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.

 

Answer: No need of regulatory framework for OTT players. It will kill the net neutrality. It will affects the mobile penetration. Saying internet penetration in india is ‘evolving’ in India is nothing short of a joke because India just has internet connectivity. TSP and ISP speed are not adequate. Going after app means:

1.      New app innovation will be affected largly because the all TSP will target the app makers

2.      We will be violating net neutrality. USA’s FAA also approved net neutrality and I strongly beleive that only thing we have to do is net neutrality.

3.      Already Airtel’s Wynk attached other links. These corporates can do anything, everything will become asper their requirements.

So only net neutrality is solution for everything.

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.

 

Answer: NO, getting OTT providers outside the country under a licensing system because Indian Law does not apply to outside India and Indian company will start to shift to outsie India that will be a major loss to the Nation. Flipkart and Snapdeal is already operating from outside. Licencing system will simply kill the business oppertuinity in India. Another set of policy will surely kill the small app developers which will not in line with Government’s policy to develop business 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.

 

Answer: OTT increase will increase the TSP revenue. If OTT revenue affects the TSP revenue how Airtel shows 89% increase in Q4 profit, FY15 Vodafone revenue increased by 11% Idea shows 64% increase.The whole threory is myth because OTT growth increases the Data usage and TSP revenue will increase.

TSP’s are marking up the data cost irrationally and this should be controlled. Why should customers pay twise because alrady they are paing for data usage.

OTT pricing services will surely reduce the income becose customers stopped using apps and this will reduce data usage and TSP will loose the revenue.

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.

Answer: NO, Telecom operators/ISPs are access services providers, can control how much we access, what we access, how fast we access and how much we pay to access content and services on the Internet. It’s important for access to knowledge, services and free speech, as well as freedom and ease of doing business online, for this access to be neutral. All sites must be equal. The same access speed, the same data cost, no licensing for internet. No gateway censorships, no speeding up of specific websites No “zero rating” or making some sites free over others.

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.

 

Answer: Yes there an imbalance in the system since TSP’s are repeatedly getting away with violation of basic principles of open access to all services as mentioned above. OTT players do not need more regulations, more regulations are just a recipe for a disaster. What we need is a regulation to make sure TSP’s are not exploiting customers via exorbitant data prices and uninformed policy changes. Also, to put simply, there will be negative impact on economy if such idiotic policies are put into place. You will simply drive out all “indie developers” and all start ups from our country.

we need a regulatory policy to prevent larger companies to encroach on smaller ones. This is the only policy India needs right now when it comes to OTT apps

 

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.

 

Answer: Security comes under Home Ministry and TRAI has nothing to do with that. Already we are having policies in place to prevent misuse OTT voices and our inteligence agencies are regularly monitoring coordinating with other agenceise outside India. Therefore it is best of TRAI to not use security as an excuse. Use and purchase of SIM cards is now also monitored, therefore we can verify the identity of each person using internet.

 

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

 

Answer: All app developers have a privacy policy as well as run a support email regarding questions. In order to maintain safety, privacy, and security, we can use Encryption, Use of digital certificate and privacy policy.

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.

Answer: It is astonishing that TRAI lists a majority of laws where net neutrality is upheld, and asks the person answering questions to draw from ETNO? How biased it is, indeed. But anyhow, India should not drive any policy from the EU directly, since the market in EU and India are completely different. India barely has 20% internet penetration whereas the EU has is 100%. Therefore, saying it short, India does not need a regulatory framework to boss over OTT providers.

 

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

 

Answer: Net neutrality is must in India, this will guarentees telecom operators do not discreminate between users, their communications and contents. All users should access the same and whole network. Operators are developed diffent models for diffent operators that restricting the access by throttling or blocking contents and services and this should be stopped. Only net neutrality will give equality.

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: Net Neutrality does not prevent the operator from traffic management until unless it reasonable whether they actually seek to protect the freedom of communication of end-users. These practice may be legitimate in two situations that is at the time of Unforeseeable and temporary congestion the operator can temporarily implement but it should be justified properly or at the time of security thread at network.

 

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?

 

Answer: Since there are no transferance and fair pricing in India so it is not at all advisable to put OTT under trafic management technique.

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

 

Answer: OTT’s are not eating TSP revenue but they are adding income to the TSP’s. We have to make a viable business model. TSP’s should make their service affordable, providing good services. The more and more app usage increases the data usage and data usage increases the operators income.

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.

 

Answer : TSP’s cannot discriminate, under no condition they are allowed to discriminate. Telecom not really a free market. There are just 4-5 players anywhere and there is a barrier to a new player entering the market because of the spectrum allocation. They have been given protection from competition by the Govt. So government needs to regulate the telecoms. Apps are free market and no need to regulate.

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: There is not at all any justification in differencial pricing. Differencial pricing is a method used by operators to make more and more money nothing else.

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 need to treat OTT seperately. They are just services available in internet. TSP should concentrate on their own services, comes up with new inovative ideas and customer satisfaction. Powerful telecom companies have an interest in imposing their control over information and communication networks. They do so by, for instance, banning innovative VOIP applications from mobile telecommunications services. Anti-Net neutrality practices are thus fundamentally anti-competitive and harm consumers as well as economic growth. They discourage innovation. They put barriers to entry which prevent the emergence of the new innovations. It follows that an open and equitable access to the communications infrastructure is the foundation of social and economic benefits and needs to be preserved.

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

Answer: There are quite a few Indian OTT apps, but, to help them, a Net Neutrality framework should be implemented. There should be no discrimination or favouritism in apps done by TSP’s because their company owns the OTT app, that way a conducive competition enabled environment can be created. Internet should be treated as public communication with net neutrality principles. This will compel the TSP to give an equal data flows and guaranteed freedom to users, freedon to send and receive contents, uses the apps wanted, connect to the network and use any programmes without harming the network.

 

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.

 

Answer: No need to license OTT players. Please uphold the principle of net neutrality. It is an obvious breach of Net neutrality is the blocking of certain protocols or applications by IAPs as a way to undermine competition. In some instances, the use of these services is subject to extra fees. The most oft-cited example of such discriminatory practices is that of the voice-over-IP (VOIP) application Skype. Although the blocking of VOIP on wireless networks has been abandoned by a few IAPs in recent months, many of them still engage in this kind of anti-competitive behaviors and will continue to do so in the future for other innovative services in the absence of Net neutrality regulation.

 

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

 

Answer: not necessary to regulate the OTT, because this will harm the free and fair neutral internet usage. TSP’s are not loosing any income just because of this services. Curbing the OTT players are totally wrong.

 

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

 

Answer: The govt must enact legislation to establish net neutrality in order to promote business in OTT apps. Even TSP’s can offer their own OTT apps and use advertising as a means to generate revenue. There is no need for regulation of OTT players. Both the Internet and managed services should be defined in the regulatory framework and steps taken to ensure that the development of managed services will not occur at the expense of the Internet.  

 

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

 

Answer :

Net neutrality should be implemented, internet speed should be increased, pricing by operators should be controlled.customers freedom should be safeguarded.