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TRAI’s Internet Licensing and Net Neutrality Consultation Paper: Simpler, Shorter Version

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A group of us have worked over the last four days to create a shortened version of TRAI’s consultation paper and Net Neutrality. We’ve converted the 118 page document into a 23 page document, reduced redundancy and largely irrelevant data. It’s been restructured in MediaNama style to make it crisper and a little less tedious. It retains all the substance of the TRAI paper, and some of the strangest and some ridiculously biased statements, but without our views, which will be separate. Note that we’ve added contextual reading and links to help you understand things better.

You can view the paper:
On Google Docs. Please share it with others, and leave tips for adding more info or making it simpler.
– Download and read the MS Word version or a PDF version.

Forward it to people who need to know about this, especially startup founders and VCs.

Next steps for us: we’re creating FAQs, and explanatory presentations for you to understand what is going on. After that, we’ll publish MediaNama’s submission.

Important: mail me at nikhil@medianama.com, in case you want to help or have ideas on what to do.

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  • Thanks for doing this. It’s an important policy decision that has huge impact, more than most of us think right now. This needs to be circulated far and wide.

  • Grimmjow

    Just skimmed through the summarized PDF. Excellent work guys.

  • Neutral Web

    very well done.

  • Praful Deshpande

    What are we readers supposed to do ??

    sign any petition or something ????

    • lavanyag

      please don’t waste your time on signing internet campaigns. they don’t help.

      TRAI has clearly asked for an email with answers to 20 questions

      so you should send them that email CCing MediaNama and other press outlets

      so TRAI cannot claim they didn’t get your inputs

  • Nitin Kumar

    Thanks for putting efforts. From my side as a consumer, i have started a blog ( http://goodenoughnotenough.blogspot.in/ ) only after looking at TRAI’s consultation paper. In my blog i am doing detailed analysis and review of whole consultation paper. Will appreciate medianama team’s and other reader’s comments.

    • Right

      went thru your blog.
      a commendable effort.
      let us see how TRAI reacts to this and similar other responses put forth by consumers.
      the fact that TRAI is even willing to consider ‘differential pricing’ is obnoxious.
      pricing for such mass usage products, services should always be simple and easy to understand and implement across millions of consumers.

  • Chetan Gangoli

    Medianama and others on social media are simply scare mongering without giving a logical reason for why telecom operators should not be allowed to charge differently for voice and data usage. The only reason presented is a circular logic of saying that net neutrality should be enforced to stop telcos charging differently for different applications of their network.

    How exactly this would be detrimental to the public good remains a mystery.

    • bdutta

      Telecommunication service providers are “utility” companies, just like gas, power, water-supply. While they are free to compete with other companies that are providing value-added services “on top of” the utility called “communication”, they — by no means, should have exclusive privileges for the same.

      Indane, HP, BP are “gas” and “fossil fuel” companies. They also provide value-added services in a non-exclusive manner via their outlets, agencies etc.

      By extension of Telco’s logic of differential pricing of fundamental data service, courier delivering expensive ecommerce purchase should charge more than what it would if were to carry plain letters ? The analogy can go on about zillion things.

      As for the government earning less revenue, then let’s put it this way — data connection service is not provided for free, and government earns revenues from it. Perhaps — not as much as government would like to. The matter that it is perhaps not priced correctly should not be an excuse. Price data services, still as utilities to cover costs and also build for future. Then operate on a level playing field where pure ISPs can also compete, without the cross-subsidy from other units of Telco business.

      • Chetan Gangoli

        The argument isn’t that straightforward. Here are my views in detail for you to comment upon. https://docs.google.com/document/d/1o2kXQKfQ2Ieek1cz4UKTdt8WD2p977L8mhU0iKKeXkw/edit

        • bdutta

          Read through, and narrowed down choosing to answer only 1 point, on revenue (which BTW is at the heart of it, everything else is secondary or less). It is a complex subject, and I’m glad, someone is willing to engage.

          Here’s what google doc says:

          Q: Don’t carriers make enough money out of data as it is? And with the growth of data revenues, wouldn’t they be adequately compensated?
          A: Current pricing for data and voice are not equal. Voice is actually cross subsidising data usage. A cellphone tower with 5 MHz of spectrum can carry about 40,000 minutes of voice traffic per day at Rs 0.40/minute yielding Rs 16,000 per day. If there were no voice traffic, the same tower could carry 30 GB of data traffic per day for Rs 7,500 per day at Rs 250/GB which is the prevailing pack rate for 3G data. This is less than half of the revenue that the tower would yield for voice.

