The Centre for Internet and Society
https://cis-india.org
These are the search results for the query, showing results 1 to 15.
Your telco could help spy on you
https://cis-india.org/news/livemint-july-30-2013-joji-thomas-philip-leslie-d-monte-shauvik-ghosh-your-telco-could-help-spy-on-you
<b>Telecom minister gives approval to changes in rules for mobile licences to enable such mass surveillance.</b>
<hr />
<p style="text-align: justify; ">The article by Joji Thomas Philip, Leslie D'Monte and Shauvik Ghosh was originally <a class="external-link" href="http://www.livemint.com/Politics/rpWFiDJroLgpLQ6yKdR3pJ/Telcos-to-soon-link-with-government-monitoring-system.html">published in Livemint</a> on July 30, 2013. Sunil Abraham is quoted.</p>
<hr />
<p style="text-align: justify; ">Telecom companies and Internet service providers will soon help the government monitor every call made, every email sent and every website visited, with the Centre deciding to connect their networks to its automated surveillance platform known as the Centralised Monitoring System (CMS).</p>
<p style="text-align: justify; ">Communications minister <span class="person"><a href="http://www.livemint.com/Search/Link/Keyword/Kapil%20Sibal">Kapil Sibal</a></span> has approved changes in existing rules and new clauses to be inserted in mobile licences for enabling such mass surveillance, copies of documents reviewed by <i>Mint</i> reveal.</p>
<table class="invisible">
<tbody>
<tr>
<th><iframe frameborder="0" height="250" src="http://www.youtube.com/embed/o1r6OSv-WyI" width="320"></iframe></th>
<td style="text-align: justify; ">
<p>The department of telecommunications (DoT) will shortly send a letter to all telcos asking them to connect their “lawful interception system (LIS)” to the CMS “at a regional monitoring centre through an interception, store and forward (ISF) server placed in the licensee’s premises”, according to the documents.</p>
<p>Telcos including <span class="company"><a href="http://www.livemint.com/Search/Link/Keyword/Bharat%20Sanchar%20Nigam%20Ltd">Bharat Sanchar Nigam Ltd</a></span> (<span class="brand"><a href="http://www.livemint.com/Search/Link/Keyword/BSNL">BSNL</a></span>), <span class="company"><a href="http://www.livemint.com/Search/Link/Keyword/Mahanagar%20Telephone%20Nigam%20Ltd">Mahanagar Telephone Nigam Ltd </a></span>(MTNL), <span class="company"><a href="http://www.livemint.com/Search/Link/Keyword/Reliance%20Communications%20Ltd">Reliance Communications Ltd</a></span>, <span class="company"><a href="http://www.livemint.com/Search/Link/Keyword/Bharti%20Airtel%20Ltd">Bharti Airtel Ltd</a></span>, <span class="company"><a href="http://www.livemint.com/Search/Link/Keyword/Vodafone%20India%20Ltd">Vodafone India Ltd</a></span> and <span class="company"><a href="http://www.livemint.com/Search/Link/Keyword/Tata%20TeleServices%20Ltd">Tata TeleServices Ltd</a></span> declined to comment on questions emailed in this regard.</p>
<p> </p>
</td>
</tr>
</tbody>
</table>
<p style="text-align: justify; ">“The automated process of the CMS will be subjected to the same regulatory scrutiny as is available in the present manual system under Section 5(2) of Indian Telegraph Act and Rules 419-A thereunder, with the added advantage of having a safeguard against any illegal provisioning by the telecom service providers in the present system, however, remote it may be,” DoT said in an email reply to a questionnaire with a brief on CMS.</p>
<p style="text-align: justify; ">“Safeguard has also been built against any unauthorized provisioning by having a different interception provisioning agency than the interception requisitioning and monitoring agencies thus having an inbuilt system of checks and balances. Further, a non-erasable command log will be maintained by the system, which can be examined anytime for misuse, thus having an additional safeguard,” DoT said.</p>
<p style="text-align: justify; ">The CMS was approved by the cabinet committee on security (CCS) on 16 June 2011, with government funding of Rs.400 crore. It is expected to enable the government to monitor all forms of communication, from emails to online activity to phone calls, text messages and faxes by automating the existing process of interception and monitoring. The government completed a pilot project in September 2011 under which the Centre for Development of Telematics (C-DoT) installed two ISF servers, one of them for MTNL.</p>
<p style="text-align: justify; ">“The interception services have been integrated and tested successfully for these two telecom services providers (TSPs),” the note said, referring to MTNL and Tata Communications Ltd. MTNL officials declined to comment. There was no response to queries by Tata Communications.</p>
<p style="text-align: justify; ">It added that training had been imparted to six law enforcement agencies—the Intelligence Bureau, the Central Bureau of Investigation, the Directorate of Revenue Intelligence, the Research and Analysis Wing, the Delhi Police and the National Investigation Agency.</p>
<p style="text-align: justify; ">However, the documents also reveal that the CMS project is getting delayed over technical issues such as lawful interception systems sending the intercept-related information (IRI) in “their own proprietary format”; difficulty in tracing the movement of “the target from the home network to the roaming network”; and how to independently provision voice and data interception of mobile users.</p>
<p style="text-align: justify; ">The government is simultaneously devising a strategy to counter criticism from the media and privacy lobby groups that this surveillance platform has no privacy safeguards. Mint reported on 13 July that fresh questions were raised on the CMS infringing on the rights of individuals, especially in the wake of the US government’s PRISM surveillance project.</p>
<p style="text-align: justify; ">In an internal note on 16 July to help Sibal brief the media, DoT said even as the CMS will automate the existing process of interception and monitoring “... all safeguards that are currently in place in the manual mode of interception will continue”.</p>
<p style="text-align: justify; ">The note argued that implementation of the CMS “will rather enhance the privacy of the citizens” since it will not be necessary to take the authorization (for tapping) to the nodal officer of the telecom service providers “who comes to know whose or which phone is being intercepted”. The note added that after the CMS is implemented, provisioning of interception will be done by a CMS authority, who would be different from the law enforcement agency authorities.</p>
<p style="text-align: justify; ">“The law enforcement agency (LEA) cannot provision for interception and monitoring and the CMS authority cannot see the content but would be able to provision the request from the LEA.Hence, complete check and balance will be ensured. Further, a non-erasable command log will be maintained by the system, which can be examined anytime for misuse, thus having an additional safeguard,” added the department’s note briefing the minister.</p>
<p style="text-align: justify; ">Also, acknowledging that “questions were being asked about the practices of Indian agencies and the privacy and rights of its citizens”, national security adviser <a href="http://www.livemint.com/Search/Link/Keyword/Shivshankar%20Menon">Shivshankar Menon</a> in a 23 June note to the ministries of home, external affairs and telecom, the department of electronics and information technology, and the cabinet secretary said: “Only home secretaries of the Centre and states can authorize such monitoring; orders are valid for two months, are not extendable beyond six months; records are to be maintained, use of storage is limited and a review committee of cabinet secretary, law secretary and secretary of the telecom department regularly screens all cases.”</p>
<p style="text-align: justify; ">Menon also admitted that when it came to individual privacy rights, there were “larger issues that needed serious consideration and wider consultation with industry, advocacy groups and NGOs (non-governmental organizations) as has been the case so far in the draft privacy Bill... For data protection and retention in India, however, there may be a need to consider legislation or strengthening existing legislation, as the march of technology has made most present laws irrelevant.”</p>
<p style="text-align: justify; ">Privacy experts are convinced that safeguards are needed, especially since India does not have a privacy law.</p>
<p style="text-align: justify; ">“To safeguard public interest, the government should also draft a law that will make it a criminal offence if a CMS authority is found in possession of any personal information culled through the CMS. That will prove to be a deterrent,” said <span class="person"><a href="http://www.livemint.com/Search/Link/Keyword/Sunil%20Abraham">Sunil Abraham</a></span>, executive director of the Centre for Internet and Society, a privacy lobby body. “Also, the government must build an audit trail using PKI (public key encryption) and people as an additional safeguard.”</p>
<p style="text-align: justify; ">“As I understand it, there is also no clear statutory backing for the CMS,” said <span class="person"><a href="http://www.livemint.com/Search/Link/Keyword/Apar%20Gupta">Apar Gupta</a></span>, a partner at law firm Advani and Co. that specializes in information technology (IT) law. “What is important is that every tapping order should be backed by a reason. This was the case with the manual process. Will this be possible in an automated surveillance system such as the CMS?”</p>
<p style="text-align: justify; ">“What is disturbing is that there is no transparency with regard to the CMS. Everything is happening under the radar with media reports periodically giving us glimpses into the project,” he said. “A state should protect its interests but should do so in a manner that safeguards privacy and limits abuse.”</p>
<p style="text-align: justify; ">According to the <i>Freedom on the Net 2012</i> report by Freedom House, an independent privacy watchdog body, of the 47 countries analysed, 19 had introduced new laws or other directives since January 2011 that could affect free speech online, violate users’ privacy, or punish individuals who post certain types of content. India, which scored 39 points out of 100 (score achieved out of 100 for censoring the Internet), was termed partly free by the report, which was released on 24 September.</p>
<p style="text-align: justify; ">Globally, 79% of the respondents in another study said they were concerned about their privacy online, with India (94%), Brazil (90%) and Spain (90%) showing the highest level of concern, according to a June survey undertaken by research firm ComRes, and commissioned by Big Brother Watch, an online privacy campaign.</p>
<p>
For more details visit <a href='https://cis-india.org/news/livemint-july-30-2013-joji-thomas-philip-leslie-d-monte-shauvik-ghosh-your-telco-could-help-spy-on-you'>https://cis-india.org/news/livemint-july-30-2013-joji-thomas-philip-leslie-d-monte-shauvik-ghosh-your-telco-could-help-spy-on-you</a>
</p>
No publisherpraskrishnaTelecomInternet GovernanceCensorshipPrivacy2013-07-30T06:13:07ZNews ItemWorkshop on Set-top Boxes
https://cis-india.org/telecom/events/workshop-set-top-boxes
<b>The Centre for Internet and Society (CIS) is organising a one-day workshop in Delhi on Tuesday, July 12 on the evolution and state of the set-top box as an access device in India. </b>
<p style="text-align: justify;">The workshop will be conducted by Dr. Rakesh Mehrotra who is a professor at Sharda University. It will be supported by an advisor from the Telecom Regulatory Authority of India to cover the aspect of regulation. The workshop will focus on the expanding functionality and innovations in set-top box (STB) technologies. It will also include an exposition on the regulatory regime applicable to STBs, around issues of interoperability, competition and privacy, and conclude with an outlook on the future of STBs.</p>
<p style="text-align: justify;">We will initiate research collaborations with suitable participants to produce papers after the workshop. Certificates of participation will be provided.</p>
<h3>Apply</h3>
<p style="text-align: justify;">There are limited spots for participants. Please state your interest by filling out this form here- <a class="external-link" href="http://goo.gl/forms/Mj77h0nkeVBJgHJn2">http://goo.gl/forms/Mj77h0nkeVBJgHJn2</a> The deadline for filling application is <strong>July 5, 2016</strong>.</p>
