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.No, it is not too early to establish a regulatory framework. However, it is very likely that the framework will end up benefitting corporates massively, while the average internet user will end up paying exorbitant rates.
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, these services should not be brought under the licensing regime. The telecom corporates in the company already gain huge profits from 90% of India's population who do not have access to the internet, or are not internet users. Those who have access to the internet, too, do not call everyone on their contact list through these apps. They too pay the nominal rates.
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.
The growth of the internet is DEFINITELY affecting their revenues. Most of the urban youth and working class use the internet on a daily basis, whether at home through wifi, or through data packs over the phone.
The increase in data revenues takes place almost every 6 months, sometimes without users getting any information beforehand. There is no requirement to charge specifically for certain services.
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.
For every corporate that receives huge profits, the main profits come from a simple activity of purchasing in bulk and selling in smaller units, just like wholesale and retail. Hence, I do not think telecom operators themselves should hike these prices!
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.
Yes, I agree. It is only natural that these imbalances will exist, due to the different nature of services they offer. I do not think there really is a need to address these issues. These issues are usually self correcting.
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.
I think there is already a little too much security on the internet. Consumers do not know who is listening in and where. Basic compliance measures could include consumer benefiting rules, such as-
1. Consumers should be e-mailed a weekly or monthly log of their activities that the Internet players have kept a tab of.
2. Consumers can opt for sites that can be blocked, and the internet players should block these sites for said consumers only.
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
Internet players should give the consumers, in written, a list of the app's pros and cons, and consumers themselves can choose to opt for the service or not.
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.
Recruit young graduates and working professionals, not only people from the government or from corporates.
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.
Net neutrality is very important in the Indian context.
We are still a growing country, and it is known that the internet and access to a global platform helps increasing the level of education, global & social awareness among users.
By imposing differentiated pricing for apps and sites, the policy makers would be clipping off the wings of our developing country.
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.
India is a free country. So is the internet. There is so requirement for any discrimination or traffic management practices. Traffic management is the responsibility of the site. By cutting off a section of users by making them unable to pay for the sites, one would be hampering a lot of economic growth.
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?
Yes, they must publish these techniques. But it is very important for them to consult with the population (through surveys) that actually uses the internet daily.
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.
1. As is already prevalent, base charges for internet usage keep hiking every 6-8 months. This could increase their income from existing customers.
2. Introduce more base packs for internet so that the lower middle class and blue collar working class can access the internet at nominal rates.
3. Telecom operators should bear the up-gradation costs.
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.
Yes to non price based discrimination services.
Acceptable circumstances - political instability, infrastructural break down, inter communal disharmony (since the bad side of the internet could just add fuel to the fire under such situations)
Restrictions on communal or political websites can be places.
To ensure transparency to consumers, telecom operators must send them a mail with their terms and conditions, and consumers should put a circle (O) on the terms they agree with and a cross (X) on the terms they do not agree with.
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, there is no justification for allowing differential pricing for data access and OTT communication services. Base fares and prices should cover all, as long as it is within the limit of the packs chosen by the consumer.
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.
The existing framework is good enough, there is no need for a change in the same.
Question 16: What framework should be adopted to encourage India specific OTT apps? Please comment with justifications.
Software engineers, business communities, etc can be educated on OTT apps, and given training on developing and handling the same.
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.
Yes, they should be licensed and categorized. For the framework, the ETNO can be read through.
Question 18: Is there a need to regulate subscription charges for App based/OTT communication services? Please comment with justifications.
No, there is no need to regulate subscription charges for app based/OTT Communication services. We already pay for these charges while paying fro basic internet fares. Paying for the same service twice is not justified.
Question 19: What steps should be taken by the Government for regulation of non-communication App based/OTT players? Please comment with justifications.
No steps should be taken for the regulation of these apps. This action would curb the user's freedom.
Question 20: Are there any other issues that have a bearing on the subject discussed?
Yes. Flipkart and Airtel recently signed the Airtel Zero deal. I think this should be recalled asap. Paying for the same service twice, and differentiating among consumers based on their ability to pay is extremely uncalled for.