Counter comments on TRAI Consultancy paper on Regulatory Framework for Over-the-top (OTT) services.


Counter comments on CP of TRAI on Regulatory Framework for Over-the-top (OTT) services.   Link:  wp.me/p1ZsI2-GA 

To Chairman, TRAI India.   advqos@trai.gov.in.  http://trai.gov.in/

Submitted by,                                                                                     Dated 08 May 2015.

Abraham Paul. P.

Ex. VP (TS) SPCNL, SIEMENS ICN Germany/ Director (SC) SIEMENS RHQ, UAE/ GM & SMT TBG, BPL Mobile, India/ TES (I) DOT India. e-mail: papaul@hotmail.com  Twitter.com/PA_Paul

Subject: Counter comments on CP of TRAI on Regulatory Framework for Over-the-top (OTT) services.

Ref: Please refer to my comments and response to TRAI in the links. http://wp.me/p1ZsI2-G5   and my paper on Net “Neutrality without hurting Telcos and End users.  http://wp.me/p1ZsI2-ES

Counter comments on TRAI Consultancy paper on Regulatory Framework for Over-the-top (OTT) services.

I appreciate TRAI’s effort in bringing out a comprehensive document on the subject which will serve as a reference paper to any student of technology.

About Counter comments:

  1. As has been explained in detail in my comments and answers to TRAI’s consultancy paper on this, the subject matter is very complex; going into details will be like opening another Pandora’s box.

Any attempt to regulate Internet will be a horrendous mistake.

Internet being what it is and openness its main strength; reigning in of it under sorts of regulatory controls by a particular country or region is going to be almost an impossible task as it will defeat its basic strength, purpose and utility.  This being my view, it is felt that going in detail on various comments will be a futile exercise. It will be more fruitful to see  what are TRAIs counter comments of on various comments from major stake holders.

2. However, there are valid points in Telecom Service Provider’s concerns about disparate OTT products and services eating into their means of revenue especially in the area of Telecommunication based value added services. It is more so when it is done by external OTT players with no agreements either with the Government in the region or with the TSPs, and having no licensed spectrum in the region but using TSP’s spectrum, network, systems and customer base and sell their products and services, free or at competitive cost. Most probable that they will slowly start charging once they gain the field.

Increasing cost of usage by TSPs as being indicated by COAI is no solution as it will only push more of their loyal customers to OTT services that will further diminish TSPs revenue on one side and higher cost of usage will make huge volume of low end customers to fall off killing TSPs business volume on the other side.

3. Ultimate solution is elsewhere. Please see my paper on “Net Neutrality without hurting Telcos and End users. http://wp.me/p1ZsI2-ES  As mentioned in my above paper, and comments and answer to questions in TRAI consultancy paper on the subject, the ultimate solution is in switching over to end to end systems products and service to IP based Systems, Networks, transport and user end devices that can then function truly net neutrally.

It means that functionalities and service delivery of TSP’s & ISPs can be rolled into one. With such a scenario, though still there can be various modes of same service and  delivery, its tariff could be based mostly on its quality, efficiency and user friendliness and finally left to the market so that competition will set the tariff, cost and pricing.

4. Security shall be major concern. Various forms of Security risks in leaving any country’s entire communication systems open to large number of unlicensed and unregulated external players from around the globe is a major concern, it is for the Government to ponder what and how something can be done to safeguard nation’s interest on top priority.

There are options like what I had been propagating for many years in my paper, “Exclusive Govt. owned Communication Systems and Networks for Crisis and Disaster management and national security.”  http://wp.me/p1ZsI2-dh Future wars will be less with Guns and Bombs but more in the Cyber space.  Hope Government will seriously look at it.

5. CLOUD and CLOUD COMPUTING is one of the options. It is understood that ISRO had already put or orbit three satellites for this purpose and three more are in the anvil. With this in place India should have an exclusive CLOUD for security reasons.  How is it related to #Netneutrality is explained in my paper, this shall be a fully firewalled INDIA cloud that would include the communication spectrum in the region so as to prevent illegal and un-authorised technology players getting into the India networks under the cloud. The sooner it happens, the better.

Conclusion. Till then TRAIs paper and efforts on Net neutrality will remain as a good exercise to make awareness of the issues involved among various stake holders including Government and the general public.

Abraham Paul. P.

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Reference:

  1. Net Neutrality without hurting Telcos and End users. http://wp.me/p1ZsI2-ES
  2. Response TRAI on Regulatory Framework for Over-the-top (OTT) services. http://wp.me/p1ZsI2-GS
  3. Government  owned Communication Systems and Networks for Crisis and Disaster management and national security.”  http://wp.me/p1ZsI2-dh
  4. Impact of transition from Voice to Data and Multimedia. http://wp.me/p1ZsI2-23
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Response to TRAI Consultancy paper on Regulatory Framework for Over-the-top (OTT) services


Response to TRAI Consultancy paper on Regulatory Framework for Over-the-top (OTT) services.  

Short link: http://wp.me/p1ZsI2-G5

To                                                                           Dated 22 April 2015.

