Centre for Internet and Society

April 2017 Newsletter

praskrishna — 2017-05-20T12:59:17Z

Welcome to the CIS newsletter for April 2017.

Dear readers,

Previous issues of the newsletters can be accessed here.

Highlights
In a report on the information security practices of Aadhaar, Amber Sinha and Srinivas Kodali documented numerous instances of publicly available Aadhaar numbers along with other personally identifiable information of individuals on government websites. CIS along with like minded organizations made a submission to the Government of India to frame a feasible accessibility guidelines for mobile apps since there is no single standard in existence at the moment. A two-day 100 Women Edit-a-thon was held in March 2017 by CIS-A2K team along with Odisha's biggest newspaper Sambad. The event was inspired by BBC’s 100 Women series and edit-a-thons with the same name in December 2016. More than 20 female journalists participated and registered as new Odia Wikipedians. On March 31, 2017, the Ministry of Personnel, Public Grievances and Pensions, Department of Personnel and Training released a Circular framing rules under the Right to Information Act, 2005 (“RTI Rules”). The Ministry invited comments on on the RTI Rules. CIS submitted its comments. In an article originally published in Hindu Businessline on March 31, Sunil Abraham lists out 11 reasons why Aadhaar is not just non-smart but also insecure. Shuttleworth Foundation has announced Sunil Abraham as Honorary Steward for its September 2017 fellowship round. CIS worked on a three part case study. The first case study on digital protection of traditional knowledge was published by GIS Watch in December 2016. The other two case studies along with the synthesis overview has also been published.

CIS in the news:

NGOs, individuals urge state CMs to curb Internet shutdown (The Times of India; April 4, 2017).
India’s National ID Program May Be Turning The Country Into A Surveillance State (Pranav Dixit; BuzzFeed News; April 4, 2017).
Privacy, what? Bengaluru police leaks 46,000 phone numbers on Twitter (Neha Vashishth; India Today; April 6, 2017).

Bengaluru cops' twitter handle in ethical storm (Umesh Yadav; The Times of India; April 6, 2017).

Opposition questions govt move to make Aadhaar must (Komal Gupta; Livemint; April 12, 2017).
Aadhaar: A widening net (Komal Gupta, Apurva Vishwanath and Suranjana Roy; Livemint; April 21, 2017).
Chemistry research in India 'still not in big league' (IANS and India Online News Portal; April 24, 2017).
Stop the Haphazard Internet Shutdown Says MP Jay Panda (Regina Mihindukulasuriya; Businessworld; April 26, 2017).
Now, Aadhaar details displayed in Mizoram too (Sebastian P.T.; National Herald; April 26, 2017).
After SPB-Ilaiyaraaja, Sony Music and Sun Network lock horns over copyrights (Priyanka Thirumurthy; Newsminute; April 26, 2017).
Analysis: Data Protection in India - Getting It Right (Suparna Goswami and Varun Haran; Info Risk Today; April 26, 2017).
India bans social media in Kashmir for one month (Telegraph; April 27, 2017).
J&K social media ban: Use of 132-year-old Act can’t stand judicial scrutiny, say experts (Shruti Dhapola; Indian Express; April 28, 2017).

CIS members wrote the following articles:

How Aadhaar compromises privacy? And how to fix it? (Sunil Abraham; Hindu; April 1, 2017).
Digital native: You can check out, you can never leave (Nishant Shah; Indian Express; April 2, 2017).
Aadhaar marks a fundamental shift in citizen-state relations: From ‘We the People’ to ‘We the Government’ (Pranesh Prakash; Hindustan Times; April 3, 2017).
It’s the technology, stupid (Sunil Abraham; Hindu Businessline; April 7, 2017).
Privacy in the Age of Big Data (Amber Sinha; Asian Age; April 10, 2017).
Digital native: Are You Still Having Fun? (Nishant Shah; Indian Express; April 17, 2017).
Digital native: Snap out of outrage mode (Nishant Shah; Indian Express; April 30, 2017).

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Accessibility & Inclusion
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India has an estimated 70 million persons with disabilities who don't have access to read printed materials due to some form of physical, sensory, cognitive or other disability. As part of our endeavour to make available accessible content for persons with disabilities, we are developing a text-to-speech software in 15 languages with support from the Hans Foundation. The progress made so far in the project can be accessed here.

Submission

Mobile Accessibility Practices (Nirmita Narasimhan; April 12, 2017).

Event

Global Accessibility Awareness Day 2017 (Organized by Prakat Solutions, Mithra Jyothi and CIS; Bengaluru; May 18, 2017).

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Access to Knowledge
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Our Access to Knowledge programme currently consists of two projects. The Pervasive Technologies project, conducted under a grant from the International Development Research Centre (IDRC), aims to conduct research on the complex interplay between low-cost pervasive technologies and intellectual property, in order to encourage the proliferation and development of such technologies as a social good. The Wikipedia project, which is under a grant from the Wikimedia Foundation, is for the growth of Indic language communities and projects by designing community collaborations and partnerships that recruit and cultivate new editors and explore innovative approaches to building projects.

►Wikipedia

As part of the project grant from the Wikimedia Foundation we have reached out to more than 3500 people across India by organizing more than 100 outreach events and catalysed the release of encyclopaedic and other content under the Creative Commons (CC-BY-3.0) license in four Indian languages (21 books in Telugu, 13 in Odia, 4 volumes of encyclopaedia in Konkani and 6 volumes in Kannada, and 1 book on Odia language history in English).

Blog Entries

Note: All the following events were held earlier but the reports were published in the month of April:

Women's Day Edit-a-thon at Jeewan Jyoti Women's Empowerment Centre, Pune (Subodh Kulkarni; April 10, 2017).
Marathi Wikipedia Edit-a-thon at Savitribai Phule Mahila Ekatma Samaj Mandal, Aurangabad (Subodh Kulkarni; April 13, 2017).
Google-translated Telugu articles prioritisation exercise: January iteration (Pavan Santhosh; April 15, 2017).
Telugu Wikipedia stall at Vijayawada Book Festival (Pavan Santhosh; April 15, 2017).
Women's Day Edit-a-thon at Jnana Prabodhini (Subodh Kulkarni; April 15, 2017).
Bargarh Manuscript Digitisation Project (Sailesh Patnaik; April 16, 2017).
Imperial College Orientation Program, Bargarh (Sailesh Patnaik; April 16, 2017).
Orientation & Training session for Environmental Activists in Satara (Subodh Kulkarni; April 16, 2017).
Marathi Wikipedia Edit-a-thon at Rajarshi Chhatrapati Shahu College, Kolhapur (Subodh Kulkarni; April 16, 2017).
Marathi Wikipedia Edit-a-thon at Shivaji University, Kolhapur (Subodh Kulkarni; April 16, 2017).
Marathi Wikipedia Edit-a-thon at Sangli, Maharashtra (Subodh Kulkarni; April 16, 2017).
Orientation & Training session of Jalbiradari Activists (Subodh Kulkarni; April 16, 2017).
"Free-license Wings To Your Books" in Guntur (Pavan Santhosh; April 16, 2017).
"Free-license Wings To Your Books" in Vijayawada (Pavan Santhosh; April 16, 2017).
Adikavi Nannaya University Telugu Wikipedia Workshop (Pavan Santhosh; April 16, 2017).
Odia Wikipedia Workshop in IIMC, Dhenkanal (Sailesh Patnaik; April 17, 2017).
Sambad 100 Women Edit-a-thon (Ting Yi Chang and Sailesh Patnaik; April 18, 2017).
Google-translated Telugu articles prioritisation exercise: February iteration (Pavan Santhosh; April 18, 2017).

►Copyright and Patent

National Conference on Intellectual Property Rights and Public Interest (Organized by Indian Law Institute; New Delhi; April 7 - 8, 2017). Maggie Huang took part in the event.

►Openness

Our work in the Openness programme focuses on open data, especially open government data, open access, open education resources, open knowledge in Indic languages, open media, and open technologies and standards - hardware and software. We approach openness as a cross-cutting principle for knowledge production and distribution, and not as a thing-in-itself.

Publication

Economic, Social and Cultural Rights in India: Opportunities for Advocacy in Intellectual Property (Sunil Abraham and Vidushi Marda; GIS Watch and Association for Progressive Communications; April 23, 2017). Total 4 reports: Synthesis Overview, Access to Mobile Technology, Traditional Knowledge Digital Library, and FOSS and Open Standards.

Submission

Comments on the Right to Information Rules, 2017 (Amber Sinha; April 27, 2017).

Event Organized

NASA Space Apps Challenge 2017 (CIS, Bengaluru, April 22, 2017).

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Internet Governance
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As part of its research on privacy and free speech, CIS is engaged with two different projects. The first one (under a grant from Privacy International and IDRC) is on surveillance and freedom of expression (SAFEGUARDS). The second one (under a grant from MacArthur Foundation) is on restrictions that the Indian government has placed on freedom of expression online.

►Privacy

Blog Entries

Analysis of Key Provisions of the Aadhaar Act Regulations (Amber Sinha; April 3, 2017).
Right to be Forgotten: A Tale of Two Judgements (Amber Sinha; April 7, 2017).

►Free Speech and Expression

Blog Entries

Killing of Yameen Rasheed Reveals Worsening Human Rights Situation in the Maldives (Pranesh Prakash; April 25, 2017).
Internet Shutdowns in 2016 (Japreet Grewal; April 27, 2016).

►Miscellaneous

Blog Entry

Regulating Bitcoin in India (Vipul Kharbanda; April 20, 2017).

Event

Amutha Arunachalam - Stand Shielded of Digital Rights (CIS; New Delhi; May 5, 2017).

Participation in Event

ISO/IEC JTC1/SC 27 Meetings (Organized by Bureau of Indian Standards; University of Waikato and Novotel; New Zealand; April 18 - 25, 2017). Udbhav Tiwari attended the meetings.

►Cyber Security

Event Organized

Dr. Madan M. Oberoi - Digital Forensics and Cyber Investigations (CIS; New Delhi; April 7, 2017).

Participation in Event

Brainstorming Session on the Global Conference on Cyberspace (GCCS 2017) (Organized by the Ministry of Electronics & Information Technology; New Delhi; April 12, 2017). Japreet Grewal attended the session.

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About CIS
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The Centre for Internet and Society (CIS) is a non-profit organisation that undertakes interdisciplinary research on internet and digital technologies from policy and academic perspectives. The areas of focus include digital accessibility for persons with disabilities, access to knowledge, intellectual property rights, openness (including open data, free and open source software, open standards, open access, open educational resources, and open video), internet governance, telecommunication reform, digital privacy, and cyber-security. The academic research at CIS seeks to understand the reconfigurations of social and cultural processes and structures as mediated through the internet and digital media technologies.

► Follow us elsewhere

Twitter: http://twitter.com/cis_india
Twitter - Access to Knowledge: https://twitter.com/CISA2K
Twitter - Information Policy: https://twitter.com/CIS_InfoPolicy
Facebook - Access to Knowledge: https://www.facebook.com/cisa2k
E-Mail - Access to Knowledge: a2k@cis-india.org
E-Mail - Researchers at Work: raw@cis-india.org
List - Researchers at Work: https://lists.ghserv.net/mailman/listinfo/researchers

► Support Us

Please help us defend consumer and citizen rights on the Internet! Write a cheque in favour of 'The Centre for Internet and Society' and mail it to us at No. 194, 2nd 'C' Cross, Domlur, 2nd Stage, Bengaluru - 5600 71.

► Request for Collaboration

We invite researchers, practitioners, artists, and theoreticians, both organisationally and as individuals, to engage with us on topics related internet and society, and improve our collective understanding of this field. To discuss such possibilities, please write to Sunil Abraham, Executive Director, at sunil@cis-india.org (for policy research), or Sumandro Chattapadhyay, Research Director, at sumandro@cis-india.org (for academic research), with an indication of the form and the content of the collaboration you might be interested in. To discuss collaborations on Indic language Wikipedia projects, write to Tanveer Hasan, Programme Officer, at tanveer@cis-india.org.

CIS is grateful to its primary donor the Kusuma Trust founded by Anurag Dikshit and Soma Pujari, philanthropists of Indian origin for its core funding and support for most of its projects. CIS is also grateful to its other donors, Wikimedia Foundation, Ford Foundation, Privacy International, UK, Hans Foundation, MacArthur Foundation, and IDRC for funding its various projects.

For more details visit https://cis-india.org/about/newsletters/april-2017-newsletter

Policies to Sustain India's Market

Shyam Ponappa — 2017-05-20T03:06:30Z

The question is whether policies can be better framed to harness the market potential. Why is so much investment flowing into India's securities markets?

The article published in the Business Standard on May 3, 2017 was also mirrored on Organizing India Blogspot on May 4, 2017.

Probably because of (a) India’s market size and (b) growth, despite all its inconsistencies and difficulties. Are higher price-earnings multiples desirable? Yes if they are sustained, because more capital is available for equivalent productivity; otherwise, no. The question is whether policies can be better framed to harness the market potential.

India’s large market with its headroom for prosperity seems propelled partly by its own momentum, and its stocks partly by liquidity. The net investment in mutual funds in 2016-17 of Rs 3.43 lakh crore was reportedly double the previous year, the highest in the last decade. Domestic investment in pure equity funds in the last two years exceeded foreign portfolio investment (FPI), because of lower FPI and higher domestic investment. Retail investors grew in the last three years from 28.6 million to 39.3 million. Other positive factors were a government with a strong mandate and falling oil prices.

Now, reasonable earnings from some large companies and rising global markets augur well, although earnings must improve broadly and a number of caveats remain. These relate to non-performing assets/loans (NPAs/NPLs), structural problems in sectors such as iron and steel, construction, power, telecom, transport, agriculture, continuing deficiencies in infrastructure and institutions, and in productivity. There are social pressures from divisive electioneering, a disturbing rise of exclusionary tendencies echoed globally, and government overreach. There are also self-induced crises because of inappropriate policies, as in telecom, unviable situations created by populism, or by judicial orders, as seen in telecom, coal and power. There could also be failure to improve productivity (by a third to 9 per cent, as during the growth years), or adverse external developments.

