Centre for Internet and Society

TRAI Consultation on Differential Pricing for Data Services - Post-Open House Discussion Submission

sumandro — 2016-03-30T13:13:30Z

The Centre for Internet and Society sent this submission to the Telecom Regulatory Authority of India (TRAI) following the Open House Discussion on Differential Pricing of Data Services, held in Delhi on February 21, 2016.

Download the submission document: PDF.

Post-Open House Discussion Submission to TRAI

Dear Ms. Kotwal,

This is to heartily congratulate TRAI once again for taking several steps, including the Open House Discussion, to ensure that various opinions about the topic of ‘differential pricing for data services’ are presented and are responded to - and are all in full public view.

This brief note is to a) add to the positions and arguments submitted previously by the Centre for Internet and Society (CIS), India, b) put in writing our comments during the Open House Discussion (January 21, 2016), and c) respond to other comments shared at the same event. We have six points to share in this note:

Forbearance is not an option: We are of the opinion that though the data services market has thus far been kept un-monitored and unregulated, and there are several reasons why this situation should not continue any more. Although the reality of differential pricing (that is data packets originating from different sources being priced differently by ISPs) was highlighted with the recent offering of zero rated packs, it is a general practice in the sector, as illustrated by widely available special/curated content packs for the user to consume data from a specified web-based source. It is not surprising that most such special/curated content packs involve an arrangement between the ISP and a prominent leader in the web-content/platform sector, such as Facebook and Twitter. Serious market distorting impacts of such arrangements are imminent if they are allowed to continue without any monitoring, enforced public disclosure, and regulatory actions by a public authority.
Address differential treatment of data, and not only differential pricing: Pricing is only of the three ways in which data services can be treated differently by the ISPs depending upon the source of the data packets concerned. The other two ways are: a) differential speed, or throttling of some data packets and prioritisation of the others, and b) differential treatment of data protocols, for example, the blocking of peer-to-peer or voice-over-IP traffic by an ISP. If the public authority decides to only regulate differential pricing of data service, it is highly probable that ISPs may shift to other forms of discrimination between data packets - either in terms of prioritising some data packets over others based upon their origin, or blocking of specific protocols such as voice-over-IP to prevent the functioning of certain web-based services - and continue the market distorting impacts through these other means.
Allow and define reasonable network management practices: Reasonable network management has to be allowed to enable the ISPs to manage performance on their network. However, ISPs may not indulge in acts that are harmful to users in the name of reasonable network management. Below is a set of potential guidelines to identify cases when discrimination against classes of data traffic in the name of reasonable network management can be considered justified and permissible:
- there is an intelligible differentia between the classes which are to be treated differently,
- there is a rational nexus between the differential treatment and the aim of such differentiation,
- the aim sought to be furthered is legitimate, and is related to the security, stability, or efficient functioning of the network, or is a technical limitation outside the control of the ISP, and
- the network management practice is the least harmful technical means that is reasonably available to achieve the aim.
Establish an effective enforcement mechanism: TRAI must establish an enforcement mechanism that is open to users [and groups of users] and private sector actors as current forums are insufficient. Clear and simple rules must be established ex-ante, if they are violated - ex-post regulation must be undertaken on the basis of principles listed in the TRAI consultation paper, that is “non-discrimination, transparency, affordable internet access, competition and market entry, and innovation” [1]
Take regulatory decisions now, but also conduct and commission further research to review and refine the decisions over a defined period of time
Need for better collection and proactive disclosure of statistics: TRAI publishes quarterly performance indicators statistics collected from the telecom companies about telephone, mobile, and internet sectors in India [2]. It will be very useful for researchers and analysts, and allow for a much more informed public debate on the matter, if the content and form of such data are improved in the following ways:

Content:
- Please start collection (unless already done) and publication of not only data of average incoming and outgoing MOUs, average of total outgoing SMSs, Average Revenue Per User, and average data usage per GSM and CDMA subscriber, but distributions of the same in terms of user deciles (that is in terms of representative figures for each 10% section of users in ascending order of usage),
- Provide granular data about data usage across service areas and service providers (the numbers on ‘average data usage’ and total ‘revenue from data usage’ provided at present are very insufficient for the state of public debate),
- Provide data about internet subscriber base according to network technologies (for both wired and wireless) and the service providers concerned,
- Provide data about IP-based telephony across service areas and service providers,
- Provide data separately for the North Eastern states, and
- Provide granular data (separated from the corresponding state data) for all tier-1 cities.
Form:
- Please do not publish the data only as part of the quarterly reports available in PDF format, but also as independent machine-readable spreadsheet file (preferably in CSV format),
- Do not only publish quarterly data in separate files, but also provide a combined (all quarters together) dataset that would make it much easier for researchers and analysts to use the data,
- In some exceptional cases, the data is not provided in the report directly but a diagram containing the data is published [3], which should be kindly avoided, and
- Please publish these statistics as open data, that is in open standards and under open licenses.

Further, we request TRAI to explore possibilities of distributed sourcing of data, perhaps from the users themselves, about the actual network usage experiences, including but not limited to signal strength, data transfer speed (incoming and outgoing), frequency of switches between mobile (GSM and CDMA) and wi-fi connectivity, etc.

References

[1]. http://trai.gov.in/WriteReaddata/ConsultationPaper/Document/CP-Differential-Pricing-09122015.pdf.

[2]. http://www.trai.gov.in/Content/PerformanceIndicatorsReports/1_1_PerformanceIndicatorsReports.aspx.

[3]. http://www.trai.gov.in/WriteReadData/PIRReport/Documents/Performance_Indicator_Report_Jun_2015.pdf , sections 1.43 and 1.44 (pp. 31-32).

For more details visit https://cis-india.org/telecom/blog/trai-consultation-on-differential-pricing-for-data-services

Will India win net neutrality battle?

praskrishna — 2016-01-11T02:28:44Z

There is more than what meets the eye in Facebook’s ‘noble mission’ of providing internet for all.

The article by Pratap Vikram Singh and Taru Bhatia was published by Governance Now on January 5, 2016. Sunil Abraham gave inputs.