Chairman, TRAI India

http://trai.gov.in/

advqos@trai.gov.in. 

Submitted by   Abraham Paul. P          

Ex. VP (TS) SPCNL, SIEMENS ICN Germany/ Director (SC) SIEMENS RHQ, UAE/ GM & SMT TBG, BPL Mobile, India/ TES (I) DOT India.

e-mail: papaul@hotmail.com  Twitter.com/PA_Paul 

Subject: Regulatory Framework for Over-the-top (OTT) services.

Ref: Consultancy paper on the above.

Please see my blog: Net Neutrality without hurting Telcos and End users. http://wp.me/p1ZsI2-ES

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Answers to the questions in the above consultancy paper.  

Question 1: Is it too early to establish a regulatory framework for 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. 

Answer 1:  Yes. Some beginning should be made now with a regulatory framework that could be adapted to changes in the future.

INTERNET is the best thing happened in the world of communication technology. INTERNET came into existence like a by chance bastard with no regulatory control in place and it is almost impossible to fully reign in now.

It so happened, that openness is main strength and virtue of Internet that make it a boon to ICT as a whole; anything done to restrict it will fully defeat it.

Internet being an umbrella system that nurture everything under it without discriminating what, why, who, secure or unsecure, good, bad or ugly and what not; thus making it a boon to most but can also be bane to many.

Security and discreteness being important requirements in any business, same shall be applicable in Telecom business also. Though telecom operation by nature is interworking between domains of different service providers, there shall be clearly defined business practices in using others resources and customer base.

The way out is not to remove openness of Internet but to regulate its access at subsystem level where it infringes into areas of business of other licensed service providers without appropriate business understanding with them.

World wide web being like one big sea, and information interchange happen in pure chance manner In millions of alternate paths, it is impossible to bring this regulation within itself. However, while trying to regulate externally, it should not totally turn it to something else that curtail its openness which is its main virtue.

The only way to do this is by creating subnets as regulated INTRANET CLOUDS below it keeping World Wide Web intact at the top level.

Analogy can be in viewing INTERNET as a universal train, INTRANET  CLOUDS as Cabins attached in it. Travelling between CLOUDS can be done by entering and existing world wide web as happening now without any problem.

So if it is found that something needs to be done, it should be in the peripheral networks and not in the Internet. It may be kept in mind this discussion is only about OTTs who are using TSPs network or switch in their service delivery encroaching TSP’s legal business without clear understanding between them. All other Internet services for PSTN/PLMN shall continue in the same way as it is without hindrance.

              Please see a simple schematic on this given below.

Net Neutrality (1)

Question 2: Should the 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.

Answer 2. Yes. (Conditionally of course.)

ITU-T regulates Telephony, ETSI regulate Mobile telephony and defines rules about access and controls. Having in place such well established system of fully regulated Licensed Telecom service providers handling Voice, messaging and video cal services, it becomes unfair to the principle of level playing that OTT services offering same services over the top OTT mode remain un-regulated and unlicensed and treated differently.

Question is how OTT players using WWW can be brought under licensing regime by some country somewhere unless there is scope to regulate ‘world wide web’?

Earlier Telephone exchanges handled only voice calls, Telegraph managed text messages and TELEX handled text between Tele-printers. Then came dial up access that provided 64kbps pipe for Voice and Data. Digital land line and mobile phone exchanges provide access for Voice, FACSIMILE and Data and access to Internet through ISPs.

With advent of Word wide web, things have changed a lot. The omnipresent and omnipotent world wide web that caters for almost all needs of everyone without barriers, time, place or distance with no bias to any one, has made it look like the old regulatory regimes impediment to progress.

Can we go back and say Telephony systems shall handle only Voice, not Data or transact Data only between the subscribers of PSTN/PLMN? Perhaps not.

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.  

Answer 3 – Part 1. Obviously, Yes.

Growth of OTT impacts the traditional revenue stream of TSPs.

It is a natural consequence of technology advancement.

Reasons: No one can stop advancement of technology and changes that happen too quickly now.  It is a fact that advancement in technology and convergence of Voice and Data had adverse impact on Telecom business.  This major shift of Voice based usage to  other high speed Data and multi-media services over Internet took the business away from Telecom Service providers to external digital, multimedia and various mobile managed e-commerce  service providers and along with it went out a major chunk of its revenue.

Please see my blogs: ‘Impact of transition from Voice to Data & Multimedia. http://wp.me/p1ZsI2-23 and It is suicidal for Telcos to allow banking industry hijack pay by phone VAS.   http://wp.me/p1ZsI2-d

Answer 3. Part 2. Does the increase in data revenues of the TSPs sufficient to compensate for this impact? 

Depends on what the Telcos and OTT combined business models are.

Reasons. OTTs by nature are using TSPs overall infrastructure network and customer base in carrying out their business. Otherwise, it will not come under OTT category.

Here comes the need to look at the term “Net neutrality” in a different perspective.

