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.  


To Chairman, TRAI India.

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:

Subject: Counter comments on CP of TRAI on Regulatory Framework for Over-the-top (OTT) services. Dated 08 May 2015.

Ref: Please refer to my comments and response to TRAI in the links.   and my paper on Net “Neutrality without hurting Telcos and End users.

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.

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 it under sorts of regulatory controls by a particular country or region is going to be almost an impossible task  and it will defeat its basic strength, purpose and utility.  Such being my view on this, 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. None the less,  there are valid points in Telecom Service Provider’s concerns about disparate Over the top (OTT) players 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 that have no agreements either with the Government or with any Telecom Companies (TELCOs) in this region, and having no licensed spectrum in the Country but using Telecom Service Providers (TSP’s) spectrum, network, systems and customer base and sell TSPs products and services; free of charge or at competitive cost. Most probable that they will slowly start charging once they gain more access and business in the field.

These OTT players can tie up with regional Internet Service Providers (ISPs) that can be accessed over TV cable connectivity and totally bye pass Telcos by providing Voice over Internet protocol (VOIP) connectivity between computers and through new generation Mobile phones by logging into ISP over local WiFi link. May be that is why some of the ISP owners keenly voicing for #Netneutrality.

However, increasing cost of usage by TSPs as being indicated by COAI to overcome this 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.

Fact is IP based Information Communication Technology (ICT) will disrupt legacy TELCOS. Even phones are no more just phones but mini Computers that take care of almost all forms end users technology needs that can be realized through advanced Computers in addition to Information Communication service which is now becoming just a small area of the whole range of products and service that getting wider and wider everyday. I had predicted a decade back the possible impact of transition from Voice to Data and Multimedia in my blog  Currently it is experienced by all mobile users how bad is the quality of simple Voice call services by almost all Mobile phone service providers. Reasons of this are explained in my papers in the links above.

Therefore, it becomes necessary to take the arguments beyond Net neutrality. According to me, the way out is to collate TSPs and ISPs.  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 neutral.

It means that functionalities and service delivery of TSPs & ISPs can be rolled into one. With such a scenario, though there can still be various modes of same service and  delivery; its tariff could be based mostly on its quality, efficiency and user friendliness and finally left for the market and competition will to decide and set the tariff, cost and pricing. OTT(2)

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.” 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.



1. Impact of transition from Voice to Data and Multimedia.

2. Telecom Industrialists need caution on broad band network ideas that do not fit in the future.

3. Net Neutrality without hurting Telcos and End users.

4. Response TRAI on Regulatory Framework for Over-the-top (OTT) services.

5. Government  owned Communication Systems and Networks for Crisis and Disaster management and national security.”



About Abraham Paul

Vision & Objective: Telecom has always been the passion of my life. After 60 years of outstanding career and many personal contributions to the industry, I still have same urge, and desire to give back to the industry, the abundant experience, knowledge and potential acquired, by providing consultancy service to forward looking enterprises and entrepreneurs in Legacy and New generation Telecom & IT in the areas of Business Management, Technology, Engineering and Services. Apolitical and religiously unbiased.
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