Dear TRAI,
I am writing to you about the need of net neutrality in India. In this
age, the internet is as important as education.As developing nation,
the internet is a vital resource.
following are my answers to the questions you posted recently
regarding this issue.
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: I don't think that OTT players need any regulatory framework,
and if we do so,it would violet net neutrality.
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.there seems no need for such license. licensing will make
service costlier both for end user and provider.
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:Yes,in a positive way for telecoms.Increase in use of OTT apps
leads to increase in data usage and therefore increase in revenues of
TSPs.
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,why should TSP charge from both customer(end-user) and OTT
service provider. for example,
1. Radio channels cannot tax television channels for reduction in revenue.
2.Electricity manufacturer cannot tax Electronics device manufacturer
as their devices use electricity made on their Infrastructure.
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:No imbalance exists between the OTT players and the TSP. As
they both are in different buisness.What we really need is regulation
to make sure TSP’s are not exploiting customers via exorbitant data
prices and uninformed policy changes.
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:Governments,TSP and OTT players should respect consumer’s Right
to Privacy. India is independent and free country should not become a
complete surveillance state which taps every OTT service which a
consumer accesses. OTT players shouldn’t be forced to keep data
records.
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:OTT services should adopt security standards in online
communication and should follow right privacy policy.they should use
appropriate technologies such as encription,digital certificates to
ensure users privacy and security.
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: NO regulatory framework is needed which violates Net Neutrality.
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 should be strictly enforced in India with
guildlines proposed by the Federal Communications Commission (FCC).
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:No form of traffic discrimination should ever be permitted.
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:As I said above,No form of traffic discrimination should ever
be permitted.
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:he TSPs alone should be responsible for network upgradation or
maintenance.
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: any kind of discrimination should not pe permitted,as its
against net neutrality.
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 justification.TSPs are already charging for data services.
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.No change in structure of framework is needed.
Question 16: What framework should be adopted to encourage
India-specific OTT apps? Please comment with justifications.
Answer:India-specific OTT apps doesn't need any encourangement,just
they need is free internet(Net Neutrality).
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 of licensing OTT players.
Question 18: Is there a need to regulate subscription charges for OTT
communication services? Please comment with justifications.
Answer: NO NEED.
Question 19: What steps should be taken by the Government for
regulation of non-communication OTT players? Please comment with
justification
Answer: Government involvement in this matter is not needed.
Question 20: Are there any other issues that have a bearing on the
subject discussed?
Answer: 1.Need net neutrality law.
2.need plan on upgrading internet speeds and quality in india. India
has the worst internet speeds.
Regards,
Tejas Mali