From the point of view of TSPs, can Net neutrality shall also mean: Method of call charging of Telephony related services shall be NEUTRAL to the type of system that handles it. It means, be it that the service is rendered over Land line systems, Mobile Phone systems or IP based systems which include Internet & OTT players; same method of charging shall apply and of course, leaving the competition in the market place to decide it.

Such an ideology of with understanding of all stakeholders involved can turn Net neutrality as an advantage to Telecom Service Providers.

Please see my paper: Net Neutrality without hurting and safeguarding End users http://wp.me/p1ZsI2-ES

Average holding time of IP related Telephony calls over circuit switched paths with in the telecom system being about 6 times that of voice calls; charging and billing of such calls based on the call duration according to various tariff package can generate enough revenue of the TSPs to compensate for the impact of OTTs poaching telephony related services from TSPs.

In order to realize this, the basic need is to make OTT players as licensed service providers. Like ISPs, all OTTs shall be subscribers of one or many Licensed Telecom Service providers and access to OTT players shall not be on toll free basis.

In addition to the above, by making OTTs licensed and subscribers of TSP’s a revenue sharing model can be established between the OTTs and TSPs using ‘payment gateways’  to apportion and share revenue between various stake holders that can further enhance revenue of TPSs thus converting the set back of #Network neutrality as an advantage to TSPs.

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.  

Answer 4: As already answered in Answer to Questions 1 & 3.

As average holding time of Data calls is about 12 minutes, charging by duration of calls can generate enough revenue. Tariff can be kept low and without looking into data volume so as not to burden the consumers. Additional revenue can be earned from connectivity charges and revenue share with OTT players.  

Question 5: Do you agree that imbalances exist in the regulatory environment in the operation of OTT players? If so, what shall 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 justifications.  

Answer: 5. As already answered to Question 3. 

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.

 Answer 6:

6/1: Security is a major concern. This can be fully addressed only when India has its own INDIA-CLOUD below World Wide Web for insulating the country as I have written in my blog: Exclusive Govt. owned GSM Systems & Networks for Administration and Crisis / Disaster management. http://wp.me/p1ZsI2-dh

Moreover, making OTTs as licensed players and making it legal subscribers of one or of many TSPs, some of the security concerns can be addressed.

Ans. 6/2. As mentioned under Answer 3; OTTs are made licensed and legal subscriber of a TSP call data records for all data calls on circuit switched paths shall be available.

Ans. 6/3. There shall be a universal agreement that every OTT player that wants to handle Telephony related service like switching voice calls in VOIP mode shall be licensed and become subscriber of a PSTN/PLMN within the country or anywhere.  There shall be methods to refuse access unlicensed OTT players through TSPs in TSPs and associated ISPs. How to ensure this is the question?

Charging, billing and apportioning of revenue share shall be done by associated payment gateways as being done now in Roaming houses as the calls handled via ISPs which are licensed subscribers of TSP involved. (See the schematic in Answer 1)

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.  

Answer 7: Same as given in the answer to questions 3 and 6 above.  

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 summarized in para 4.29?

And, what practices should be proscribed by regulatory fiat? Please comment with justifications.

Answer: 8. India will have a billion phones soon. E-Commerce, Pay by phone services are growing enormously and Direct beneficiary transfers to Mobiles etc in the anvil. So India should take a lead in these things. Please see what I have been propagating over a decade for an ‘Exclusively banked Universal Money Management by Phones system’ in the link http://wp.me/p1ZsI2-4g

My point is, instead looking into other countries; India should come up with ideas that are suitable for us.   As may be seen in my papers mentioned above, India is in urgent need of an India cloud with required number of GPS satellites systems and networked across the country. For security reasons it shall be fully firewalled and the server part of all important systems shall be under this cloud so that these can be properly regulated.  

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.

Answer 9: As mentioned earlier, Net-neutrality in Indian context shall mean that as far the end users as consumers of the service, all forms of technology advantages shall be made accessible and at affordable cost to them while safe guarding the business interest of the Telcos and ISPs involved. It is therefore, there is some justification of considering that net-neutrality shall mean providing services rendered through every network; Land lines, Mobile Phones, Computers and user end devices on identical mode of charging on ‘same service – same charge’ basis making it network neutral.

Nevertheless, there shall be different tariff plans based on the level of service and then left to the market place so that competition based on quality and efficiency will decide the pricing.  If this can achieved it will be a win-win solution for the service providers as well as for the consumers.

Question 10: What forms of discrimination or traffic management practices are reasonable and consistent with a pragmatic approach? 

What should or can be permitted? Please comment with justifications. 

Answer 10: Partly answered under previous questions. In addition to that please see my blog: Net Neutrality without hurting and safeguarding End users http://wp.me/p1ZsI2-ES

The traffic management shall be based on the fundamentals of Telephony lest the entire system can fail. With average holding time of  data calls being 12 minutes, it is only any body’s guess if huge volume of traffic 0.2 TU per line on toll free access lines can create in telecom system and network. The switch will fail due to overloaded no time and make every other system in the network to collapse due to overcrowding junction routs.

The real solution is in Telcos switching over to IP based switching making TSP & ISP rolled into one; which is going to take time.