The room for improvement is epitomised by low per capita productivity. According to Bloomberg, the International Labour Organization’s output per worker for India in 2017 is 20 times lower than for Germany. Yet, expectations run high for India in reports from sources such as Euromonitor, the International Monetary Fund, London’s Centre for Economic and Business Research (CEBR), and PricewaterhouseCoopers (PwC). Euromonitor predicts India’s consumer market will be the third largest by 2030, ahead of Japan and Germany. Growth will be for products such as smartphones, automobiles, and durables such as TV sets, refrigerators and air conditioners. For instance, India is the third largest market for smartphones after China and the US. In automobiles, India is the fifth largest market with over 3.3 million cars sold in 2016 and continues to attract global manufacturers.

However, Euromonitor cautions against rising inequality with the Gini index rising from 39.9 per cent in 2011 to 41.6 per cent in 2016 and estimated at 43.4 per cent by 2030. The CEBR estimates that by 2028, India’s gross domestic product will be the third largest after China and the US. PwC forecasts that in 2050, India will be the second largest economy (in purchasing power parity) after China, the US being third and Indonesia fourth, with a caveat: “Emerging economies need to enhance their institutions and their infrastructure significantly if they are to realise their long-term growth potential.”

Can our policies better contribute to realising this market potential? Consider the options. One approach is open exploitation, unmindful of whether the ownership and distribution of profits is domestic or foreign. Prices are determined solely by supply and demand, without government regulation or any other authority. Another extreme is that the government decides everything, which has been seen to fail. A third option is a mix, with open-market principles in areas that can sustain them, such as in consumer goods, tempered with appropriate regulation, e.g., against harmful substances. Ideally, policies should be for the long-term common good with sustainable levels of equitable access. Regulation is essential where network economics apply with few players, as in electricity and communications. Our mix is not ideal because realpolitik and populism overwhelm the need for deep understanding followed by the objective and convergent deliberation needed to frame beneficial policies (through sound institutions, also lacking).

Our policies are often indifferent to where ownership lies, and sometimes, this is a problem. For example, heavy industries or electronics majors abroad often have government backing. Indian enterprises start with a disadvantage, because of restricted access to capital, and at higher cost. Another aspect is when the ownership of major local corporates with privileged access to markets changes to being majority foreign-owned, because the profits are sent abroad. Yet another is that we do not have ecosystems for manufacturing start-ups through commercialisation and scaling up, in terms of financing, production and procurement. Attention seems confined to early-stage start-ups or to small-and-medium enterprises, with no ecosystem to see them through to establishing scale, comparable, for instance, to the building up of Huawei through consistent procurement.

Our greatest deficiency, however, remains lack of good infrastructure. Correcting this requires a long view, capital, slow payback and long lead times for results, usually beyond election cycles. Easily sidelined for populist measures for immediate gains, this area needs concerted, bipartisan, societal convergence. A case in point is telecom and broadband, where spectrum auctions loom again, even as operators struggle with low revenues and high debt from previous auctions. Another is the recent Supreme Court ruling against compensatory tariffs for two ultra-mega power projects at Mundra, of 4,000 Megawatt (Mw) (Tata) and 4,620 Mw (Adani), based on whether a “change in law” applies only to Indian laws. If the tariffs were upheld, five buyer states would get a lower than average price paid, substantially below the current market price. If these projects become unviable, they will add to the deadweight of NPAs. The banks they owe will also suffer, and there will be the opportunity cost of benefits foregone from the lower-priced electricity.

There may be a case for prioritising infrastructure, beginning with defining our objectives and then framing policies to achieve them. For power projects, it’s reasonably priced electricity; for telecom, it’s reasonably priced services. Until these are made possible through appropriate policies, there’s little likelihood of realising our full potential.

For more details visit https://cis-india.org/telecom/blog/business-standard-may-3-2017-shyam-ponappa-policies-to-sustain-indias-market

22 nieuwe leden voor Partnership on AI

praskrishna — 2017-05-19T06:54:20Z

Partnership on AI, een non-profit organisatie ter bevordering van het algemeen begrip van kunstmatige intelligentie en de ontwikkeling van best practices, heeft 22 nieuwe leden aangekondigd.

The news was published by Telecom Paper on May 17, 2017.

Tot de nieuwe leden behoren eBay, Intel, McKinsey & Company, Salesforce, SAP, Sony, Zalando, Cogitai, Allen Institute for Artificial Intelligence, AI Forum of New Zealand, Center for Democracy & Technology, Centre for Internet and Society – India, Data & Society Research Institute, Digital Asia Hub, Electronic Frontier Foundation, Future of Humanity Institute, Future of Privacy Forum, Human Rights Watch, Leverhulme Centre for the Future of Intelligence, UNICEF, Upturn, en de XPRIZE Foundation. Partnership on AI werd vorig jaar september opgericht. Tot de oprichters behoren onder meer Amazon, Facebook, IBM, Microsoft, Google DeepMind en Apple.

For more details visit https://cis-india.org/internet-governance/news/telecom-paper-may-17-2017-22-nieuwe-leden-voor-partnership-on-ai

March 2017 Newsletter

praskrishna — 2017-05-20T12:47:11Z

Welcome to March 2017 newsletter of the Centre for Internet & Society (CIS).

Dear readers,

Previous issues of the newsletters can be accessed here.

Highlights
CIS submitted comments on the draft Rights of Persons with Disabilities Rules for the consideration of the Department of Empowerment of Persons with Disabilities, Government of India. Anubha Sinha in a blog post has identified the various kinds of IP in an app and explained the protections available under Indian IPR law. CIS-A2K is conducting a Wiki internship project for students of New Law College, Pune under the guidance of Prof.Dr.Mukund Sarda, Dean and Principal of New Law College. In an Op-ed published in the Hindu, Sunil Abraham has stated that though biometrics may be appropriate for targeted surveillance by the state, it is wholly inappropriate for everyday transactions between state and law abiding citizens. CIS has published a survey that draws upon a range of literature including news articles, academic articles, and presentations and seeks to disaggregate the potential benefits and harms of big data, organising them into several broad categories that reflect the existing scholarly literature. CIS submitted comments on the Information Technology (Security of Prepaid Payment Instruments) Rules, 2017. The comments were in response to the Information Technology (Security of Prepaid Payment Instruments) Rules 2017. The Ministry of Electronics and Information Technology issued a consultation paper which called for developing a framework for security of digital wallets operating in the country. Ritam Sengupta, Dr. Richard Heeks, Sumandro Chattapadhyay, and Dr. Christopher Foster have co-authored a paper that presents exploratory research into “data-intensive development” that seeks to inductively identify issues and conceptual frameworks of relevance to big data in developing countries.

CIS in the news:

The 12-digit conundrum (Richa Mishra; Hindu Businessline; March 13, 2017)
EVMs: How transparent is the Indian election process? (Smriti Sharma Vasudeva; The Statesman; March 14, 2017).
Nasscom chief saying full data protection isn’t possible should wake us from our digital slumber (First Post; March 16, 2017).
Privacy concerns multiply for Aadhaar, India’s national biometric identity registry (One World Identity; March 17, 2017).
No ID, no benefits: thousands could lose lifeline under India’s biometric scheme (Guardian; March 21, 2017).
Why We Should All Worry About The Mandatory Imposition Of Aadhaar (Rimin Dutt and Ivan Mehta; Huffington Post; March 24, 2017).
India’s biometric ID scans make sci-fi a reality (Amy Kazmin; Financial Times; March 27, 2017).
क्‍या आधार पर जल्दबाज़ी में है सरकार? (NDTV; March 27, 2017).
Get an Aadhaar card if you don't have one (Priya Nair and Sanjay Kumar Singh; Business Standard; March 27, 2017).
The Aadhaar of all things (Shriya Mohan; Hindu Businessline; March 31, 2017).

CIS members wrote the following articles

Digital native: Lie Me a River (Nishant Shah; Indian Express; March 19, 2017).
It’s the technology, stupid (Sunil Abraham; Hindu Businessline; March 31, 2017).
How Aadhaar compromises privacy? And how to fix it? (Sunil Abraham; Hindu; March 31, 2017).

Submission

Comments on the draft Rights of Persons with Disabilities Rules (Nirmita Narasimhan; March 29, 2017).

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►Pervasive Technologies

Blog Entry

Intellectual Property Rights and Mobile Apps (Anubha Sinha; March 6, 2017).

►Wikipedia

Blog Entries

"Marathi Bhasha Gaurav Din" celebrations in Maharashtra (Manasa Rao; March 7, 2017).
Women’s History Month: Sambad collaborates with Odia Wikipedia for a Two Day Edit-a-thon (Sailesh Patnaik; March 16, 2017).
Wikisource:Internship Project at New Law College, Pune (Subodh Kulkarni; March 28, 2017).

Events Organized

Women's Day Edit-a-thon (Co-organized by Sterlite Tech Foundation, Jnana Prabhodhini, and CIS-A2K; Pune; March 10, 2017). Subodh Kulkarni was one of the trainers.
Marathi Wikipedia Edit-a-thon on Environment Management (Organized by CSIBER College and CIS-A2K; Kolhapur; March 30, 2017). Subodh Kulkarni was a trainer.

►Openness

Participation in Events

National Consultation on OER for Higher Education (Organized by Commonwealth Educational Media Centre for Asia; New Delhi; March 3, 2017). Anubha Sinha attended the event.
Open Development Book - Authors' Workshop (Organized by International Development Research Centre and Centre for Innovation in Learning and Teaching; University of Cape Town, South Africa; March 11 - 12, 2017). The workshop gathered the contributers to an upcoming book by IDRC on open development. Elonnai Hickok, Gus Hosein from Privacy International and Sumandro Chattapadhyay are writing a chapter for this book.
Indo - French Perspectives on Digital Studies (Organized by Digital Studies Group; Jawaharlal Nehru University, New Delhi; March 15, 2017). Anubha Sinha was a speaker.

Blog Entries

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Internet Governance
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►Privacy

Submission

Comments on Information Technology (Security of Prepaid Payment Instruments) Rules, 2017 (Udbhav Tiwari, Pranesh Prakash, Abhay Rana, Amber Sinha and Sunil Abraham; March 23, 2017).

Participation in Events

WISER Lecture : Sumandro Chattapadhyay on Deregulation by Code (Organized by the University of the Witwatersrand; Johannesburg; March 8, 2017). Sumandro Chattapadhyay gave a talk.
Conference on Safety Against Online Child Sexual Abuse (Organized by CID, Telangana and the Department for Women Development and Child Welfare, Telangana; March 16 - 17, 2017). Japreet Grewal was a speaker.
State of Digital Rights in India (Organized by Centre for Communication Governance at National Law University, Delhi and the Internet Freedom Foundation, in association with Access Now; India International Centre, New Delhi; March 24, 2017). Japreet Grewal and Sumandro Chattapadhyay took part in panel discussions.
Hangout on Technology and Jobs (Organized by Google; March 24, 2017). Vanya Rakesh was a speaker.

Blog Entry

Analysis of Key Provisions of the Aadhaar Act Regulations (Amber Sinha and edited by Elonnai Hickok; March 31, 2017).

►Cyber Security

Upcoming Event

Digital Forensics and Cyber Investigations (CIS; New Delhi; April 7, 2017). IPS officer Dr. Madan M. Oberoi will give a talk.

►Big Data

Blog Entry

Benefits, Harms, Rights and Regulation: A Survey of Literature on Big Data (Amber Sinha, Vanya Rakesh, Vidushi Marda and Geethanjali Jujjavarapu; edited by Sunil Abraham, Elonnai Hickok and Leilah Elmokadem; March 23, 2017).

Participation in Event

The Fintech Disruption - Innovation, Regulation, and Transformation (Organized by Carnegie India; March 28, 2017). Sumandro Chattapadhyay attended the event.

►Freedom of Expression

Event Organized

Essentials of building internet tools for inclusion (Valencia, Spain; March 6, 2017). A talk jointly proposed by Chinmayi SK and Rohini Lakshané was selected for the Internet Freedom Festival.

Participation in Events

From Virtual to Reliable: Exploring Freedom and Facts in the World of WWW (World Wide Web) (Organized by Embassy of the Kingdom of Netherlands and Adaan Foundation; March 21, 2017). Saikat Datta and Amber Sinha were panelists.
Internet Freedom Festival 2017 (Organized by IFF; Valencia, Spain; March 6 - 10, 2017). Vidushi Marda participated in the event. Vidushi also attended these sessions: Data Protection Law and its Different Manifestations; Using the Ranking Digital Rights Corporate Accountability Index for Advocacy & Research; The identity we can't change: a new wave of biometric policies around the world and Enabling free speech online by legal defence: the need for skilled lawyers to secure the free flow of information online: Vidushi channeled a discussion about Shreya Singhal v. Union of India as an important case study in understanding how legal defence has been used to secure rights online.

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Telecom
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CIS is involved in promoting access and accessibility to telecommunications services and resources, and has provided inputs to ongoing policy discussions and consultation papers published by TRAI. It has prepared reports on unlicensed spectrum and accessibility of mobile phones for persons with disabilities and also works with the USOF to include funding projects for persons with disabilities in its mandate:

Newspaper Column

Organisational Hurdles in Telecom (Shyam Ponappa; Business Standard; March 1, 2017 and Organizing India Blogspot; March 2, 2017)

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Researchers at Work
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The Researchers at Work (RAW) programme is an interdisciplinary research initiative driven by an emerging need to understand the reconfigurations of social practices and structures through the Internet and digital media technologies, and vice versa. It aims to produce local and contextual accounts of interactions, negotiations, and resolutions between the Internet, and socio-material and geo-political processes:

Research Paper

Exploring Big Data for Development: An Electricity Sector Case Study from India (Ritam Sengupta, Dr. Richard Heeks, Sumandro Chattapadhyay, and Dr. Christopher Foster; Global Development Institute, University of Manchester; March 29, 2017).