India is gearing up for an era of startups and entrepreneurship and the man pushing it as one of his biggest development and self reliance agenda is none other than prime minister Narendra Modi, who launched the ‘Startup India, Standup India’ campaign this year. Few technology giants, led by the likes of Facebook and some telecom service providers, however, have thrown a technology spanner. It is important to note that a significant number of the startups in India are internet-based – next only to the US and China in having maximum number of tech startups, according to industry body NASSCOM.

For these to flourish and for India to have next Facebook or Google it is important to have an open and neutral internet, believe digital rights experts. A network which doesn’t discriminate between the data packets (smallest unit of information sent in binary format over a network) and provides level playing field for all. “It is critical for the Startup India campaign. If we let the principles of net neutrality be compromised, then it makes it very difficult for entrepreneurs and startups to compete against established players, who can close off the market for upstarts by schemes like differentiated pricing and zero rating (toll free access to websites or apps),” said Vishal Misra, associate professor, department of computer science, Columbia University.

A prerequisite for startups

A few months from now, country’s telecom regulator, the Telecom Regulatory Authority of India (TRAI), is going to decide whether internet would remain neutral and whether it will continue to foster innovation. A major threat to net neutrality, according to civil society and digital rights experts, comes from zero rating – toll free access to a few selected websites or apps, a strategy adopted by internet service providers or internet platforms to hook users to those select few sites. For telecom and internet service providers zero rating is a new stream of revenue, a way to secure optimal return on investment from their existing subscriber base – without requiring additional investment. The ISPs are arguing that they should be given more flexibility in managing their network – in a way they should be allowed to assume the role of gatekeeper of the internet.

For ISPs, net neutrality is an obsolete and utopian idea. Facebook, which has grown into a mammoth internet platform since its inception in 2004, has recently joined this bandwagon. Under its Free Basics initiative (erstwhile internet.org), the internet giant provides toll free access to a set of websites (including Facebook obviously!) handpicked by itself to the users. In India so far it has partnered with Reliance Communications.

Facebook by far is the most audacious and aggressive proponent of ‘zero rating’ scheme. From lobbying the prime minister to giving back-to-back ads in television channels and two-page ads in national dailies to circulating a vaguely written letter in support of Free Basics on its social media site, Facebook is pitching for ‘digital equality’ by giving access to 'basic internet’ or say a slice of the internet.

Cautioning against zero rating, Prabir Purkayastha, chairperson, Society for Knowledge Commons, said the way zero-rating is being discussed, it seems Indians are only the consumers of internet, which is not true. “Indians are also the innovators on internet,” said Purkayastha. “Internet has given the innovators the right to connect to the users without having a huge amount of money. This is the character that will be destroyed if zero-rating will be implemented,” he says.

That’s true. Be it US-based Facebook or Google or Indian Flipkart or PayTm or SnapDeal, had it not been for open and neutral internet they wouldn’t have become what are today.

Raman Jit Singh Chima, global public policy director, Access Now, a New York-based firm working for digital rights, said the idea is to prevent a telco or an internet platform from assuming a role of a gatekeeper and control access. Misra, too, has written extensively on the counter-productiveness of zero rating: stifling of innovation and service providers loosing incentive to improve service and keep prices low. Both Misra and Chima testified their views on net neutrality to the standing committee on IT in August after the department of telecommunications submitted an expert committee report on the neutrality issue.

Whither public consultation

To formulate a regulation on how internet will shape up, the TRAI has come out with two consultation papers concerning net neutrality in the last nine months. The first consultation paper on ‘regulatory framework for over the top players (OTTs)’, which came in March, was written in favour of telecom and internet service providers. “It was embarrassing,” said Purkayastha. Over 1.2 million people wrote to the regulator. This was result of the savetheinternet.in campaign ran by free internet activists and lawyers, who were later joined by All India Bakchod (AIB) whose video on net neutrality went viral on YouTube (the video has received three million views in last eight months). This was unprecedented in the history of TRAI consultations. However, the fate of those responses is still unclear.

In December the regulator brought another paper. This time it was titled ‘regulation on differential pricing’. Contrary to the initial paper, this paper is far more objective and reasonable, said Nikhil Pahwa, founder, MediaNama portal and a key volunteer behind savetheinternet.in campaign. The regulator has sought comments on its second paper by December 30 and counter-comments by January 7. Till the time a final call is taken, the telecom regulator has instructed Reliance Communications, Facebook’s India telecom partner, to put Free Basics on hold.

The savetheinternet.in campaign has formulated the responses to the new consultation paper and has made it available for everyone favouring net neutrality to send it to the TRAI. The AIB team has released another video titled ‘Save the Internet - 2 – Judgement Day’, which has been viewed close to one million times in just four months.

The neutrality debate started in India in December 2014 when Airtel, country’s largest telco, announced – although it later backtracked – that the company would charge consumers more for using VOIP services, on top of the data charges. Later, it went on to launch Airtel Zero, wherein it struck deal with online services providers for user access at zero rate. Facebook had already introduced internet.org by then. While it was initially led by civil society, the debate was later joined by politicians – Naveen Patnaik, M Chandrashekhar, Jay Panda, Rahul Gandhi and Arvind Kejriwal – who strongly came out in support of net neutrality.

Facebook has termed its zero rating platform as a philanthropic activity intended to connect billions of unconnected population so that they can access education, health and employment related information. It has urged users to sign a petition, cautioning them against "a small, vocal group of critics" lobbying to prevent 1 billion people from accessing 'affordable internet'. Under Free Basics, Facebook claims, it doesn't charge app developers and includes them if they comply to its 'objective tech specs'.

Free Basics: A camouflage?

Critics, however, call it a walled garden. In providing free access to close to a hundred websites it continues to play the role of a gatekeeper. It is not the poor who decide what to access but Facebook! While it says that it is not making money out of Free Basics as it doesn't display ads in the Free Basics version of Facebook, it keeps the option of monetisation open in the future.

“It [Free Basics] has been camouflaged as charity," said a senior TRAI official, in an off the record conversation. While speaking to the Guardian on Facebook’s zero rating in December, Tim Berners Lee, founder of world wide web (www), said, “In the particular case of somebody who's offering... something which is branded internet, it's not internet, then you just say no. No it isn't free, no it isn't in the public domain, there are other ways of reducing the price of internet connectivity and giving something... [only] giving people data connectivity to part of the network deliberately, I think is a step backwards.”

