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Lets be objective over the issue and respond to the point.Response to the consultation paper issued by TRAIQuestion 1: Is it too early to establish a regulatory framework for Internet/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.Comment - Don't think a new set of laws are needed. The regulations should flow through the existing laws of the specific area the Internet service caters and its already happening . E.g.1. App based Taxi service should follow existing or any upcoming laws specific to Taxi Service Industry in India as we saw in Uber's case it was banned due to non compliance.2. Same for content providers like Facebook, Twitter or blogging sites though these are community governed and self regulated, governments have already intervened and made sure social harmony and values are maintained under existing laws. e.g. Various facebook pages being pulled down by UPA government.3. Same has happened with Skype you can't call from a USA number being in India to an India's number.There are various such examples where existing and specific laws based on the type of service have already taken their course.Question 2: Should the Internet/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.Comment :- Licensing goes against the exact spirit of internet and the general direction Indian economy is going under Mr. Modi, having said that these arguments can be put against TSP providers as well since they also got "Telegrams" and "Post Cards", "pagers" out of business. The model of business is evolving and if a service which was earlier provided under a fee and was affordable to a small section of the society in a limited way is giving way to innovation and efficient mode to communicate it should be supported in all the ways possible. Your department should see how very small business owners like laundry wala, tailers, beauticians, kirana store owners, auto wallas, sabji wallas are using Whatsapp or their Indian competing services to now run their business efficiently and connect to a wider audience. These innovations and services with more and more small players entering and taking it to the next level is what internet is all about. Licensing will only give way to corruption and huge inefficiencies in the system as we have seen in Indian context historically.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.Comment:- The theme of this question is very regressive, SMS and mobile telephony impacted telegrams and postcard revenue of Indian postal department where was this question of compensating. On the other hand services like Amazon, Flipkart or other emerging E-Tailers (Since entrepreneurship was not thought off in such a light and was allowed to grow independent of regulations and red-tape'sm) have actually saved Indian postal services. Please visit any postal office in India and see for yourself what kind of booming business is provided to the national postal carrier by these new budding businesses since they were allowed to grow at the first place.Also there is no question of preserving traditional revenue model as a heritage to the society. Government should provide and make sure the infra like optical fiber, cable network can be laid at the most cost effective manner possible and treat it as a matter of national interest. Every admin unit based on population density and expected demand in next 10 years should be prepared for at least 4 MBPS linkage per house-hold in terms of infrastructure available in the same manner we should plan for Sewage and water management. As the consultation paper says at the beginning we are at a nascent stage of Internet evolution this is the perfect time to put a plan in place. Tax it , Subsidize it, make laws and have TSPs as operating partners working for normal profits since this is a matter of national Interest and social impacts are way huge.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.Comments :- TSP Networks should be marked as a matter of national interest, a necessity for a connected and growing society along with piped drinking water, right to education and other similar well meaning laws bringing down the cost of installation and maintenance. The data relating to installation, and maintenance of infrastructure available for communication services like Internet should be made public for each admin unit in India along with a plan on what is being done at local level to bring it up to a minimum per household threshold(I personally think 4 mbps, but let's have a panel).Any licensing or pricing option will simply make great new innovation in the field of internet services out of reach of our growing but still very poor society. Propaganda machines backed by all kind of money will own the internet using this pricing model.Your department should also consider that when an OTT or internet service serves a customer there is a cost incurred at the data processing and storage level as well, the bytes travelling via network is a small part of the whole cycle. These OTT/Internet service providers put in a huge intellectual capital and innovation to make sure data is processed and transferred in very efficient way, please check how Whatsapp can transfer a 500mb video file so quickly(its the compression algorithm), same goes for amazing strategies adopted by youtube for videos and skype for phone calls.Only the concerned government department issuing licenses and TSPs if they start applying innovation in laying down infrastructure we can support democracy and Net Neutrality.