Hi,
This is a humble request to keep the internet a free and fair medium and not to divide it by favouring selective businesses. Internet is by the people and for the people.
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: Yes it is too early and should never be implemented. Internet penetration is growing, so why not increase the bandwidth? Why are we still stuck at average broadband speeds of 2mbps whereas city states like Singapore already have 1gbps fibre lines for domestic use.
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: There should be no licensing as everything which relies on a free internet should be kept free of licenses.
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: Indian telecom companies should take Singapore telecom companies as an example. Watch and learn how telecom markets across the world are developing.
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: Telecom operators could promote the usage of post paid plans with fixed priced plans. The more data offered the more expensive the plan would be. But OTT players should never have to pay for use of the network. Prepaid plans should be discouraged.
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: Telecom operators could promote the usage of post paid plans with fixed priced plans. The more data offered the more expensive the plan would be. But OTT players should never have to pay for use of the network. Prepaid plans should be discouraged.
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: Data security can never be centralized when OTT players range from across the world. OTT players should provide a level of security and users should bear in mind that if online services are used, privacy is at stake.
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: Encryption is the answer to all data security issues. OTT players should enforce encryption on all services 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.
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: India is truly a democratic country. In a true democracy, net neutrality is of the utmost importance for all players to have a fair playing field. And we as democratic people should stand by it, no matter if the player belongs to our country or a foreign one.
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: I do not think any kind of traffic management practices are reasonable. If the bandwidth is flooding up, upgrade it. Fibre connections to all is the answer which many developed countries have already adopted.
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: Yes, OTT operators could benefit from it and manage their traffic better.
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 up gradation costs? Please comment with justifications.
Answer: The present government is very much development focussed. I'm sure the govt will spend on network up gradation costs partially.
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: Any kind of discrimination is not acceptable to me.
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: Telecom operators could promote the usage of post paid plans with fixed priced plans. The more data offered the more expensive the plan would be. But OTT players should never have to pay for use of the network. Prepaid plans should be discouraged.
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.Question 16: What framework should be adopted to encourage India specific OTT apps? Please comment with justifications.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.Question 18: Is there a need to regulate subscription charges for App based/OTT communication services? Please comment with justifications.Question 19: What steps should be taken by the Government for regulation of non-communication App based/OTT players? Please comment with justifications.Question 20: Are there any other issues that have a bearing on the subject discussed?
Thank you!
Best regards,
Kiron Joel D'Lima