Speaking in favour of zero rating, Payal Malik, associate professor, economics, Delhi University, said that it is wrong to assume that all consumers will get hooked to zero rated sites. “In a way you are saying that all humans have same preferences and likes and dislikes, which is very unlikely,” said Malik.

Experts representing telecom industry argue that the net neutrality regulation should be geography specific and the telecom players should be given more flexibility in dealing with the network. Mahesh Uppal, a senior telecom consultant and director, ComFirst India, while speaking at a round table discussion in Delhi, said that a majority of population in the West including countries opting for strict net neutrality – including Netherlands, Slovenia and the US – are already connected. "The data connectivity is primarily through fixed lines - copper, co-ax cable or optical fibre wired — wherein it is easier to add capacity to meet traffic growth. However this is difficult to do so for wireless networks," said Uppal. In developing countries, including India, mobile telephony and internet majorly runs on wireless. Hence, he argued, telecom and internet service providers should be given flexibility to zero rate. For Uppal, if zero rating or sponsored content is implemented properly “it can be one of the ways to scale up internet access” to the unconnected regions.

Neutrality proponents, however, differ. “It is basic economic theory, and zero rated sites get a price advantage. There are studies that show customers stay within the world of zero rated sites and never venture outside or are aware of the full internet,” professor Misra said.

Zero or equal rating?

So is there a middle ground? Are there ways to increase access without tampering with open and neutral character of the internet? Experts believe there are. Some of the solutions are not completely black and white, but in between. While there is a fierce opposition to zero rating, it might work, according to Sunil Abraham, executive director, centre for internet and society (CIS), if provided with an amount of equal rating (giving free data pack to users so that they can access any site or app they want).

Mozilla Foundation advocates equal rating. The foundation has sought to create such an alternative in Bangladesh and countries in Africa within the Firefox OS ecosystem. The foundation has tied up with telecom operator Grameenphone in Bangladesh to provide 20 Mb data per day for free to users, in exchange for viewing an advertisement. The model could be easily replicated in India, said Pahwa of MediaNama.

For African countries, the foundation has partnered with Orange. Both allow Africans to purchase $40 Firefox OS smartphones that come packaged with free three to six months of voice calling, text, and up to 500 Mb of monthly data. Purkayastha of Knowledge Commons said that zero-rating plan by telecom operators only makes sense when government services are provided for free through it. “That is the form of zero-rating I would support.”

There are a few platforms which are reimbursing data in megabytes to users accessing partnering apps. The user can then use the free data pack to access any other site or app. Some of them include: mCent, Gigato and DataMi. mCent, owned by Boston-based firm Jana, is a pioneer in this area. It is being used by 30 million users cross 98 countries. In India, according to Jana, one out of every 10 internet users has subscribed to mCent.

Yes, it does violate neutrality as it puts those app providers not having enough money at a disadvantageous position vis-à-vis to those having deep pocket to reimburse data to users. “I think it’s a grey area,” said professor Misra. On the surface it seems to be just like Free Basics, however, Gigato (or mCent) is making no pretense that what they are doing is philanthropy of increasing access, said professor Misra, adding that it is still acceptable as user will have the data to venture out of the walled garden. The senior TRAI official too finds it acceptable. “In my opinion, Facebook should become like Gigato,” he said.

If the regulator is going to protect consumers’ right and also not stifle startups and entrepreneurism, it will have to ensure some broad, core principles of the internet. It will have to prevent both the ISPs and the internet platforms from becoming gatekeepers. It must not allow any throttling, blocking, fast and slow lanes, discrimination based on price or quality of service and distortion of level playing field. How and whether TRAI is going to do these would be clear in a few months.

For more details visit https://cis-india.org/internet-governance/news/governance-now-pratap-vikram-singh-and-taru-bhatia-january-6-2015-will-india-win-net-neutrality-battle

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

Trai promises final call on differential pricing by month-end after 'lively' open house

praskrishna — 2016-01-26T02:41:56Z

The Telecom Regulatory Authority of India (Trai) will take a final call on differential pricing by the end of January , its chairman said, describing the open house discussions on the regulator's contentious consultation paper as "lively".

The article by Economic Times was published on January 22, 2016. CIS gave inputs.

"It was a very lively consultation, the hall was full. We will take all these into account and hope that by the end of the month, we should be able to come out with our position," Trai chairman Ram Sewak Sharma said.

He, however, refused to link this consultation paper to the broader topic of net neutrality . "Net neutrality is a different subject. First we will decide differential pricing, then we will look at other issues. I cannot say at this time what Trai will do on the larger issue of net neutrality , but we will certainly take a call," Sharma said.

The open house saw a near packed house, with representatives from Trai, several telecom companies, civil society organisations, industry bodies, and individuals, but the debate did not turn out to be as explosive as the acrimonious lead-up to it.

Facebook India's policy head Ankhi Das, whose presence was hugely anticipated after a recent round of high octave communication between Trai and Facebook was made public, did not turn up.

A representative of Facebook, whose zero-rated programme called Free Basics has been at the cent re of the controversy surrounding the differential pricing paper, said: "As a company we have commented. With Free Basics we hope to bring people online in a non-discriminatory manner... We hope Trai will encourage Free Basics.

"Telcos including Bharti AirtelBSE -0.37 %, Idea CellularBSE 0.05 %, Reliance CommunicationsBSE -1.58 %, Sistema Shyam, Tata Communications, VideoconBSE -0.54 % Telecom, and Vodafone made a case for allowing differential pricing, and most cited extending the practice from voice to data services.

"Differential pricing should be incorporated as were done in voice telephony. Data should be encouraged while the content part can be taken up in another consultation paper," a Vodafone representative said.

The volunteer-led savetheinternet.in coalition said: "Internet is not a marketplace. Though telcos advocate differential pricing in the name of different customer classes, but when they charge for third party content, it becomes a problem."

Civil society organisations also made detailed submissions, explaining their positions. While most, including industry body Internet and Mobile Association of India, said they were against differential pricing, some took a slightly cautious view. "What hasn't been discussed is that there is already differential pricing and this is undocumented," said a representative of Centre for Internet and Society. "Free Basics isn't following certain protocol standards, and this is a concern. We don't have enough data on internet usage, costs, user experience, to take a decision now," he added.

