Subject: Maintain NET neutrality over TSP / ISP.
From: Ananth S Iyer
Date: 07-Apr-15 12:10 PM
To: advqos@trai.gov.in, netneutralityindia@gmail.com
Reply-to:
ananth.s.iyer@gmail.com

Question 1: Is it too early to establish a regulatory framework for Internet/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.
Yes it is too early we should wait till at least 25% person of the population or 90% of the all under the age of 25 are using Internet.
Charging now will discourage the users to use, developers to innovate.
In this context, the only framework that I recommend, is to introduce a framework know as: Protection Of Net Neutrality Framerwork.
Question 2: Should the Internet/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.
Yes all communication electronic should be under a NET Netutrality regime.
At present should have a no charge as the penetration reachus optimal levels we could cover these under regulations.
Explain  what licensing YOU wants, and what does licensing even mean?
Are we the ones to decide who can make an application in India or not?
Does TRAI simply want to pull the plug on app development and IT sector in India?
My request to TRAI will be to instead enforce Net Neutrality.
Internet is simply a resource like electricity
Question 3: Is the growth of Internet/OTT impacting the traditional revenue stream of Telecom operators/Telecom operators? If so, is the increase in data revenues of the Telecom Operators sufficient to compensate for this impact? Please comment with reasons.
It is affecting all the TSP in a positive way by contributing more to the profit
1.      Bharti Airtel Q4 net profit surges by 89% to Rs 962 crore, 
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
Why should a consumer pay for the same service twice over?
Question 4: Should the Internet/OTT players pay for use of the Telecom Operators 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 of product/service differentiation? Please comment with justifications.
No
Telecom operators/ISPs are access services providers, and can control either how much you access, what you access, how fast you access and how much you 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 equally accessible
-          The same access speed at the TSP/ISP level for each (independent of telco selection)

Question 5: Do you agree that imbalances exist in the regulatory environment in the operation of Internet/OTT players? If so, what should be the framework to address these issues? How can the prevailing laws and regulations be applied to Internet/OTT players (who operate in the virtual world) and compliance enforced? What could be the impact on the economy? Please comment with justifications.
Yes there indeed exists 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. My service provider is deducting for BUONGIORNO(CBGAME) service over and above the net charges where the control is not in the hands of consumers but on the hands of handset makers and developers.  Over and above the TSP are to be banned to use paid POPUPs to increase revenue.

Question 6: How should the security concerns be addressed with regard to Internet/OTT players providing communication services? What security conditions such as maintaining data records, logs etc. need to be mandated for such Internet/OTT players? And, how can compliance with these conditions be ensured if the applications of such Internet/OTT players reside outside the country? Please comment with justifications.
is TRAI the authority to do so? How do you propose.
Question 7: How should the Internet/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
Encryption, Point to points protocol, inisisting on use of secure layer and use of digital certificates
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 or the best practices? And, what practices should be proscribed by regulatory fiat? Please comment with justifications.

Question 9: What are your views on net-neutrality in the Indian context? How should the various principles be dealt with? Please comment with justifications.

Net neutrality is the need of the hour in India.Net Neutrality is a founding principle of the Internet which guarantees that TSP and ISP operators remain mere transmitters of information and do not discriminate between different users, their communications or content accessed. It ensures that all users, whatever their resources, access the same and whole network.
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.
No discrimination unless force de majeure
Question 11: Should the Telecom Operators 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?
I don’t trust our TSP’s therefore I oppose the traffic management techniques for OTT apps.
Question 12: How should the conducive and balanced environment be created such that Telecom Operators 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.

Electricity company invest a lot on the electricity networks and power generation and the fan and light manufacturers get a free ride on it.
The people who use fans and lights pay the electricity companies for the electricity,
Simillarly ke the people who use Whatsapp and Skype pay the Telcos for data.
Question 13: Should Telecom Operators 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, TSPs cant be allowed to discriminate.
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, TSPs cant be allowed to discriminate.
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.
OTT are to be treated as services found on the internet do not discriminate  
Question 16: What framework should be adopted to encourage India specific OTT apps? Please comment with justifications.
OTT are to be treated as services found on the internet do not discriminate  
Question 17: If the App based/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.
Please DO NOT license OTT players. There is no need for it as of today. Please uphold the principle of net neutrality and leave OTT players alone
Question 18: Is there a need to regulate subscription charges for App based/OTT communication services? Please comment with justifications.

There is NO NEED to regulate any services offered over the internet
Question 19: What steps should be taken by the Government for regulation of non-communication App based/OTT players? Please comment with justifications.

The govt must enact legislation to establish net neutrality in order to promote business in OTT apps.
Question 20: Are there any other issues that have a bearing on the subject discussed?