The pragmatic way is as suggested by me earlier to convert the net neutrality issue an advantage to TSPs by deriving adequate revenue to prevent them collapse and go out of business. 

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?

Answer 11: For this it is necessary to define these techniques. It was the practice with DOT to make the TRC issue specifications and standards for everything related to Telecom. Every TSPs are obliged to follow these specifications, rules regulations and conditions. There is an Acceptance Testing department under Technical & Development Circle to ensure its compliance. (I worked in that unit for over 20 years.)

Question is how it can be applied to OTT players that are not licensed? Please see more on this in my noting under Question 20. 

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 upgradation costs? Please comment with justifications?  

Answer 12. Please see my noting under question 20.  

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 should be adopted to ensure transparency to consumers? Please comment with justifications.  

Answer 13: Please see my noting under Question. 20.

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. 

Answer 14.

One of the advantages consumers find in OTT communication service is availability of features by which they can communicate each other at no cost or negligible cost.

Ideally net neutrality shall mean same tariff for same service irrespective of which network the consumer use for getting the service. However, it need to be discriminated based on availability, speed of access, quality of service, and flexibility users comfort such universal accessibility over mobile devices. Finally, competition in the market place shall decide pricing on each of the above.

As mentioned in earlier answers, there can be generally three methods of charging the OTT communication.

  1. Based quantum of data transacted over OTT
  2. A single unit access charge after an initial charge free duration (As success or failure of the call cannot ascertain in data calls) and Unit charges for the remaining duration of the call.
  3. Revenue is realized by revenue share from OTT player and no charge from the TSP side in the principle of ‘’Called party pays basis” treating OTT player as the Called party. If none of the above is practical, TSPs may think of increasing monthly rent of the users who all need data access to OTT players.

In order to keep cost to user low, the tariff shall be such that it do not cause heavy burden on the consumers. As considerable percent of users being from the lower social & economic strata, who may not need data access, there can be given discriminative service without Data at cheaper monthly rent as already being done. There can be lower rental for rural and village customers both on rental as well as data service.

Please see my notes in answer to question 20. 

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.  

Answer 15: Please read my blog: Segregation of Service Provision from Network operation / Universal Numbering Plan.  http://wp.me/p1ZsI2-t  

Question 16: What framework should be adopted to encourage India specific OTT apps? Please comment with justifications. 

Please see noting in Answer to Question 20 wherein I have explained about India Cloud and exclusive IP based OTT server.

Question 17: If the OTT communication service players are to be licensed, should they be categorized as ASP or CSP? If so, what should be the framework? Please comment with justifications.

 Answer 17. Yes. Otherwise, TSPs have no contractual obligation to provide access to and from OTTs through their network or direct to their switches. It can be contested in Courts.

 Question 18: Is there a need to regulate subscription charges for OTT communication services? Please comment with justifications.  

Answer 18. If direct access is given to OTT servers through circuit switched paths it shall treated and charged as PABX lines. 

Question 19: What steps should be taken by the Government for regulation of non-communication OTT players? Please comment with justifications.  

Answer 19. The question is why non-communication players are OTTs and whether they use TSPs network and switching system to get access in any process of delivery of service. The only way to discriminate it is by filtering it at ISP stage in case of Internet access from PLMN/PSTN. All Internet services to non-communication OTT players shall continue. That is what ISPs and Internet is meant to for.  

Question 20: Are there any other issues that have a bearing on the subject discussed?  

Please see my blogs below: With IP based switching and Networks going to be the future, the Telecom systems as of now will not last long.  Government and regulators should have kept in mind this while revising the licenses and selling out spectrum at high cost to Telecom Service providers.

Please see my blog: Who need Spectrum; How much, Where and When? http://wp.me/p1ZsI2-82 

  1. Indian air space is allowed to be crowded by various international players like Skype, Viber, WhatsApp, Chat On, Snapchat, Instagram, Kik, Google Talk, Hike, Line, WeChat, Tango, ecommerce sites (Amazon, Flipkart etc.),Ola, Facebook messenger, Black Berry Messenger, iMessage, online video games and movies (Netflix, Pandora) as mentioned in Para 2. of the TRAI’s CP on this. One of them yet have own spectrum in this country. They manage riding over TSPs systems, network and spectrum.

It is also possible that they sneak into Mobile networks using methods such as emergency access to any available network without SIM that is mandatory in Mobile telephony.  It is evident from the fact that we able to access some of these services from mobiles without SIM.

As we have seen it is not possible to reign in Internet and its openness. A long term solution is in all TSPs switching over to IP based systems and networks. Eventually it will happen but it is going to take time. Even with that consumer access to mobile systems will be over legacy and new generation networks using appropriate and adequate spectrum. Whether TSPs will be able to hold on to their business till then is to be seen.

  1. Another solution to reduce burden on TSPs by segregating Network operation from Service provision as explained in my blog in the link http://wp.me/p1ZsI2-t With most of even voice calls, messaging and data and multi-media related services are being handled external to local system the Traffic pattern is becoming totally different. Traffic is on the increase due to low user charger and higher penetration to other areas of Telephony and non-telephony related VAS needing more systems of higher capacities and networks. Technology is changing fast and life cycle of systems, H/W as well as S/W are becoming less and less. TSPs are already finding it difficult to balance between CAPEX + OPEX and Earnings.

