Dear Sir,
It is highly appreciated that TRAI has taken the positive step of crowd-sourcing views regarding the issue at hand. In connection to that here are my opinion on the topics.
Before starting with my response it is essential to understand the very nature of Internet. In its base level its like electricity. Now I don't expect the electricity service provider to dictate the appliances I can or can not run. It is even more preposterous to assume that CESC tomorrow may come out with their own brand of home appliances and start with meddling with the existing connection quality to favor their own brand.
This is against the spirit of the free and fair competition and is a baby step towards moving the internet towards a oligarchy of a few companies with the greatest sufferers being India and her progress. India is among the slowest in Asia Pacific in terms of speed of access and we are just barely connected. However, yet we see that instead of improving on those aspects the telecommunication companies are more concerned with being as restrictive as possible with regards to the same. As you may be aware a similar question was brought before FCC in USA and the tenet could not hold muster as the principles of net neutrality was upheld.
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.
Question 2: This licensing will serve no purpose as the companies will more than likely shift bases to a location which is more favorable and the ease of conducting business is there. E-commerce companies like Flipkart and SnapDeal are based outside India because of laws in India that simply do not provide a favorable climate. Can India now afford to lose out on the one shining beacon of hope that is doing the rounds of the dismal Industrial climate and potential job creation of the nation i.e IT and Internet based startups. TRAI with all due respect should give due consideration to the potential harm such a regime can cause India
Question 3: Is the growth of OTT impacting the traditional revenue stream of If so, is the increase in data revenues of the TSPs sufficient to compensate for this impact? Please comment with reasons.
Answer 3: This is the portion where the arguments of the Telcos fall flat. More OTT service usage creates more data usage and then which in turn create revenue for this companies. However, the unbridled greed is guiding them to form a strategy of charging the consumer twice. The data charges being levied currently are arbitrary and TRAI should look into regulating the same. Some latest headlines regarding the revenues of Telcos reads thus
1. Bharti Airtel Q4 net profit surges by 89% to Rs 962 crore, meets estimates
2. Vodafone India service revenue up 11.7% in first half of FY15
3. Idea Cellular posts 64 pct profit rise as subscriber numbers grow
Using pricing of access to OTT tantamount to double billing for a service already paid for.
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 for the same justifications mentioned above. By adopting this strategy essentially we are indirectly burdening the customer. The OTT providers will levy the charges back from the end consumer for a service they are entitled to.
The fundamental tenets should be
- 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 telecom-style licensing of Internet companies (see this and this)
- No gateways (Internet.org, Airtel OneTouch Internet, Data VAS), censorship or
selection;
- No speeding up of specific websites (that may or may not pay telcos)
- No “zero rating” or making some sites free over others
Please nip these anti-competitive practices in the bud.
Regards
Shaon