<h3>Fee and Funding</h3>
<p style="text-align: justify;">There is no registration fee for the workshop. Participants will be served lunch and refreshments at the venue. Please note that there is no funding for travel and accommodation.</p>
<p> </p>
<p>
For more details visit <a href='https://cis-india.org/telecom/events/workshop-set-top-boxes'>https://cis-india.org/telecom/events/workshop-set-top-boxes</a>
</p>
No publishersinhaTelecomEventPrivacy2016-06-24T15:13:22ZEventWi-Fi Direct promises range, bandwidth higher than Bluetooth
https://cis-india.org/news/wi-fi-direct
<b>Sharing, printing and connecting for Wi-Fi devices is going to be more convenient than ever with soon-to-be-launched technology Wi-Fi Direct, which enables devices to connect to each other without a conventional Wi-Fi hub. This article by Ramkumar Iyer was published in the Hindu on 31 October 2010.</b>
<p>Previously known as Peer-to-Peer Wi-Fi, this new technology will allow the Wi-Fi Direct enabled devices to connect directly to each other anytime, anywhere.</p>
<p>It's much like Bluetooth except that it promises typical Wi-Fi range (up to 200 metres) and bandwidth (up to 250 mbps) much higher than what Bluetooth technology offers.</p>
<p>Moreover, the devices have a quick set-up mechanism, follow the latest security protocols and can easily connect to existing Wi-Fi networks.</p>
<h3>Seamless usage</h3>
<p>It means that the huge variety of existing Wi-Fi applications can be used with the new technology seamlessly.</p>
<p>The Wi-Fi Alliance — a coalition of technology industry giants that does the research and standardisation in Wi-Fi — announced on October 25 that it had begun certifying devices as being compatible with the new technology protocol. </p>
<p>According to the Wi-Fi Alliance Website, the technology can be implemented in any device such as cameras, mobiles, laptops and human interface devices.</p>
<h3>Single-tech solution</h3>
<p>“The Wi-Fi users worldwide will benefit from a single-technology solution to transfer content and share applications quickly and easily among devices, even when a Wi-Fi access point isn't available,” said Wi-Fi Alliance Executive Director Edgar Figueroa in a press release. </p>
<p>The technology is aimed at both consumer and enterprise applications and has a vast range of applications which aim at making gaming, sharing, printing and remote operations simpler and convenient.</p>
<p>While the Wi-Fi Direct's entry into the market may present new opportunities for application developers, it may be argued that such kind of range and speed can be easily misused.</p>
<h3>Security consciousness</h3>
<p>Bhaskar Ramamurthi, Professor at the Department of Electrical Engineering, IIT-Madras, agrees: “This technology poses a security risk because if just one device in a group is compromised, almost all the devices in the group are at risk too. And this is especially true of organisations, because unlike in the past, wireless data transfers can now take place without the organisation being able to monitor them and particularly over a larger area. </p>
<p>“People will now have to be more security conscious than ever. Especially, the ones with a previous case of security breach.”</p>
<h3>End of Bluetooth?</h3>
<p>Wi-Fi Direct not only has all the features of Bluetooth, but boasts superior transfer speeds and range. Does this mean the demise of Bluetooth? </p>
<p>Experts speculate that Bluetooth will not be affected much.</p>
<blockquote>
<p>“In an existing market where there are millions of Bluetooth-enabled devices, it is unlikely that any manufacturer will retire the technology just because of a new one.</p>
</blockquote>
<blockquote>
<p>“Bluetooth will not be affected much; at least in the next couple of years,” said Sunil Abraham, Executive Director of Centre for Internet and Society, Bangalore.</p>
</blockquote>
<p>Read the original in the <a class="external-link" href="http://www.thehindu.com/sci-tech/technology/article859680.ece">Hindu</a></p>
<p>
For more details visit <a href='https://cis-india.org/news/wi-fi-direct'>https://cis-india.org/news/wi-fi-direct</a>
</p>
No publisherpraskrishnaTelecom2011-04-02T08:13:27ZNews ItemWhy spectrum needs a change in approach
https://cis-india.org/telecom/blog/indian-express-rajat-kathuria-isha-suri-why-spectrum-needs-a-change-in-approach
<b>Rajat Kathuria and Isha Suri write: It must be recognised that spectrum needs to be combined with other infrastructure to enable service delivery.</b>
<p style="text-align: justify; ">One must bear in mind that the cost of deploying other infrastructure in remote areas is nearly twice as much, while revenue opportunities are far lower, damaging if not destroying the rural business case. The stark digital divide needs a fresh approach to crack it.</p>
<p style="text-align: justify; ">On September 22, the government released the draft Indian Telecommunication Bill, 2022, seeking to replace the colonial era Indian Telegraph Act, 1885. The draft bill compares spectrum to aatma: “In a way, spectrum is similar to aatma, which is ajar, amar as described in Shrimad Bhagwad Gita. Like aatma, spectrum too does not have any physical form, yet it is omnipresent.” And yet there is one immutable difference in this material world. While the value of aatma is inestimable, spectrum has always had a banal price tag associated with it.</p>
<hr />
<p><a class="external-link" href="https://indianexpress.com/article/opinion/columns/why-spectrum-needs-a-change-in-approach-8235997/">Click to access</a> the full article published in Indian Express on October 29, 2022</p>
<p>
For more details visit <a href='https://cis-india.org/telecom/blog/indian-express-rajat-kathuria-isha-suri-why-spectrum-needs-a-change-in-approach'>https://cis-india.org/telecom/blog/indian-express-rajat-kathuria-isha-suri-why-spectrum-needs-a-change-in-approach</a>
</p>
No publisherRajat Kathuria and Isha SuriTelecom2023-01-18T23:35:10ZBlog EntryWho Minds the Maxwell's Demon (Revisiting Communication Networks through the Lens of the Intermediary)
https://cis-india.org/telecom/blog/who-minds-the-maxwells-demon
<b>A holistic reflection on information networks and it’s regulatory framework is possible only when the medium-specific boundary that has often separated the Internet and Telecom networks begins to dissolve, to objectively reveal points of contention in the communication network where the dynamics of network security and privacy are at large – namely, within the historic role of the intermediary at data/signal switching and routing nodes. </b>
<p style="text-align: justify; ">It is unfair to contextualize the history of the Internet without looking at how analog information networks like cable and wireless telegraph and later, the telephone, almost coincidentally necessitated the invention of automated networks for remote machine control and peer-to- peer communication over the Internet that promised to drastically reduce intermediary overheads. While the whole world was fraught in patent wars over wired private networks, the first nodes of the ‘open’ internet were built in a two-week global meeting of computer scientists who were flown down to simply prepare for ‘a public exhibition’ of the ARPANET in 1971.</p>
<p style="text-align: justify; ">While India only received it’s first telephone in New Delhi late into the 20<sup>th</sup> century, “Telegraph Laws” to most of the Indian working class always remained an ominously urgent telegram that brought the news of a dear one who had taken seriously ill. And so, on a lateral note, it is apt to bring to light the life of one Mr Almond Brown Strowger, wherein the idea of an automatic telephone exchange was given birth to by the <b>‘business of death’.</b></p>
<p><i> </i></p>
<h3>The Automatic Telephone Exchange</h3>
<p style="text-align: justify; ">Almond Strowger was an undertaker based in Missouri, in a town where there was yet another undertaker, who’s wife incidentally was an operator in the then manual telephone exchange. Strowger came to believe the reason he received fewer phone calls was that his business competitor’s wife ended up preferentially routing all callers seeking Strowger’s funeral services to her undertaker husband instead. Strowger conceived the initial idea in 1888 and patented ‘The Automatic Telephone Exchange’ in 1891. <a href="http://goo.gl/oieIJ">http://goo.gl/oieIJ</a></p>
<table class="listing">
<tbody>
<tr>
<th><img class="image-inline" src="../../internet-governance/blog/resolveuid/8ec6c81ad81940739eb4fcaa67ad1da2" /></th>
</tr>
</tbody>
</table>
<p style="text-align: justify; ">Popularly known as the ‘Strowger Switch’, the Step-by Step switch (SXS switch) consisted of two interfaces – One at the customer’s end that used telegraph keys (and later a rotary dial) to send a train of electric current pulses corresponding to the digits 0 -9 all the way to the exchange. The actual Strowger switch at the exchange, used an electromechanical device that could move vertically to select one of 10 contacts, and then rotated to select one of another 10 in each row – a total of 100 choices. Consequently was formed in 1892, the Strowger Automatic Telephone Exchange Company at Indiana with about 75 subscribers. Strowger later sold his patents for $10,000 in 1898 to the Automatic Electric Company, a competitor of Bell System’s Western Electric. His patents were eventually acquired by Bell systems for $2.5 million in 1916, showing just how much growth and investor interest the telephone industry had gained by then.</p>
<h3 style="text-align: justify; ">Switching Paradigms</h3>
<p style="text-align: justify; ">The architecture of global communication was headed towards different ideals and directions. Most media historians contrast these methodologies into ‘circuit switching’ and ‘packet switching’, or a connection-oriented fault intolerant system on one hand and another connection-less fault tolerant protocol respectively, both of which were being developed concurrently. In reality however, a major driving factor were the stakeholders backing the infrastructure of the rapidly growing communication industry, who were looking for growing returns on their investments. And hence these parallel ramifications may also be looked at through the lens of closed proprietary and medium specific networks versus an open, shared, medium in-specific paradigm of information theory.</p>
<p style="text-align: justify; ">Circuit switching relied on an assured dedicated connection between 2 nodes, and was especially patronized by the industry that saw telecommunication as the latest fad in urban luxury (a key factor in the distinction of suburban areas as the affluent moved into urban areas that were ‘connected’ by telephone). Owners and manufacturers of the hardware infrastructure became the most significant stakeholders. The revenue model was based on the amount of time the network was used and hence was popular in analog voice telephone networks.<b> </b>The entire bandwidth of the channel was made available for the duration of the session along with a fixed delay between communicating nodes. Therefore, even if there was no information being transmitted during a session, the channel would not be made available to anyone else waiting to use it unless released by the previous party. Early telephone exchanges relied on manual labour to facilitate switching until the automated exchange came about.</p>
<p style="text-align: justify; ">Packet switching on the other hand, leaned towards the paradigm of shared bandwidth and resources, and more importantly approached communication with complete disregard to the medium of transmission, be it wired or wireless. Furthermore, it also disregarded the content, modality and form of communication with an objectified data-centric approach. Information to be transmitted was divided into structured “packets” or “capsules”. These packets were all ‘thrown’ into the shared network pool consisting of numerous other such packets, each with its own destination, to be carefully buffered, stored and forwarded by intermediary routers in the network. Apart from occasional packet loss, the time taken to send a message is indeterminate and is dependent on the overall traffic load on the network at any given time.</p>
<h3 style="text-align: justify; ">INTERFACE MESSAGE PROCESSOR and the ICCC ‘Hackathon’</h3>