A representative of Tata CommunicationsBSE 0.58 % said "sponsored data services" exist around the world and argued citing an example that providing free voice service does not confer competitive advantage.

"If there are two pizza vendors: one with a toll-free service for taking orders and the other where you pay money to order without a toll-free service. The uptake in the pizza depends on the quality and the price of the pizzas. It is not because it is a toll free call," he said.

This comparison drew laughter in the open house, and became the butt of jokes on Twitter from internet freedom advocates. "Btw, I think a new analogy from the telco guys today, comparing the internet with pizza. How creative," tweeted Nikhil Pahwa, who under the banner of savetheinternet.in has been campaigning for net neutrality.

IAMAI president Subho Ray's candid commentary on submissions, calling some of them "badly done homework", did not go down well with some members of the audience.

Individual entrepreneurs made a case for not having differential pricing, as that would mean the telcos would get to decide the access for their business. Some people suggested alternatives. Digital Empowerment Foundation founder Osama Manzar said unlicensed spectrum or Wi-Fi could be used to provide access in the rural areas.

Trai launched the differential pricing consultation paper on December 9, which was followed by Facebook starting a mass campaign, asking its users to support Free Basics, urging them to email Trai in support of "digital equality" and supporting Free Basics.

For more details visit https://cis-india.org/telecom/news/trai-promises-final-call-on-differential-pricing-by-month-end-after-lively-open-house

CIS Submission to TRAI Consultation on Free Data

pranesh — 2016-07-01T16:04:27Z

The Telecom Regulatory Authority of India (TRAI) held a consultation on Free Data, for which CIS sent in the following comments.

The Telecom Regulatory Authority of India (TRAI) asked for public comments on free data. Below are the comments that CIS submitted to the four questions that it posed.

Question 1
Is there a need to have TSP agnostic platform to provide free data or suitable reimbursement to users, without violating the principles of Differential Pricing for Data laid down in TRAI Regulation? Please suggest the most suitable model to achieve the objective.

Is There a Need for Free Data?

No, there is no need for free data, just as there is no need for telephony or Internet. However, making provisions for free data would increase the amount of innovation in the Internet and telecom sector, and there is a good probability that it would lead to faster adoption of the Internet, and thus be beneficial in terms of commerce, freedom of expression, freedom of association, and many other ways.

Thus the question that a telecom regulator should ask is not whether there is a need for TSP agnostic platforms, but whether such platforms are harmful for competition, for consumers, and for innovation. The telecom regulator ought not undertake regulation unless there is evidence to show that harm has been caused or that harm is likely to be caused. In short, TRAI should not follow the precautionary principle, since the telecom and Internet sectors are greatly divergent from environmental protection: the burden of proof for showing that something ought to be prohibited ought to be on those calling for prohibition.

Goal: Regulating Gatekeeping

TRAI wouldn’t need to regulate price discrimination or Net neutrality if ISPs were not “gatekeepers” for last-mile access. “Gatekeeping” occurs when a single entity establishes itself as an exclusive route to reach a large number of people and businesses or, in network terms, nodes. It is not possible for Internet services to reach their end customers without passing through ISPs (generally telecom networks). The situation is very different in the middle-mile and for backhaul. Even though anti-competitive terms may exist in the middle-mile, especially given the opacity of terms in “transit agreements”, a packet is usually able to travel through multiple routes if one route is too expensive (even if that is not the shortest network path, and is thus inefficient in a way). However, this multiplicity of routes is generally not possible in the last mile.¹ This leaves last mile telecom operators (ISPs) in a position to unfairly discriminate between different Internet services or destinations or applications, while harming consumer choice.

However, the aim of regulation by TRAI cannot be to prevent gatekeeping, since that is not possible as long as there are a limited number of ISPs. For instance, even by the very act of charging money for access to the Internet, ISPs are guilty of “gatekeeping” since they are controlling who can and cannot access an Internet service that way. Instead, the aim of regulation by TRAI should be to “regulate gatekeepers to ensure they do not use their gatekeeping power to unjustly discriminate between similarly situated persons, content or traffic”, as we proposed in our submission to TRAI (on OTTs) last year.

Models for Free Data

There are multiple models possible for free data, none of which TRAI should prohibit unless it would enable OTTs to abuse their gatekeeping powers.

Government Incentives For Non-Differentiated Free Data

The government may opt to require all ISPs to provide free Internet to all at a minimum QoS in exchange for exemption from paying part of their USO contributions, or the government may pay ISPs for such access using their USO contributions.

TRAI should recommend to DoT that it set up a committee to study the feasibility of this model.

ISP subsidies

ISP subsidies of Internet access only make economic sense for the ISP under the following ‘Goldilocks’ condition is met: the experience with the subsidised service is ‘good enough’ for the consumers to want to continue to use such services, but ‘bad enough’ for a large number of them to want to move to unsubsidised, paid access.

Providing free Internet to all at a low speed.
1. This naturally discriminates against services and applications such as video streaming, but does not technically bar access to them.
Providing free access to the Internet with other restrictions on quality that aren’t discriminatory with respect to content, services, or applications.

Rewards model

A TSP-agnostic rewards platform will only come within the scope of TRAI regulation if the platform has some form of agreement with the TSPs, even if it is collectively. If the rewards platform doesn’t have any agreement with any TSP, then TRAI does not have the power to regulate it. However, if the rewards platform has an agreement with any TSP, it is unclear whether it would be allowed under the Differential Data Tariff Regulation, since the clause 3(2) read with paragraph 30 of the Explanatory Memorandum might disallow such an agreement.

Assuming for the sake of argument that platforms with such agreements are not disallowed, such platforms can engage in either post-purchase credits or pre-purchase credits, or both. In other words, it could be a situation where a person has to purchase a data pack, engage in some activity relating to the platform (answer surveys, use particular apps, etc.) and thereupon get credit of some form transferred to one’s SIM, or it could be a situation where even without purchasing a data pack, a consumer can earn credits and thereupon use those credits towards data.