Blog Entry

Evaluating Safety Buttons on Mobile Devices: Preview (Rohini Lakshané and Chinmayi S.K.; March 27, 2017).

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► Follow us elsewhere

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E-Mail - Access to Knowledge: a2k@cis-india.org
E-Mail - Researchers at Work: raw@cis-india.org
List - Researchers at Work: https://lists.ghserv.net/mailman/listinfo/researchers

► Support Us

► Request for Collaboration

For more details visit https://cis-india.org/about/newsletters/march-2017-newsletter

A Pathfinding Approach for Digital India

Shyam Ponappa — 2017-03-03T16:39:37Z

It's not only the installation of the OFC, but of ensuring quality and reliability.

The article was published in the Business Standard on January 31, 2017 and reproduced on Organizing India Blogspot on February 1, 2017.

Most people believe an optical fibre cable (OFC) connection is necessary for broadband. While largely true, this is often financially viable only in urban agglomerations. What is less known is that trading companies use wireless links between New York and Chicago for high-speed electronic trades.[1] For people outside urban clusters, wireless is a less expensive alternative to fibre. They get only a few megabits per second, but realistically, ubiquitous broadband at 2 Mbps would be great.

Three factors are driving internet access and usage in India. An overriding factor is the growth of wireless devices and traffic as a global phenomenon. Cisco estimated in June 2016 that in 2015, wired access comprised 52 per cent of IP traffic, but would reduce to one-third by 2020, while wireless access would increase to two-thirds. This trend is reinforced by another factor: Innovation that lowers costs and improves performance in mobile wireless (Chart 1).

Chart 1: Mobile Innovation Lowers Costs and Improves Performance

Sources: Cisco Visual Networking Index; International Telecommunication Union; IE Market Research; Motorola, Deutsche Bank; Qualcomm
Note: Data speed indicated the maximum downlink speed, not average observed speeds. The average observed speeds depend on many factors, including infra, subscriber density and device harware and software

The third factor is the combination of the geographic spread of our population, the concentration of broadband penetration (Chart 2), and the limited coverage of OFC networks. While major cities and their connecting links are covered by OFC, less populated and less commercially attractive areas between them are not. In hilly terrain, there is considerable difficulty in laying OFC, which extends far beyond cost. In urban areas, cost can be a deterrent because we lack reasonable, uniform charges for rights-of-way. Such procedures and practices are difficult to institute and enforce, but are essential for robust, viable OFC networks.

Chart 2: Broadband Penetration

Source: http://www.thehindu.com/sci-tech/technology/internet/The-India-wide-web/article14588938.ece

It's not only the installation of the OFC, but of ensuring quality and reliability. OFC networks in India apparently suffer from 12 to 14 cuts per km per month, whereas the international benchmark is 0.7 cuts per km km per month. Apart from more frequent repairs, the capital expenditure in India is nearly three times as high as in Australia or the US.[2]

Estimates for installing OFC using standard procedures vary from about Rs 1 lakh to Rs 4 lakh per km. However, there have been attempts at getting costs down by radical changes in approach. For example, Andhra Pradesh considered an OFC installation of 22,500 km estimated Rs 4,700 crore. By stringing fibre overhead along electric cables, however, the estimate was cut to Rs 333 crore, reducing costs from Rs 21 lakh to under Rs 1.5 lakh per km. It remains to be seen how this network will perform in terms of quality and reliability. Also, wireless technology is needed to extend connectivity from the fibre to villages, and cellular network costs rise with less bandwidth. For instance, one estimate is that excluding spectrum costs, a network using 5 MHz costs nearly 70 percent more than using 20 MHz.

For all these reasons, we need concerted action to redesign our approach to broadband, covering the fundamentals of infrastructure, spectrum and market design. The exponential growth in mobile services has reached a plateau, and is complicated by the taint of the 2G spectrum scams. This has resulted in a mindset combining witch-hunting and paranoia in the press, the public, government departments, and the judiciary. This is not conducive for the coordinated, collective strategy and action that is required to extricate ourselves. Several proven wireless technologies are not permitted in India, although the Telecom Regulatory Authority of India has recommended their use. Methods to increase connectivity like those listed below are urgently needed, with requisite environmental safeguards such as the use of renewable energy.

60 GHz (V band) wireless gigabit for short-haul;
70 and 80 GHz (E band) for multi-gigabit backhaul up to 5 km;
TV White Space for the middle mile from the fibre to users in villages up to 8-10 km away in a single hop;

Additional steps, e.g.:

Increasing unlicensed spectrum in the 5.8 GHz band from 50 MHz to 80 MHz to enable 866 Mbps per channel, or more for gigabit capacity;

Enabling secondary sharing of spectrum bands such as TV White Space, which has the possibility of existing Indian IPR establishing domestic manufacturing and dominating this niche;

It is evident that despite intense efforts by the people involved, our existing approach is simply not getting us to where we need to be. This has been repeated by government and private sector representatives many times. There’s no substitute for developing a sound approach, collectively and participatively, with professional facilitation, cutting across government, industry (operators and equipment providers), users, and the judiciary, to devise whatever solutions will deliver better results. We have to move away from adversarial deadlock.

A good way to begin is by accepting facts, and considering the evidence before dismissing points of view. For licensing, we know that government collections from revenue sharing far exceed the auction fees foregone (“Breakthroughs Needed for Digital India”). We have the experience of building other infrastructure such as roads and airports on revenue-sharing principles. We have to take a similar systematic, phased approach to designing and implementing broadband networks. Policies on infrastructure resource use including spectrum need to be rationalised, and the sector organised through participative path-finding and problem solving. We have to build national champions in manufacturing to keep costs affordable, for instance, using TV White Space. India could set the standard with its IPR and products where OFC is infeasible or unviable for connectivity to villages and rural clusters. Both the administrative and political leadership need to do this, working with all stakeholders, and not treating any of them as adversaries, or cronies.

[1]. ‘Information Transmission between Financial Markets in Chicago and New York’, Gregory Laughlin, Anthony Aguirre, and Joseph Grundfest, Cornell University Library, arXiv.org

[2]. Conference presentation, Sterlite, http://www.trai.gov.in/sites/default/files/Sterlite-Badri.pdf

For more details visit https://cis-india.org/telecom/blog/business-standard-january-31-2017-and-organizing-india-blogspot-february-1-2017-shyam-ponappa-a-pathfinding-approach-for-digital-india

January 2017 Newsletter

praskrishna — 2017-03-01T06:00:37Z

Welcome to the January 2017 newsletter of the Centre for Internet and Society (CIS).

Dear readers,

We are pleased to bring you the Centre for Internet & Society's January newsletter. Previous issues of the newsletters can be accessed here.

Highlights
The Rights of Persons with Disabilities (RPD) Act, which was passed in December 2016, seeks to give effect to the rights and obligations enshrined in the United Nations Convention on the Rights of Persons with disabilities, which India signed and ratified nearly a decade ago. Nirmita Narasimhan in a blog entry has summarized the key provisions of the Act relating to digital accessibility. The latest judgment in the matter of Super Cassettes v. MySpace is a landmark and progressive ruling, which strengthens the safe harbor immunity enjoyed by Internet intermediaries in India. CIS was one of the intervenors in the case, and has been duly acknowledged in the judgment. Meena Gayathri became the first South Indian Wikiwoman to complete 100 Wikidays challenge. The challenge required Wikipedians to create one new article per day for one hundred days in a row. Gayathri's contribution and passion towards Telugu language and culture have transcended into a "knowledge revolution". The Committee on Digital Payments constituted by the Ministry of Finance and chaired by Ratan P. Watal, Principal Advisor, NITI Aayog, submitted its report on the "Medium Term Recommendations to Strengthen Digital Payments Ecosystem" on December 09, 2016. The report was made public on December 27, and comments were sought from the general public. CIS submitted its comments. The comments were authored by Sumandro Chattopadhyay. ICANN sought community input on the Proposed ICANN Community Anti-Harassment Policy on 7 November 2016. In response to this CIS submitted its comments. The comments were authored by Padma Venkataraman, Rohini Lakshané, Sampada Nayak and Vidushi Marda. The eleven sessions selected for the Internet Researchers' Conference 2017 (IRC17) to be held at the IIIT Bangalore campus during March 3-5, 2017 has been announced. The conference is being organised by the Centre for Information Technology and Public Policy (CITAPP) at IIIT Bangalore and CIS.

CIS in the news

India’s Digital ID Rollout Collides With Rickety Reality (Gabriele Parussini; Wall Street Journal; January 13, 2017).
Millions of Indians move from cash to digital payments. But some ask whether it’s safe (Rama Lakshmi; Washington Post; January 14, 2017).
Sunil Abraham on Aadhaar's misuse during demonetisation (Economic Times; January 14, 2017)
The soon-to-be launched Aadhaar Pay will let you make purchases using your fingerprint (Indulekha Aravind; January 15, 2017).
Lost your phone? Here's how you can make your mobile theft-proof (Sanjay Kumar Singh; Business Standard; January 16, 2017).
The Dangers Of Aadhaar-Based Payments That No One Is Talking About (Mayank Jain; Bloomberg; January 17, 2017).
Supreme Court issues notice to WhatsApp, Centre on data privacy (MJ Antony, Ayan Pramanik and Apurva Venkat; Business Standard; January 17, 2017).
Demonetisation: Cost Vs Benefit (NDTV; December 24, 2016). Sunil Abraham took part in the Big Fight programme aired by NDTV. The video was published on January 17, 2017.
For India’s complaints department, visit Facebook Live (Amy Kazmin; Financial Times; January 23, 2017).

CIS members wrote the following articles:

Cashlessness Needs Connectivity (Shyam Ponappa; Business Standard; January 4, 2017).
Digital Native: The Dream of the Cyborg (Nishant Shah; Indian Express; January 8, 2017).
Digital transitions in the newsroom: How are Indian language papers adapting differently? (Zeenab Aneez; London School of Economics and Political Science; January 16, 2017).
Digital native: Back at it Again (Nishant Shah; Indian Express; January 22, 2017).

Jobs

Policy Officer (Cyber Security)
Senior Policy Officer (Cyber Security)
Internship - Application accepted throughout the year
Survey Participants for Research on Musician Livelihood

Blog Entry

Digital accessibility in the Rights of Persons With Disabilities Act 2016 (Nirmita Narasimhan; January 23, 2017).

Participation in Event

Workplace Solutions Champions Consultative Workshop (Organized by Enable India, January 21 - 22, 2017; Ecumenical Christian Centre, Bangalore). Nirmita Narasimhan attended the workshop.

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Access to Knowledge
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Our Access to Knowledge programme currently consists of two projects. The Pervasive Technologies project, conducted under a grant from the International Development Research Centre (IDRC), aims to conduct research on the complex interplay between low-cost pervasive technologies and intellectual property, in order to encourage the proliferation and development of such technologies as a social good. The Wikipedia project, which is under a grant from the Wikimedia Foundation, is for the growth of Indic language communities and projects by designing community collaborations and partnerships that recruit and cultivate new editors and explore innovative approaches to building projects.

►Copyright and Patent

Blog Entry

Super Cassettes v. MySpace (Redux) (Anubha Sinha; January 16, 2017).

Event Organized

Seminar on Rethinking Copyright and Licensing for Digital Publishing Today (Organized by Pro Helvetia - Swiss Arts Council, Goethe-Institut Max Mueller Bhavan New Delhi, and CIS; New Delhi; January 23, 2017). Anubha Sinha attended the event.

►Wikipedia

Blog Entries

WikiSangamotsavam 2016 (Manasa Rao; January 18, 2017).
Telugu Wikipedia Stall at Hyderabad Book Fair (Manasa Rao; January 18, 2017).
Telugu Wikipedia Stall at Rajahmundry Book Fair (Manasa Rao; January 18, 2017).
Mini Workshop on Tools: Wikipedia Monthly Meetup, Hyderabad (Manasa Rao and Pavan Santhosh; January 18, 2017).
Meet Telugu Wikipedian Surampudi Meena Gayathri – the first South Indian Wikiwoman completing 100 Wikidays Challenge (Ting-Yi Chang; January 23, 2017).

Event Organized

Odia Wikipedia and Orientation Training Programme (Organized by CIS-A2K team; Indian Institute of Mass Communication, Dhenkanal; January 31, 2017).

►Openness

Participation in Event

CBGA - Consultation on Opening Up Access to Budget Data in India (Organized by CBGA; January 27, 2017; New Delhi). Sumandro Chattapadhyay was a speaker.

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Internet Governance
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►Privacy

Submission

Comments on the Report of the Committee on Digital Payments (Sumandro Chattapadhyay and Amber Sinha; January 12, 2017).

Blog Entries

The Design & Technology behind India’s Surveillance Programmes (Udbhav Tiwari; January 20, 2017)
Workshop on ‘Privacy after Big Data’ (Amber Sinha; January 27, 2017).

Events Organized

Discussion on Ranking Digital Rights in India (India Islamic Cultural Centre, New Delhi; January 7, 2017).
Rankathon on Digital Rights (CIS office, New Delhi; January 8, 2017).

Participation in Events

Global Governance Futures 2027 - Session 3 (Organized by Global Public Policy Institute and supported by Robert Bosch Stiftung; New Delhi; January 17, 2017). Sumandro Chattapadhyay joined Ankhi Das (Facebook) and Arun Mohan Sukumar (Observer Research Foundation) to discuss the "data governance" scenarios developed by the GGF 2027 Fellows.
CPDP (Computers, Privacy and Data Protection) 2017 (Organized by Privacy International; Brussels, January 26, 2017). Amber Sinha participated as a panelist.

►Big Data

Blog Entry

New Media, personalisation and the role of algorithms (Amber Sinha; January 2, 2017).