<p style="text-align: justify; ">Plans forged on into the early 1960s towards the development of an open architecture to enable network communication between computer systems, culminating in the invention of the ‘interface message processor’ that promised to herald the coming of an era of packet switching by enabling the ARPANET (Advanced Research Projects Agency Network), the first wide area packet switched network – and precursor to the world wide web as we know it today.</p>
<p style="text-align: justify; ">While the Information Processing Techniques Office (IPTO) had previously contracted Larry Roberts who in 1965 developed the first packet switched network between two computers , the TX-2 at MIT with a Q-32 in California, a growing need was felt to have a centralized terminal with access to multiple sites that would enable any computer to connect to any site. The first IMP was commissioned to be built by the engineering firm BBN (Bolt, Beranek and Newman, a professor student trio from MIT).</p>
<table class="listing grid">
<tbody>
<tr>
<th><img class="image-inline" src="../../internet-governance/blog/resolveuid/b1a67e16e3314a0e854294ab95758314" /></th>
</tr>
</tbody>
</table>
<p>(The very first Interface Message Processor by BBN: Courtesy: <a class="external-link" href="http://goo.gl/tvo8n">http://goo.gl/tvo8n</a>)</p>
<p style="text-align: justify; ">By 1971, the four original nodes that connected the ARPANET (viz, UCLA, Stanford Research Institute, University of Utah and University of California at Santa Barbara) had expanded to 15 nodes, but the lack of a common host protocol meant that a full-scale implementation and adoption of the ARPANET was far from complete. The time had come to allow the public to engage with the promising future that the Internet held. What entailed was the organization of first public International Conference on Computer Communication (1972) (<a href="http://goo.gl/PFhtL">http://goo.gl/PFhtL</a>) under the umbrella of the IEEE Computer Society at the Hilton Hotel, Washington D.C. In many ways the event was the original version of a modern day new media art ‘hackathon’ and involved about 50 computer scientists who were flown in from around the globe alongside the likes of Vint Cerf and Bob Metcalfe. The deadline of a public demonstration provided the much-needed impetus to drive the network to functional completion. Exhibits included a variety of networked applications like the famed dialogue between the ‘paranoid patient’ chatbot PARRY and doctor ELIZA, motion control of the LOGO ‘Turtle’ across the network and remote access of digital files that were printed on paper locally. A milestone in distributed packet switching had been achieved and the stage had been set to compete with the archaic paradigm of circuit switched networks, even as delegates from AT&T (incidentally one of the funders of the event) watched on with the hope that the demonstration would run into a fatal glitch.</p>
<h3 style="text-align: justify; ">Who Minds the Maxwell's Demon</h3>
<p style="text-align: justify; ">It may not be boldly evident from the vast corpus of policy research surrounding the regulation of communication networks (be it the issues of network security, privacy, anonymity, surveillance or billing systems) that key-points in the control system where dynamics play at large, are at the interfacing nodes and data/signal switches at either transceiver nodes as well as intermediary nodes. This is further underlined by the historical fact that the invention of the automatic telephone exchange was fuelled by the necessity to ensure a paradigm of unbiased circuit switching within the context of a networked business.</p>
<p style="text-align: justify; ">Just a glimpse at the number of patents that directly or indirectly refer to the Automatic Telephone Exchange patent shall bring to light myriad applications that range from “Linking of Personal Information Management Data”, “Universal Data Aggregation”, “Flexible Billing Architecture”, ”Multiple Data Store Authentication” , “Managing User to User Contact using Inferred Presence Detection” to various paradigms surrounding distributed systems for cache defeat detection, most of which are part of PUSH technology services that manage networked smartphone applications from instant messaging to email access. Other proposed systems for spectrum management and dynamic bandwidth allocation, such as policy alternatives to spectrum auction that entail frequency hopping at the transmitter level shall invariably depend on a centralized automated intermediary who shall in theory have transparent access to data flow. The role of routing intermediaries with specialized access, poses many interesting questions with regards to policy issues that surround network privacy and security.</p>
<p style="text-align: justify; ">This brings us back to the seemingly comical reference that this article makes to a mysterious entity named the ‘Maxwell’s Demon’. A thought experiment proposed by James Clerk Maxwell, involved a chamber of gas molecules at equilibrium that was divided into two halves along with a ‘door’ controlled by the “Maxwell’s Demon”. The demon had the ability to ‘open’ the door to allow faster than average molecules to enter one side of the chamber while slower molecules ended up on the other side of the chamber, causing the former side to heat up while the other side gradually cooled down, thereby establishing a temperature difference without doing any work, and thus violating the 2<sup>nd</sup> Law of Thermodynamics. The parallel drawn in this article between networked switching intermediaries and the Maxwell’s demon does not go beyond this simple functional similarity.</p>
<p style="text-align: justify; ">However for the ambitious reader, it maybe interesting to note that ever since the invention of digital computers, scientists have actively pursued the paradox of Maxwell’s demon to revisit physical fundamentals governing information theory and information processing, which has involved analyzing the thermodynamic costs of elementary information manipulation in digital circuits – A study that probably constantly engages Google as they pump water through steel tubes to cool their million servers.</p>
<p style="text-align: justify; ">We shall save all this for another day, but on yet another related note, everytime say an email sent to an invalid address bounces back to your inbox as a “Mailer Daemon”, let it be known that the “Daemon” in Operating System terminology that refers to an invisible background process that the user has no control over, infact directly owes it’s etymology to the paradox of ‘Maxwell’s Demon’.</p>
<p>
For more details visit <a href='https://cis-india.org/telecom/blog/who-minds-the-maxwells-demon'>https://cis-india.org/telecom/blog/who-minds-the-maxwells-demon</a>
</p>
No publishersharathTelecom2013-03-05T07:37:37ZBlog EntryWhat's Needed Is User-Centric Design, Not Good Intentions
https://cis-india.org/telecom/blog/organizing-india-blogspot-shyam-ponappa-january-6-2013-what-is-needed-is-user-centric-design-not-good-intentions
<b>The inadequacy of essentials and conveniences around us results from a slack approach to both design and execution. We know we are deficient in execution, but we need to be more aware of deficiencies in approach and design. Good intentions, while important, cannot substitute for good systems design and execution.
</b>
<hr />
<p>Shyam Ponappa's column was published in <a class="external-link" href="http://organizing-india.blogspot.in/2013/01/whats-needed-is-user-centric-design-not.html">Organizing India Blogspot</a> on January 6, 2013 and in the <a class="external-link" href="http://www.business-standard.com/india/news/shyam-ponappa-design-not-good-intentions/497562/">Business Standard</a> on January 3, 2013.</p>
<hr />
<p style="text-align: justify; "><b>Things That Work…</b><br />Simple aspects of everyday living that actually work in India can leave one wonderstruck. Like the daily newspapers, organised and delivered seamlessly, reasonably early in the day, almost regardless of where one lives provided it’s a city or town. Or the availability of milk, eggs, bread, vegetables, fruit, and whatever else for daily provisions. And this despite the supposed shortcomings of our logistics and organisation in the context of wholesale and retail markets. Some of the revolutions that we’ve lived through in the last two decades include the manifestation of such wonders, like the phenomenal and ubiquitous growth in the supply of dairy and poultry products.<br /> <br /> On a different plane, as it were, are the changes in the quality of automobiles and the improvements in India’s roads, although patchy and considerably lagging. Likewise, there have been revolutions in mobile communications and in air travel, disregarding anomalies such as the horror of Mumbai airport on private airlines, with its incompetent cab mafia on arrival, and a disorganised and demeaning crush on departure, squeezing past crowded boarding gates. (This is the state of the commercial capital? Woe betide us — but I digress...) Another source of wonder is the performance of the Indian Railways. Much abused by exploitative politicians, given short shrift on everything from cleanliness and toilets to much else, overloaded by hapless passengers in desperate need of transportation. One can only marvel at these services.</p>
<p style="text-align: justify; "><b>…And Things That Don’t</b><br />And yet, there are debilitating areas that seem utterly intractable, like sanitation, water, power supply and communications services for data (apart from voice).</p>
<p style="text-align: justify; ">Comparing the state of sanitation or power with the railways, one might say the latter had the benefit of being set up as an integrated system since the 1850s, although deprived in recent times of systematic development and investment, and so reduced to decrepitude. By contrast, sanitation has been playing catch-up on our old, established society, behind the curve for hundreds of years, never having had the advantage of installation as <i>ab initio</i> systems. Open drains are an Indian feature, even in Delhi. A similar situation obtains in power supply, where the contradictions and inequities of piecemeal, encapsulated interventions that tried to address power generation first were followed by sporadic efforts to address transmission and distribution, with realpolitik all the while playing to the users’ self-indulgence of having it all without paying for it. This sense of entitlement without accountability has resulted in the vicious circle of “free power” that leads to no power, annihilating possibilities for improvement.</p>
<p style="text-align: justify; ">In communications services for data (broadband), we have a different kind of problem. For one, governments, citizens and activists don’t seem to get it that these services are as essential to infrastructure as energy and transportation. There is no logic to their exclusion, but it has taken the National Telecom Policy of 2012 (NTP-2012) to announce the objective that telecom is part of infrastructure, although the associated benefits, such as lower interest rates, are yet to follow.</p>
<p style="text-align: justify; "><b>User-Centric Systems</b><br />The malady with sectors such as power, communications and transport is that solutions seem to be designed without an integrated, end-to-end, goal-oriented perspective favouring users. For instance, otherwise successful initiatives like the Delhi Metro provide services from an islanded “product perspective” that is simply not user-centric in its orientation. This results in insufficient feeder buses, inadequate parking at the Metro stations, a gaggle of disorganised cycle-rickshaws at stations like Mayur Vihar, and so on. Instead of being an unadulterated blessing, a Metro station in the neighbourhood becomes a curse, because user needs are not treated as being central to the delivery of the service. Passengers are left floundering while people in the environs (like the denizens of Mayur Vihar) are left to fend for themselves. There is also the question of capacity and demand. Again, the “product perspective” results in overcrowding and other inconveniences. On the flip side, well-meaning though misguided critics attack attempts to build capacity in anticipation of demand, as was the Metro by proponents of a Bus Rapid Transit system pushing for the latter as a silver bullet instead of as an adjunct.</p>