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 virtual world) and compliance enforced? What could be the impact on the economy? Please comment with justificationsComments:- The imbalance exists- but not in the internet regulatory rather in taxation environment. Existing laws should be domain specific governed by concerned ministries and departments. On taxation if Whatsapp generates its revenue or part of its revenue in India make it mandatory to have them a physical presence in India and tax that revenue stream and use that for public utility which can be "Internet for all". The taxation and physical presence rule should be progressive so the mega players should be giving back to the society but small players who are building the next generation apps and services should be allowed to grow freely, till they reach "Rent Seeking" stage.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.Comment:- When we log in to a service provider it's a private citizen interacting with service provider and the data I share with them is between us two. I sign a contract and the established players already have mechanism in place to let people know what would be shared, retained and what would be not. E.g when you download an app it specifically asks your permission to access your data and functions available on your smart-phone. But again for public safety Governments can play a role of defining, in broad stokes what logs and audits should be maintained for certain service providers, again this falls under specific needs of a domain e.g. banking, trading, financial gateways need KYC, all the transactions logs, BASEL 2, SOX compliance in IT solutions, make sure public has access via RTI or some other mechanism full access to his personal or public domain logs.On foreign major players, need to have their presence on Indian ground and pay taxes on revenues from Indian soil.Though Internet and services on them are already run and governed by some of the finest and most socially responsible persons you can find on our planet and if somebody is crossing the line Internet has its own mechanism to take them down e.g. we haven't seen a porn site getting as big as Facebook or twitter. Governments should play a role spreading awareness in what a Internet service consumer should look for when signing up for a service and the service agreements can be standardized so it's easy for users to read and understand and check for non compliance. Last thing Internet needs is a Nanny state with hugely limited resources trying to regulate it.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.Comments:- OTT and App providers are bound by platform providers terms and conditions e.g. apple store, Android market, Microsoft app store. Your department should study the existing norms already in place for privacy and data sharing, read about W3 consortiums and open source communities governing the rules of internet and if you feel anything is lacking specific to Indian context please list them on public domain, Indian Internet users community is very strong and can self govern. Again Governments role should be in awareness via various channels e.g. Media, Internet companies, NGOs etc, and intervention only under specific laws and court orders with full transparency and redressal mechanism.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.Comments:- ETNO as per the consultation paper itself is being rejected by EU and other countries. on 4.29 instead of price discrimination best way is to get OTT communication provider operate under existing telecom laws and taxed locally for the services, or a cess used for up gradation of the broadband network.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.Comments:- Net Neutrality as managed by existing market forces and Internet activist groups (read W3C, ISOC, ICANN and so many others) along with end consumers is the most efficient form to manage it. Apple insistence on not supporting a few type of services led to emergence of Android based ecosystem, Google always flags sponsored searches as "sponsored" or "Ad". The argument that there was/is some form of inefficiency by existing players so it's OK to introduce a huge amount of inefficiency into the system is non correct. Governments should support Net Neutrality and if think Device and Search neutrality lags somehow should work towards forming something in the lines of UNESCO with all the activists groups and governing councils as stakeholders sitting around a table defining the rules of the game.Question 10: What forms of discrimination or traffic management practices are reasonable and consistent with a pragmatic approach? 97 What should or can be permitted? Please comment with justifications.Comments:- Malicious intents, illegal contents, concerted DDOS attacks, Virus, Trozen spreads should be identified and managed, TSPs and Governments should use the experience of OTT and Internet service providers and create action plans in place to identify these network issues and throttle them, since it's a collective responsibility. There should be dedicated lines for law and order agencies, SOS services and public utility(not for profit services are a good example) and this should be listed on each service provider with reason why it qualifies for priority lane, with TSPs ready to quickly redress under time bound laws in case of appeals or grievances. Also this dedicated lane shouldn't be more than a small percentage e.g. may be 10% of the available capacity(a qualified pane should define this).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?Comments :- Yes and it should be bound by law, along with time bound redressal mechanism.