Participation in Events

Training programme for Chairs, Convenor and Experts for International Standardization Work (Organized by National Institute of Training for Standardization, under the Bureau of India Standards; January 19 - 20, 2017; NOIDA). Udbhav Tiwari attended the training programme.
Seminar on Understanding Financial Technology, Cashless India, and Forced Digitalisation (Centre for Financial Accountability; New Delhi; January 24, 2017). Sumandro Chattapadhyay spoke on the emerging architecture of FinTech in India.

►Free Speech & Expression

Submission

Comments on the Proposed ICANN Community Anti-Harassment Policy (Padma Venkataraman, Rohini Lakshané, Sampada Nayak and Vidushi Marda; January 13, 2017).

Blog Entry

Social Media Monitoring (Amber Sinha; January 13, 2017).

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Telecom
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CIS is involved in promoting access and accessibility to telecommunications services and resources, and has provided inputs to ongoing policy discussions and consultation papers published by TRAI. It has prepared reports on unlicensed spectrum and accessibility of mobile phones for persons with disabilities and also works with the USOF to include funding projects for persons with disabilities in its mandate:

Article

Cashlessness Needs Connectivity (Shyam Ponappa; Business Standard; January 4, 2017 and Organizing India Blogspot; January 5, 2017).

Event

Internet Researchers' Conference 2017 (IRC17) - Selected Sessions (Organized by Centre for Information Technology and Public Policy and CIS; IIIT, Bangalore; March 3 - 5, 2017). Eleven sessions have received 10 or more nominations.

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About CIS
-----------------------------------
The Centre for Internet and Society (CIS) is a non-profit organisation that undertakes interdisciplinary research on internet and digital technologies from policy and academic perspectives. The areas of focus include digital accessibility for persons with disabilities, access to knowledge, intellectual property rights, openness (including open data, free and open source software, open standards, open access, open educational resources, and open video), internet governance, telecommunication reform, digital privacy, and cyber-security. The academic research at CIS seeks to understand the reconfigurations of social and cultural processes and structures as mediated through the internet and digital media technologies.

► Follow us elsewhere

Twitter: http://twitter.com/cis_india
Twitter - Access to Knowledge: https://twitter.com/CISA2K
Twitter - Information Policy: https://twitter.com/CIS_InfoPolicy
Facebook - Access to Knowledge: https://www.facebook.com/cisa2k
E-Mail - Access to Knowledge: a2k@cis-india.org
E-Mail - Researchers at Work: raw@cis-india.org
List - Researchers at Work: https://lists.ghserv.net/mailman/listinfo/researchers

► Support Us

► Request for Collaboration

For more details visit https://cis-india.org/about/newsletters/january-2017-newsletter

Cashlessness Needs Connectivity

Shyam Ponappa — 2017-02-02T15:17:34Z

And connectivity needs political and administrative convergence. This new year brings with it uncertainties amidst the push for cashlessness. Without going into the demerits or otherwise, some clarity on a road map to go forward from where we are might help with realistic planning to manage our way out of this situation.

The article was published by Business Standard on January 4, 2017 and mirrored in Organizing India Blogspot on January 5, 2017.

Cashless transactions need ubiquitous connectivity, which we don’t have. Without it, the goal is simply unfeasible. Better to recognise this now, rather than act out elaborate charades, resulting in avoidable economic hardship and social ructions. Connectivity needs effective, efficient communication links at a reasonable cost. These call for realistic objectives and solid implementation, not bluster and unrealistic goals or plans, such as fibre-optic networks everywhere, payment systems on a hastily assembled database riddled with imposters, or insufficient security and privacy.

What is required?

The need is for internet connectivity using fibre backbones, extending to users through aggregation networks that are mostly wireless. The chances of establishing these networks increase if political parties and government agencies take concerted action on how to do so. This is necessary for two reasons. One is that our present network development and spectrum policies do not facilitate achieving universal broadband, especially in areas with lower commercial potential than prosperous urban clusters. The second is the legacy of network development with entrenched rivalries and perceived ways of managing spectrum, and the aftermath of the spectrum scam. These constrain society’s collective ability to configure solutions for connectivity, as opposed to the biased or limited perceptions of stakeholder groups such as the government, the judiciary, the citizenry, and industry (comprising service providers and equipment suppliers). Government agencies also have divergent agenda, e.g., the Telecom Regulatory Authority of India (Trai) is responsible for recommending spectrum use, the Department of Telecommunications/Ministry of Communications has licensing authority and runs the state-owned operators, the Ministry of Information and Broadcasting holds certain spectrum bands, the Ministry of Defence and government agencies hold other bands, and the Ministry of Electronics and Information Technology is responsible (without the authority) for providing broadband. Hence, the need for a convergent approach, as effected partially for electricity supply, from coal mining through transportation to distribution (although other sectors – hydel, hydrocarbons and nuclear – are yet to be similarly linked).

What needs doing

Radical changes such as pooling and sharing network infrastructure have to be considered for widespread connectivity. Such changes can’t happen with confrontation and mistrust, but only with trust and cooperation. This may seem naïve, but the ruling party leadership sets the tone for cooperation, as does the administrative leadership. Their pitch has to be sufficiently persuasive to induce diverse stakeholders – other political leaders, the judiciary, the citizenry who want industry to pay their pound of flesh while getting good services that are priced very low, and the operators, who have huge investments in networks and spectrum rights – to consider sharing equipment, and to work out worthwhile terms for everyone.

Currently, contending political parties pursuing selfish objectives as antagonists settle at the lowest achievable equilibrium. To understand why, consider two parties, A and B, with objectives along the horizontal X axis for A and the vertical Y axis for B in the chart.

When parties pursue conflicting interests confrontationally, they end up at N or Nash Equilibrium, where neither can improve their position without the other’s concurrence. Assume A has the objective of maximising a majoritarian agenda, while B seeks to maximise dynastic control of its leadership positions. This holds for any objectives that are unrelated (orthogonal). If their objectives are along the same dimension — say, control of the Centre or of the same states, there can be no accommodation: one wins what the other loses. This has happened so far, as parties are periodically voted in and then out by a disenchanted electorate. But if they accommodate, their equilibrium could move up to S, the “Best Feasible Equilibrium” point, where the acceptable limits of their respective objectives meet. (For more details, see: “Tata’s Corus Buy: A Game Theory Analysis”, organizing-india.blogspot.in, November 2, 2006, and "India’s Access To Nuclear Fuel & Technology", April 3, 2008.)

Imagine waking up to find that instead of the usual confrontation and vitriol, a different and gracious protocol awaits you. One of harmonious interaction marked by accommodation and courtesy, despite nature being red in tooth and claw. Utopian? Perhaps. But not if the powers that be realise that the way out of the cashless crisis is to seek benefits for everyone, instead of self-destructing by chasing chimera such as pure cashlessness or other unrealistic goals. Instead, they could give people what they need but don’t have: ubiquitous communications infrastructure that facilitates all activities (not just cashless transactions), and a more secure, well-ordered environment for pursuing their livelihoods and well-being. Policy decisions to share network infrastructure would be the start of this journey.

We can then break out of the impasse created by legacy communications policies and posturing, e.g., which party was responsible for what scam, the popular obsession with high auction prices for spectrum while wanting cheaper services, and operators committed to cornering spectrum.

Once the leadership collaborates, they’ll find that communications services delivery will be much improved by sharing capacity and coordination. This would enable other stakeholders – private sector operators, the citizenry, the judiciary – to accept that everyone gains from cooperative access to and delivery of communications services, provided adequate profits are generated and shared equitably. This will help in accepting a more rational, pay-for-use policy on the lines of highways, metro rail, or oil pipeline usage, and recognise the financial infeasibility of having auctions as well as funds for investments in networks for countrywide broadband access.

Government and stakeholders can then work together to develop solutions that are fair and practical. For instance, one or more consortium/s of operators with the government as a co-investor in each (on the lines of Singapore’s OpenNet) can co-own the network and coordinate for most effective and efficient service delivery. Earnings from spectrum usage can be collected by the government once the networks are commercially viable, as for developing any other infrastructure. Such collections are likely to exceed the auction fees foregone, as with revenue sharing from licence fees.

For more details visit https://cis-india.org/telecom/blog/business-standard-shyam-ponappa-january-4-2017-cashlessness-needs-connectivity

December 2016 Newsletter

praskrishna — 2017-01-28T12:02:23Z

Welcome to the December 2016 newsletter of the Centre for Internet and Society (CIS).

Dear readers,

Wishing you a happy and prosperous New Year. As the New Year unfolds we are glad to bring you developments from the last month of the year gone by for your reference. Thank you for reading the Centre for Internet and Society's (CIS) December 2016 newsletter.

Previous issues of the newsletters can be accessed here.

Highlights
Telugu Theatre scholar Pranay Raj Vangari created a record by completing a challenge that is famous worldwide in Wikimedia community - "100 Days-100 Articles". Rohini Lakshané attended the 25th session of the World Intellectual Property Organization Standing Committee on the Law of Patents held in Geneva from December 12 - 15, 2016 and made a statement on Future Work. She also submitted a statement on the Assessment of Inventive Step to Secretariat for the WIPO Standing Committee for the Law of Patents, Twenty Fifth Session. CIS submitted inputs to the Working Group on Enhanced Cooperation on Public Policy Issues Pertaining to the Internet (WGEC) on 15 December 2016. The WGEC sought inputs on two questions that will guide the next meeting of the Working Group which is scheduled to take place on the 26-27 January 2017. Udbhav Tiwari wrote an article on the technical, legal and jurisdictional issues around the recent Twitter and email hacks claimed by the ‘Legion Crew’, and what can targeted entities do to better protect themselves. Amber Sinha wrote a blog entry that focuses on network management, in general, and deep packet inspection, in particular and how it impacts the privacy of users. CIS is pleased to bring you the second title of the CIS Papers series. This report by P.P. Sneha comes out of an extended research project supported by the Kusuma Trust. The study undertook a detailed mapping of digital practices in arts and humanities scholarship, both emerging and established, in India. Zeenab Aneez wrote a report that examines the digital transition underway at three leading newspapers in India, the Dainik Jagran in Hindi, English-language Hindustan Times, and Malayala Manorama in Malayalam. Our focus is on how they are changing their newsroom organisation and journalistic work to expand their digital presence and adapt to a changing media environment. CIS made a submission on the Consultation Note on Model for Nation-wide Interoperable and Scalable Public Wi-Fi Networks published by the TRAI on November 15, 2016. Our analysis of the solution proposed in the Note, in brief, is that there is no need of a solution for non-existing interoperability problem for authentication and payment services for accessing public Wi-Fi networks.

CIS in the news:

Lack of clarity about cashless and online transactions makes digital payments more worrisome (Neha Alawadhi; Economic Times; December 1, 2016).
Changing the typographic landscape of a country: one letter at a time (Pooja Saxena; Storyweaver; December 1, 2016).
No laws in India to protect customers if they lose money during digital transactions (Alnoor Peermohamed; Business Standard; December 2, 2016).
Fake Narendra Modi apps aplenty, but it’s up to users to protect themselves (Indian Express; December 2, 2016). Also see Nandini Yadav's blog post in BGR on December 3, 2016.
Your digital wallet can be a ‘pickpocket’ (The Hindu; December 5, 2016).
Most popular smartphone apps inaccessible to disabled: Study (ET Telecom; December 7, 2016).
English gottila,job illa (Regina Gurung; Indian Express; December 7, 2016).
Bumpy road ahead for RFID Tags in vehicles (Smriti Sharma Vasudeva; Statesman; December 7, 2016).
India's Tech Policy Entrepreneurs (Rohin Dharmakumar; The Ken; December 8, 2016).
Vijay Mallya cries foul after his Twitter and email accounts are hacked (Alnoor Peermohamed; Business Standard; December 10, 2016).
విజ్ఞాన నిధి వికీపీడియా.. (Namaste Telangana; December 11, 2016).
వికీపీడియాతో విజ్ఞాన విప్లవం (Andhra Bhoomi; December 11, 2016).
Wikipedia is a Newspaper (Namaste Telangana; December 11, 2016).
Wikipedian Pavan Santhosh says Telugu Wikipedians are creating Knowledge revolution (in Telugu) (Andhra Jyoti; December 12, 2016).
Wikipedia Event in Mangalore (Vijaya Karnataka; December 18, 2016).
With power, phone and internet services affected, Chennai is still recovering from Cyclone Vardah (Vinita Govindarajan and Sruthisagar Yamunan; Scroll.in; December 20, 2016).

पीजी जूलॉजी विभाग में एक दिवसीय समागम का आयोजन (Hindustan, December 20, 2016).

How private companies are using Aadhaar to try to deliver better services (but there's a catch) (M. Rajshekhar; Scroll.in; December 22, 2016).
‘IT hub’ K’taka ranks No 12 in e-deals (Christin Philip Mathew; New Indian Express; December 27, 2016).
India’s ruling party takes online abuse to a professional level (Samanth Subramanian; December 31, 2016).

CIS members published the following articles:

Digital native: The View from My Bubble (Nishant Shah; Indian Express; December 4, 2016).
Indian Newspapers' Digital Transition (Zeenab Azeez; Reuters Institute for the Study of Journalism; December 9, 2016).
The Digital Protection of Traditional Knowledge: Questions Raised by the Traditional Knowledge Digital Library in India (Sunil Abraham and Vidushi Marda; GIS Watch; December 9, 2016)
The Curious Case of Poor Security in the Indian Twitterverse (Udbhav Tiwari; The Wire; December 17, 2016).
Pranay Raj record in 100 days-100 articles (Pavan Santhosh; Andhra Jyoti; December 17, 2016).
Digital Native: People Like Us (Nishant Shah; Indian Express; December 18, 2016).
వంద రోజులు.. వంద వ్యాసాలు - తెలుగు వికీపీడియాలో మోత్కూరు యువకుని రికార్డు (100 Days...100 Articles: Wikipedian from Motkur created record in Telugu Wikipedia) (Pavan Santhosh; Andhra Jyoti; December 18, 2016).