<p style="text-align: justify; "><b>What Could Have Been, But Isn’t Yet<br /></b><span>The Unique Identification Authority of India’s Aadhaar augured a potentially revolutionary electronic enabler. In practice, however, its design has been baffling. A brilliant concept – abstracting a smart identification number from a smart card – has been reduced to an identifier for cash transfers to bank accounts. The question is, why to bank accounts and not to transactions, whether for retail or for services, activated by a mobile phone? Kenya’s M-Pesa was the pioneer for mobile money transfer, subsequently enhanced to include interest earned on virtual accounts.<a href="#fn*" name="fr*">[*]</a> Introduced in India by ICICI Bank with Vodafone in November 2012 and State Bank of India in January 2013, not only would this be much more practicable as the majority of our population doesn’t have bank accounts, it would cost far less, while being much more convenient for users. It would obviate setting up millions of physical micro-accounts at relatively high cost at banks, as well as giving users proximate access to products and services.</span></p>
<p style="text-align: justify; "><span>Another puzzling aspect is the contradictory, sometimes changing signals about Aadhaar. It is supposedly voluntary, yet reportedly mandatory now for marriage registrations, yet not accepted by banks for account opening, nor by some mobile phone operators, nor for passport applications, nor for driver’s licences. And inexplicably, except as a ruse to garner votes from non-citizens, it is for all residents (who choose to apply?), and although it could include citizenship information, it doesn’t.</span></p>
<p style="text-align: justify; "><span>It is best to start out right, recognising that we need user-centric, end-to-end systems design and execution, and apply this approach across the board going forward.</span></p>
<hr />
<p style="text-align: justify; ">[<a href="#fr*" name="fn*">*</a>]. <a class="external-link" href="http://on.ft.com/UpzONs">http://on.ft.com/UpzONs</a></p>
<p>
For more details visit <a href='https://cis-india.org/telecom/blog/organizing-india-blogspot-shyam-ponappa-january-6-2013-what-is-needed-is-user-centric-design-not-good-intentions'>https://cis-india.org/telecom/blog/organizing-india-blogspot-shyam-ponappa-january-6-2013-what-is-needed-is-user-centric-design-not-good-intentions</a>
</p>
No publisherShyam PonappaTelecom2013-01-25T11:26:40ZBlog EntryWhat a highway can do
https://cis-india.org/telecom/blog/what-a-highway
<b>Despite signs of transformational change, we need more - SOPs and quality</b>
<p>Even as the country reels from the extended rains and the imminent Commonwealth Games, there are unmistakable signs in Delhi’s environs of an unprecedented transformation. To see and feel this, try driving to the Delhi-Noida toll bridge (the “DND”), and go past Noida on the expressway to Greater Noida.</p>
<p>It isn’t perfect, and there are many details that could be handled better, from the assets built to how we use them. These include unfinished verges with construction debris near the Ashram crossing, cambers without proper drainage that get flooded in some stretches of the expressway, motorcyclists sheltering from the rain under the flyovers/overpasses spilling on to the expressway, pedestrians with no place to cross, trucks at night without even reflectors, trucks that are parked without hazard lights, tractors, and occasional cattle. Most dangerous are the undisciplined drivers who act as if they are puttering along at 30 km per hour while going at the 100 km speed limit or more, or who drive on the wrong side against oncoming traffic. And the resurfacing of the road in parts leaves much to be desired…</p>
<h2>The transformation under way</h2>
<p>Ignore this cavilling and carping, however, and it is bliss. One can cover 30 km from the DND toll plaza to Greater Noida in 20 minutes legally, although within New Delhi, it may take as long or even longer to travel just a few kilometres. I was amazed recently driving from Shantiniketan to Greater Noida in 40 minutes. It was like driving in California — quite different from the contentious driving that is customary on our roads.</p>
<p>The sheer ease and convenience apart, another, arguably greater, benefit is the gain in productivity. It is this potential for productivity that, if we can wring from ourselves, is one part of the equation in our pursuit of an improved quality of life. It is especially important because of our vast numbers, including the much-bruited potential demographic dividend, which is not new. As Babur put it in the 16th century*: “…if they fix their eyes on a place in which to settle …as the population of Hindustan is unlimited, it swarms in.” Little has changed, and much needs to be built from the ground up, starting with sanitation and water, not to mention energy, communications, and transportation systems.</p>
<p>But just consider: the limited instance of the drive on the expressway reveals a productivity gain of three to four times at 20 minutes for covering 30 km, compared with covering only 7-10 km in the same time (or taking three to four times longer for 30 km). That’s a gain of 300-400 per cent!</p>
<p>There’s another noticeable change: a willingness of everyone to work very much harder at whatever they do. All levels of people, from entrepreneur-managers to electricians, plumbers, gardeners, and day labourers, work so hard that a major change seems to be afoot. I am familiar with the hardworking farmer and rural wage earner, having grown up on a farm myself. I have also experienced the recalcitrance of some public sector employees and private sector unions, as well as the productive, hard-charging PSU, government, and private sector employees. Yet, in the work attitudes of boomtown Greater Noida, I see impressive energy and application.</p>
<h2>The failings</h2>
<p>Let me not gloss over the weaknesses. There are big failures in delivery capability, and these arise from two critical lacunae:</p>
<p>a) <strong>SOPs, systems and procedures</strong></p>
<p>A major failing appears to be the lack of Standard Operating Procedures (SOPs) even for simple construction jobs, like painting metal: the ramrod, sequential steps of first scrape, then clean, apply primer, apply the first coat of paint and dry off; then apply the second coat… People simply don’t follow sound work practices — systems and procedures that, when applied, yield consistent good results. This is partly an endogenous failing, arising from lack of appropriate education/training and discipline. It is also partly attributable to the lack of organised systems and procedures.</p>
<p>b) <strong>Infrastructure</strong></p>
<p>An equally critical exogenous failing of the environment is reliable infrastructure, whether in the form of energy (power/electricity), communications, transportation excepting a one-off good stretch of highway, or water and sanitation. Take any single area, say energy. The extent of wasted manpower because of lack of adequate electricity supply is beyond imagination.</p>
<p>Add the bases for learning and functioning competently, and there’s education (including training) and health care as a support function. Proper education and training — and discipline — are absolutely essential for learning and developing sound work processes, and for applying them. There was an impression many years ago that incompetence or recalcitrance in delivery resulted from the inadequate capacity of individuals. In the last several years, it is evident that we have good people, but they have very poor training, systems and organisation, and equally poor infrastructure. You could call it a lack of leadership and discipline at all levels.</p>
<h2>What we need</h2>
<p>We need two sets of fixes. The first is for our inherent failings: the lack of SOPs and the need to learn to work to inexorable checklists and timelines. It is imperative to learn the discipline of project management at all levels — starting from the top, not the bottom! This is a sweeping change that entails shifting from feudal criteria to respect for professional competence and processes.</p>
<p>The second fix required is a supportive environment: good infrastructure and the appurtenances of good policies. Going by the figures, we will build more roads, power plants and factories in the next few years than in the last 60. But the net gain to society will depend on their quality. If they are shoddy, the gains will be much less. Assets that are not integrated into coherent systems will be less beneficial than if they are integrated to deliver results, e.g. isolated housing without a web of transportation and communication links near where people work; isolated good stretches of highway. It is imperative that we design and execute the infrastructure to support our productivity. This is an area of weakness we must address and execute more comprehensively.</p>
<p>Read the original in <a class="external-link" href="http://www.business-standard.com/india/news/shyam-ponappa-whathighway-can-do/406622/">Business Standard</a></p>
<p>
For more details visit <a href='https://cis-india.org/telecom/blog/what-a-highway'>https://cis-india.org/telecom/blog/what-a-highway</a>
</p>
No publisherShyam PonappaTelecom2012-05-10T10:26:52ZBlog EntryUse of DPI Technology by ISPs — Response by the Department of Telecommunications
https://cis-india.org/telecom/dot-response-to-rti-on-use-of-dpi-technology-by-isps
<b>CIS filed requests under the Right to Information with the Department of Telecommunications, Telecom Regulatory Authority of India, BSNL and MTNL, asking a number of questions related to the use of Deep Packet Inspection (DPI) technology by Internet Service Providers (ISP) in India and corresponding regulations.</b>
<p style="text-align: justify; ">We raised the following questions with the Department of Telecommunications (DoT) and the Telecom Regulatory Authority of India (TRAI):</p>
<ol>
<li style="text-align: justify; ">Do ISP's in India (public and private) use DPI technology? Please provide details of all ISPs known to use this technology.</li>
<li style="text-align: justify; ">Please provide copies of documents relating to rules and regulations and license agreements for use of DPI (infrastructure and processes) by ISPs in India.</li>
<li>What are the purposes for which this technology is used in India?</li>
<li style="text-align: justify; ">Please provide details and copies of documents relating to regulation of network traffic management by ISPs in India.</li>
</ol>
<p style="text-align: justify; ">DoT has responded to this application, while the response from the TRAI is awaited.</p>
<p style="text-align: justify; ">According to the DoT response to the RTI "as per the present License for provision of Internet Services, based on Internet Guidelines dated 24/08/2007, there is no direction/reference for DPI as mentioned in your RTI application."</p>
<ol> </ol>
<p>The following questions were asked of BSNL/ MTNL:</p>
<ul>
<li style="text-align: justify; ">As a national Internet service Provider, does BSNL deploy DPI on any Internet network in India? If so, please provide details of equipment used, including, but not limited to</li>
</ul>
<ol>
<li>Hardware and software</li>
<li style="text-align: justify; ">Details of purchase (manufacturer, date, price)</li>
<li>Technical specifications</li>
</ol>
<ul>
<li style="text-align: justify; ">Please provide details of the nature of information obtained through DPI of Internet networks and clear details of what purpose such information is used for.</li>
</ul>
<ul>
<li style="text-align: justify; ">Please provide details and copy of documents pertaining to traffic management and traffic shaping policies followed by BSNL.</li>
</ul>
<p style="text-align: justify; ">MTNL has responded to the application, while the response from BSNL is awaited. In response to the above questions, MTNL sent the following reply:</p>
<p><ol>
<li>MTNL does not do any DPI.<br />a. 1(1), 1(2), 1(3): not applicable in view of reply 1 above</li>
<li>Not applicable in view of reply 1 above.</li>
<li>Not applicable in view of reply 1 above.</li>
</ol></p>
<ol> </ol><ol> </ol>
<p style="text-align: justify; ">While MTNL has denied the deployment of DPI technology in their networks, it is interesting to note that they have avoided providing details of their traffic management policies.</p>
<p>For a scanned version of the response we got from the Department of Telecommunications, <a href="https://cis-india.org/telecom/use-of-dpi-technology-by-isps.pdf" class="internal-link">click here</a>.</p>
<p>
For more details visit <a href='https://cis-india.org/telecom/dot-response-to-rti-on-use-of-dpi-technology-by-isps'>https://cis-india.org/telecom/dot-response-to-rti-on-use-of-dpi-technology-by-isps</a>
</p>
No publisherSmita MujumdarTelecom2012-07-19T07:45:17ZBlog Entry Unlock = Open, not Choked!
