First of all I must say that TRAI is being unfair to the general public in asking such descriptive long questions which general public cannot answer giving technical details. It would have been much better if you had posted a multiple choice questionnaire. You seem to be favouring mobile companies who can add revenue to your organization and who can probably give you much better answers justifying why they should be allowed to charge the general public extra for specific apps/services!
Your questionnaire is one of the most complex question papers I have seen! If you want people's proper opinion, make it more simple and make sure everyone knows about it!
I am trying my best to answer in simple words of an educated middle class person.
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.
There need not be any framework specifically for OTT players. Whatever framework is there for general apps/ websites will be more than enough. You are creating complications for new entrants. You are trying to kill innovation by making complications.
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.
NO! There should be no licencing. Again as mentioned in previous answer you are complicating matters, making India an unfavourable country for doing any kind of business.
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.
No. The mobile companies are earning lots through data usage and they are skewing facts by saying that its hurting their revenues. Let them shut whatsapp and Skype for a day and see how their data usage falls! Let them charge an extra 10 rupees for a 1GB data bundle, that should help more, rather than charging per package!
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.
A big NO!!!
All sites must be equally accessible
The same access speed at the telco/ISP level for each (independent of
telco selection
The same data cost for access to each site (per KB/MB). (includes OTT
apps
No gateways (Internet.org, Airtel OneTouch Internet, Data VAS),
censorship or selection unless there's thread to the country.
No speeding up of specific websites (that may or may not pay
telcos)
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.
There is an imbalance. All rules are favouring mobile companies' whims and fancies.
You need to make sure that the general public is not swindled by unfair pricing by mobile companies and that they don't form cartels to deprive Indian public of internet and modern means of communication.
If you don't allow these services in India, the rest of the world will move forward and we'll be left in the stone ages. Is that what you want?
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.
I don't think any additional security is needed. A person using mobile internet would have already submitted ID proof while purchasing SIM card, so that is more than enough. The mobile companies should make sure they issue connections only to genuine people. Pinpointing OTT players is not right. Terrorists should be caught irrespective of what service they use. If you block one mode of communication, they'll find another. Will you go on blocking all services like this? One day we'll have to start using pigeons.
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.
You really expect general public to come up with such technical answers? I am not sure. How are banks ensuring security, safety and privacy through their mobile banking apps? The same rules can be applied. I don't know how they do it, but I am sure it can be done.
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.
What is ETNO para 4.23? Are these questions for the public or only for mobile companies, so that you can receive more replies from them and get convinced that they are right?
I am not going to waste my time researching what is ETNO para 4.23/
I only say there's no need for any regulatory framework. Is there any regulation for Temple run or subway surfers? As long as a person has purchased a SIM with a valid ID there's no need for any more compications.
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.
I don't know what is para 5.47 I can only say this much....we need net neutrality. There shouldn't be any discrimination on what we do using the internet.
This is just like a power company charging us higher amount if we use AC. They only charge per unit.
The internet should be treated as a similar service and should be charged on number of MB or GB we use. What we do with the internet is not the telecom company's concern. Now you are talking about whatsapp and Skype. what if they start packages for youtube, google, everything...general internet will be a thing of the past and we will only have access to the packages we have subscribed. This is the most ridiculous thing we've heard of!
If you want India to develop, internet has to be neutral and without any discrimination/ preferences towards particular apps/ websites! Period!
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.
Discrimination is only allowed when there's security threat to the network itself.
Not because someone is using gmail to send terror mails, blocking gmail throughout India. That's madness, stupidity.
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?
There is no transparency at all currently. Therefore we cannot trust the telecom companies to manage traffic honestly. Transparency is needed but this will not help in neutrality. I can't really understand what's the connection. We are talking about making the internet non-discriminatory and accessible to all. How does traffic management come into the picture? You want to confuse the public.
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
how is this connected to neutrality? Are we the ones to comment on how Telcos should upgrade their network? It's their headache if they want to survive in the competition and make India a better place.
Who bears the upgradation cost? Isn't it obvious? Telcos will increase their rates as soon as they upgrade. Obviously the user is going to pay!
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.
NO! A BIG NO!
There should be no discrimination. I don't want to give any justifications because I am against the whole idea.
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. Just because one part of their business is suffering they cannot block other innovations.
For eg. Both Telegram service and BSNL were owned by central govt. Once Mobile services started people stopped using telegram. Could the govt have started levying extra charge on mobile users or prevented mobile market from developing because another service (telegram) is becoming obsolete?
Telcos have to move on with the times. With time everything will become obsolete and new technologies will come up. They have to accept this and try to become leaders in the latest technologies. Not by preventing innovation.
If people want to use Skype, they should be allowed and telcos should make sure their internet is the best. For now, video calling using Indian ISPs is pathetic and grainy compared to a Telstra of Australia.. With time better modes of communication will come up and Telcos should upgrade. They can charge extra for better services but should make sure it's not unaffordable.
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.
No, they are not bulk users. We receive more junk SMSes than whatsapp messages. Whatsapp and Skype have better blocking system than the DND list which is useless.
Question 16: What framework should be adopted to encourage India-specific OTT apps? Please comment with justifications.
There's nothing India-specific. Any app or site, whether based in India or outside should be treated equally. Telcos should not be allowed to create their own apps and give preferential treatment over their own 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.
What's ASP/CSP? Please don't treat this as an IAS entrance exam. We are general public!
I can say this much.There should be no licensing. You are trying to make India a country where no one would want to do business. There's so much corruption in the licencing authorities! you are encouraging corruption, black money and ruining the image of India.
Question 18: Is there a need to regulate subscription charges for OTT communication services? Please comment with justifications.
No. Telcos can charge for the data used and OTT players can charge whatever they want. The competition in the space will automatically regulate the prices. You cannot regulate the prices set by companies outside India.
Question 19: What steps should be taken by the Government for regulation of non-communication OTT players? Please comment with justifications.
The internet has to be made neutral. India will lose out in development if such restrictions are placed.
Question 20: Are there any other issues that have a bearing on the subject discussed?
Pricing of data packs: Everything is arbitrary. They have new plans every week which confuse users and the details of packs are not clearly given.
No net neutrality law: This is completely unfair. The law should be made and any violations should be punished.
Internet speeds are pathetic in India. Many speed packs are defined as 'Upto 2Mbps' which means it will attain a max of 2Mbps for 1 second in a month whereas the real speeds will be only 128Kbps. If the customer complains, they says that your pack is 'UPTO 2 Mbps' not a 'stable 2Mbps'. Leader in the pack is BSNL. They should be penalized for cheating customers!