Jobs

CIS is seeking applications for:

Event Co-organized

International Accessibility Summit of Shaastra 2017 (Organized by CIS and IIT, Madaras; December 31 - January 3, 2017). Nirmita Narasimhan was a panel moderator.

Participation in Event

Best Practices in Digital Accessibility (Organized by IIM, Bangalore; December 19, 2016). Nirmita Narasimhan was a panelist.

►Copyright and Patent

Statements

25th Session of the WIPO SCP: Statement on Assessment of Inventive Step (Rohini Lakshané; December 15, 2016).
25th Session of the WIPO SCP: Statement on Future work (Rohini Lakshané; December 16, 2016).

Participation in Event

7th Emerging Markets Finance Conference (Organized by Finance Research Group in association with Vanderbilt Law School; Mumbai; December 15, 2016). Anubha Sinha was a panelist.

►Wikipedia

Blog Entries

Freedom in Feb — an awareness increasing campaign (Tito Dutta; December 8, 2016).
A Shortcut to Freedom (Tito Dutta; December 14, 2016).
Marathi Wikipedia Edit-a-thon in Kolhapur (Subodh Kulkarni; December 16, 2016).
Ongoing Proof-reading Effort by ALC Student Wikimedians in Telugu Wikisource (Pavan Santosh and Ting-Yi Chang; December 30, 2016).

►Openness

Submission

Comments on the Draft National Policy on Software Products (Anubha Sinha, Rohini Lakshané, and Udbhav Tiwari; December 11, 2016).

-----------------------------------
Internet Governance
-----------------------------------

►Privacy

Blog Entries

Privacy and Security Implications of Public Wi-Fi - A Case Study (Vanya Rakesh; December 9, 2016).
Habeas Data in India (Vipul Kharbanda and edited by Elonnai Hickok; December 10, 2016).
Workshop Report - UIDAI and Welfare Services: Exclusion and Countermeasures (Vanya Rakesh; December 14, 2016).
Enlarging the Small Print: A Study on Designing Effective Privacy Notices for Mobile Applications (Meera Manoj; December 14, 2016).
Protection of Privacy in Mobile Phone Apps (Hitabhilash Mohanty and Edited by Leilah Elmokadem; December 15, 2016).
ISO/IEC JTC 1 SC 27 Working Group Meetings - A Summary (Vanya Rakesh; December 16, 2016).
Deep Packet Inspection: How it Works and its Impact on Privacy (Amber Sinha; December 16, 2016).

Participation in Events

Industry Consultation Panel on Data Retention - DSCI (Organized by Data Security Council of India; New Delhi; November 23, 2016). This was mirrored on the website on December 6, 2016. Udbhav Tiwari was a panelist.
11th DSCI-NASSCOM Annual Information Security Summit 2016 (Organized by DSCI and NASSCOM; December 14, 2016). Udbhav Tiwari was a panelist.
Workshop on Center for IT and Society (Organized by IIT, Delhi; December 20, 2016). Amber Sinha attended the event.

►Free Speech & Expression

Blog Entries

ISIS and Recruitment using Social Media – Roundtable Report (Vidushi Marda, Aditya Tejus, Megha Nambiar and Japreet Grewal; December 15, 2016).
Inputs to the Working Group on Enhanced Cooperation on Public Policy Issues Pertaining to the Internet (WGEC) (Sunil Abraham and Vidushi Marda, with inputs from Pranesh Prakash; December 17, 2016).

Participation in Event

Myanmar Digital Rights Forum (Organized by Phandeeyar, You Can Do IT, Engage Media and Myanmar Centre for Responsible Business with support from the Embassy of Sweden; December 14 - 15, 2016). Sunil Abraham was a speaker.

►Big Data

Participation in Events

"Decoding the Digital" (Organized by Centre for IT and Public Policy at IIIT; Bangalore; December 12 - 14, 2016). Vanya Rakesh attended the event.
The EU and Free Flows of Data - Data Protection, Trade and Law Enforcement (Organized by the Department of European Studies; Bangalore; December 14, 2016). Ameila Andersdotter gave a talk.

Blog Entry

The Technology behind Big Data (Geethanjali Jujjavarapu and Udbhav Tiwari; December 1, 2016).

►Cyber Security

Blog Entries

Developer team fixed vulnerabilities in Honorable PM's app and API (Bhavyanshu Parasher; December 4, 2016).
Incident Response Requirements in Indian Law (Vipul Kharbanda; December 28, 2016).
Mapping of India’s Cyber Security-Related Bilateral Agreements (Leilah Elmokadem and Saumyaa Naidu; December 29, 2016).
Mapping of Sections in India’s MLAT Agreements (Leilah Elmokadem and Saumyaa Naidu; December 31, 2016).

Event Organized

Multistakeholder Consultation on Encryption (Organized by CIS with ORF and Takshashila Institution; TERI, Bangalore; December 17, 2016).

Submission

CIS Submission to TRAI Consultation Note on Model for Nation-wide Interoperable and Scalable Public Wi-Fi Networks (Japreet Grewal, Pranesh Prakash, Sharath Chandra, Sumandro Chattapadhyay, Sunil Abraham, and Udbhav Tiwari, with expert comments from Amelia Andersdotter; December 12, 2016).

Research Paper

Mapping Digital Humanities in India (P.P. Sneha; December 30, 2016).

► Follow us elsewhere

Twitter: http://twitter.com/cis_india
Twitter - Access to Knowledge: https://twitter.com/CISA2K
Twitter - Information Policy: https://twitter.com/CIS_InfoPolicy
Facebook - Access to Knowledge: https://www.facebook.com/cisa2k
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CIS Submission to TRAI Consultation Note on Model for Nation-wide Interoperable and Scalable Public Wi-Fi Networks

2016-12-12T13:59:00Z

This submission presents responses by the CIS on the Consultation Note on Model for Nation-wide Interoperable and Scalable Public Wi-Fi Networks published by the TRAI on November 15, 2016. Our analysis of the solution proposed in the Note, in brief, is that there is no need of a solution for non-existing interoperability problem for authentication and payment services for accessing public Wi-Fi networks. The proposed solution in this Note only adds to over-regulation in this sector, and does not incentivise new investment in the sector, but only establishes UIDAI and NPCI as the monopoly service providers for authentication and payment services.

The comments were authored by Japreet Grewal, Pranesh Prakash, Sharath Chandra, Sumandro Chattapadhyay, Sunil Abraham, and Udbhav Tiwari, with expert comments from Amelia Andersdotter.

1. Preliminary

1.1. This submission presents responses by the Centre for Internet and Society (“CIS”) [1] on the Consultation Note on Model for Nation-wide Interoperable and Scalable Public Wi-Fi Networks (“the Note”) published by the Telecom Regulatory Authority of India (“TRAI”) on November 15, 2016 [2].

1.2. The CIS welcomes the effort undertaken by TRAI to map regulatory and other barriers to deployment of public Wi-Fi in India. We especially appreciate that TRAI has recognised [3] two key barriers to provision of public Wi-Fi networks identified and highlighted in our earlier response to the Consultation Paper on Proliferation of Broadband through Public WiFi [4]: 1) over regulation (including, licensing requirements, data retention, and Know Your Customer policy), and 2) paucity of spectrum [5].

2. General Responses

2.1. Before responding to the specific questions posed by the Note, we would like to make the following observations.

2.2. There is no need of a solution for non-existing interoperability problem for authentication and payment services for accessing public Wi-Fi networks. The proposed solution in this Note only adds to over-regulation in this sector. The proposed solution does not incentivise new investment in the sector, but only establishes UIDAI and NPCI as the monopoly service providers for authentication and payment services.

2.3. As the TRAI has consulted widely with industry and other stakeholders before it settled on the list of priority issues contained in Section C.6 of the Note, we are surprised to find that this Note aims to address only the problem of lack of “seamless interoperable payment system for Wi-Fi networks” (Section C.6.d. Of the Note), and does not discuss and propose solutions for any other key barriers identified by the Note.

2.4. The Note fails to clarify the “interoperability” problem in the payment system for usage of public Wi-Fi networks that it is attempting to solve. The Note identifies that lack of “single standard” for “authentication and payment mechanisms” for accessing public Wi-Fi networks as a key impediment to provide scalable and interoperable public Wi-Fi networks across the country [6]. By conceptualising the problem in this manner, TRAI has bundled together two completely different concerns - authentication and payment - into one and this is at the root of the problems emanating from the proposed solution in this Note.

2.5. Lack of standard process for authentication is created by over-regulation via Know Your Customer (“KYC”) policies, and selection of eKYC service provided by UIDAI as the only acceptable authentication mechanism for all users of public Wi-Fi networks across India, creating further economic and legal challenges for smaller would-be providers of public Wi-Fi networks as they assess their liabilities and start-up costs. Additionally, since this would amount to making UID/Aadhaar enrolment mandatory for any user of public wi-fi networks, it seems to create a contradiction with previously communicated policy from the UIDAI and the Government that no such obligation should arise. Supreme Court has also mandated over successive Orders that enrolment for UID/Aadhaar number should remain optional for the citizens and residents.

2.6. As was observed by the respondents to the TRAI Consultation concluded earlier this year, there is no interoperability problem that needs to be solved regarding payments for accessing public Wi-Fi networks. Payment services continue to be evolved and payment aggregator services provided by existing companies may be expected to resolve many of the outstanding issues of service proliferation in the upcoming years, at least in the absence of additional mandatory technical measures imposed by the government. Bundling of payment with authentication will only undermine the already existing independent market for payment aggregators, and further enforce mandatoriness of UID/Aadhaar number.

2.7. Further, the payment mechanism proposed would seem to worsen difficulties for tourists and foreigners in accessing public Wi-Fi in India, as well adds an additional layer of authentication in a system already identified (even in the Note itself) to be overburdened by regulations regarding KYC and data retention. Section C.6.b of the Note highlights the problems faced by foreigners and tourists when the authentication mechanism is premised upon use of One Time Password (OTP) that requires a functioning local mobile phone number. It contradicts itself later by proposing an authentication method that requires the user to not only download an application onto their mobile/desktop device, but also to enrol for UID/Aadhaar number and/or to use their existing UID/Aadhaar number. Instead of reducing the existing barriers to provision of and access to public Wi-Fi, which the Note is supposed to achieve, it creates significant new barriers.

2.8. The technological architecture advanced by the Note upholds support of governance and surveillance projects that, in addition to being costly in their implementation and thereby slowing down the objective of getting India connected, are also of questionable value to the security of the Indian polity. UID, UPI, and related projects risk undermining cyber-security through their reliance on centralised architectures and interfere with healthy competitive market dynamics between commercial and non-commercial actors.

2.9. The Note continues to only consider and enable commercial models for the provision of public Wi-Fi networks. We have identified this as a problematic assumption in our last submission [7]. It is most crucial that TRAI does not ignore and fail to promote and facilitate the possibility of not-for-profit models that involve grassroot communities, academia, and civil society.

2.10. Last but not the least, the term “Wi-Fi” refers to a particular technology for establishing wireless local area networks. Further, the term is a trademark of the Wi-Fi Alliance [8]. It is this not a neutral term, and it must not be used as a general and universal synonym for wireless local area networks. We recommend that TRAI may consider using a technology-neutral term, say “public wireless services” or “public networking services”, to describe the sector. Following the terminology used in the Note, we have decided to continue using the term “Wi-Fi” in this response. This does not reflect our agreement about the appropriateness of this term. Important: The recommendation for technology-neutral regulation also comes with the qualification that safeguards like regulations on Listen Before Talk and Cycle Time are required to prevent technologies like LTE-U from squatting on spectrum and interfering with connections based on other standards.

3. Specific Responses

Q1. Is the architecture suggested in the consultation note for creating unified authentication and payment infrastructure will enable nationwide standard for authentication and payment interoperability?

3.1. No. The proposed infrastructure is likely to be costly for a large number of actors to implement and undermine some of the ongoing innovation in the Indian digital payment services industry. Rather than being helpful, it risks introducing additional requirements on an industry that TRAI has already identified as facing a number of large challenges.

3.2. There is no need for a unified architecture that provides nationwide standard for authentication and payment interoperability. It does not offer any incentive towards provision of public Wi-Fi networks. Neither is there an interoperability problem at the physical or data link layers that has been pointed out, nor is government mandated interoperability required at the payment or ID layer since there are private entities that provide such interoperability (like, payment aggregators). Additionally, we believe it is inappropriate that the TRAI is trying to predict the most suitable business/technological model for digital payments to be used for accessing commercial Wi-Fi networks. India has a booming online payments industry, and it must be allowed to evolve in an enabling regulatory environment that allow for competition and ensures responsible practices.

3.3. The Note identifies several structural impediments to expansion of public Wi-Fi networks in India, namely paucity of backhaul connectivity infrastructure (Section C.6.a), Inadequate associated infrastructure to offer carrier grade Wi-Fi network (Section C.6.c), dependency of authentication mechanism on pre-existing (Indian) mobile phone connection (Section C.6.b), and limited availability of spectrum to be used for public Wi-Fi networks (Section C.6.e). All these are crucial concerns and none of them have been addressed by the architecture suggested in the Note.

Q2. Would you like to suggest any alternate model?

3.4. Yes. The model proposed in the Note is likely to exclude several types of potential users (say, foreigners and tourists), and impose a single authentication and payment service provider for accessing public Wi-Fi networks, which may undermine both competition and security in the market for these services.

3.5. Internationally, there are cities and regions (say, the city of Barcelona and the Catalonia region in Spain) where public Wi-Fi networks have been provided in a pervasive and efficient manner by taking a light regulatory approach that enables opportunities for potential providers to set up their own infrastructures and additionally have access to backhaul. Further, reducing legal requirements on authentication should be considered in place of government mandated technical architectures for authentication and payment. In particular, allowing for anonymous access to Public Wi-Fi or wireless connectivity would reduce both the administrative and the technical burden on potential providers at the hyper-local level, especially for providers whose main activity it is not, and cannot be, to provide internet services (say, event venues, malls, and shops).