https://cis-india.org/telecom/blog/unlock-open-not-choked
<b> Don't let a virus stall initiatives and weaken the economy.</b>
<p>This article first appeared in the <a class="external-link" href="https://www.business-standard.com/article/opinion/unlock-open-not-choked-120060400079_1.html">Business Standard</a> and on June 4, 2020.</p>
<hr />
<p> </p>
<p>A
recent column in this newspaper juxtaposed the way smart, experienced
people have high expectations, only to be disappointed by our weak
state’s predictable failures (<em><a href="https://www.business-standard.com/article/opinion/strong-expectations-from-a-weak-state-120052401090_1.html" rel="nofollow" target="_blank">Strong expectations from a weak state</a>, May 25</em>).
Is there justification for any optimism, or at least hope? Here is an
exploration of reasons for persisting in the face of continued odds, and
pushing for economic recovery. Why should one persist with constructive
efforts? Because a rising tide lifts all boats, and one’s contribution
can affect outcomes. And because attempts at partial opening will not
suffice.</p>
<div>
There could be new economic opportunities by way of capacity, logistics
or markets, or a wider array of sustainable consumer choices, whether
for manufactured goods, services, or activities. Think back, and surely
you have witnessed government action extend beyond the grind of just
keeping everything going.</div>
<div>
One instance of major change that affected the economy was in 1990, when
the secretary of the Department of Electronics N Vittal worked in close
consultation with industry. This resulted in path-breaking reforms,
such as the setting up of “high-speed” links (of a mere 64 kilobits per
second at the time) between Information Technology (IT) companies in
Indian software technology parks and their international clients, and
various tax incentives that followed much later. The offshore services
industry gathered strength, and later expanded to cover IT-enabled
services with call centres and business processing, extending to
knowledge processing.</div>
<div>
Likewise, telecommunications reforms began in 1990, when prime minister
Chandra Shekhar led a shaky government for a brief period. The
telecommunications ministry was looking for a private sector consultant.
Through an invisible network, an investment banker who had been a
management consultant in San Francisco was asked to look into
telecommunications reforms. This led to the setting up of the Athreya
Committee and its recommendations: On separating policy-making from
operations, corporatising the Mahanagar Telephone Nigam as an operating
company for Delhi and Mumbai, and Bharat Sanchar Nigam for the rest,
while recommending access to private sector operators. All this was not
smooth and painless, and took years, but did happen eventually, although
the separation remains untidy.</div>
<div>
By 1998, telecommunications operators were in a situation similar to the
predicament some months ago, of weak revenues and a debt overhang, with
some differences. There were many operators with heavy debt because of
government charges and limited revenue generation capacity, because of
smaller networks and less clients. This is the “winners’ curse” of
auctions, when exorbitant amounts are paid to government for auctions,
with nothing left for building and running networks and enterprises to
generate the revenues to justify those payments. There are exceptions,
as in the social democrat Nordic states, or state-controlled allocations
as in China, or in Japan for a number of years.</div>
<div>
Key people in government grasped this. The Prime Minister’s Office
consulted with industry and external consultants, and took action. This
resulted in the New Telecom Policy 1999 (NTP-99), whereby the major
change was converting up-front licence fees to revenue sharing, although
the policy was uneven because of cherry-picked recommendations.
Initially, the government set the percentage share too high. It took
years to reduce and trigger rapid growth. This came about through
reduced government charges, calling party pays (which cut call costs),
and a price war, brought on by the stealth entry of a new technology
(CDMA) network, which the authorities allowed despite incumbent
protests. Mobile services then grew exponentially from 2004, until the
2G spectrum scam surfaced in 2011.</div>
<div>
A stream of articles advocated extending revenue-sharing to spectrum
fees as for licence fees, and for shared infrastructure including
spectrum. In 2011, a senior official in the DoT was sufficiently
impressed to explore the possibility of evaluating alternatives using
simulation models. But the 2G scam broke after the first few meetings of
DoT officials, and this process was aborted. Instead of major changes
based on simulations, a mere statement of intent about spectrum pooling
and sharing made it into NTP-2012.</div>
<div>
There were other incredible developments, although with no apparent
results (yet). For instance, in 2013, a non-governmental organisation,
the Centre for Internet and Society in Bengaluru, arranged for the
former chief technology officer of the US Federal Communications
Commission, Jon Peha, who had pioneered changes in America, to meet with
top officials of the DoT, the Telecom Regulatory Authority of India,
and some IIT professors. The latter conducted successful trials using TV
White Space spectrum for the Ministry of Electronics and Information
Technology. The details are many, but the point is that constructive
advocacy can have an impact.</div>
<div>
<strong>Reviving the Economy Now</strong></div>
<div>
We are in a difficult situation, with our economy and society battered
by the lockdown and much else. We will need to do everything possible to
recover, and it will take years. Attempts at partial opening will not
suffice. Systemic revival calls for unrestricted flows of money, people,
activity, and goods and services.</div>
<div>
While reactivating the economy, we will need to be cautious through the
pandemic (through “social distancing”, using masks to reduce infection,
avoiding close contact with outsiders, and so on). But survivors have to
live with this virus, as with other strains of viruses and bacteria,
and other threats.</div>
<div>
Consider traffic accidents, which average over 145,000 deaths annually (data 2013-2017: <a href="https://ncrb.gov.in/sites/default/files/chapter-1A-traffic-accidents-2017_0.pdf">https://ncrb.gov.in/sites/default/files/chapter-1A-traffic-accidents-2017_0.pdf</a>).
Extrapolating, this means a million fatalities in seven years, yet we
don’t shut down all traffic. By comparison, Covid-19 had about 6,000
fatalities since January.</div>
<div>
A proportion of the medical fraternity opines that (a) there is
community spread of Covid-19, and (b) with many cases milder than the
expected severity, that most patients need home care rather than
hospitalisation. If these continue, our health systems will not be
overwhelmed with severe cases. Also, so far, India has had a relatively
low fatality rate of 2.8 per cent (<em>see chart</em>).</div>
<p> </p>
<p> </p>
<p><img src="https://cis-india.org/telecom/case-fatality-rate/" alt="null" width="50%" /></p>
<p> </p>
<div>
Source: Data - <a href="https://ourworldindata.org/coronavirus">https://ourworldindata.org/coronavirus</a></div>
<div>
As long as these factors hold, our priority has to be unfettered
economic activity. Countries with higher fatality rates, including
Sweden, China, Japan and Germany in the chart, have open economic
activity (with tremendous productivity). We will weaken and our problems
will escalate if we are held back.</div>
<p> </p>
<p>
For more details visit <a href='https://cis-india.org/telecom/blog/unlock-open-not-choked'>https://cis-india.org/telecom/blog/unlock-open-not-choked</a>
</p>
No publisherShyam PonappaTelecomEconomicsCovid192020-06-15T03:04:18ZBlog EntryUnlicensed Spectrum Policy Brief for Government of India
https://cis-india.org/telecom/unlicensed-spectrum-policy-brief-for-govt-of-india
<b>Centre for Internet & Society and the Ford Foundation are delighted to bring you the Unlicensed Spectrum Policy brief for Government of India. The policy brief authored by Satya N Gupta, Sunil Abraham and Yelena Gyulkhandanyan contains an Executive Summary and eight chapters. The research aims to recommend unlicensed spectrum policy to the Government of India based on recent developments in wireless technology, community needs and international best practices.</b>
<h2>Executive Summary</h2>
<p>The aim of this policy brief is to recommend unlicensed spectrum policy to the Indian Government based on recent developments in wireless technology, community needs and international best practices. We seek to demonstrate the need for and importance of unlicensed spectrum as a medium for inexpensive connectivity in rural/remote areas and source of innovation by serving as a barrier-free and cost-effective platform for testing and implementing of new technologies.</p>
<p>The specific frequency bands that we request for unlicensing are: 433-434 MHz, 902-928 MHz, 1880-1900 MHz, 2483-2500 MHz, 5150-5350 MHz, and 5725-5775 MHz. These demands reflect the widespread market adoption in countries where these bands have already become unlicensed.</p>
<p>Interference concerns to licensed users, which are the predominant reason for the limited allocation of unlicensed spectrum, are greatly diminished. Interference-free spectrum use by multiple operators is enabled by the short-range, low-power nature of most of the technologies operating in these spectrum bands, as well as innovative techniques that facilitate spectrum sharing.</p>
<p>Technological advancements such as Wireless Local Area Network (WLAN), Ultra Wide Band (UWB), Radio Frequency Identification (RFID), Near -Field Communication (NFC) systems, and others have demonstrated that when an opportunity for cost-efficient and flexible spectrum usage is presented in the form of unlicensed spectrum, the market is likely to respond through innovation and expansion.</p>
<p>The value of unlicensed spectrum in bridging the digital divide has been demonstrated through community wireless networking projects as well as inexpensive ITES (IT enabled services) operating on unlicensed spectrum that have been created to spread connectivity to digitally-marginalized areas. As demonstrated by numerous case studies, such networks administer e-learning, e-commerce, telemedicine, e-agriculture, and many other initiatives that lead to equitable social and economic growth, making unlicensed spectrum a “public good”.</p>
<p>The International Telecommunication Union (ITU), European Union telecom regulatory bodies, as well as leading state telecom policy makers and regulators such as the FCC (U.S. Federal Communications Commission) and OFCOM (UK Office of Communications) have recognized that the optimal use of radio spectrum is dependent on flexible spectrum management policies and the multi-time sharing of this precious resource. Of late, the relevance of unlicensed spectrum is being recognized by policy makers in India as well. This is evident from the National Telecom Policy 2012, as well as recent remarks on the subject made by senior government officials.</p>
<hr />
<p>Download the Unlicensed Spectrum Policy brief for Government of India below:</p>
<ul>
<li><a href="https://cis-india.org/telecom/unlicensed-spectrum-brief.pdf" class="internal-link" title="Unlicensed Spectrum Policy for Government of India">PDF Document</a> [519 Kb]</li>
