Hello Sir/Ma'am

Following are my answers to the 20 question consultation paper by TRAI on the issues related to Net Neutrality.

Answer 1.
It is absolutely too early to establish a regulatory framework for such services, because unlike many other countries Internet has not reached widespread and deep penetration in our country, internet access speeds are most of the time painfully low and the coverage of high-speed broadband in the country is not significant enough even after almost a decade of it's introduction to Indian mainstream consumers. I'd rather say rhat the resources should be used for betterment of the overall customer experience with Indian mobile operators and for bringing stricter laws for grievance redressal.

Answer 2.
No I do not feel that it's needed, that such services be brought under licencing, for a very simple reason, that such norms are not imposed on these kind of services in many countries where the national mobile service providers (big or small) are not as greedy as the ones here. Example: Airtel (particularly). Mobile services providers in those countries rather focus on improving their data services and network infrastructure so that more consumers use their network to access the said services. That's how they earn their revenue and generate profit for themselves. Our Indian mobile service providers claim regularly they have invested huge sums of money to establish their network infrastructure. Why does their network work good enough then, mobile 3G speeds are almost as low as 2G GPRS speeds and that's when the user is located in the middle of a major urban city, not some far flung area. They would instantly make an excuse of high concentration of 3G users within a small locality. If that's the truth, then why don't they advertise this fact also while advertising their supposedly "superior network with superior 3G coverage and speeds"?

Answer 3.
Yes it is true that the growth of OTT services is impacting the traditional revenue stream of TSPs, if you feel the only services provided by them is calls and SMSes. Why don't you look at the Value Added Services? They also form a substantial chunk of their revenue and I'm not making this claim based on my own opinion. This fact is provided by TRAI itself. So why don't we take into consideration the VASes as well as Data Services and then also consider the fact that if data services would have been upto the mark, their would have been more customers using their data services hence these same Tips would have made profits. What we see them doing is resorting to promoting non-net-neutral practices just for the sake of making profit and in turn hiding their own inability to deliver a better standard of data and value added services.

Answer 4.
No, absolutely unnecessary in the light of the fact that if data services provided by TSPs is of a satisfactory standard they would automatically generate enough revenue by the attracted Customer Base and more people opting for their data services because of increased reliability and better value for money. It's already not as cheap as compared to other countries to have a good 3G data plan for an Indian consumer. This move will just make it all the more expensive and out of reach of the consumers overall. The problem is something else but the solution provided in the question is for something completely different entirely.

Answer 5.
Your question is incomplete. It asks for an opinion while it does not provide a clarification as to what needs to be regulated or checked when it comes to OTTs. Under what kind of laws do you want to bring the OTTs? Criminal, Social or Financial or all of them? Please clarify first.

Answer 6.
Please don't tell me TRAI or the cyber laws division does not already have a protocol setup for handling such security issues. If you don't, then as a consumer it's really shocking for me and very embarrassing for you. Well to put simply,  yes, we do need a setup for checking security threats that may come through the said OTTs. Data usage logs, trends and statistics must be kept, and a transparent system of warning them upon violation of security parameters must be implemented. Upon multiple violations an OTT must be made liable to ban to operate in India.

Answer 7.
Simply by keeping all their user related information securely with themselves only and not to share with any non-government body and that too only in case of national/social security threat. They must be advised again sharing any information related to their users with another OTT or any other non-government body for that matter, without a clear consent by the user specifically.

Answer 8.
Not familiar with ETNO so cannot comment.

Answer 9.
Net Neutrality in the Indian context quite simply means users having freedom to avail any service on the Internet which by it's inherent nature might itself be free or paid. Let the user decide if they want to use the paid version of a service or are happy and content with the free version that may have some limited features. Leave it to consumers, not to the mobile service providers, because service providers or for that matter anybody does business only to make profit. And once profit making comes into picture without correcting their own flaws, mobile service providers will definitely kill the neutral aspect of the Internet service as a whole. They will make it more expensive over all for a consumer to avail Internet facilities which were actually otherwise supposed to be their right.

Answer 10.
Keywords regarding sensitive aspects like that of political, religious, social and civil unrest causing activities must be monitored. Otherwise any other data traffic management practice doesn't seem significant enough to be of such high concern.

Answer 11.
Yes, absolutely so that TRAI can keep a watch on them that they don't throttle data usage by customers using these OTT services.

Answer 12.
Let this be clear, as more people start using OTTs, mobile data service providers will have an increased customer base. This will Automatically mean more revenue for them, only if they make their network better and infrastructure more robust. Now common sense says one who earns profit from a venture would obviously be the one who would have to bear the upgradation costs, simply because they want more customers and in turn more profit that way. Invest if you want to earn.

Answer 13.
Price based or not price based, any kind of favour or discrimination would mean going against the basic spirit of Net Neutrality. This kind of discrimination is totally out of the question if you want to uphold Net Neutrality in favour of all the Indian consumers.

Answer 14.
No. Please read answer 13 again.

Answer 15.
Yes, this makes much more sense. Whatever they earn is due to people who use those services, so let the government of the people decide what part of their earning should be shared with the stakeholders so that they don't feel left out. But as said earlier stakeholders are not to be mistaken with mobile service providers only. They may only Claim a share in OTTs profits once they fulfil the expectations of the Indian consumers.

Answer 16.
They should be promoted more rather instead of being regulated first. We seriously need some global services in these field that originate from India.

Answer 17.
Communication Service Providers. Simply because at their core that's what they are actually doing. Providing service to promote communication between human beings.

Answer 18.
No. Enough points of justification provided in answers above.

Answer 19.
Ask them for their road map for the future and if needed create another category for them and establish rules and regulations keeping the user's interest under consideration.

Answer 20.
The existing prices of data service plans by all the mobile operators needs a detailed justification, if they are unable to provide it, there must be strict enforcement of penalties on them.