3.6. The CIS suggests the following steps towards conceptualising an “alternative model”:

remove existing regulatory disincentives,
urgently explore policies to promote deployment of wired infrastructures in general, and to enable a larger range of actors, including local authorities, to invest in and deploy local infrastructures by reducing licensing requirements in particular,
examine spectrum requirements for provision of public Wi-Fi, and
provide incentives, such as allowing telecom service providers to share backhaul traffic over public Wi-Fi, and ways for telecom service providers to lower their costs if they also make Internet access available for free.

Q3. Can Public Wi-Fi access providers resell capacity and bandwidth to retail users? Is “light touch regulation” using methods such as “registration” instead of “licensing” preferred for them?

3.7. CIS holds that capacity and bandwidth are neither comparable to tangible goods nor to digital currency. They are a utility, and the provider of the utility has to accept that their customers use the utility in the way they see fit, even if that use entails sharing said capacity and bandwidth with downstream private persons or customers. Wi-Fi capabilities are currently a built-in standardised feature of all consumer routers. Any individual, community, or store with access to an internet connection and a consumer router could become a public Wi-Fi access provider at no additional cost to themselves, furthering the goals of the Indian government in its Digital India strategy to ensure public and universal access to the internet.

3.8. In order to exploit the opportunities awarded by a large amount of entities in the Indian society potentially becoming Public Wi-Fi providers, TRAI should require neither registration nor licensing of these actors. Imposing administrative burdens on potential public Wi-Fi access providers creates legal uncertainty and will cause a lot of actors, who may otherwise contribute to the goals of Digital India, not to do so. This is particularly true for community organisers and citizens, who may not have access to legal assistance and therefore may avoid contributing to the goals of the government.

3.9. Light touch regulation when it comes to both granting license to public Wi-Fi access providers as well as authentication of retail users, however, are needed not only as an exceptional practice for such instances but as a general practice in case of entities offering public Wi-Fi services, either commercially or otherwise. Further, additional laxity in administrative responsibilities is needed to incentivise provision of free, that is non-commercial, public Wi-Fi networks.

Q4. What should be the regulatory guidelines on “unbundling” Wi-Fi at access and backhaul level?

3.10. The Note refers to unbundling of activities related to provision of Wi-Fi but it does not define the term. It is neither explained which specific activities at access and backhaul levels must be considered for unbundling.

3.11. While unbundling should clearly be allowed and any regulatory hurdles to unbundling should be removed, any such decision must be taken with a focus on urgently addressing the stagnated growth in landline and backhaul, as identified in Section C.6.a of the Note. Relying only on spectrum intensive infrastructures, such as mobile base stations, for providing connectivity, creates a heavy regulatory burden for the TRAI, while simultaneously not ensuring optimal connectivity for business and private users. The CIS is concerned that the focus of the Note on standardising a government-mediated authentication and payment mechanism detracts attention from this urgent obstacle to the fulfillment of the Digital India plans of accelerated provision of broadband highways, universal access, and public, especially free, access to internet services.

3.12. From the example of European telecommunications legislations, implementation of policy measures to ensure that vertical integration between infrastructure (say, cables, switches, and hubs) providers and service (say, providing a subscriber with a household modem or a SIM card) providers in the telecommunications sector does not become a barrier to new market entrants has yielded much success in countries that have pursued it, like Sweden and Great Britain.

3.13. Further, there should be no default assumption of bundling by the TRAI. In particular, the TRAI should consider reviewing all regulations that may cause bundling to occur when this is not necessary, and put in place in a monitoring mechanism for ensuring that bundled practises (especially in electronic networks, base station infrastructures, backhaul and similar) do not cause competitive problems or raise market entry barriers [9]. In most EU countries, especially where the corporate structure of incumbent(s) is not highly vertically integrated, interconnection requirements for electronic network providers of wired networks in the backhaul or backbone (effectively price regulated interconnection), and a conscious effort to ensure that new market players can enter the field, have ensured a competitive telecommunications environment. TRAI may consider reviewing the European regulation on local loop unbundling (1999) and discussions on functional separation (especially by the British regulatory authority Ofcom), within an Indian context.

Q5. Whether reselling of bandwidth should be allowed to venue owners such as shop keepers through Wi-Fi at premise? In such a scenario please suggest the mechanism for security compliance.

3.14. Yes. Venue owners should be allowed to provide public Wi-Fi service both on a commercial and non-commercial basis.

3.15. It is not clear from the Note and the question what type of security concerns the TRAI is seeking to address. In terms of payment security, the payment industry already has a large range of verification and testing mechanisms. The CIS objects to the mandatory introduction of the proposed payment system so as to ensure greater security for Wi-Fi access providers and the users.

3.16. As far as hardware-related security issues are concerned, it is again unclear why consumer equipment compliant with existing Wi-Fi standards would not be sufficiently secure in the Indian context. Wi-Fi has proven to be a sturdy technical standard, its adoption is high in multiple jurisdictions around the world, and it also enjoys great technical stability. Similar security assessments could easily be made for alternative wireless technologies, such as WiMaX.

3.17. The CIS foresees problems is in the allocation of risk and liability by law. The already existing legal obligation to verify the identity of each user, for instance, is likely to introduce a large administrative burden on potential Public Wi-Fi providers, which may lead to such potential providers abstaining from entering the market. Should the identification requirement be removed, however, other concerns pertaining to legal obligations may arise. These include liability for user activities on the web or on the internet (cf. copyright infringement, libel, hate speech). We propose a “safe harbour” mechanism in these cases, limiting the liability of the potential public Wi-Fi provider.

Q6. What should be the guidelines regarding sharing of costs and revenue across all entities in the public Wi-Fi value chain? Is regulatory intervention required or it should be left to forbearance and individual contracting?

3.18. The market segments identified by the TRAI in Section F.18 of the Note should normally all be competitive markets themselves, and so do not require regulatory assistance in sharing of costs and revenues. The more elaborate the requirements imposed on each actor of each market segment identified by the TRAI in Section F.18, the more costly the roll-out of public Wi-Fi is going to be for the market actors. Such a cost is not avoided by price regulation.

3.19. The TRAI may instead consider introducing public funding for backhaul roll-out in remote areas, where the market is unlikely to engage in such roll-out on its own. Presently, some Indian states (such as Karnataka) are committing to public funding for wireless access in remote areas. The Union Government can assist such endeavours.

Endnotes

[1] See: http://cis-india.org/.

[2] See: http://trai.gov.in/Content/ConDis/20801_0.aspx.

[3] See Section C.6 of the Note.

[4] See: http://trai.gov.in/Content/ConDis/20782_0.aspx.

[5] See: http://cis-india.org/telecom/blog/cis-submission-to-trai-consultation-on-proliferation-of-broadband-through-public-wifi-networks.

[6] See Section E.11. of the Note.

[7] See: http://cis-india.org/telecom/blog/cis-submission-to-trai-consultation-on-proliferation-of-broadband-through-public-wifi-networks.

[8] See: https://www.wi-fi.org/.

[9] See: Monitoring bundled products in the telecommunications sector is also recommended by the OECD: http://oecdinsights.org/2015/06/22/triple-and-quadruple-play-bundles-of-communication-services-towards-all-in-one-packages/.

For more details visit https://cis-india.org/telecom/blog/cis-submission-trai-note-on-interoperable-scalable-public-wifi

Net subs grow significantly but public Wi-Fi idea flayed

praskrishna — 2016-11-21T13:55:18Z

Even as internet subscribers are growing significantly across Indian states, TRAI's idea of public Wi-Fi has been flayed by stakeholders.

This was published by Indian Television on November 21, 2016. Pranesh Prakash was quoted.

Maharashtra has recorded the highest number of internet subscribers in India at 29.47 million, followed by Tamil Nadu, Andhra and Karnataka in that order, according to government data. At the end of March 2016, India had a total of 342.65 million subscribers. BharatNet project meantime plans to connect all 2.5 lakh gram panchayats in the country through broadband.

Delhi had registered 20.59 million internet users, while Kolkata and Mumbai recorded 9.26 million and 15.65 million, respectively.

Tamil Nadu recorded 28.01 million subscribers, while the neighbouring states of Andhra Pradesh and Karnataka respectively registered 24.87 million and 22.63 million. Himachal Pradesh saw the lowest number of subscribers at 3.02 million.

Of the over 342 million subscribers, over 67 per cent are from urban India. At the end of FY16, the rural internet subscriber base stood at 111.94 million. Tamil Nadu recorder the highest number of urban subscribers at 21.16 million, while UP (East) telecom circle is ahead in terms of rural internet customer base at 11.21 million.

Public Wi-Fi condemned

Telecom stakeholders recommending an open and cheap internet have raised concerns over privacy and regulatory hurdles following the release of TRAI's consultation paper on public Wi-Fi.

The Internet Freedom Foundation co-founder Aravind Ravi Sulekha was apprehensive that the proposed regulations could lead to invasion of privacy and interfere with the freedom of hotspot providers to operate freely. The proposals may turn out to be regressive, Sulekha said.

TRAI proposed hotspot providers would have to register with the government and users could access hotspots only after paying using a service tied to their Aadhaar number.

Centre for Internet and Society policy director Pranesh Prakash said that TRAI solution was a classic example of over-regulation and centralism. It turns out that TARI was unclear about the problem to be solved, he added.

For more details visit https://cis-india.org/telecom/news/indian-television-november-21-2016-net-subs-grow-significantly-but-public-wifi-idea-delayed

Free data, net neutrality: Discussion on TRAI paper

praskrishna — 2016-10-25T01:34:13Z

Given the complicated issues around net neutrality, an open house discussion was held in Hyderabad on October 24, 2016 on Telecom Regulatory Authority of India’s consultation paper on free data. The event was organized by TRAI. Udbhav Tiwari attended the open house discussion.

The consultation paper by TRAI can be found here. I largely espoused the position put forth by CIS in its Written Comments submitted to TRAI in June, 2016 which can be found here. The TRAI open house discussion was attended by:

Telenor
Reliance Communications Ltd.
Idea Cellular
Aircel
COAI & AUSPI
IAMAI
Datami
Internet Freedom Foundation

There was also a seminar on Unsolicited Downloads & Background Exchange organised by TRAI and IIT Hyderabad. The participants in the seminar were:

Venki Nishtala, CTO, Rediff.com
Ashwani Rana, Head of Connectivity & Access Policy, Facebook
Sachin Yadav, Director Forensic Services, PWC
Vijay Kolli, Head Mobile Strategy and Market Development, Akamai India
Dr. Abhinav Kumar, Assistant Professor, IIT Hyderabad

Also see the report on Indian Television

For more details visit https://cis-india.org/telecom/news/free-data-net-neutrality-discussion-on-trai-paper

Seminar on Quality of Services in Telecom and Data Services: Issues, Challenges and Solutions

praskrishna — 2016-10-19T02:15:43Z

National Institute of Public Finance and Policy, New Delhi, National Institute of Public Finance and Policy, New Delhi organized a seminar on quality of services in telecom and data in Delhi on September 21, 2016. Shyam Ponappa was a speaker.

CUTS and IIT have recently published a report on quality of services in mobile data services, which is available here. The aim of the organizers was to bring together a diverse group of stakeholders to generate a debate on the findings of the study. This will be followed by a broader discussion on the next steps towards achieving better QoS in telecom and data services. For agenda of the meeting, click here.

Video

For more details visit https://cis-india.org/telecom/news/seminar-on-quality-of-services-in-telecom-and-data-services-issues-challenges-and-solutions

A Market Structure for Digital India

Shyam Ponappa — 2016-10-10T02:09:06Z

If delivery is priced below cost, communications services will be unsustainable and ineffective. The stress in the telecom sector is evident from the data. The market capitalisation of listed telecom operators has been stagnant since the 3G auction in 2010, while the government collected Rs 2.83 lakh crore of non-tax charges from them.

The article originally published in the Business Standard on October 5, 2016 was mirrored in Organizing India Blogspot on October 9, 2016.

In March 2010 before the auction, the capitalisation was Rs 1.84 lakh crore; in March 2016, it was Rs 1.71 lakh crore, with the BSE Sensex up nearly 60 per cent. A larger share of earnings has gone to government rather than shareholders, and also to banks as interest (Rs 2.08 lakh crore). The irony is that no operator has bid so far for the most useful spectrum bands on auction, 700 and 900 MHz. Uncertainties abound, and there are several questions.

Reliance Jio's entry, although expected, is a jolt. Will voice calls priced below mandatory interconnect charges be treated as being predatory or anticompetitive? The technicality is that Jio doesn't have high market share, apparently a criterion under competition law. Will this hold, given that Jio's entry has reduced total market capitalisation? Will delivery capability in terms of network size and/or market power from associated businesses be relevant criteria for dominance? What happens when Jio does have sizeable market share?

On the face of it, lower prices seem better for users. Look more closely and it's not so simple, especially when you consider other services in India offered for free or at highly subsidised rates. One issue is the structure of a market that supports delivery below cost, and its quality of services/products. Another is the criterion that maximises social welfare that should drive government's policies. Is consumer surplus in the short term a reasonable criterion? As it happens, we have experienced markets with constrained consumer surplus for years. For example, in the category of infrastructure and essential inputs/utilities, we've had this approach towards fertilisers, electricity, petroleum products like kerosene, cooking gas and diesel until recently, water, and sewerage. We've also experienced this in our entire range of manufactured products earlier, when we had exorbitant import barriers. These experiences have been less than sanguine. The misuse of kerosene and gas, and the effects of diesel subsidies are prominent examples. The distortions that have set in, such as overuse of ground water and fertilisers, and the vicious circle with electricity and diesel generators, will be difficult to correct.