          If the above math is correct, and even if the onus is on the government to ensure that a business gets to earn as much as it did, and then grow (quite contrary to notion of free-market economy), even then the simple answer is to increase the price of “plain” data to a level which ensures the revenue to be at same level what operators get from voice. However, the reason cellular operators are loath to do that is for exactly the reason of “free-market effect”.

          Clearly, it is not that simple, and that the revenue-parity — even if achievable in spite of true free-market economics, isn’t what cellular operators would be happy or content with.

          Does this description remind one of anyone they know ?

          – We wish to not only retain, but to grow our revenues, come what may

          – We do not wish to innovate or take chances but at most eventually replicate, very safely, very guardedly what someone else has proven to work

          – We do not wish to reduce the level of death-like grip we have on our ecosystem where we’d continue to eat a very healthy share of the pie, in name of fair sharing – starving innovation there

          – We would love to continue to be a lazy, obese, good-for-nothing, bully in the market, … continuing to do what we do, but are presently upset that some new kids have stolen the show, taken away our pocket-money and life-style
          – And thus, want mumma-papa (government, via the regulators) to get all of that back… not through fair-play, not by becoming more worthy/deserving, not by changing life-style (i.e. way business is done).

          OTT’s are causing disruption, and cellular service providers are trying every trick in the book to stop that disruption. They’d much rather kill the innovation happening in the internet space, then to innovate themself.

        • Chetan Gangoli

          1. Nikhil has agreed to link to my arguments http://bit.ly/1CrP7Xc from his pro neutrality FAQ. That is a slightly more refined version. But the argument essentially is this : OTT players invest nothing in networks, ride on them while destroying carrier revenues and want regulators to protect them from the defensive measures that carriers would take. It’s not carriers that are asking for protection, but the OTT guys.
          2. Carriers are cross subsidising data with voice revenue, but that in itself is neither illegal nor unethical. Almost all businesses have differential margins on different products
          3. The name calling doesn’t strengthen your argument.

        • bdutta

          Why should OTT service providers “have” to pay for building networks ? This is argument I am unable to get.

          As a “data” consumer, the cost of building & operating the network is already paid for by the consumer. If that is insufficient, and sub-cost, then it needs to be fixed.

          As for (who is) “asking for regulation”, it is just the other face of the same coin which reads “asking for protection (from regulation)”. As a regulator, TRAI must have “best interest of consumers” as it’s foremost goals. Of course, it needs to balance it between short-term view and longer-term view.

          Sorry, if you think that the last part of my previous comment sounded like name-calling. While nothing personal, but Telecom industry in India – is where it is today, because of a very narrow, purely money-minded approach to it’s ecosystem. It is the same reasons why this (http://www.medianama.com/2011/11/223-live-trais-open-house-on-mvas/) VAS regulation TRAI consultation/discussion happened earlier in 2011, or the state of VAS report back from 2007 (http://www.slideshare.net/mohitgundecha/mobile-vas-in-india).

          Telco operators and innovation, especially of the kinds we have in India (usually — there are small pockets of exception, but they have faint little voice), rarely go hand-in-hand. Whatever little innovation they have to show, is all front-ending innovation of others, who are then squeezed-out of their profits thanks to highly unfair revenue-share, that dissuades further innovation.

        • Chetan Gangoli

          My limited point is that the three principles on which NN is based (check the wikipedia page) are not compromised by telcos charging OTTs differentially – as long as they have a clear and non discriminatory definition of which OTT traffic will get charged.
          Secondly, anything to qualify as an innovation should provide consumers with a benefit that was previously unavailable. OTT voice calling doesn’t qualify as innovation if you agree with this definition. Voice calling has been available for over a hundred years. The only value that OTTs have brought is a cost reduction because they don’t pay for the infrastructure they use. While all other internet content shared a symbiotic relationship with telecom carriers, that’s not true for OTT voice.
          I agree with you on VAS. It was scandalous and in my personal experience telcos had begun to pay for the thuggery in lost market share. The only people who gained were VAS companies. TRAI however, jumped the gun with regulations instead of allowing market forces to punish the telcos that were unable or unwilling to control the VAS guys.

        • bdutta

          Pricing and packaging has been the mainstay of so-called innovation in this market (traditional telcos, and more so in India).