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 up-gradation costs? Please comment with justifications.Comments :- Government should declare Internet related infrastructure of national importance and make it a part of regional master plans. The land acquisition and ground work should be completed by government in a very time bound manner with regulatory authorities watching, bringing down the cost. The installation should be given to TSPs under a fixed fee with the whole plan/related data in public domain and under RTI. The operation and maintenance should be auctioned. If we remove all these inefficiencies in the system with TSPs always striving to innovate and bring down their costs due to market competition. Instead of them being crafty to manage the data packets they can focus on expanding the capacity for next generation. On how to bear network up gradation costs- For every Uber there would be an Ola, or taxi for sure, for every amazon there would be a Flikcart, snapdeal spun out by local innovators due to neutral nature of Internet, this has forced the offshore companies to actually come on ground in India and compete, adding basis points to our real GDP. This expanding base of taxation can be used to upgrade the network.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 112 should be adopted to ensure transparency to consumers? Please comment with justifications.Comments:- P2P can be a good example of de-prioritization and users should pay to use these services if they want guarantee on service above a minimal threshold. Of course any such rule should be in public domain and with redressal mechanism. Also lets not worry about facebook or other such services getting paid in future and what will happen to consumers. Simply due to the nature of Internet to remove in-efficiency there would be more innovators taking it to next level. Monopoly and other unfair business practices are anyways under CCI.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.Comments :- No, there is None. Only way is to strengthen tax regime if they are making money attributed to Indian consumers lets tax them accordingly in a progressive manner. Let the business model evolve, its natural progression from postcards to telegram to pagers to mobile phone/sms to VOIP. If TSPs without throttling anyone due to their "innovative nature" come up with better VIOP way to communicate let them compete.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.Comments :- Due to super-fast innovation driven evolving nature of Internet any such classification would become obsolete before our regulators would have time to amend it, with less than 10% of GDP coming up as revenues for Indian government there are simply not enough resources to maintain these classifications and regulations, leading to corruption, confusion and huge in-efficiencies in a largely efficient model we currently have.Question 16: What framework should be adopted to encourage India specific OTT apps? Please comment with justifications.Comment :- There are already great India specific OTTS making their mark simply due to neutral nature of Internet, Zomato, Tripoto, OLA, snapdeal, flipkart, housing ... and many more. It has been happening due to a shared Neutral Internet platform they have along with established global big players in the business. This has forced likes of Uber, Amazon to really come on ground and spread incentives into Indian markets. Now try creating a dedicated lane there is no way anymore Indian OTTs would come up. India innovators are always on a shoestring budget and can't really compete with a Reliance + Facebook, or Airtel + Airtel friendly OTTS and service providers combinations . These practices should be outlawed and severely discouraged. Democratizing technology is the only way our people can break out of the poverty traps.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.Comment :- Based on #15 any such categorization and license regime is not sustainable. Let's make our competition commission strong and have an agile taxation policy to make the best of this situation.Question 18: Is there a need to regulate subscription charges for OTT communication services? Please comment with justifications.Comment :- Let the market forces take their course. Look for unfair business practices like predatory pricing, monopolizing and take swift actions. Have big foreign players to show their on-ground presence, register entities in India and have stake in India e.g. Skype should have an office in India and services should be managed as per telecom company provider rules, Indian government has already got them to lock skype calls when in India from USA number to local India number, I think they can be asked to show stake on ground for taxation purpose and booked if are found "Rent Seeking" just because they have an app sitting somewhere in California. There are already regulation about how online payments are managed for services provide in India lets strengthen the regulation their and check the whole money trail. These laws under specific domains under specific ministries can be sustained due to expertise these agency already have.Question 19: What steps should be taken by the Government for regulation of non-communication OTT players? Please comment with justifications.Comments :- As #18 if the entities are above a threshold in valuation and using the national bandwidth over a threshold, ask them to have a significant presence in India and pay taxes for India based business revenues. Non-compliance, lets sue them in their countries for outstanding taxes owed to India and ban them as needed. But no way promote them by letting TSPs collaborate with them and create a rich boys club owned Internet.Question 20: Are there any other issues that have a bearing on the subject discussed?Comments:- This whole issue should be seen as a way to bring out a national policy on how to expand Internet to each and every corner of India cheaply and efficiently, and remove any obstacles in the way via government fiat. Instead of making it an OTT, app/service provider vs TSP issue, the government should look for ways to make sure TSPs costs are low. Licensing fee, land acquisition policies should be aimed at that. TSPs should make any bandwidth management policy if they are using right now public and be ready to redress.