The idea is to have few major network operators who set up and run the systems and networks on Pan India basis which are shared by various service providers on revenue share basis. This can remove the burden of huge invest cost from the TSPs. This is a far cry.

  1. Another solution to over come the current problem of OTTs is as I mentioned in my paper ‘Net Neutrality without hurting TSPs and safeguarding interest of Consumers’ http://wp.me/p1ZsI2-ES

The idea is to bring in some form of regulatory measure by bringing the OTTs under it. This cannot be done as far the operations remain fully through internet in the world wide web.

Please see the schematic below.

OTT(2)

4. The way out is to create an India Cloud and provide and bring in OTTs operating in India and abroad through it. Consumers interact with OTTs and vice versa via the Internet cloud.

Each OTT shall have specific IP address for its URL.

There shall be payment gateways under the India Cloud that will enable TSPs to derive share of revenue for the traffic originated from and terminated on it. For direct access between TSPs and OTTs, there shall be enough circuit switched connectivity between TSPs and OTTs according to traffic needs.

In case of entering TSPs via its spectrum, it need be allowed in the basis of treating OTTs as a PABX.

In case of accessing OTTs via ISPs, it shall be through India Cloud with specific IP URL address.

There shall be Payment gateways in set up and serviced the model of Roaming houses for apportioning and sharing of revenue between various stake holders. All call records and statistics shall be available in these payment gateways.

Separate switching system for catering to OTT players.

As there is enough scope of business that can be done over net, it need to be examined whether there can be a separate switching system can be set up under India cloud that can be legally accessed by licensed OTT players in India via any TSPs network. It is possible by opening out regional roaming feature and option to login to any available network. Access to the system from consumer will be identical to current mobile access to any other TSP system.

Such common switching system will function as switch + ISP + Payment gateway.

Conclusion. Internet is great. Everyone including me would like to continue it the same way. However, as Telecom professional with over 60 years of outstanding experience in the field I consider it my duty to point out the above discriminations and disparities related to the topic under discussion. I understand it is a very complex issue and it will open out lot of unsolvable problems due to the nature of Internet being what it is, good, bad & ugly.

The most scary issue is the security aspect. World over everything is slowly becoming dependant on digitals systems and digital communication of sorts. It is powerful and provides comfort to human kind in many forms and also can become equally disastrous. As mentioned in the first part, controlling Internet is impossible. What I have been propagating for many years is that India should have its own umbrella network set up by GPS linked with exclusive Govt. owned GSM and systems country wide.  Good to know that ISRO is already on about it. Hope, the commotion about Net neutrality will get settled and India will march forward as a fore runner in the field of Information Communication Technology.  

Yours faithfully.

Abraham Paul. P.

69. Kakkanadu Lane, Kesavadasapuram,

Pattom P.O. Thiruvananthapuram. Kerala. 695004.

Ph: +91 471 2446644, +91 9446322644.

Currently in Dubai. Ph. +971563244867 & +971 44425577

E-mail: papaul@hotmail.com Titter.com/PA_Paul

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Net Neutrality without hurting Telcos and End users.


Net Neutrality without hurting Telcos and End users.

http://wp.me/p1ZsI2-ES

Author. P. Abraham Paul. 13 April 2015

Introduction: No one can stop advancement of Technology; and then Technology changes too quickly too.  However, most Technology advancements disrupt the paths it go through and grow. Same is truer in Information Communication Technology of sorts. Advancement in ICT brought in convergence of Systems & Networks, mode connectivity, the end links and User end devices. INTERNET is the best thing happened in Communication technology in past few decades.

From the technology and business perspective, the differentiation between Mobile Networks and Fixed phone network is slowly vanishing making Voice, Data / Multimedia and  INTERNET  characteristics in Mobile systems  similar to these in Fixed Networks.  Differences are the end link, type of access, bandwidth limitations and user devices. Thus advance in Technology converged various forms of ICT based transactions that helped to provide Universal mode of Telecommunication offering Net Neutrality for all. Strangling Net neutrality will be a horrendous mistake. However, it is suicidal for Telcos to allow Over the top (OTT) service providers poach all sorts of Telephony related products and services and its revenue along with it.

From DOT days Government neglected Telecom and it is the Public Telecom Service Providers by licensed Private PLMN operators made the Telecom in India what it is now. But then it is to be seen that how long Telecom Technology, systems, network and transport continues in the present form as IP based ICT is the order of the future. Access to ISPs and to INTERNET is no more monopoly of Telcos. ISP access is now available through Cable TV network any many other sources. Devices that can penetrate any TSPs network and to ISPs without SIMs are already there. Future systems and networks will be handling  Telecom, TV, Internet all rolled in one.