The former kind of rewards platform is not as useful when it comes to encouraging people to use the Internet, since only those who already see worth in using in the Internet (and can afford it) will purchase a data pack in the first place. The second form, on the other hand is quite useful, and could be encouraged. However, this second model is not as easily workable, economically, for fixed line connections, since there is a higher initial investment involved.

Recharge API

A recharge API could be fashioned in one of two ways: (1) via the operating system on the phone, allowing a TSP or third parties (whether OTTs or other intermediaries) to transfer credit to the SIM card on the phone which have been bought wholesale. Another model could be that of all TSPs providing a recharge API for the use of third parties. Only the second model is likely to result in a “toll-free” experience since in the first model, like in the case of a rewards platform that requires up-front purchase of data packs, there has to be a investment made first before that amount is recouped. This is likely to hamper the utility of such a model.

Further, in the first case, TRAI would probably not have the powers to regulate such transactions, as there would be no need for any involvement by the TSP. If anti-competitive agreements or abuse of dominant position seems to be taking place, it would be up to the Competition Commission of India to investigate.

However, the second model would have to be overseen by TRAI to ensure that the recharge APIs don’t impose additional costs on OTTs, or unduly harm competition and innovation. For instance, there ought to be an open specification for such an API, which all the TSPs should use in order to reduce the costs on OTTs. Further, there should be no exclusivity, and no preferential treatment provided for the TSPs sister concerns or partners.

“0.example” sites

Other forms of free data, for instance by TSPs choosing not to charge for low-bandwidth traffic should be allowed, as long as it is not discriminatory, nor does it impose increased barriers to entry for OTTs. For instance, if a website self-certifies that it is low-bandwidth and optimized for Internet-enabled feature phones and uses 0.example.tld to signal this (just as wap.* were used in for WAP sites and m.* are used for mobile-optimized versions of many sites), then there is no reason why TSPs should be prohibited from not charging for the data consumed by such websites, as long as the TSP does so uniformly without discrimination. In such cases, the TSP is not harming competition, harming consumers, nor abusing its gatekeeping powers.

OTT-agnostic free data

If a TSP decides not to charge for specific forms of traffic (for example, video, or for locally-peered traffic) regardless of the Internet service from which that traffic emanates, as as long as it does so with the end customer’s consent, then there is no question of the TSP harming competition, harming consumers, nor abusing its gatekeeping powers. There is no reason such schemes should be prohibited by TRAI unless they distort markets and harm innovation.

Unified marketplace

One other way to do what is proposed as the “recharge API” model is to create a highly-regulated market where the gatekeeping powers of the ISP are diminished, and the ISP’s ability to leverage its exclusive access over its customers are curtailed. A comparison may be drawn here to the rules that are often set by standard-setting bodies where patents are involved: given that these patents are essential inputs, access to them must be allowed through fair, reasonable, and non-discriminatory licences. Access to the Internet and common carriers like telecom networks, being even more important (since alternatives exist to particular standards, but not to the Internet itself), must be placed at an even higher pedestal and thus even stricter regulation to ensure fair competition.

A marketplace of this sort would impose some regulatory burdens on TRAI and place burdens on innovations by the ISPs, but a regulated marketplace harms ISP innovation less than not allowing a market at all.

At a minimum, such a marketplace must ensure non-exclusivity, non-discrimination, and transparency. Thus, at a minimum, a telecom provider cannot discriminate between any OTTs who want similar access to zero-rating. Further, a telecom provider cannot prevent any OTT from zero-rating with any other telecom provider. To ensure that telecom providers are actually following this stipulation, transparency is needed, as a minimum.

Transparency can take one of two forms: transparency to the regulator alone and transparency to the public. Transparency to the regulator alone would enable OTTs and ISPs to keep the terms of their commercial transactions secret from their competitors, but enable the regulator, upon request, to ensure that this doesn’t lead to anti-competitive practices. This model would increase the burden on the regulator, but would be more palatable to OTTs and ISPs, and more comparable to the wholesale data market where the terms of such agreements are strictly-guarded commercial secrets. On the other hand, requiring transparency to the public would reduce the burden on the regulator, despite coming at a cost of secrecy of commercial terms, and is far more preferable.

Beyond transparency, a regulation could take the form of insisting on standard rates and terms for all OTT players, with differential usage tiers if need be, to ensure that access is truly non-discriminatory. This is how the market is structured on the retail side.

Since there are transaction costs in individually approaching each telecom provider for such zero-rating, the market would greatly benefit from a single marketplace where OTTs can come and enter into agreements with multiple telecom providers.

Even in this model, telecom networks will be charging based not only on the fact of the number of customers they have, but on the basis of them having exclusive routing to those customers. Further, even under the standard-rates based single-market model, a particular zero-rated site may be accessible for free from one network, but not across all networks: unlike the situation with a toll-free number in which no such distinction exists.

To resolve this, the regulator may propose that if an OTT wishes to engage in paid zero-rating, it will need to do so across all networks, since if it doesn’t there is risk of providing an unfair advantage to one network over another and increasing the gatekeeper effect rather than decreasing it.

Question 2

Whether such platforms need to be regulated by the TRAI or market be allowed to develop these platforms?

In many cases, TRAI would have no powers over such platforms, so the question of TRAI regulating does not arise. In all other cases, TRAI can allow the market to develop such platforms, and then see if any of them violates the Discriminatory Data Tariffs Regualation. For government-incentivised schemes that are proposed above, TRAI should take proactive measure in getting their feasibility evaluated.

Question 3

Whether free data or suitable reimbursement to users should be limited to mobile data users only or could it be extended through technical means to subscribers of fixed line broadband or leased line?

Spectrum is naturally a scarce resource, though technological advances (as dictated by Cooper’s Law) and more efficient management of spectrum make it less so. However, we have seen that fixed-line broadband has more or less stagnated for the past many years, while mobile access has increased. So the market distortionary power of fixed-line providers is far less than that of mobile providers. However, competition is far less in fixed-line Internet access services, while it is far higher in mobile Internet access. Switching costs in fixed-line Internet access services are also far higher than in mobile services. Given these differences, the regulation with regard to price discrimination might justifiably be different.

All in all, for this particular issue, it is unclear why different rules should apply to mobile users and fixed line users.

Question 4

Any other issue related to the matter of Consultation.