<li><a href="https://cis-india.org/telecom/unlicensed-spectrum-brief.doc" class="internal-link" title="Unlicensed Spectrum Policy brief for Government of India">Word File</a> [124 Kb]</li>
</ul>
<p>
For more details visit <a href='https://cis-india.org/telecom/unlicensed-spectrum-policy-brief-for-govt-of-india'>https://cis-india.org/telecom/unlicensed-spectrum-policy-brief-for-govt-of-india</a>
</p>
No publisherSatya N Gupta, Sunil Abraham and Yelena GyulkhandanyanTelecomPublications2012-09-11T16:23:45ZBlog EntryUnfettering Stranded Capacity
https://cis-india.org/telecom/blog/organizing-india-blogspot-shyam-ponappa-june-4-2015-unfettering-stranded-capacity
<b>Government can't control market forces, but can and must fix regulatory issues. First, the good news: the government does appear to be making serious efforts to tackle stranded capacity and stalled projects, as in the instances below. Such issues need to be resolved because of their effect on future investment and employment. Now, the bad news: one part is that some problems need solutions which are fraught with political risk.</b>
<p style="text-align: justify; ">The article was published in the <a class="external-link" href="http://www.business-standard.com/article/opinion/shyam-ponappa-unfettering-stranded-capacity-115060301557_1.html">Business Standard</a> on June 3, 2015 mirrored in <a class="external-link" href="http://organizing-india.blogspot.in/2015_06_01_archive.html">Organizing India Blogspot</a> on June 4, 2015.</p>
<hr />
<p style="text-align: justify; ">We want reforms, but don't want to pay for them. For instance, coal-based power needs additional investment to lower emissions. While beneficial, it will not be popular. Worse, sometimes even the path to resolution may not be clear, yet new ways have to be found, because business-as-usual along the paths taken is unsustainable going forward. This becomes evident in considering issues such as electricity distribution, where states have key responsibility and authority for some of what needs to be done. Concerning spectrum and coal allocation, there's widespread mistrust about operators getting something for nothing, sort of an East-India-Company syndrome, despite user benefits from lower rates and better services if there is appropriate regulation. We'll have to get over this mindset to stop doing ourselves in. This holds regardless of which party rules and at what level - the Centre, state or local government - or what their philosophy might be: rightist, leftist, something in between, or simply pragmatist.</p>
<p style="text-align: justify; ">The most prominent category of stranded capacity is where capital has been invested, but the capacity is unusable for some reason. Examples abound in infrastructure, in manufacturing, and in residential and commercial development, as detailed in the Economic Survey. But there are other categories of stranded capacity which are more difficult to address, because they are in the nature of opportunity costs rather than invested capital. They deserve equal attention because an opportunity loss, or benefit foregone from paths not taken, can result in as much detriment as from a stalled investment. But before we get into examples of opportunity costs, consider the more straightforward case of investments in power generation that are infructuous.</p>
<h3 style="text-align: justify; ">Stranded Power Generation</h3>
<p style="text-align: justify; ">An estimated Rs 60,000 crore is unproductive in stranded power generation projects which stopped operating because fuel was unavailable. About a quarter of this relates to 31 gas-based plants of over 14,300 MW, nearly 60 per cent of the total gas-based capacity of 24,150 MW. Another 23 per cent or 5,500 MW is operating at below the 30 per cent plant load factor required to just cover costs. The government has devised a scheme using the Power System Development Fund to import liquefied natural gas to run some of these projects at 30 per cent capacity. Operators must compete through reverse-bids with a fixed tariff of Rs 5.50 per unit. The lowest bidders win PSDF support, which will be paid to distributors. There is a ceiling of Rs 3,500 crore to gas-based projects, and plants aggregating 8,000 MW had submitted bids by early May.[<a class="external-link" href="http://powermin.nic.in/upload/loksabhatable/pdf/LS23042015_Eng.pdf">1</a>]</p>
<p style="text-align: justify; ">Regarding electricity distribution, press reports suggest that states buy only 20-30 per cent of their requirement at the prevailing low spot rates in the last three months,ranging from Rs 2.56 to Rs 2.82 per unit. This is because of the distributors' committed power purchase agreements as well as their weaker finances. In some cases as in Delhi, some old plants incur highoperating costs, and power from clean, gas-based plants costs more.[<a class="external-link" href="http://tatapower-ddl.com/UploadedDocuments/Tariff%20and%20Financial%20issues%20impacting%20Delhi%20Discom%E2%80%99s%20and%20Delhi%20consumers.pdf">2</a>]</p>
<p style="text-align: justify; ">Another serious problem is that of "regulatory assets" in Delhi. This euphemism covers under-recoveries because tariffs were set too low for years in response to popular demand. There was a crisis last year when NTPC refused to supply power until the distributors paid their dues, while the state owed the distributors Rs 20,000 crore. The problem is ongoing; meanwhile, the regulator has increased tariffs, but not enough to recover past losses. While a number of states have begun transmission and distribution reforms,[<a class="external-link" href="http://www.business-standard.com/article/economy-policy/power-reforms-gain-ground-in-states-115052701561_1.html">3</a>] it's already evident with rising generation that unless financial and distribution capacity are built on sound principles, electricity supply cannot stabilise for users. We must grasp the nettle of a disciplined, responsible approach.</p>
<p style="text-align: justify; ">On a broader front, the government has been coordinating meetings between government officials, banks, and the RBI, seeking to resolve problems affecting some Rs 3.51-lakh crore in stressed projects in steel, cement, power and transport.</p>
<h3 style="text-align: justify; ">Opportunity Losses (or The Road Not Taken)</h3>
<p style="text-align: justify; ">The regulations on radio frequency spectrum show how administrative rules can deprive us of readily available benefits. The most glaring example is the prevention of roaming using 3G spectrum. The resource was available, and was allocated to operators for various locations, but their roaming agreements were disallowed. This doesn't help us, whether from the perspective of government's increased share of revenues from greater usage, or the denial of user benefits from a better service offering. Instead, this approach constrains capacity by an arbitrary rule. Such issues need to be reviewed and rationalised to unfetter latent capacity towards attaining Digital India.</p>
<p style="text-align: justify; ">Another instance is that of limitations imposed on spectrum sharing which have nothing to do with technology. The reason exclusive spectrum allocations were introduced years ago was to prevent radio frequency interference. Now, imposing arbitrary limitations on spectrum usage results in denying ourselves available capacity. More radical and complex alternatives like pooling spectrum and facilities, and common carrier access for certain services, deserve consideration for exactly the same reasons: increased productivity and benefits from investments already made. Otherwise, it is like stranded capacity in stalled projects.</p>
<p style="text-align: justify; ">The same issues apply to the auction of mineral rights for core industries in domestic manufacturing. Any ingenuous fascination with free-market principles in allocating resources that overlook the fundamental requirements of a strong manufacturing base in a large country, or that don't comprehend the realpolitik of how free-market dogma is selectively argued, will leave us farther behind on the road to prosperity.</p>
<p>
For more details visit <a href='https://cis-india.org/telecom/blog/organizing-india-blogspot-shyam-ponappa-june-4-2015-unfettering-stranded-capacity'>https://cis-india.org/telecom/blog/organizing-india-blogspot-shyam-ponappa-june-4-2015-unfettering-stranded-capacity</a>
</p>
No publisherShyam PonappaTelecom2015-07-11T16:00:11ZBlog EntryUnderstanding Spectrum
https://cis-india.org/telecom/blog/understanding-spectrum
<b>What is spectrum and how do government and commercial decisions on this scientific phenomenon affect public facilities and costs? Shyam Ponappa examines this in his latest blog published in the Business Standard on March 4, 2010.</b>
<p>Twenty years ago, “spectrum” implied the colours of the rainbow. Now, we understand that spectrum also relates to mobile phones. We encounter spectrum daily, in TV remote controls, microwave ovens, even sunlight. So, what exactly is spectrum, and how do government and commercial decisions on this scientific phenomenon affect public facilities and costs?</p>
<p>“Spectrum” is short for “electromagnetic spectrum”, the range of radiated energies that envelop the Earth. This electromagnetic radiation (EMR) is primarily from the sun, and secondarily from the stars/cosmos, radioactive elements in soil, rock and gases... .</p>
<p>One section of EMR is visible light; another is radio frequency (RF) spectrum. There are many other “wavelengths” in EMR with different characteristics and effects, such as infrared and ultraviolet rays. All countries have the same RF spectrum in equivalent areas.</p>
<h3>How is spectrum used?</h3>
<p>The length of a wave, its associated frequency (“wavelengths” or “cycles” per second) and energy determine its usage (see <a href="https://cis-india.org/advocacy/telecom/understanding" class="internal-link" title="Spectrum">Figure 1</a>).</p>
<ol><li>Radio waves are relatively long, with wavelengths from 1,000 metres (1 km) to 10 cms, and frequencies from 3 kilohertz (3,000 cycles per second) to 3 gigahertz (GHz) or 3 billion cycles per second for the shortest, sometimes also called microwaves. (There are longer waves, e.g., electric power, of several km.)</li><li>Microwaves in the centimetre and millimetre range can have frequencies up to 300 GHz. There is an overlap in terminology depending on use; microwaves for cooking use several hundred watts of electricity at RF wavelengths of about 32 cms (915 MHz) and 12 cms (2.45 GHz). Microwaves from low-powered devices of a few watts at these frequencies are used for communications, and emit insignificant heat.</li><li>Infrared waves are smaller, and are felt as heat, e.g., from lamps and infrared grills used for cooking. Higher infrared bands used for communications in remote control devices and for imaging/night vision have no heating effect.</li><li>Wavelengths between 700 and 400 nanometres (about 430 to 750 terahertz or THz) form the visible spectrum from red to violet, combining to form white light. For example, we perceive wavelengths of about 635-700 nm (430-480 THz) as the colour red.</li><li>Shorter wavelengths form ultraviolet rays, of which those around 380-280 nm cause sunburn. Sunlight at sea level comprises about 53 per cent infrared, 44 per cent visible light, and 3 per cent ultraviolet rays.</li><li>Yet smaller waves are classified as X-rays, and the smallest as gamma rays, both used in medical and industrial imaging.<br /></li></ol>