1. Basic fundamentals of Public Switched Telephone Networks.

At the outset, while analysing the part OTT players  in the area of   conventional Telecommunication, there seems to be an urgent need to revisit the basic fundamentals of Telephony and also about the need to keep these principles in tact. By definition, Public Switched Telephone systems, both PSTN and PLMN are obliged to give access and connectivity to and between subscribers of own and of other PLMNs & PSTNs anywhere across the word.  All other Private telephone systems like PABXs etc., have to be basically subscribers of one or other PSTN or PLMN and function within stipulated rules of their connectivity and operational limits. (Any PABX or any other Private communication system or else that do not have enough junction lines according to expected busy hour traffic over the junction can clog the Public telecom system it is connected to.)  It means PSTN/PLMN are not obliged to provide access and connectivity to any unlicensed communication players of any sort that are not legally or rightfully the subscribers of a PSTN or PLMN. Same is true with ISPs.

Hence one of the issues is  whether the OTT players are legally subscribers of a PSTN/PLMN or not? If yes, the issue is reduced to method of connectivity and commercial understanding between the TSPs and OTT players. Of course, in the case of accessing OTTs via Internet, how this can be ensured is a question to ponder. 

1.1. Internet also need to grow continuously to meet the needs of the day.

Now Internet is being used to access and acquire every form of information & knowledge, personal and business communication, applications for services, e-commerce and mobile banking needs by individuals as well as small, medium and large enterprises, organisations and various arms of Governments across the world, which is growing exponentially every day.

Unless there are enough access pipes and bandwidths are made available between the end users and the millions of Servers in the mighty net, entire system will become slower and slower. Those who often complain of delays in getting connected and slow through put need to know that Internet work over a mesh of shared network of pure chance routing and through put depends on availability of access paths with enough bandwidth in these pure chance alternate paths in every access points from the origination up to the destination. Any bottle neck in between anywhere will make the transport slow.  A user contracted for 1 mbps data may not get same through put when connected to a user having only 256 kbps connectivity. This is more true in case of real time applications and products.

2. Impact of transition from basic Voice and Data to Multimedia and IP based products.

Please see what I wrote many years back: Impact of transition from Voice to Data & Multimedia. http://wp.me/p1ZsI2-23  Major shift of Voice based and other high speed Data and multi-media services over to INTERNET based usage will inevitably take away the business from Telecom Service providers to external digital, multimedia and various e-commerce and mobile banking service providers, and along with it goes out a major chunk of their revenue.

2.1.  A major chunk of CAPEX of Telcos Systems and Network and the revenue earned are related to basic Voice and Data Services.  Same is true with Non-telephony related Value added services.   In a given Eco system, Telephony related usage and revenue remain more or less constant. Non-telephony related value added products and services such as pay by phone and many other e-commerce services offer an excellent way to enhance Telephone usage and thereby enhance revenue.

However, providing uncontrolled free access to external systems on circuit switched paths for long duration of real time applications, will cause congestion due to heavy traffic that will not only make the telecom system to fail due to overload but also make other systems in the network to collapse due to congestion  in the  junction circuits. It will also clog the Internet.

2.2. With the advent of 3G / 4G and new generation digital services, the transition from Voice call business to Direct and IP based Data and Multimedia already moved out substantial amount of business revenue from Telecom Industry to external service providers such as banks, content providers, and other multimedia companies. Allowing external service providers to use the access through Telecom network and systems and Telecom SPs Customer base that are set up and run incurring huge amount of  CAPEX / OPEX and cost of License and Spectrum and are compelled to meet the need to expand it further in order to cater for these ever growing non-telephony service related services. That is why I have been pointing out the folly of Government policies of Telecom such as  delinking Spectrum from License and selling it by auction at high cost.  See my post “Who need Spectrum; How much, Where and When? http://wp.me/p1ZsI2-82 

2.3.  Revenue sharing is the way out. Telecom Industry will find it difficult to survive unless they ensure adequate share of revenue from these external Service providers and industries that by default use their customer base, systems and network. Telecom Industry,  therefore, has all the right to get adequate share of revenue from both Telephony related and non-telephony related  services and it is suicidal for them to remain as mere onlookers while other industries hijack their revenue potentials.

2.4. Whether Net neutrality shall be applicable both ways?

Many are of the opinion that tariffing should left to competition and the market place to decide. But how it can happen for a zero-valued product or service that are provided by some OTT players. Here is the importance to have relook at the term “Net Neutrality”

In normal telephony environment, there is call charging based local call, national call or international calls depends on the destination and time of the day and day of the year. Due to various reasons there can be different tariff for calls over different mode of connectivity, fixed mobile etc. Of course, with IP technology, it can become cheaper, still unfair to ask for it at zero cost as the calls involve systems and networks of different stake holders.

Or is it better to make tariff also Net Neutral and leave it to the competition in the market place to decide it?

