Subject: Net Neutrality- Needed in India. A few suggestions
From: Ajeshgowtham J
Date: 09-Apr-15 10:57 AM
To: advqos@trai.gov.in

Hi,

Please find my answers in bold.

  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? Yes its too early. And it will be after another 50 years.
  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? No.  
  3. Is the growth of OTT impacting the traditional revenue stream of telecom service providers (TSPs)? If so, is the increase in data revenues of the TSPs sufficient to compensate for this impact? So, when telephones and emails ate into the  revenue of Postal Network, were they asked to pay to the postal network. Its just the technology is growing. And what about Newspapers, are you going to ask online bloggers to give money to newspapers just because its eating into their market. Even now telecom companies are making money on Data that I use over the net. Its sufficient. And internet is a open market. If they feel these services are taking a share of their market no one is stopping them from providing a similar service and taking it back. 
  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? No OTT players need not pay over and above the data charges paid by the customers. There is profit already being made on these services.
  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? There are no imbalances presently. A so called framework will hinder the development of new players from entering into the market unless they have enough money to fight with established players with good financial backing. 
  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? From a messaging service/VoIP service point of view, you can ask them to maintain records against the user ID. But the data should not be accessed without necessary warrants. This is in order to protect one's privacy. 
  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?They are not providing a service like banking or trading where the data is required to have greater security. The general security measures taken by mail services like Gmail should be the norm or they should post the message that "The data shared by you can be accessed by anyone over the net in their apps and/or websites".
  8. In what manner can the proposals for a regulatory framework for OTTs in India draw from those of European Telecommunications Network Operators (ETNO)? What practices should be proscribed by regulatory fiat?. No regulations excepy for data security. 
  9. What are your views on net-neutrality in the Indian context?Its required asthe start up boom in India needs to grow and contribute to the economy positively. 
  10. What forms of discrimination or traffic management practices are reasonable and consistent with a pragmatic approach? What should or can be permitted?No discrimination should be there over the internet except for reproduction of copyrighted content or stealing patented ideas of other apps/websites.
  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? We do not want TSPs to control the internet that I view. 
  12. How should a conducive and balanced environment be created such that TSPs are able to invest in network infrastructure and Content and Application Providers (CAPs) are able to innovate and grow? Who should bear the network upgradation costs?TSPs can call for funds yearly, which I am sure the people/companies will be willing to contribute to (not only in India but also across the world). I am sure of people contributing as the experience of the internet would be enhanced as infrastructure improves. And also this would ensure that the funds are being used properly as there will be multiple stakeholders who will watch closely on how the money is spent.
  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?No discrimination please. 
  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?No need for differential pricing. 
  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?No. They are just like any one else. Once again no discrimination.
  16. What framework should be adopted to encourage India-specific OTT apps?No discrimination regional or otherwise. 
  17. If the OTT communication service players are to be licensed, should they be categorised as Application Service Providers (ASP) or Communications Service Providers (CSP)? If so, what should be the framework?Do not change the present system. 
  18. Is there a need to regulate subscription charges for OTT communication services?What steps should be taken by the Government for regulation of non-communication OTT players?No. Each service will ask for a fee which they think the user would be willing to spend for their service. If user feels its high he will not avail the service. 
  19. Are there any other issues that have a bearing on the subject discussed? Nothing I can Think of right now. Please do not trouble net neutrality.
Regards,
Ajeshgowtham J