None.

In India’s mobile telecom sector, according to a Nielsen study, an estimated 15% of mobile users are multi-SIM users, meaning the “gatekeeping” effect is significantly reduced in both directions: Internet services can reach them via multiple ISPs, and conversely they can reach Internet services via multiple ISPs. See Nielsen, ‘Telecom Transitions: Tracking the Multi-SIM Phenomena in India’, http://www.nielsen.com/in/en/insights/reports/2015/telecom-transitions-tracking-the-multi-sim-phenomena-in-india.html↩

For more details visit https://cis-india.org/internet-governance/blog/cis-submission-trai-consultation-free-data

Slow internet driving you nuts? Here is how your service provider is fleecing you

praskrishna — 2016-07-01T15:32:58Z

June 20 was World Wifi Day — an occasion to celebrate speedy, reliable internet connections. India, although a major internet market and the fastest growing now, is a very odd place for such celebration. Average internet speed in India is lower than all other countries in BRICs and lower than most other emerging economies.

The article was published in the Economic Times on June 23, 2016. Sunil Abraham was quoted.

Plus, wired broadband speeds available to 17 million paying consumers in India are far below what service providers promise when they charge end users for particular data services. A data service package that promises 8 Mbps will typically max out at 5 Mbps (Mbps is megabits per second, a measure of internet speed). Wireless connections are even more patchy.

Still worse, the Telecom Regulatory Authority of India (Trai) and consumer advocacy groups haven't made much headway and service providers are ready with a set of arguments. Trai, which will release a consultation paper on promoting WiFi in public places, has a fairly conservative definition of broadband — that download speed should not fall below 512 kbps (kilobits per second; 1Mbps equals 1,000 kbps).

The end result: high-paying consumers suffer.

In a wired broadband service used at homes, few factors determine performance. First, the contention ratio, a key metric that measures the number of internet users sharing a fixed amount of data capacity or 'bandwidth' in a location at the same time. If the number of such users is large, the contention ratio will be high and real internet speed low.

Third is per capita spectrum usage/holdings in a country and India's is far below that of Western countries and major emerging economies.

In India, a low bandwidth availability country to begin with, wired broadband services typically have high contention ratio and/or high latency. Service providers Bharti Airtel, RCom and BSNL did not reply to ET's queries on internet speed.

Bijender Yadav, chief technology & information officer at Sistema Shyam Teleservices, another service provider, told ET data download speeds could fall below contracted levels in case of improper network planning and bandwidth distribution, or if there are glitches in the transmission link between a service provider's internet gateway and the home broadband user's premises.

A senior executive of a leading wired broadband service said, on the condition of anonymity, that companies do make certain assumptions.

Say, 10 customers are sold 2 Mbps connections, which means 20 Mbps should be available. But the company may provide only 5 Mbps for these 10 customers, assuming not all customers will be using their internet connections heavily at the same time. Therefore, the guaranteed internet speed is not 2 Mbps, but just 500 kbps.

Many telco executives ET spoke to said while the contention ratios are high given bandwidth availability, since bandwidth is a "scarce resource" it must be "optimised" to keep prices low for consumers. These executives spoke off record.

Consumer advocacy groups are however sceptical of this argument. They say companies are simply maximising data connection sales without offering good network quality.

"Telcos are selling bandwidth way beyond the optimum capacity of their networks and compromising on speed. Could they have done this if bandwidth was a tangible resource like cars or machines...imagine selling more cars than you've manufactured," asks Hemant Upadhyay, advisor (telecom and IT) at Consumer Voice, a leading telecom consumer group.

Consumer groups have recently urged the telecom regulator, Trai, to ensure an app that can continuously monitor bandwidth availability should be in use.

Sunil Abraham, executive director of Bengaluru-based research organisation, Centre for Internet and Society, argues Trai must ensure mandatory disclosure of contention ratios by service providers. "If such disclosures become mandatory, home broadband users can buy wired internet connections more judiciously with a better sense of what data speeds to expect from telcos and the possible quality of their experience."

Trai did not offer any comment on the call for mandatory disclosure of contention ratios by wired broadband operators.

A top executive of a leading operator, speaking off record, dismissed the proposal, saying "it wouldn't make sense to mandate service providers to make such disclosures as contention ratios vary from place to place".

Some experts are optimistic that WiFi networks may offer better services to high-paying data consumers. Bharti Airtel, Vodafone and new entrant Reliance Jio Infocomm are deploying WiFi networks.

Airtel and Vodafone have also launched WiFi hotspots apps. Jio is slated to do the same after its expected launch later this year.

But WiFi in public places hasn't taken off so far. Cumbersome authentication procedures and challenges around monetising services have been hurdles.

The speed of internet in the world's fastest growing internet market will likely remain below world average in the near future.

Second, the latency of a network, a measure of the delay a user experiences when his/her computer tries to access an internet server. If a service provider runs a low latency network, internet speed will be better.
Third is per capita spectrum usage/holdings in a country and India's is far below that of Western countries and major emerging economies.

A senior executive of a leading wired broadband service said, on the condition of anonymity, that companies do make certain assumptions.

Consumer advocacy groups are however sceptical of this argument. They say companies are simply maximising data connection sales without offering good network quality.

Consumer groups have recently urged the telecom regulator, Trai, to ensure an app that can continuously monitor bandwidth availability should be in use.

Trai did not offer any comment on the call for mandatory disclosure of contention ratios by wired broadband operators.

Some experts are optimistic that WiFi networks may offer better services to high-paying data consumers. Bharti Airtel, Vodafone and new entrant Reliance Jio Infocomm are deploying WiFi networks.
Airtel and Vodafone have also launched WiFi hotspots apps. Jio is slated to do the same after its expected launch later this year.

But WiFi in public places hasn't taken off so far. Cumbersome authentication procedures and challenges around monetising services have been hurdles.

The speed of internet in the world's fastest growing internet market will likely remain below world average in the near future.

