I am a 27 year old software engineer, who has learned almost everything related his work from the Internet.
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.
Yes it is too early, as the state of Internet services is still in the beginning stages. Can TRAI assure good Quality of service if at all the OTT framework goes against net neutrality? As of now the Internet quality is very bad.
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, registration is not needed. They are not internet service providers or mobile network operators. Facebook, Whatsapp, Gmail etc.. are not using country's land to lay cables or air waves of this country
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, it is not impacting. The data packages are not cheap to make VOIP calls.And VOIP calls using home internet does not make much sense, this will beat the purpose of mobile phones, so no need to worry.
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 of
product/service differentiation? Please comment with justifications.
No, OTT should not be charge separately. It is the end user who is using service providers network no the OTTs.
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
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virtual world) and compliance enforced? What could be the impact
on the economy? Please comment with justifications.
No, there are no imbalances. Data volumes to OTTs at this stage in India are very nominal. It is not the correct time to implement regulations on OTTs. First concentrate on Quality of service and then form regulations.
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.
Does TRAI already have any Data security or Data protection standards or Cookie policy? Why should only OTTS should follow these? any website or Mobile APP gathering or online services sensitive personal information of the customers should follow standards set by the Governmnet or TRAI. Set standards entire industry not specially for OTTs and not specially against net neutrality.
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.
OTTs should follow Federal standard like HIPPA, PCI DSS, Fedramp etc.. This is not the subject related to net neutrality this should be dealt in a separate context.
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.
For the Quality of Service that Indian telecom operators provide we can comfortably ignore the idea of forming regulations on OTT.I stay in a big city not from a small village where connectivity is not there still the 3G quality is very poor then how can network operator expect all these luxuries of separate charges for each OTT things.
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.
First respected TRAI should think about providing Quality Of Service in home broadband and 3G, and make sure to push operators to launch 4G as soon as possible. This will increase data consumption by many folds, then also if the network operators runs into losses that is the time we should think about OTT regulations or separate charges for each website or media content.
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.
Customer is paying to use service providers network, it is not the business of service provider to dictate what websites should the end user visit with what speed. Increasing the overall charge on monthly package is the only way the operators should think about.
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?
Yes they should publish the strategy and technique they use.
Question 12: How should the 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.
TSPs, because they are the ones who gets profits from the investment. The CAPs or OTTs are already paying for their internet connection correct?
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, they should not implement discrimination at all.
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 need for separate charging, the TSP should not dictate what traffic they want to carry. Is there any proof that TSP are incurring loss or paying more rents due to more traffic to Facebook or whatsapp? When there is no technical study or proof regulation will not make sense.
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 should not be treated as bulk users. It is the end user or customer who is generating the traffic. There should not be any discrimination.
Question 16: What framework should be adopted to encourage Indiaspecific
OTT apps? Please comment with justifications.
India based OTTs should not be treated separately, there is no need for going against net neutrality as of now in India. First priority should be Quality of service.
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.
No they should not be treated as ASP or CSP. There is no need for them to get license.
Question 18: Is there a need to regulate subscription charges for
OTT communication services? Please comment with justifications.
No, there is no need for regulation on OTTs.
Question 19: What steps should be taken by the Government for
regulation of non-communication OTT players? Please comment
with justifications.
No regulation is needed.
Question 20: Are there any other issues that have a bearing on the
subject discussed?
The concept of going against net neutrality is not in the spirit of the concept of Internet. In India Internet usage growth has just begun, we should not kill it with unnecessary regulation like these.