<h3>The sweet spot in the RF spectrum for telephony and the Internet</h3>
<p>For telephony and broadband, lower frequencies (700-900 MHz) are most cost-effective, as they traverse long distances without attenuation, penetrating walls and foliage. Radio waves in the atmosphere are affected by water vapour and ionisation, as well as events such as solar flares with bursts of X-rays. Depending on temperature, moisture, etc., radio waves may be absorbed, refracted, or reflected in the atmosphere, and by hills or other obstacles. Low frequency waves penetrate buildings and trees, and curve over slopes. Higher frequencies are more absorbed or reflected by the atmosphere; they are also more attenuated by distance and rain. Networks at lower frequencies require fewer towers than at higher frequencies.</p>
<h3>What are 2G and 3G?</h3>
<p>These signify different stages of technological development, starting with 1st Generation (1G) analog wireless in the 1980s, e.g., in car phones. 2G (2nd Generation) began in the 1990s with the digital wireless GSM standard for mobiles, extending to other standards, e.g., CDMA. 3G (3rd Generation) has faster data speed and greater network capacity.</p>
<h3>What is 2G/3G spectrum?</h3>
<p>There is no difference in the spectrum; only the convention of government regulations and harmonisation between countries by the International Telecommunications Union (ITU) earmark wavelengths for different applications. Both 2G and 3G can and do work at 800-900 and 1800-1900 MHz.</p>
<p>Combined with the advantages of prices dropping as volumes rise, one estimate puts 3G coverage with 900 MHz at 50-70 per cent lower cost than at the designated 2.1 GHz. 3G networks using 900 MHz (“2G spectrum”) exist in Finland, Iceland, Australia, New Zealand, Thailand, Venezuela, Denmark and Sweden, and countries like France encourage 2G networks to upgrade to 3G services.</p>
<p>Spectrum allocated for 2G and 3G by various countries is at <a href="https://cis-india.org/advocacy/telecom/spectrum" class="internal-link" title="Understanding Spectrum Figure 2">Figure 2</a>; the current and proposed allocation in India is shown below.</p>
<p>This shows India’s dearth of spectrum for public use because of government and defence allocations. We need innovative methods to maximise capacity given our needs, limited landline networks, and the relative costs. (For details on the chart, please see <a class="external-link" href="http://www.umtsworld.com/technology/frequencies.htm">umtsworld.com</a>.</p>
<p>For example, China has allocated 250 MHz in the 800/1800 MHz bands. By not charging auction fees and spectrum charges, ubiquitous networks were built at lower cost with high capacity. These result in lower costs for users and higher productivity. With its focused approach, China also developed its own standard (TD-SCDMA).</p>
<p>India’s spectrum allocation is burdened with short-term revenue collection for the government, and a shortage mentality. There is apparently insufficient clarity on spectrum usage for ubiquitous broadband/telephony as in other countries, let alone more ambitious targets, such as developing an Indian standard.</p>
<p>Our policies could address the requirement for enhanced coverage/capacity at low cost to make services available everywhere at reasonable prices. Innovative approaches to spectrum management could help get these, through:</p>
<ol><li>Technology-neutrality: the UK and Norway have not restricted the use of recently auctioned spectrum to any technology.</li><li>A focused strategy for service delivery at low cost, as in China.<br /></li></ol>
<p>This needs a combination of methods, e.g., along with technology-neutrality, (a) data-base driven, shared spectrum usage, under trial in the US, (b) “Cognitive Radio”, whereby smart devices sense available channels for dynamic, non-conflicting use in unlicensed spectrum bands, (c) incentives for rural broadband delivery, e.g., by subvention of fees and government charges, with (d) subsidies.</p>
<p>Follow the original article on <a class="external-link" href="http://www.business-standard.com/india/news/shyam-ponappa-understanding-spectrum/387446/">Business Standard</a></p>
<p>
For more details visit <a href='https://cis-india.org/telecom/blog/understanding-spectrum'>https://cis-india.org/telecom/blog/understanding-spectrum</a>
</p>
No publisherShyam PonappaTelecom2012-05-10T10:48:19ZBlog EntryTransformation, or Drift?
https://cis-india.org/telecom/blog/organizing-india-blogspot-shyam-ponappa-august-7-2014-transformation-or-drift
<b>We need transformative policies and incentives with purpose, especially in solar power and digital infrastructure.</b>
<p>The article published in <a class="external-link" href="http://organizing-india.blogspot.in/2014/08/transformation-or-drift.html">Organizing India Blogspot</a> on August 7, 2014. It was earlier published in the <a class="external-link" href="http://www.business-standard.com/article/opinion/shyam-ponappa-transformation-or-drift-114080601530_1.html">Business Standard </a>on August 6, 2014.</p>
<hr />
<p style="text-align: justify; "><span><span>An uneasy sense of drift has set in after the anticipation that accompanied the swearing-in of the National Democratic Alliance government. Surely, the government understands that its real task is to build on hopes and expectations, to channel energies, to organise and coordinate for results, even perhaps try bipartisan teams? The opportunity is to overcome factionalism and harness people's energies, instead of floundering in disunity. We need transformative policies, programmes and </span><a class="storyTags" href="http://www.business-standard.com/search?type=news&q=Incentives" target="_blank">incentives</a><span>with purpose.</span></span></p>
<p style="text-align: justify; "><span><span>Resolute efforts in specific sectors can change this sense of the same old same-old. Two aspects of infrastructure that need early attention are: first, solar power, and second,<a class="storyTags" href="http://www.business-standard.com/search?type=news&q=Digital+Infrastructure" target="_blank">digital infrastructure </a>(see "<a href="http://www.business-standard.com/article/opinion/shyam-ponappa-a-great-start-114060401642_1.html" target="_blank"><span>A great start by Modi government</span></a>", June 5, <i>Business Standard</i>).</span></span></p>
<p style="text-align: justify; "><span><span>Solar power, critically important in its own right, is essential for digital infrastructure because of the poor grid supply. Disappointingly, the steps taken are more of the same. For instance, the renewal of the national solar mission. for an increased 1,500 megawatts, is on the same lines as before - that is, a 30 per cent subsidy for solar farms, accelerated depreciation and <a class="storyTags" href="http://www.business-standard.com/search?type=news&q=Renewable+Energy+Credits" target="_blank">renewable energy credits </a>(RECs) that provide subsidies for a fixed period. While the target is higher, it is minuscule compared to the potential, and relative to other energy sources. For distributed user installations, interest-free loans seem ineffectual, because the high prices are unchanged, although payable in instalments - hardly ground-breaking.</span></span></p>
<p style="text-align: justify; "><span><span>Could the government try a more radical incentive of zero tax on equipment in addition to a 30 per cent subsidy, with immediate reimbursement and stiff penalties for misuse? Lower capital costs would probably induce much more extensive deployment, spurring manufacturing and innovation through sheer volume. This is likely for solar farms as well, and these incentives could be made available if such farms are really desirable. The government would lose upfront taxes on equipment, but avoid the cost and complexities of the <a class="storyTags" href="http://www.business-standard.com/search?type=news&q=Recs" target="_blank">RECs </a>and accelerated depreciation, while gaining taxes downstream from increased productivity.</span></span></p>
<p style="text-align: justify; "><span><span>Similarly, in communications, we need countrywide access to broadband at reasonable prices. Users could benefit from applications such as education at all levels, from secondary school to college to continuing education for adults, healthcare; e-commerce; remote working/telecommuting; government services, information; and entertainment. Of course, once we have broadband, we'd need the range of useful, attractive content and services that result in improved user satisfaction, as well as productivity. These "supplementary effects" will undoubtedly take time to develop and play out, but the prerequisite is the access.</span></span></p>
<p style="text-align: justify; "><span><span><span><span>On this score, the much-awaited spectrum sharing recommendations are sorely disappointing. Their intent is puzzling because they are so restrictive, limiting sharing to two operators who have acquired frequencies in the same band in the same manner, with a cap of 50 per cent.</span></span></span></span></p>
<p style="text-align: justify; "><span><span><span><span><span style="text-decoration: underline;"><b>Build and Run Communications Networks Like Roads</b></span></span></span></span></span></p>
<p style="text-align: justify; "><span><span><span><span>Perhaps the telecom regulator's recommendations on spectrum sharing are an opening gambit to explore active network sharing. The logic for network and spectrum sharing is compelling. With India's self-created spectrum constraints and genuine deficiencies of capital and network coverage, the rational approach for our developing economy would be to optimise their use, as with roads. For this, active network sharing, including radio access networks and spectrum, is the most efficient solution, as is the case for roads.<br /><br />Unfortunately, our policies are at the other extreme, of spectrum auctions and exclusive networks. This is least efficient for extending underdeveloped infrastructure services, as building and operating multiple exclusive networks requires the most resources, including capital. Auctions may be a reasonable alternative where there's existing infrastructure, and the issue is of allocating resources to whoever can make the best use of them. In our situation and given our needs, the way we build and operate roads may be a better alternative to achieve coverage.<br /><br />To see why, compare the contrasting approaches of building communications networks with highways and roads. Road developers not only don't have to pay auction fees for the right to build roads, they are paid periodically for the construction of the assets. Ownership of the assets is then transferred to the state or other agency, and all road tax and toll payers may use the facilities. Similarly, all licensed operators could have access to communications networks on payment. While payback periods are often longer for roads, the nature of the financial flows are the same: capital must be invested in building the network before revenues are generated from users. People need to be informed and educated about this inescapable process.<br /><br />Sparsely populated rural areas have lower revenue potential than urban areas. Hence, communications networks and services in rural areas lag because of commercial considerations. This deprivation is aggravated by front-loading auction fees for spectrum, which curtails investments in the networks and services in areas with lower potential. Also, unless operators pool resources, exclusive usage militates against full utilisation of the infrastructure. Our policies should reflect all this, instead of restricting spectrum access and sharing, including for 3G.</span></span></span></span></p>