For more details visit https://cis-india.org/telecom/news/economic-times-kalyan-parbat-june-23-2016-slow-internet-driving-you-nuts

Call drops: Dealing with the menace or just shifting goal posts?

praskrishna — 2016-07-01T16:45:45Z

It is nothing short of an irony that the world’s second largest mobile user market that boasts of being the world’s fastest growing economy is plagued by poor infrastructure and overloaded networks to an extent that many callers are cut off even before they can finish a sentence. The fault in India’s much-acclaimed telecom revolution is a questioning, frequent phenomenon called “call drops”. There have been several signature campaigns and media pressure demanding that the government and telecom companies get their heads together to fix this raging demon of a problem. However, all they have been treated with is lip service and nothing more.

The article was published by India TV News on June 29, 2016

So, on one hand we have Union Minister Ravi Shankar Prasad claiming that the call drop problem is improving as telecom companies are installing towers, and on the other is TRAI that shows reports that operators like Aircel, Vodafone and Idea are using call drop masking technology incorrectly to fudge the data on call drops. Not long ago, we had Prime Minister Narendra Modi himself take up the issue and we saw a flurry of allegations and counter allegations flying between the government and the telecom companies on where the fault actually lies.

While the government claimed it had freed enough spectrum to fix network issues and blamed the companies for not investing enough in the infrastructure, the telcos hit back at the government saying they were facing regulatory hurdles in setting up of towers because of environmental issues posed by regulation. In all, we kept going in circles and the change promised remained as elusive as its perception.

Reality is that for cell phone users in India, call drop continues as a common phenomenon and figures released by the Telecom Regulatory Authority of India (TRAI) attest to this claim. According to TRAI, the figures have doubled in the last one year and the worst affected cell has more than 3% TCH drop (traffic channel call drop) rate, which is four times higher than the permitted limit. Quality of Service Regulations has allowed service providers a 2 per cent allowance of call drops on the basis of averaging call drops per month.

TRAI has recently conducted Audit and assessment of Quality of Service being provided by service providers through independent agencies for Cellular Mobile Telephone Service, Basic Service and Broadband Services in many states. In Ahmedabad all the operators have failed to meet the call drop rate benchmark of less that 2% expect Airtel 2G. Also in Mumbai most of the operators have not met the less that 2% call drop benchmark except Airtel 2G and 3G and Vodafone 2G.

Many other states have gone through this drive test and have failed.

This begs us to put up a serious question in the interest of the more than 103.518 cr users who shell out money for pathetic services - Is the problem actually being resolved or are we, the consumers, being taken for a royal ride?

Before we set out to give you a complete idea on the state of affairs and where we stand in terms of actually working towards fixing this problem, a look at some basics first to put things in context.

What is call drop?

A call drop technically signifies the service provider’s incapability to maintain a call, either incoming or outgoing, once it has been properly established. In India, call drops are a performance indicator for the country’s telecom networks. In many cities, mobile users have to rush from one room to another or drive around neighborhoods to find better signals or better voice quality.

Call drops now figure among the top customer issues with telcos in several Indian cities. There is very little transparency on call drop data but it can be said that most companies have multiple sites where the call drop incidence is much above the set 2 percent limit. New Delhi has been particularly hit after city authorities cracked down and sealed unlicensed mobile towers.

The problem had increased so much that India’s Telecom Regulatory Authority of India, the industry regulator, had specified that telecom service providers need to compensate users for dropped calls. The regulator said that the consumers will be paid Re.1 per call up to 3 dropped calls per day, only to be turned down by the Supreme Court, rendering the TRAI decision null and void.

Telecom companies had cried foul over the directive, firstly by saying that the regulator had no authority to levy such penalty and secondly, by saying that it wasn't possible to segregate the reasons for call drops.

SC gave a 99-page judgment and said that the regulation appears to be meant only to penalise telcos. The judgment highlighted various flaws in the ruling by the Delhi high court which upheld TRAIs regulation.

It further upheld the 2% exemption extended to service providers with regard to call drops and said the regulation would have penalized them despite it.

“A penalty that is imposed ‘without any reason’ either as to the number of call drops made being three, and only to the calling consumer, ‘far from balancing the interest of consumers and service providers’, is manifestly arbitrary, not being based on any factual data or reason,” the court said.

A ‘towering’ menace

Towers act as boosters that help radio waves travel better, and are a necessary part of the telecom architecture in any country. There are approximately 5,50,000 towers in India, and industry associations think another 1,00,000 are needed. The lower radio bands need less towers to travel longer distances, so when telecom companies offer services like 3G or 4G, they have to be at higher frequencies (2,100 MHz or 2,300 MHz instead of 900 MHz), which need more tower support.

Call drops occur due to several reasons.

Cities like Mumbai, Delhi, Chandigarh, Bengaluru, Jaipur and Patna have less towers than needed. Civic authorities across the country have shut down a total of around 10,000 towers and an additional 12,000 towers cannot be used due to various reasons.

Telecom companies are reluctant to share towers. This is because they are fixed investments by subsidiaries of telecom companies. Permission to erect a tower is given by the municipal body, but no uniform standards or procedures exist here.

The setting up of boosters on buildings remains a task, and permission has to be taken on a case-by-case basis. Things could improve if telecom connectivity were seen as being similar to water and power supply, and developers were to apply for a uniform set of permissions.

If we take the recent scenario the State-run telecom operator BSNL is said to expand its network in Chhattisgarh by installing 2,000 new mobile towers in the next two years, Communications and IT Minister Ravi Shankar Prasad, stepping forward to strengthen mobile connectivity in the state.

Telecom Secretary J S Deepak recently said that penal powers cannot be “one and final solution” for call drop and the telecom firms have committed Rs 12,000 cr to install new towers to check this problem.

“Government believes in the telecom sector. The quality of service must improve and industry has responsibility. They have committed 60,000 towers. Each tower cost about Rs 20 lakh which is around Rs 12,000 crore. The industry will make this investment in next three months,” he said recently.

Most of the mobile service providers have frequently failed in quarterly sample call drop tests conducted by Trai but operators have contested the results saying that they comply with benchmark set by the regulator.

On this, the operators raised issues such as regulatory hurdles by local authorities and opposition by residents associations to installation of mobile towers.

“All top CEOs have said they will set up war rooms to address this issue. We need to work with them to facilitate installation of mobile towers,” Deepak said.

“We are coordinating with minister (Ravi Shankar Prasad) to launch portal on EMF (radiation) next month. This will give data of about 4.3 lakh mobile towers. People can go online and check if a tower is emitting radiation within limit or not so that citizens are aware that it not an issue,” he added.