Important aspect to be kept in mind is that means and ways of revenue sharing shall be such that it will not unduly increase cost of service and burden end users.  Government and Telcos should know that success of Telecom Industry as in every other Industry thrives on its business volume and the volume comes from its availability and affordability to general mass of country’s population. Cost of Super hyped handsets and other user end devises etc., and passing on the effect of high cost on License and Spectrum, to users will increase cost of usage and will push the common people out of the system and the Industry goes down the drain.   Please see my blog: Make Telecom Systems, network, Phones, product and services for the common man. http://wp.me/p1ZsI2-9i http://wp.me/p1ZsI2-9i

3. Compromise solution to upkeep Telcos Interest with Net neutrality.

Openness is the prime strength of INTERNET. Everyone agree that strangling #NetNeutrality will be a horrendous mistake. Therefore, is the need to ensure Net neutrality according to principles of  telephony without hurting Telcos while safe guarding end user’s interest keeping the basic fundamental of Telephony in tact.  

As mentioned above Telcos are slowly losing their monoploy on Telecom service delivery.  Increasing data usage charges as being proposed by COAI is not a wise solution.

Every business volume of user brings in growth and volume can happen when the products and services are accessible and affordable to general mass. Increase of data charges will make it un affordable to a large portion of subscribers and many would fall off. On the other side many more who currently use the communication service through TSP channel may will mover to OTP based services causing further  reduction in revenue.   

To get over the current stalemate what is needed is a compromise solution to turn OTT service as an advantage and continue to ensure Net neutrality without hurting Telcos and of course, also safe guarding interest of the end users.

The end users are real beneficiaries of Net Neutrality as far as Telcos tow the line using compromise solutions and Government wake up and do away the policies of milking Telcos with heavy cost on License and Spectrum.  Please see my blog: The never ending Telecom muddle in India.  http://wp.me/p1ZsI2-gG

3.1. Such being the situation Government had pushed the Telecom business into; they would not dare to indulge in higher and higher investment needed for the high-tech data networks and access pipes to support other’s e-business needs with no means of adequate return on their investment.

The Network Operators /ISPs therefore, need to find strategies and methods to get adequate share of the revenue collected by e-business units that use their customer base, their network and resources. Many are of the opinion that market competition will take care of the issue; but how market competition can happen in zero cost service?

3.2. With further advance in technology with fully IP based systems replacing current mode of telephone exchanges it is possible that TSPs and ISPs will be rolled into one. This can happen only if the present form of licensing based on areas co-terminus to  Telecom Circles  replaced with giving license on Pan India basis.

Need of Payment Gateways in PDN for apportioning and sharing of revenue. 

It is to be reconciled that the e-business and e-services related to 2.5G, 3G /4G and Data services over INTERNET  involve ‘High Volume’ of  ‘Low Value’ payments and these cannot be done by direct payments or through banks, regular credit card companies etc. Also these payments can neither be handled by the Network operators/ISPs nor by the Service provider/e-business units as the value of each transaction is known only to the e-Business/Service provider who finally sells or provide the service.

This is the most critical issue and the high tech Telecom and IP related e-Business cannot take off and the Network Operators/ISPs cannot hold on to  sustainable business plans until it is addressed and resolved.

Micro-payment Gateways in PDN is one such idea to get back part of the revenue generated from e-business based on data services.  This need coordinated efforts by all stakeholders and the regulators.

4.1. Concept of Payment Brokers middle way systems.

To be in line with technology advancements, the network operators have no choice but to induct the new technology systems related to telephony and non-telephony value added systems in their networks and find means and ways to ensure sensibly viable business propositions. As mentioned earlier, the data related services gaining predominance, and the revenue potential moves from Network Operators/ISPs to Service Providers and e-Business units, Network operators/ISPs have to look for methods to grab their share of revenue generated in the PDN to survive.  Here lies the emphasis of the Payment Broker systems, which can manage the accounting of payments, apportioning of it and sharing the revenue generated between the stakeholders.

4.2. Security is also a major concern. Volumes can be written on the hazards a fully open system can cause to various areas of security.  One method to ensure security is to provide a two level access to Internet.

This can be done by having  Exclusive Govt. owned GSM Systems & Networks for administration and Crisis /Disaster management. Please see my blog in the link:  http://wp.me/p1ZsI2-dh

Another way is to have an INTRANET layer as INDIA_CLOUD below World Wide Web for all such purposes.

Please see schematic by clicking the caption below:

Net Neutrality

Net Neutrality

4.3. INDIA CLOUD and Cloud computing.

Obviously, such payment broker system mentioned above cannot be managed by individual Network operators/ISPs as the Service Providers and e-business units are common platforms shared by customers of many different Networks/ ISPs. For obvious reasons, such system shall reside in exclusive India- Cloud below the World Wide Web (WWW) and managed by Cloud Computing.

India-Cloud as proposed, need to be fully firewalled to ward off unlicensed service providers poaching products and services from existing licensed service providers or else, using their technology systems, Network and Spectrum.

This can be realized by routing out all non telephony related data access to Internet direct through the ISPs and all Telephony related service requests (such as IP based call connecting) routed over circuit switched toll free access to licenced OTT players   associating the payment Gateways for apportioning and sharing of revenue between the Telcos and OTTs. As all non-telephony related services will be routed out to Internet as happens now there shall be no complaints from the end users of Internet.

