Net Neutrality & Differential Pricing for Data Usage...

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’