are BuTS. Please encourage consumers to more internet , instead of discouraging them by providing restriction and charges for each and everything.
Question 16: What framework should be adopted to encourage India specific OTT apps? Please comment with justifications.
Both India specific and International OTT apps are same. India specific OTT apps should be encourage by providing more support to them and good encryption technology
Question 17: If the App based/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 categorisation should be provided to consumers freedom. Starting of this new type of procedure encourages the operators to loot more from consumers for each and everything and they would prefer those whom they like or whom they get more benefit out.Customers will be thrown out of the picture.First try to improve the quality of services, increase the average speed of internet in the country , maintain 99.9% uptime of services.
Question 18: Is there a need to regulate subscription charges for App based/OTT communication services? Please comment with justifications.
No need to regualte subscription charges for OTT.The subscription charges they are charging is for the services they are providing just like operators charging for the data services consumers are using.If OTT can provide quality services they can also charge subscription
Question 19: What steps should be taken by the Government for regulation of non-communication App based/OTT players? Please comment with justifications.
Whether communication/non-communication App based apps , they should be allowed freely to provide services to consumers.Its the consumers who are paying for the service should decide what they need to do.Its not some money looting operators who in their greed for money charge for each and everything out of consumers pocket to make one section of society more richer and to treat others as slaves.
Question 20: Are there any other issues that have a bearing on the subject discussed?
Freedom of speech should be uphold by any means and no means of restriction should be put forward preventing the consumers interest and TRAI should not work for the operators.
Regards
Sunit