          However, wouldn’t you agree that Skype (for instance, as the grand-daddy of OTT) went far beyond that ?
          1) Superior voice call quality, even on poor quality so-called broadband links.
          2) Ability to do video calls (before 3G video was introduced, and even when introduced it hardly ever works)
          3) Ability to IM and file-sharing
          4) Ability to see other person’s status/ability to take calls (presence)
          5) Ability to see rich call history
          It took many evolutions of RCS as a technology to be able to come up to where the bar was set by Skype and it’s ilk. Yet, do you see an aggrasive adoption of RCS to actually offer similar grade of service ? Service that interworks with millions of other endpoints ?
          Now, is that not innovation ?

          One might be really hard pressed to show 10 random people who got MMS working in one shot, after buying a phone and getting a new connection. Or, someone how got 3G video calling to any other party with 3G connection, without as much as doing a “sankat-mochan paath” :-).

          Most of us might remember the feeble “front ended” innovation in form of “411” service… and how well it worked (or didn’t), and how useful people found it to be ? Yet, why JustDial and AskMe services were so much more popular.

          Let me share an even more fundamental service issue, i.e. basic telephony and the promise of ubiquitous service thanks to roaming. Apart from the fact that you’ve to pay with an arm and a leg for this basic service that allows you to just talk or message, I see no end of woes of people who travel and have to use cellular roaming, and even if works, indoor coverage. Those are the times, when consumers have to fall back on Skype or such services.

          OTT services didn’t spring out of the blue, one find day. They are a result of frustration that consumers faced with stagnation and lethargy on part of service providers. OTT services filled a real service-gap, without violating any terms-of-carriage !

          OTT was also a result of rapid innovation with low entry barrier. Two kids just out of college could roll out a service with little bit of investment they could garner (relatively easily — without selling their kidneys and mortgaging parental property), with 3-5 months of effort. Yet consumers would happily lap up such service.

          The differential pricing, preferential treatment of the carriage-way, traffic gating/throttling is about to kill all of that.

        • Deepak

          Very well said again

        • Deepak

          Well said

      • Gajanand Jha

        Hello, Your comment doesn’t really equate correctly it seems. Would you like Indian Govt to pose TAX on everyone the same 10% or different for different income you have. Have you heard of 80/20 rule? 80% of the profit comes from 20% of your resources. The same thing is happening, 80% of the bandwidth is being utilized by 20% of the apps leaving other apps to suffocate. See the picture, if you utilize more bandwidth, you are being charged more costing so why not apply the same thing to service providers! If a service provider utilizes more bandwidth than normal, they should be charged extra as in TAX rule. Enlighten me if you think my comment is bias in some sence or is inappropriate.

        • bdutta

          Personal income tax and corporate tax rates are not based on same principles. However, here the revenue in question comes from not only corporate income tax, but also revenue share as part of license fee. I do not think it is easy to justify business entities on differential tax rates, due to pure economic basis of taxation applied there. I won’t pretend to be an expert on this topic, but that’s my layman view on this subject.

    • Ijtaba Alavi

      What they’re doing with your DTH will happen with the internet sservices as well.
      Pay for basic data package and pay extra for every other popular internet services like facebook, whatsapp, skype etc. And they’ll be free to do so. And we mus stop TRAI from allowing them.
      Internet’s freedom is everybody’s right!
      Petitions: https://www.change.org/p/rsprasad-trai-don-t-allow-differential-pricing-of-services-let-consumers-choose-how-they-want-to-use-internet-netneutrality

      • lavanyag

        please don’t waste your time on signing internet campaigns. they don’t help.

        TRAI has clearly asked for an email with answers to 20 questions

        so you should send them that email CCing MediaNama and other press outlets

        ]so TRAI cannot claim they didn’t get your inputs

        • Ijtaba Alavi

          Have done it already! :)

      • Chetan Gangoli

        Agree. The TRAI paper has classified two classes of OTT – Realtime (Voice, Video and Message), and others. Any attempts to unbundle within these classes would be against principles of free markets.

    • Vikram Mohan

      It would also mean that your ISP can decide what web services you can access. Refer link below for the easiest explanation on net neutrality.


      • Chetan Gangoli

        I concede that my original statement was hyperbolic. The bulk of the argument for Net neutrality is essential for both free markets and a free and open democracy. My arguments are mainly against allowing OTT to monetise telecom infrastructure to the detriment of telecom revenues and ask for regulatory protection.

        • dsb_dsb

          Well you should check the Quarterly profits of telecoms before even suggesting that that telecoms are at loss.

          Secondly look at the data usage & how it’s demand is growing and projections (various papers are already available).

          Lastly look at the number of smartphones & the smartphone penetration in India and it’s projections.

          Nobody is against “Regulatory protection” for TSP/ISP’s but to allow them to control the net which is a resource of every Indian is completely wrong. Internet is a national asset & every person has a right to choose which should be protected at any cost.