Aren't there similar deleterious effects in communications from spectrum auctions and government charges that inflate input costs, and price wars that degrade investment capacity for network extension and delivery? As it is, the quality of services for voice and data is very poor. An essential resource for better connectivity is spectrum, yet government's approach to its management has been and remains inimical to its stated objective of achieving ubiquitous access of good quality. Governments make it difficult for operators to extend networks simply by not setting the right administrative policies. To quote Google Vice-President Caesar Sengupta: India is "a very large country with very little spectrum". It does not seem clear to our governments that broadband access through fixed lines for everyone is infeasible in the foreseeable future. Also, that unless radical changes are made, it is inconceivable that broadband servcies can be made available at prices and quality comparable to TV.

The Triad of Interests

Even if the criterion for public welfare is user benefits/consumer surplus, judging by price alone is simplistic, because it misses other aspects of service delivery that contribute to the cost-benefit package. One essential aspect is ubiquitous access. Another is effective, consistent service delivery, which requires quality, and stability. A third is the period or life cycle. It doesn't help if you have an inexpensive product or service today, and nothing tomorrow. The definition of long term also varies, depending on one's perception of the life-cycle cost of the product/service. For a user, it may be several years, or his/her life cycle. For a society, it may mean generations.

In addition to consumer benefits, other factors need to be considered from the perspectives of pragmatism and realpolitik. Realistically, a triad of stakeholder interests has to be balanced for a sustainable beneficial outcome. These are: consumer and producer surplus, and what might be termed "government interests" in the broadest sense defined below. The latter has been manifest in many global spectrum auctions, and although detrimental to the sector, is an aspect of reality that cannot be wished away. For example, our governments preferred rationing and auctions to more constructive approaches such as sharing infrastructure, and when the Supreme Court ruled that resources need not be auctioned, spectrum was excluded, which seems logically indefensible. For sustainable, consistent services, champions of all three criteria must partner to adopt mutually acceptable solutions.

Assumptions about Enabling Policies

Certain basic amenities comprise the essential infrastructure that everyone needs to be productive and have reasonable well-being. To some extent, this is linked to reasonably high per capita income. Without it, broad access to good infrastructure is infeasible. It takes that level of organisation, institutions and investment, including its implications for developing and organising human capital, to build such capabilities, as in Organisation for Economic Cooperation and Development (OECD) countries. Emerging economies have to manage with lower order platforms, or a subset of higher order services combined with others of lower order. Prioritisation then becomes the key, and areas of emphasis have to be chosen. This is where the priority accorded to Digital India comes in. If digital systems are crucial facilitators for development and productivity, they need to be accorded that level of importance and effort, with substantive changes to policies.

The government sets the policies and incentives. Government here means not just the central government and the states' executives, but the gamut of regulatory and government agencies: the legislature, the regulators, and the judiciary. These agencies must converge and persuade public opinion to support action in the public interest. Ultimately, society has to pay. If delivery is priced below cost in communications, the services will be as unsustainable and ineffective as in other distorted sectors with freebies.

Reference: Krishna Kant: http://www.business-standard.com/article/economy-policy/spectrum-fees-leave-no-money-in-shareholders-pockets-116092701398_1.html, Business Standard, September 28, 2016. The author can be contacted at shyamponappa@gmail.com

For more details visit https://cis-india.org/telecom/blog/business-standard-october-5-2016-shyam-ponappa-a-market-structure-for-digital-india

Digital India Needs These Policy Changes

Shyam Ponappa — 2016-10-02T10:09:17Z

Appropriate policies will increase connectivity much more than spectrum auctions.

The article originally published in the Business Standard on August 31, 2016 was mirrored in Organizing India Blogspot on September 1, 2016.

There's a "List of 10 Things" for realising India's potential that Prime Minister Narendra Modi received as the chief minister of Gujarat from Jim O'Neill, the originator of the "BRIC" concept. Many items on that list are greatly facilitated by information and communications technology (ICT): effective governance; primary, secondary, and tertiary education; improved infrastructure; and sustainable approaches that minimise negative environmental impact. While there's agreement on ICT's importance for India, there's difficulty getting it in place to best effect. This is because policy changes are needed to make Digital India a reality. These are the kinds of decisions that will turn the rhetoric about connectivity into reality.

Some changes are relatively easy, such as enabling 60 GHz Wi-Fi, while others require more effort, as explained below. These include better terms for satellite communications, enabling broadband on the 500-600 MHz bands, and spectrum and network sharing.

In our land of such range and contradictions, so much needs improvement that everything clamours for immediate attention. Attempts to address them all together are misplaced, however, because achieving results requires goal orientation, prioritisation and systematic action, to direct a convergent investment of time, effort and capital. Also, projects must be done with the realisation that the acid test is end-to-end delivery, even if it is initially to a small segment of the market. Only then can the rest of the iceberg be addressed: consistent, ongoing operation and maintenance, and scaling up. Think of the years of effort, capital and human resources invested without that first delivery in the National Optic Fibre Network. While defining objectives appropriately and setting priorities are difficult, both are imperative.

A recent report on The Networked Society City Index for 2016 by Ericsson reaffirms ICT's critical role in productivity and living standards.1 The report also shows that better-developed cities are on more sustainable paths to the goal of the desirable triple bottom line (TBL) of social, economic and environmental betterment. ICT facilitates not only sustainable development of cities and often their surroundings, but extends through the networked society far beyond their geographical environs. Even our metros need attention, with Mumbai and Delhi ranking at 36 and 38 out of 41.

The Wireless Imperative

Efforts at setting up Digital India have to contend with the reality that most non-urban communications have to be wireless, as does a significant proportion of urban access. This is because the cost and practical difficulties in laying and maintaining fibre everywhere is far greater than building wireless networks. The accompanying chart, showing the spread of broadband in India at the end of March 2016, illustrates this point.

The clusters are around major cities, with broadband penetration in Delhi/NCR highest at 58.2 per cent. Except along their major connecting links, the spaces between clusters are more difficult to connect and aggregate, as habitations are not densely clustered. Also, potential revenues are generally lower in less dense areas. Such areas urgently need lower-cost wireless coverage.

Policy Changes Required - from Easy to Difficult

Of the many constraints to building more accessible ICT in India, a major set lies within the control of government and stakeholders, provided they act together and are not adversarial about policies governing access technologies:

There are unused frequencies in the 60 GHz band for which inexpensive equipment is available abroad with a capacity of several gigabits. Press reports years ago mentioned the de-licensing of this band in India. Last November, the Telecom Regulatory Authority of India (TRAI) recommended de-licensing Wi-Fi use, and light licensing backhaul with minimal charges. Yet, this asset is wasted because there's no policy permitting its use. It costs nothing to de-license in line with global norms. Apart from additional Wi-Fi capacity, service providers could use it for backhaul from small cells. Revenues are likely to rise, and the government would collect increased taxes. Domestic manufacturers could possibly develop products for what should be a huge market.
Another proven technology is satellite communications. This is priced too high in India, as explained in "Satellite communications can drive the broadband revolution", Business Standard, 23 April 2016.2 Satcom tariffs are apparently nearly 300 times higher than in the US, while private sector applications for manufacturing satellites are languishing. Also, there is considerable potential for manufacturing associated equipment, such as VSATs, end-user terminals, and so on.
A third area is unused or underutilised government spectrum. The most-useful and least-controversial, except for turf considerations, is unused broadcast spectrum in the sub-700 MHz bands. Government departments, namely, the department of telecommunications (DoT), the Ministry of Information and Broadcasting (I&B), the Department of Electronics and Information Technology (DeITY), and the Trai, could coordinate their approach, so that I&B and Doordarshan retain the spectrum, while allowing common access to shared spectrum and infrastructure for paid use by service providers. Doordarshan could increase its reach by providing programming and content over these links.
These frequencies would be most effective in extending rural broadband, because of the distances that could be covered inexpensively. There is an issue with equipment, as there are no large, established markets anywhere yet for TV White Space devices, and there is insufficient support for local manufacturing even with Indian intellectual property rights. In fact, we have a Catch-22 situation here: such devices are likely to have massive deployment in India, but we don't have policies that allow these frequencies for broadband. The irony is that developers who manufacture prototypes in India have no access to spectrum even for testing their products, and will have to rely on markets abroad for testing as well as sales.

Other Frequencies

Rules restricting usage of other frequencies could also be amended through a coordinated process. The result could be policies that treat spectrum usage as part of a shared infrastructure solution for Digital India. Using a shared access for payment approach with secondary sharing, primary holders of spectrum can retain usage rights, while government revenues accrue from swathes of spectrum that now remain unused, and holders of spectrum earn from common access.

For more details visit https://cis-india.org/telecom/blog/business-standard-september-1-2016-shyam-ponappa-digital-india-needs-these-policy-changes

CIS Submission to TRAI Consultation on Proliferation of Broadband through Public WiFi Networks

Sunil Abraham, Sharath Chandra Ram, Vidushi Marda, and Thejaswi Melarkode — 2016-10-02T06:16:46Z

The Centre for Internet and Society (“CIS”) is grateful for the opportunity to comment on this Consultation Paper (“Paper”). The comments were prepared by Sunil Abraham, Sharath Chandra Ram, Vidushi Marda, and Thejaswi Melarkode. Special thanks to Shyam Ponappa and Arjun Venkatraman for their inputs and feedback.

Preliminary Comments

Even in the early to mid-seventies, many Indians who wanted to own a radio receiver were expected to get a license from the government. If not then they were in violation of the law and there was nothing the government could do to enforce policies for their benefit. The deregulation of radio ownership has been key to its unfettered adoption and popularity today. Similarly, Wi-Fi, a radio transceiver must be deregulated further to bridge India's digital divide.

Before addressing specific questions posed by the Paper, we would like to make the following observations:

The Paper considers only commercial models for the provision of public Wi-Fi networks. This is a problematic assumption as it ignores the potential of not-for-profit models that involve grassroots communities, academia and civil society.
The Paper is infused with a vision and philosophy that is reminiscent of a colonial, license raj, centralized, top-down, command and control based, state monopoly paradigm. This is diametrically opposed to the foundational ethos of the Internet.
The Paper assumes that more regulation is required in order to ensure mass adoption of public Wi-Fi. In fact, the exact opposite is true - the rapid proliferation of broadband through public Wi-Fi networks will only be accomplished by aggressive deregulation.
The technological architecture being advanced by the Paper signals support of governance cum surveillance projects such as Aadhaar aka UID, India Stack, UPI and related projects which only undermine cyber-security and interferes with healthy competitive market dynamics between commercial and non-commercial actors. Again this is diametrically opposed to the foundational ethos of the Internet and a modern democratic information society.

Q1. Are there any regulatory issues, licensing restrictions or other factors that are hampering the growth of public Wi-Fi services in the country?

The most pressing issue which is hampering the growth of public Wi-Fi services in the country is that of over regulation. Under the current regulatory framework, public Wi-Fi is subject to licensing requirements, data retention, and Know-Your-Customer ("KYC") policies. The next issue is paucity of spectrum. So far the approach has been to assign exclusive property rights to certain frequencies and also raise billions of US Dollars through spectrum auctions based on the Supreme Court's understanding of spectrum as a national resource. Given the advancements in transceiver technologies, such as cognitive radios, it is possible for us to transcend the grid-lock of property rights and embrace paradigms like shared and unlicensed spectrum. Innovative technologies and neutral allocation of unlicensed spectrum will result in the growth of public and community wireless networks including those built on the Wi-Fi standard.

Q2. What regulatory/licensing or policy measures are required to encourage the deployment of commercial models for ubiquitous city-wide Wi-Fi networks as well as expansion of Wi-Fi networks in remote or rural areas?

The regulatory approach should be to deregulate the radio transceiver as much as possible so as to encourage innovation with lower barriers for participation.

The question falsely assumes that only commercial players can provide public Wi-Fi, Para 1.9 of the Paper only identifies scenarios where Unified License (UL) holders can take advantage of unlicensed spectrum to provide public Wi-Fi services. It fails to recognize that civil society, academia, and grassroots communities can also bring about ubiquitous city-wide Wi-Fi networks and expansion to remote and rural areas. For example, Village Telco and mesh networks are community-driven Wi-Fi models that are allowing a large number of individuals to gain access to Internet services using a public spirited or peer-to-peer philosophy.^{^[1]}

In terms of regulatory measures, CIS would recommend minimal and proportionate regulation, i.e. the regulation of entities involved in the provision of public Wi-Fi networks based on their capacity to harm the public interest and/or individual rights. By this we mean that only public Wi-Fi networks that have a large number of users (say, more than 5,000 individual users) should be subject to any regulation. Small-scale public Wi-Fi network providers, like public Wi-Fi networks in small villages or apartment complexes, should be left to self-regulation. Regulatory burdens which serve no purpose only deter these providers from providing such services at all.

Regulation must be technology-neutral, and should focus on the entities using these technologies who are capable of unlocking good or causing harm. This neutrality should be reflected in the name of the policy: "community-networking policy" and not "community Wi-Fi policy". The necessary changes must also be incorporated in the Paper and the draft policy to make this clear. The current definition of Wi-Fi is closely coupled with certain frequencies, and public wireless networks should be promoted regardless of technology and specific frequency bands.

In cases where private data services, (such as mobile telephony/ other private application specific data infrastructures) which may have been granted permission to deploy on an open-unlicensed or delicensed part of the spectrum, experience interference from a Public Wi-Fi setup. On the same frequency band, we call for the Public Wi-Fi to be given priority. This will prevent spectrum squatting.

Q3. What measures are required to encourage interoperability between the Wi-Fi networks of different service providers, both within the country and internationally?

This is a requirement for elite parts of society only but not a deal breaker for the provision of public Wi-Fi in India. There are a variety of existing market-based approaches. The further deregulation of Wi-Fi will result in the rise of public, community and non-commercial players which in turn will lead to further innovation and competition when it comes to interoperability across disparate Wi-Fi networks and providers.

Q4. What measures are required to encourage interoperability between cellular and Wi-Fi networks?