OTT(2)

Typical example may be seen in what I had been propagating for long:  “Money through Mobile” (MTM), a system that supports all sorts of money transactions and e-commerce by phone users transparent to Banks and banking systems setup and owned by a consortium of service providers is an option for telecom service providers to look into. Please see article on Universal Money Management by phone.   http://wp.me/p1ZsI2-4g

5. Coming back to the Net neutrality issue, please see my reply to TRAIs consultancy paper on the Pandora’s Box on Regulatory Framework for Over-the-top (OTT) with some short term work around ideas till entire systems comprise of IP based switching and transport, end to end.

6. Response to the questions in TRAI consultancy paper on Regulatory Framework for Over-the-top (OTT) services  is in the link http://wp.me/p1ZsI2-G5

Or click on the caption to open the PDF file.  Reply to CP on TRAI_OTT (Q&A) (5)

Knowing fully well that the ideas and opinions in my answers   being against general view of many millions on this; it is most likely to end up a wasted effort by TRAI, I did not spent more time on it to fully refine it.  Of course, like everyone,  I also would like to have everything free, but that doesn’t change facts. Fact is that I had tested out most of these OTT applications a decade back (Money through Mobile mTm for instance) but did not to push it forward exactly for these reasons.

As mentioned earlier, the final solution is in changing over to IP based systems, network and transport, the earlier it happens the better for all, the TSPs as well as for the consumers.

7. Counter comments on TRAI CP on Regulatory Framework for Over-the-top (OTT) services.    http://wp.me/p1ZsI2-GA

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Abraham Paul. P.       papaul@hotmail.com  twitter.com/PA_Paul

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2G scam – ‘Much-a-do-about-nothing’.


Originally posted on papaulsblog:

2G scam  – ‘Much-a-do-about-nothing’.     http://wp.me/p1ZsI2-jy

Introduction: Having been actively associated in the implementation of one of the early
GSM systems in India in 1995, I choose to remain stead fast in my opinion I had on this
subject from the inception of GSM for the following reasons:-

1. Ownership of Spectrum shall remain with government.  Wireless Spectrum is a nonrenewable national resource and as such need to be handled scrupulously and judiciously by Government and Regulatory authorities. The ownership of the spectrum shall remain with Government by allowing only its ‘right of use’ so that spectrum can be withdrawn and reallocated where it is no more required or not being put to intended use by any Agency or Operator.

2. Need to move with fast changing Technology. Technology is changing very fast. What is best today would become obsolete tomorrow. Different technologies would need different frequency layer, band…

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Sex, Society and the State.


Originally posted on papaulsblog:

CAUTION: “For mature readers only”

Sex, Society and the State.

http://wp.me/p1ZsI2-2d

Author: Abraham Paul. papaul@hotmail.com   Tweet: @PA_Paul

(At the outset, I would like to inform the readers that the issues involved in this are very subjective and complex and have different perceptions in different societies across different places and as such the observations and opinions contained may not be universally agreeable to all. What prompted me to write this is the on going debate about legalizing off the track hetero sexual ad homosexual behavior by law. 

Attitudes on matters pertaining to sex are changing in this part of the world also. Therefore, I want to make it clear that I do not disagree to anyone who chooses to disagree to my view points. I can only state that, I wrote this in the context of the culture and the communal life as experienced by me in this country.)

 

Introduction: …

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About Democratization of Information #DoI and embracing IT in Governance.


Originally posted on papaulsblog:

Abraham Paul P.

Ex: V.P. SIEMENS SPCNL / G.M. BPL. Mobile / TES (I) DOT India.

papaul@hotmail.com  Tweet @PA_Paul

Democratization of Information #DoI and embracing IT in governance.     http://wp.me/p1ZsI2-g6

For kind attention of Mr. Sam Pitroda.

While agreeing fully that embracing IT is the way to improve Governance;  India being one of the nations in the forefront of IT capability, it is astonishing why Government is still far away from exploiting its potential  in the over-all governance so as to transform its various departments  efficient,  faster and transparent.

In fact, India of today, with considerable penetration of Mobile phone services, most people in the lowest social & economic strata use information communication technology in a day to day basis much more than what the governments do.

Democratization of Information #DoI through various social media would become very much useful at least for the middle class who greatly indulge in…

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Deviation from the right process of governance is the reason for most our woes.


Originally posted on papaulsblog:

Deviation from the right process of governance is the reason for most our woes.

Short link.       http://wp.me/p1ZsI2-cV

Claim of Politicians owning the Government is a blatant myth.

Introduction: In Democracy, definition of Government  ‘of the people’, ‘by the people’ and ‘for the people’ meaning that ownership of government and governance shall ultimately rest with ‘People’. The claim of  a group of elected representatives claiming ownership of government is nothing but illogical and mostly a made up ‘myth’ by political class.

The inherent perils in Indian Democracy. Unrelenting desire and self centric ambition to gain superiority over other at any cost and ever growing insatiable greed and desire for change being the basic instincts that differentiate the human race, a political setup that envisages any country be ruled by a government Of the People, By the People and For the People, is more an Utopian myth than a realizable reality…

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