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.

Answer: No. It is not too early. Regulatory framework need to be put in place which is capable of adapting to future needs.

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.

Answer: No. The internet should be free, and there shouldn't be any kind of restrictions imposed upon the free flow of information through the internet, or through communication services, even if it be from a different country.

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.

Answer: Telecom operators shouldn't be allowed to create any kind of data revenue streams that would be in conflict with net neutrality policy. Telecom operators are like toll booth operators on a newly built highway of the internet. They shouldn't be allowed to charge more money for vehicles such as cars, jeeps and less money for trucks, or vice versa. Toll booth operators should be neutral to all the vehicles that passes through the highway, just like how the internet should be neutral.

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.

Answer: Standard Prices should be based on bandwidth consumption, and should not based on data consumption.  Service differentiation based on data consumption is hindering the process of gaining benefits from a free and open internet. 

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.

Answer: Yes. The framework would be to establish a clear policy of net neutrality in the forefront, and then create regulatory mechanisms to enforce the policy as being used by Internet/OTT players. To completely remove any kind of data based prices, and to allow bandwidth based prices to be put into place. 

The economy will only be strong, if the infrastructure is strong. Internet infrastructure needs to be free to be used like a highway one takes to send goods between different stations, when satisfying customer needs. Any further complications on restricting the amount of road length you can travel (data consumption), with the kind of vehicle you travel (data services) will only inhibit the growth of economy. In such as case, only the OTT/Internet operators will be the companies benefiting at the demise of the information data sector/ mobile data services sector. The booming mobile startups that can be possible if a strong infrastructure is put in place will only strengthen the economy. 

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.

Answer: Illegal activities need to be monitored. However, not at the cost of privacy. A prior warrant will be needed. The internet should always be neutral. 

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

Answer: The Internet players need to place legally binding agreements to customers ensuring net neutrality and ensuring 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 or the best practices? And, what practices should be proscribed by regulatory fiat? Please comment with justifications.

Answer: No comments

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.

Answer:  Net neutrality in the Indian context is an important issue. Keeping the end user experience in mind is also very important issue. If India is to become a developed country in the future, it is important that internet services be similar to that is being offered in the developed countries. An Indian user, doesn't need to think about paying for 10 GB data, when the amount of information present in the internet is unlimited. The information potential of unlimited internet is being restricted here. Any kind of data gaps should be removed, as that is how it is in developed countries. 

OTT/ Internet service companies should have no say in which websites get more traffic, or more bandwidth. That would make it difficult for the rural communities trying to make use of internet to obtain benefits of the internet fail because richer corporate houses were able to strike deals with the internet service providers. It is important that the internet remains neutral. 

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.

Answer: Traffic management that discriminates data services would be unreasonable. 

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?

Answer: Telecom operators should not be allowed to prefer certain kind of data services, or websites at the cost of other data services. That would be against the principle of net neutrality. Net neutrality should ensure that all data be treated neutrally. That makes the traffic management practices irrelevant.

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.

Answer: TRAI needs to ensure that net neutrality is ensured. As long as the policy is put in place strongly, balanced environment would be created by the strong competition between telecom 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.

Answer: No. These practices are not acceptable at all. Allowing them to implement any kind of discrimnation to data services would hurt the emergence of Indian startup companies and economic growth through innovative data services so bad, that India would never achieve the growth attained by developed countries. The internet infrastructure should be a strong back bone to the Indian economy, and that is possible only if the internet remains neutral to the information being passed. 

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.

Answer: No. There is no justification. The present tariff rates to let go of any data caps on the end user at all. Developed countries do not have any tariff plans that is based on data limits. India shouldn't have it either. 

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.

Answer: No comments.

Question 16: What framework should be adopted to encourage India specific OTT apps? Please comment with justifications.

Answer: Framework established in developed countries.

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.

Answer: No comment

Question 18: Is there a need to regulate subscription charges for App based/OTT communication services? Please comment with justifications.

Answer: NO. There is no need to regulate subscription charges.

Question 19: What steps should be taken by the Government for regulation of non-communication App based/OTT players? Please comment with justifications.

Answer: Government should ensure that OTT players do not misuse their services by not subscribing to net neutrality policy.

Question 20: Are there any other issues that have a bearing on the subject discussed?

Answer: Development of internet infrastructure is essential to the economic growth of India. It is essential that the data that passes through the information highway  be treated neutrally without any kind of preferential treatment by those who can afford it. Such a policy would create havoc and destruction of any kind of benefit that the internet could have provided to the entire economy, as it would only benefit the Telecom operators instead.