          Want to see a good law for India, look at Brazil’s “Internet Constitution” which is not even mentioned in TRAI white paper.

          Brazil’s Internet law :- English version.

        • Chetan Gangoli

          I’ve changed my view significantly since that comment and the argument no longer rests on telco profitability https://docs.google.com/document/d/1cCvR6wvDUaB-fTxs_zo1B_goeJR-Z5vSRssbExM6-n0/mobilebasic#cmnt2

          Thanks for the link on Brazil internet law

        • dsb_dsb

          Try this link & use download manager for PDF :-

          http://www.publicknowledge.org/documents/marco-civil-english-version – When i tried to download it manually i.e. without download manager link was getting broken & so i used download manager to download the file.

        • Chetan Gangoli

          got it. thx

    • lavanyag

      Chetan Gangoli
      AVP Marketing at Idea Cellular Ltd Is that you Chetan? Enough said.

      • Chetan Gangoli

        Yes, it is. Would you prefer that I comment anonymously?

        Here’s a detailed argument for differential charging of OTT that I’ve put up with full disclosure. If you can put your arguments as questions and I’ll try to answer them. I hope you don’t find the FAQ format too restrictive. http://bit.ly/1NYYOoy

      • bdutta

        Sorry @Iavanyag, as much as I consider that Net-Neutrality must be maintained, the fact that someone is commenting and sharing thoughts with their real name, must be commended and appreciated. Hiding behind anonymous handles takes away the credibility of opinion – don’t you think ?

        Even if there is a conflict of interest, anyone is free to debate on the merits of argument. Let’s try to keep the discussion factual, in spite of our strong opinions :-).

  • lavanyag

    Why are you MEDIANAMA deleting/censoring comments here?

    “please don’t waste your time on signing internet campaigns. they don’t help.

    TRAI has clearly asked for an email with answers to 20 questions

    so you should send them that email CCing MediaNama and other press outlets

    so TRAI cannot claim they didn’t get your inputs”

  • lavanyag

    Not having net neutrality is like the electricity distribution companies charging you differentially for various electrical equipment.
    Get Free tube lights and bulb package. Pay exponentially more for ceiling fan and Music system. #TRAI #SayNoToOperators

  • bdutta

    Wow, that google doc sure has lot of eyeballs !! Google tells me that features (s.a. for editing it) are unavailable until the crowd clears !!

  • becomingguru

    Very funny to see what the revolution of the Internet is made out to be in the paper – as the loss causer for SMS revenues.
    And the IT minister wants servers of all internet companies to be in India.
    And people speak whatever they want, on Facebook – how dare they!

    I don’t know whether to laugh or to cry!
    Paper has been authored by someone who hates internet, e-commerce, online booking of cabs, freedom of speech and is bothered about SMS revenues going down.

  • Vamsidhar Reddy

    Telecom industries concern for their survival, government is concern for revenue. they both kill the evolution and development of technology.

  • lavanyag

    Here are some Deadlines –
    Last date of sending comments to TRAI :
    24th April, 2015 to advqos@trai.gov.in
    – After that, counter comments by: 8th May 2015

    Contact TRAI – Who’s responsible: A. Robert. J. Ravi, Advisor (TD & QoS)
    – TRAI

    Contact No: +91-11-23230404,
    Fax: +91-11-23213036.

    – Address: Mahanagar Doorsanchar Bhawan, Jawahar Lal Nehru Marg, (Old Minto Road ), New Delhi – 110002

  • max

    SAVE THE INTERNET. UPHOLD NET NEUTRALITY. Telecom companies want to regulate internet. You can stop them. Sign the petition: http://chn.ge/1Enucrm TRAI has asked consumers to respond with views on 20 questions related to net-neutrality by April 24th 2015. Please send replies to TRAI email id advqos@trai.gov.in. http://bit.ly/1c4Pty2

  • Hi ,
    After reading all about Net Neutrality. What email shall i send from my end to TRAI
    Is it need to be a simple request mail or I shall answer all the questions as here:

    Please guide me so that I can help others as well.


    • dsb_dsb

      advqos@trai.gov.in – Send your replies to this official mail provided by TRAI in it’s paper.

  • lavanyag

    Airtel Zero risks being sued both by Competition Commission of India and TRAI for abuse of dominant Power under section (4) of the Act and misuse of scarce spectrum license (telecommunications license being misused for Information services). http://goo.gl/6XrlKb

  • Carl Frank

    Any rumours about the deadline of 24 April being extended?

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