So after the launch of portal on EMF (radiation) next month, the fight on hurdles might be resolved, which will then raise questions on the operators if the call drop issue still persists.

Do companies benefit from call drops?

All the benefits depend on the tariff plan. If it’s measured in seconds, the telecom company gains nothing — no matter how many times the connection cut, billing resumes at the same rate. But if it is measured in minutes, or if the plan contains features such as a certain number of free calls in every billing cycle, call drops is a nightmare for the consumers.

Telecom firms claim that 95 per cent of tariff plans involves billing in seconds. Since call drops are the most common in overcrowded areas, interruptions tend to shorten the call and, to that extent, reduce the average revenue per user per minute. Since companies measure their performance on the basis of call drops too, it is risky for anyone to intentionally create conditions for drops, thus porting to another operator.

Cellular Operators Association of India (COAI) in a report said that the telecom industry is facing a lot of challenges which are leading to call drops:

State bodies initiate actions against the towers without any prior notices like disconnecting electricity supplies, sealing the premises and even dismantling of tower sites.
Restrictions imposed by state governments and municipalities for wireless sites for erecting cell-sites in non-commercial areas, sealing of the cell-sites by municipal authorities.
Issues pertaining to Right of Way (RoW) – due to no approval, operators are not even in a position to put up sites. Frequent fiber cuts due to infrastructure projects are recurring phenomena in almost all circles.
Site outages on account of long power failures and delay in restoration of power supply by electricity boards.
Owner/legal issues, which is an important factor, because if the operator does not obtain the permission to set up the cell site, calls in the area would be dropped.
Interference due to illegal wide band radio and coverage restrictions arising out of cross border spectrum interference.
Shortage of spectrum amid surging data traffic growth and the lack of availability of a sufficient quantum of globally harmonized spectrum in contiguous form is the biggest impediment to the deployment of wireless technologies in the access network and hence for better quality of service resulting in increased call drops with the increase in data traffic.

Government’s role and what it can do

The government says that call drops can be addressed to a large extent through better management of spectrum, something that will only provide partial relief. The occurrence of call drops is higher at busy areas, typically city centres. This means there is an unequal spread of traffic across the spectrum.

Regardless of these technical roadblocks, there is actually quite a lot that the government can do.

General allowing of shared spectrum so that the same bandwidth is homogenously distributed among towers that are in a row.
Government rules prohibit spectrum swapping, but to tackle the issue a policy should be amended for the same.
Unused spectrum bands, which are either not used or have been missed due to the traffic in the bandwidth should be reformed and put to efficient use.
Every state should be encouraged to use uniform procedures on towers and policies regarding this should be amended.
Set up rules for companies to improve on their services. Besides penalty which has been dropped government should keep a check on telcos to work properly.

Pranesh Prakash, Policy Director at the Centre for Internet and Society said that Telecom companies in India have scarcity in terms of spectrum, which needs to be rationalised by allowing spectrum policy in India.

He also added that the government’s decision of not allowing spectrum supply doesn’t really make sense as India needs the policy. Also, the radiations emitted by the spectrum which are harming people should be scientifically taken care of.

What are the benchmarks for call drop that should be followed by the telcos?

TRAI has laid down the quality of service benchmarks for call drop rate to be less than 2 percent. The 2 percent call drop benchmark means that not more than 2 percent calls made from a network should automatically disconnected in a telecom circle.

Recently, the call drop test was conducted in Bhopal and Mumbai. TRAI found that most operators in Mumbai, except Airtel 2G/3G and Vodafone 2G, are not meeting the under 2 per cent call drop rate benchmark. In the drive tests conducted during May 10 to 13 in Mumbai, the call drop rates of No 1 carrier, Bharti Airtel's 2G and 3G networks, stood at 1.49 per cent and 1.94 per cent, while Vodafone-2G's was 1.68 per cent.

Other than Airtel and Vodafone in 2G, all operators failed to meet the Call Drop Rate benchmark in Bhopal. TRAI in a report said that Idea, Reliance and BSNL all have Call Drop Rates in the range of 10 percent or above. These are exceptionally high and clearly indicate urgent need for improvement in order to deliver reasonable levels of service.

What steps should be taken to improve the problem?

A lot has to be done to settle the issue. The mobile towers do not have an unlimited capacity for handling the current network load. So telecom companies need to increase the towers to tackle the load. This is being followed as telecom operators have decided to invest Rs.12,000 crore for installation of 60,000 more towers over the next three months, while the BSNL will install 21,000 BTS towers a report said.

A report by TRAI said that the problems like removal of towers from certain areas by authorities needs to be addressed. Also, with the increase in the usage of 3G networks, the growth rate of mobile towers supporting 2G networks has reduced, which also needs to be addressed.

Recently, Union Minister Ravi Shankar Prasad claimed that the call drop problem was improving with various telecom companies are installing about 1.24 lakh towers to mitigate the issue. In a report he said, “Things are improving....private telecom operators have installed one lakh towers, while the State-owned BSNL has put in place 24,000 Base Transceiver Station (BTS) towers across the country in the past one year to improve the call drop problem.”

The roadmap

Surveys are being conducted and a lot of efforts are being made by the operators and also TRAI to solve the call drop issue. However, in a country with the world’s second-largest mobile user market it is tough to solve the problem completely but not impossible. That, in theory, is the situation. On ground though, things don’t appear to be running in tune with tall claims by the government or the telecom companies. If the situation is improving, as the government claims, change needs to be visible, which is apparently not the case. Also, if the investments are being made to the tune of what the telecom companies are claiming, that would translate into solving the issue.

The moot point here is that if the number of towers is the root cause behind the millions of consumers facing this absolute nightmare of an issue, can this “go-getter” government not come to any arrangement so as to solve the issue? Perhaps, the government, which displayed exemplary enthusiasm in gaining a seat in the coveted Nuclear Suppliers Group, needs to translate some of that energy into getting to a solution for an issue plaguing a large and growing population of its billion plus populace. It would only serve some good. No pun intended.

For more details visit https://cis-india.org/telecom/news/india-tv-news-june-26-2016-call-drops