No measures are required. Millions of consumers in India already are able to interoperate between cellular networks and their home and office networks as they are in charge of the authentication or they have left these networks open. The reason they are unable to operate more easily with other networks is due to data retention, and KYC policies. Even in countries with much more challenging national security concerns, the data retention and KYC policies are not so strict. We are paying a terrible price in terms of broadband adoption because of our flawed approach to surveillance and cyber security. The answer here lies in deregulation of existing requirements, especially for community based organisations, NGOs, research institutions, educational institutions, galleries, museums, archives and public libraries. This will address the needs of those who cannot pay and are vulnerable. For those who can pay - commercial actors will innovate and provide the high-quality interoperability that they seek - this will not require any action on the part of the government.

Q5. Apart from frequency bands already recommended by TRAI to DoT, are there additional bands which need to be de-licensed in order to expedite the penetration of broadband using Wi-Fi technology? Please provide international examples, if any, in support of your answer.

In a 2012 policy brief on unlicensed spectrum^{^[2]}, CIS recommended the changes, listed below [in italics]. Since then, more modern approaches may have emerged which merit revisiting this question. These advances also merit delicensing bands more aggressively as the proprietary approach becomes more and more dated. This approach should also be technology neutral and must find a balance between proprietary, unlicensed, and shared spectrum.^{^[3]}

Frequencies in the 6, 11, 18, 23, 24, 60, 70, and 80 GHz bands, to facilitate replicating examples like Webpass (USA) which has radios capable of delivering up to 2Gbps both upstream and downstream.^{^[4]}
Frequencies in the 5.15 GHz-5.35 GHz bands, as well as 5.725-5.775 GHz bands are unlicensed for indoor use only. These bands should be unlicensed for outdoor use as well in order to facilitate the creation of wider wireless communication networks and the use of innovative technologies.
There should be more unlicensed spectrum in the 2.4 GHz range, beyond what is already unlicensed, for the expansion of wireless communication networks.
The 1800-1890 MHz band, which is earmarked for the operations of low power cordless communication in India, should be unlicensed in line with international practices. Many bands for this use have already been unlicensed in Europe and the United States. ^{^[5]}
50 Mhz in the 700Mhz - 900Mhz band, earmarked for broadcast should be made available to better utilize available spectrum, almost 100Mhz is currently unused in most parts of the country.

Q6. Are there any challenges being faced in the login/authentication procedure for access to Wi-Fi hotspots? In what ways can the process be simplified to provide frictionless access to public Wi-Fi hotspots, for domestic users as well as foreign tourists?

The challenge here is that of over regulation and the belief that elaborate KYC requirements will solve problems of national security. What these requirements achieve is a lot of inconvenience for the general population while criminals are able to evade detection through fake IDs, burner phones, etc. as KYC requirements only create barriers without security payoffs. The fact that jurisdictions such as the UK, and other countries in Europe allow for purchase of SIM cards without KYC norms goes to show that there are effective ways of gathering intelligence that do not involve a KYC regime.

In terms of authentication, a healthy ecosystem will allow for both anonymous access to Wi-Fi hotspots as well as access through authentication.

There is a need for deregulation in order to allow anonymous access. For access through authentication, some providers may wish to have light KYC norms whereas others may choose to have rigorous KYC norms that are integrated with Aadhaar, India Stack, etc. The decision should ultimately be taken by the provider and thus deregulation is the key. The most frictionless model is the unauthenticated model that allows anonymous access, followed by a light KYC regime, and the model with the most friction is that with intensive KYC requirements.

The existing customer log-in procedure requirements that have been laid down by the Department of Telecommunications (DoT), Ministry of Communications, Government of India, which necessitate a user to provide a photo ID or to avail a one-time password (OTP) through SMS should be done away with for two reasons. First, it does not allow for a user to access the public Wi-Fi network without authentication and this leads to a loss of anonymity over that network when the user accesses any Internet-based services. Secondly, it assumes that all people will have access to mobile phones/smartphones. So far as the Indian scenario is concerned, this is certainly not the case in many households where only the head of the family, who is more often than not a male member, has access to such devices. Many individuals also use much simpler devices which may not be able to receive OTPs (see Raspberry Pi models, for example). Such a requirement would, in effect, deprive a large number of individuals from accessing public Wi-Fi services and would defeat the purpose of even setting up such networks.

Q7. Are there any challenges being faced in making payments for access to Wi-Fi hotspots? Please elaborate and suggest a payment arrangement which will offer frictionless and secured payment for the access of Wi-Fi services.

This question is backed by three assumptions. First, it assumes that only commercial provision of Wi-Fi is possible. Second, it assumes that "a (singular) payment arrangement" is the preferred approach. Third, it assumes that it is possible for regulators to predict the most appropriate business / technological model for payments online. This is best left to competition between commercial and noncommercial players in the market. The existing regulations from the RBI and laws that govern electronic transactions are sufficient. No specific regulations are required for access to Wi-Fi hotspots.

Q8. Is there a need to adopt a hub-based model along the lines suggested by the WBA, where a central third party AAA (Authentication, Authorization and Accounting) hub will facilitate interconnection, authentication and payments? Who should own and control the hub? Should the hub operator be subject to any regulations to ensure service standards, data protection, etc.?

"A central third party AAA (Authentication, Authorization and Accounting) hub" is antithetical to the foundational ethos of the Internet. Any attempt to foist that on Indian citizens will lead to a slowing down of wireless broadband adoption. From a cyber-security perspective this can only lead to large-scale and irreversible disasters and on the contrary policy measures should be taken to prevent centralization. For Indian cyberspace to be a resilient and free market, competition amongst both commercial and noncommercial players must be enabled for Authentication, Authorization and Accounting.

Q9. Is there a need for ISPs/ the proposed hub operator to adopt the Unified Payment Interface (UPI) or other similar payment platforms for easy subscription of Wi-Fi access? Who should own and control such payment platforms? Please give full details in support of your answer.

As we submitted in response to the earlier question: "a central third party AAA (Authentication, Authorization and Accounting) hub" is antithetical to the foundational ethos of the Internet. Aadhaar aka UID, India Stack and the Unified Payment Interface (UPI) are similar state sanctioned monopolies that only increase fragility and interfere with the functioning of markets. Also this question assumes that citizens will have to pay for access to WiFi. Therefore, we recommend that the government does not regulate payments beyond the existing measures in Banking Law.

Q10. Is it feasible to have an architecture wherein a common grid can be created through which any small entity can become a data service provider and able to share its available data to any consumer or user?

The government or the regulator should not be making recommendations on technical architectures. All that is required to the lift all limits on reselling or sharing data via law.

Q11. What regulatory/licensing measures are required to develop such architecture? Is this a right time to allow such reselling of data to ensure affordable data tariff to public, ensure ubiquitous presence of Wi-Fi Network and allow innovation in the market?

CIS would ask for forbearance in this regard, as anything else will be a case of over regulation.

Q12. What measures are required to promote hosting of data of community interest at local level to reduce cost of data to the consumers?

There are two measures that can be taken. The first is to change the public procurement policy to promote openness in the form of free and open source software, open standards, open content, open access, open educational resources and open data.

The second is to use public funds to shape the market and create publicly licensed material, or material available under exceptions and limitations of copyright law. To promote hosting data of community interest at a local level, public funds must be used to create intellectual property that can be freely licensed to the public. India already has a progressive copyright law, and the exceptions available under it should be seeded by the government through public funding. These exceptions include the statutory exception of copyright cess/ levy to broadband bills, exceptions for the disabled, libraries and archives and also education.

Q13. Any other issue related to the matter of Consultation.

Figure 2.2 of the Paper depicts Wi-Fi Monetization Pyramid based on Cisco's Wi-Fi Opportunity Pyramid.[2] As pointed out earlier, this ignores the possibility of non-commercial models. To quote Bruce Schneier, "surveillance is the business model of the Internet" ^{^[6]} and this business model is one that should not be encouraged. The pyramid only allows for a for-profit model and it is inherently based on needless surveillance of users. While monetization may be one of the main incentives, it is by no means the only way to sustain such public Wi-Fi networks and for this reason, CIS recommends that such a depiction be discarded.

The balancing of this monetization pyramid is one of the requirements to put in place an effective public Wi-Fi network structure. Another issue arises with respect to the definition of Wi-Fi. Currently, spectrum is limited to the 2.4 GHz or the 5 GHz bands but this has been expanded upon to encompass the LTE (4G) Core during the GSMA, Wireless Broadband Alliance and Wi-Fi Alliance 3GPP following the Mobile World Congress in 2013. Such a set-up would allow for frequency hopping between bands and to prevent (or allow) this, the definition of Wi-Fi in the context of public Wi-Fi networks must be clarified.

^{^[1]} See Centre for Internet and Society, Unlicensed Spectrum Brief for the Government of India, June 2012; Available at http://cis-india.org/telecom/unlicensed-spectrum-brief.pdf

^{^[2]} Supra note 1.

^{^[3]} Example of shared spectrum being advanced in the US: " Specifically, the FCC adopted rules for CBRS, opening 150 MHz of spectrum in the 3550-3700 MHz band for commercial use. A Spectrum Access System (SAS), which is now in the process of being hammered out at the FCC with prospective coordinators, will make it possible to share spectrum where it hasn't been done before ." See, Monica Alleven, "Google, Intel, Nokia and more partner to advance U.S. 3.5 GHz CBRS", Fierce Wireless, (February 18, 2016) available at http://www.fiercewireless.com/tech/google-intel-nokia-and-more-partner-to-advance-u-s-3-5-ghz-cbrs .

^{^[4]} " Webpass buildings have radios capable of delivering up to 2Gbps both upstream and downstream… Anything beyond 5,000 meters will still work but you lose bandwidth… Webpass radios operate in many different frequencies, including the unlicensed 2.4GHz and 5GHz bands used by Wi-Fi, Barr said. Webpass also uses the 6, 11, 18, 23, 24, 60, 70, and 80GHz bands. These include a mix of licensed and unlicensed frequencies…" See, Jon Brodkin, "500 Mbps broadband for $55 a month offered by wireless ISP", arsTECHNICA, (June 18, 2015), available at: http://arstechnica.com/information-technology/2015/06/500mbps-broadband-for-55-a-month-offered-by-wireless-isp/

^{^[5]} Supra note 1, at 17.

^{^[6]} See Bruce Schneier, 'Stalker economy' here to stay, CNN, (Nov. 26, 2013, 17:53 GMT), available at http://edition.cnn.com/2013/11/20/opinion/schneier-stalker-economy/index.html

For more details visit https://cis-india.org/telecom/blog/cis-submission-to-trai-consultation-on-proliferation-of-broadband-through-public-wifi-networks

Centre for Internet and Society

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December 2016 Newsletter

CIS Submission to TRAI Consultation Note on Model for Nation-wide Interoperable and Scalable Public Wi-Fi Networks

1. Preliminary

2. General Responses

3. Specific Responses

Q1. Is the architecture suggested in the consultation note for creating unified authentication and payment infrastructure will enable nationwide standard for authentication and payment interoperability?

Q2. Would you like to suggest any alternate model?

Q3. Can Public Wi-Fi access providers resell capacity and bandwidth to retail users? Is “light touch regulation” using methods such as “registration” instead of “licensing” preferred for them?

Q4. What should be the regulatory guidelines on “unbundling” Wi-Fi at access and backhaul level?

Q5. Whether reselling of bandwidth should be allowed to venue owners such as shop keepers through Wi-Fi at premise? In such a scenario please suggest the mechanism for security compliance.

Q6. What should be the guidelines regarding sharing of costs and revenue across all entities in the public Wi-Fi value chain? Is regulatory intervention required or it should be left to forbearance and individual contracting?

Endnotes

Net subs grow significantly but public Wi-Fi idea flayed

Public Wi-Fi condemned

Free data, net neutrality: Discussion on TRAI paper

Seminar on Quality of Services in Telecom and Data Services: Issues, Challenges and Solutions

Video

A Market Structure for Digital India

The Triad of Interests

Assumptions about Enabling Policies

Digital India Needs These Policy Changes

CIS Submission to TRAI Consultation on Proliferation of Broadband through Public Wi­Fi Networks

Preliminary Comments

Q1. Are there any regulatory issues, licensing restrictions or other factors that are hampering the growth of public Wi-Fi services in the country?

Q2. What regulatory/licensing or policy measures are required to encourage the deployment of commercial models for ubiquitous city-wide Wi-Fi networks as well as expansion of Wi-Fi networks in remote or rural areas?

Q3. What measures are required to encourage interoperability between the Wi-Fi networks of different service providers, both within the country and internationally?

Q4. What measures are required to encourage interoperability between cellular and Wi-Fi networks?

Q5. Apart from frequency bands already recommended by TRAI to DoT, are there additional bands which need to be de-licensed in order to expedite the penetration of broadband using Wi-Fi technology? Please provide international examples, if any, in support of your answer.

Q6. Are there any challenges being faced in the login/authentication procedure for access to Wi-Fi hotspots? In what ways can the process be simplified to provide frictionless access to public Wi-Fi hotspots, for domestic users as well as foreign tourists?

Q7. Are there any challenges being faced in making payments for access to Wi-Fi hotspots? Please elaborate and suggest a payment arrangement which will offer frictionless and secured payment for the access of Wi-Fi services.

Q9. Is there a need for ISPs/ the proposed hub operator to adopt the Unified Payment Interface (UPI) or other similar payment platforms for easy subscription of Wi-Fi access? Who should own and control such payment platforms? Please give full details in support of your answer.

Q10. Is it feasible to have an architecture wherein a common grid can be created through which any small entity can become a data service provider and able to share its available data to any consumer or user?

Q11. What regulatory/licensing measures are required to develop such architecture? Is this a right time to allow such reselling of data to ensure affordable data tariff to public, ensure ubiquitous presence of Wi-Fi Network and allow innovation in the market?

Q12. What measures are required to promote hosting of data of community interest at local level to reduce cost of data to the consumers?

Q13. Any other issue related to the matter of Consultation.

CIS Submission to TRAI Consultation on Proliferation of Broadband through Public WiFi Networks