Wednesday, December 30, 2015

Comments RE: TRAI Consultation Paper on Differential Pricing for Data Services


Following are my comments in reference to the consultation paper on differential pricing release by TRAI available at the following URL:

I think the consultation paper does a very good job of laying out the current landscape by outlining the benefits as well as pitfalls of the current differential pricing schemes being advertised by TSPs (Telecom Service Providers). I would like to compliment the TRAI for the same.

I would like to strongly oppose allowing any such differential pricing schemes. 

The TSP's and platform providers are pushing these schemes very strongly, under the veil of altruism, without getting into the real motives behind this. This is what makes all these attempts disingenuous and hard to trust.

The dream of digital india and connecting the next billion of our population needs to be fulfilled as soon as possible. And it is the responsibility of Indian government and all regulatory authorities to make that happen faster. But, they must also ensure that it is done in a way that doesn't compromise the most compelling quality of the current internet - that it allows free competition and encourages true innovation.

As an example, if I think of a good idea today and decide to create a web portal, I can bring it online and make it accessible to the entire world within hours. I tried doing that with the "Free Basics" platform, and they require a time of 6-8 weeks to review my proposal, and may very well decide to reject it on "technical" grounds.

Clearly, such controlled platforms and differential pricing by TSP's must be disallowed at all costs. However, I strongly feel that it is irresponsible to simply reject a proposal without providing a workable solution to achieving the idea of digital india.

Towards that end, it is important to understand that the spectrum over which these data services are delivered by TSP's are a national resource, and only licensed to TSP's for deploying their services as per the regulatory guidelines. The regulators have a duty to prescribe rules that ensure the use of this national resource is done for promoting our national goal of digital india.

A very simple way of achieving this is by mandating the TSP's to provide a limited amount of data to every subscriber every month free of cost. This could be something as little as 50-100 MB per month. The free data could even come with some caveats such as no video or file downloads, to ensure that the limited data is used most effectively. It would be perfectly reasonable to throttle the bandwidth for such free users, as well as give them a slightly lower priority over the paid users. There is plenty of other innovation that can be done here, without compromising the basic principle of open internet.

The TSP's will naturally incur some additional cost in providing this "free" service, and they should be allowed to recover it using some reasonable and transparent means, such as delivering advertisements during the free sessions. 

In terms of technical feasibility, this is as feasible as the "Free Basics" platform, but is much clearer in terms of the motives behind the approach, and most importantly, keeps the internet open to competition and innovation. 

To take my specific example, I will still be able to take my portal online within hours and have people access it over their "free" connection. And since the "free" connection is limited bandwidth and "slower", I will make sure I design my portal to be suitably lean in terms of bandwidth requirements. Open competition will make sure that applications which run well on these "free" connections thrive automatically, without needing a "monitor", just the way internet has thrived over all these years.

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