My submission to TRAI
Question 1: Should the
TSPs be allowed to have differential pricing for data usage for accessing
different websites, applications or platforms?
Answer: No. TSPs cannot be
allowed to have differential pricing for Data usage for accessing different
sites.
My reasons are:
1. Such TSPs
may even make it prohibitively expensive for accessing e.gov services, which
could be potentially dangerous and legally untenable.
2. Existing
revenue models of TSPs are based on Net neutrality and revenue sharing. If TRAI
allows this to be tweaked in favour of one TSP Reliance communications, there
could be serious legal issue and governmental revenues can drop.
Question 2: If
differential pricing for data usage is permitted, what measures should be
adopted to ensure that the principles of non- discrimination, transparency,
affordable internet access, competition and market entry and innovation are
addressed?
Answer:
1. It should
stand the test of net neutrality.
2. It should
be fully under the control of an organization which is legally answerable to
the Indian polity.
3. It cannot
be controlled even in the back end, by an organization who do not come within
the jurisdiction of Indian law.
4. It should
be ‘No charge’ basis and not ‘Free’. ‘No charge’ should clearly confirm that
the consumer is not charged for the ‘Free’ services used in his subsequent
usage.
Question 3. Are there
alternative methods/technologies/business models, other than differentiated
tariff plans, available to achieve the objective of providing free internet
access to the consumers? If yes, please suggest/describe these
methods/technologies/business models. Also, describe the potential benefits and
disadvantages associated with such methods/technologies/business models?
Answer:
Yes. There are existing
models as in the case of Wikipedia or Google, which have maintained net
neutrality and still managed to raise revenue. My suggestions are:
1.
A new aggregator model as being done by ‘Uber’ is
worth exploring for such services. We must encourage formation and registration
of ‘aggregator services, which can pool the spectrum available from various
TSPs and offer services, where in the sole aim of the aggregator is to provide
the services on ‘No Charge’ basis but can claim access to the data generated by
usage. This would be something similar to lease of ‘asset’ by uber for a
limited time and paying for the service to the asset owner while providing the
customer a service. The aggregator can limit the utilization of the ‘No Charge’
services to certain period everyday or upto certain Down load limits.
2. USO funds
which are lying idle should be used for meeting the spreading of the ‘No
charge’ services. These funds can be transferred on DBT basis to eligible
classified citizens. The citizen will choose the services, pay the bills and claim
reimbursement from the government; else the payment can be transferred in
advance every month.
Question-4: Is there any
other issue that should be considered in the present consultation on
differential pricing for data services?
Answer: Yes.
1. With the
emphasis on digitization of most of the government services, it is the duty of
the government to provide the internet services to all of its citizens on ‘ No
charge’ basis to the extent they use its service for their own needs to access
governmental departments.
2. The
government will be a major beneficiary as the cost of providing the service physically
is greatly reduced if done digitally and this savings should ,be used to bear
the cost of availing internet services from any TSP.
3. More
specifically, health related access, access to provide law and order, internal
security, if done through the digital media can be far more effective and the
benefits could be universal.
4. These can
not be allowed to be hijacked for profitability and it is the duty of TRAI to
ensure that excessive profits are not generated at the pretext of providing
‘Free service’