<p style="text-align: justify; "><span><span><span><span>The real irony is that the pay-for-use principle is well accepted for roads; yet the opposite principle of auctions is used for communications networks. This is the unintended consequence of accepting auctions without thinking through what we need in our circumstances compared with advanced economies, and how to achieve those objectives.</span></span></span></span></p>
<p style="text-align: justify; "><span><span><span><span>Our spectrum policies have resulted in small bands of non-contiguous spectrum holdings that severely restrict capacity. Besides, operators have to invest heavily simply to protect the assets built. Yet countrywide broadband services need more spectrum to be used much more effectively to facilitate last-mile access. The kind of solution we need is for all remaining spectrum to be used for a common-access network, owned by a consortium of operators, including state-owned Bharat Sanchar Nigam and Mahanagar Telephone Nigam as "anchors". Once integrated with existing networks, operators can commercially deploy services with enhanced capacity, for which they pay as they use, and get paid. Broadband can be revolutionised by setting this up and converting spectrum fees to pure revenue sharing, as happened for mobile telephony with licence fees years ago. With the benefit of hindsight, the fees can be set low from the start, with regulatory oversight to avoid predatory pricing, and growth will most likely explode.</span></span></span></span></p>
<p>
For more details visit <a href='https://cis-india.org/telecom/blog/organizing-india-blogspot-shyam-ponappa-august-7-2014-transformation-or-drift'>https://cis-india.org/telecom/blog/organizing-india-blogspot-shyam-ponappa-august-7-2014-transformation-or-drift</a>
</p>
No publisherShyam PonappaTelecom2014-08-11T04:57:38ZBlog EntryTRAI-ing Times: The Story So Far
https://cis-india.org/telecom/blog/trai-ing-times-the-story-so-far
<b>24th December, 2014 marked a pivotal moment in the Indian experience with network neutrality. On this date, one of India’s largest telecom players, Bharti Airtel, announced the introduction of a new ‘VoIP’ usage policy for its mobile users.</b>
<p style="text-align: justify;"> </p>
<p style="text-align: justify;"> </p>
<p style="text-align: justify;">Under this policy, usage of VoIP services would henceforth be <em>excluded</em> from standard data usage packs and would instead be charged at standard data rates (of 4p / 10KB on 3G and 10p / 10KB on 2G).<a name="_ftnref1" href="#_ftn1"><sup><sup>[1]</sup></sup></a> Alongside this modification to 2G and 3G packs, a separate data pack exclusively for VoIP services was to be introduced. <a name="_ftnref2" href="#_ftn2"><sup><sup>[2]</sup></sup></a></p>
<p style="text-align: justify;">The flurry of activity the announcement precipitated included widespread consumer and civil society outrage<a name="_ftnref3" href="#_ftn3"><sup><sup>[3]</sup></sup></a>, a statement by the Union Minister for Telecom<a name="_ftnref4" href="#_ftn4"><sup><sup>[4]</sup></sup></a>, a justificatory counter-statement by Airtel itself<a name="_ftnref5" href="#_ftn5"><sup><sup>[5]</sup></sup></a> and ultimately, a statement by TRAI. <a name="_ftnref6" href="#_ftn6"><sup><sup>[6]</sup></sup></a> While it remains to be seen whether this was a calculated move by Airtel to kick-start the neutrality discussion in India (as some suspect<a name="_ftnref7" href="#_ftn7"><sup><sup>[7]</sup></sup></a>), the implementation of the new policy/pack was deferred pending TRAI's proposed consultation paper on OTT services. <a name="_ftnref8" href="#_ftn8"><sup><sup>[8]</sup></sup></a></p>
<p>In the context of the impending (though seemingly delayed<a name="_ftnref9" href="#_ftn9"><sup><sup>[9]</sup></sup></a>) release this paper, we take this opportunity to study TRAI-linked output on network neutrality in the past. This study was carried out using RTI requests [Part I] and targeted keyword searches of the TRAI website [Part II].</p>
<h3><strong>Information received through RTI requests</strong></h3>
<div><strong><br /></strong></div>
<p style="text-align: justify;">We had filed the following request under the Right to Information Act, 2005 on the subject and net neutrality and any material available with them generated in the course of internal or other discussions:</p>
<table class="grid listing">
<tbody>
<tr>
<td>
<p align="center"><strong>Request for Information under the Right to Information Act, 2005</strong></p>
<p align="left">To</p>
<p align="left"><strong>Shri V.K.Saxena </strong></p>
<p align="left">Dy. Advisor (GA.) & Central Public Information Officer-LO</p>
<p align="left">Telecom Regulatory Authority of India</p>
<p align="left">Mahanagar Doorsanchar Bhawan,</p>
<p align="left">Jawaharlal Nehru Marg, Old Minto Road,</p>
<p align="left">New Delhi-110 002</p>
<p align="left"><strong>Date of application</strong> : 08-10-2014</p>
<p align="center">Subject:<strong> Documents relating to Network Neutrality</strong></p>
<p>1. Please provide a list of all the consultations/discussions/meetings that have taken place with respect to network neutrality by TRAI.</p>
<p>2. Please provide a list of all responses received by TRAI which concern network neutrality.</p>
<p>3. Please provide a list of other documents/memos/minutes regarding network neutrality available with TRAI.</p>
<p style="text-align: justify;">4. Does TRAI possess power to punish ISPs for violating principles of network neutrality? If so, please mention the provision of law which permits this.</p>
<p>5. What measures are taken by TRAI to monitor network neutrality violations by ISPs? For example, throttling of internet content/protocols.</p>
<p>6. What is the procedure for a consumer to file a complaint with TRAI regarding network neutrality violations?</p>
<p style="text-align: justify;">7. Please provide copies of any documents regarding complaints received / action taken with respect to network neutrality violations in the past three years.</p>
<p style="text-align: justify;">It is certified that I am a citizen of India and that I do not fall within the BPL category. I am enclosing Rupees thirty (Rs. 10) towards the application fee and photocopying costs under the RTI Act for the information and documents requested. Kindly inform me at the address stated below if any further fees are required to be paid.</p>
<p><strong> </strong></p>
<p><strong>Applicant</strong> : <strong>Signature of the Applicant</strong></p>
<p>Tarun Krishnakumar</p>
<p>Centre for Internet and Society</p>
<p>194, 2nd C Cross Road, Domlur II Stage,</p>
<p>Bangalore - 560071</p>
</td>
</tr>
</tbody>
</table>
<p>____________________________________________________________________________________________________________________________________________________________________________________</p>
<p>In response to the same, we received the following reply which smacked of non-application of mind by the concerned officer to the request:</p>
<table class="grid listing">
<tbody>
<tr>
<td>
<p>To,</p>
<p>Shri Tarun Krishnakumar</p>
<p>Centre for Internet and Society</p>
<p>194, 2nd C Cross Road, Domlur II Stage</p>
<p>Bangalore (Karnataka) - 560071.</p>
<p><strong>SUBJECT: REQUEST FOR SUPPLY OF INFORMATION UNDER THE PROVISIONS OF THE RIGHT TO INFORMATION ACT, 2005.</strong></p>
<p>Sir,</p>
<ol type="1">
<li style="text-align: justify;"> Please refer to your application dated 08.10.2014 , seeking information under the provisions of the Right to Information Act, 2005 regarding Network Neutrality related matter. </li></ol>
<ol type="1">
<li> It is informed that the information sought by you vide the above referred application is not available in TRAI. </li></ol>
<ol type="1">
<li style="text-align: justify;"> The Appellate Authority in TRAl under section 19 (1) of the "Right to Information Act, 2005" is Shri Suresh Kumar Gupta, Pr. Advisor (CA&QOS), Telecom Regulatory Authority of India, Mahanagar Doorsanchar Bhawan, Jawaharlai Nehru Marg, Old Minto Road, New Delhi-110 002, Tele:011- 23216930, Fax : 011- 23235270. </li></ol>
<p>Yours faithfully,</p>
<p>(V.K. Saxena)</p>
<p><strong>Central Public Information Officer (LO)</strong></p>
<p><strong>Tele: 011-23211622</strong></p>
</td>
</tr>
</tbody>
</table>
<p>____________________________________________________________________________________________________________________________________________________________________________________</p>
<div> </div>
<div><br />
<p>In reply, we filed the following appeal with the designated Appellate Authority:</p>
<table class="grid listing">
<tbody>
<tr>
<td>
<p align="center"><strong>Appeal under the Right to Information Act, 2005</strong></p>
<p><strong> </strong></p>
<p><strong>To</strong> :</p>
<p>Appellate Authority</p>
<p>Shri. Suresh Kumar Gupta,</p>
<p>Pr. Advisor (CA and QoS),</p>
<p>Telecom Regulatory Authority of India,</p>
<p>Mahanagar Doorsanchar Bhawan,</p>
<p>Jawaharlal Nehru Marg, Old Minto Road,</p>
<p>New Delhi - 110002</p>
<p><strong>Date: </strong> 23.11.2014</p>
<p align="center"><strong>Subject: </strong> Appeal under Section 19(1) of the Right to Information Act, 2005 with reference to your reply No. 1(658)/2014-RTI dated 10.11.2014</p>
<p>Dear Sir,</p>
<p style="text-align: justify;">I write to you with reference to my RTI Application dated 08.10.2014 for information relating to 'network neutrality' held by TRAI. The CPIO, Shri. V.K. Saxena, rejected my request vide letter no. 1(658)/2014-RTI dated 10.11.2014 stating that " <em>the information sought by you vide the above referred application is not available in TRAI.</em>" (enclosed herewith). As the applicant, I am unsatisfied and aggrieved by the above decision and hereby appeal against the same.</p>
<p><strong>Circumstances and Grounds of Appeal</strong> <strong>:</strong></p>
<p style="text-align: justify;">By way of my application (enclosed herewith), I sought any and all information held by TRAI in relation to 'network neutrality'. For example, questions 1 - 3 queried the list of consultations etc. that have taken place involving network neutrality and sought copies of all documentation pertaining to the same. The other questions sought information pertaining to the powers of TRAI in relation to internet service providers and complaints received by it in relation to network neutrality. I submit that the failure of the CPIO to provide any answer to my queries is erroneous and therefore liable to be set aside on appeal to you.</p>
<p style="text-align: justify;">It is well-documented that there is at least one consultation connected with the subject-matter of my application i.e. 'network neutrality' released by TRAI in December 2006 (Paper No. 19/2006). In fact, the paper is currently available on the TRAI website at the following URL: <a href="http://www.trai.gov.in/WriteReaddata/ConsultationPaper/Document/consultation27dec06.pdf"> http://www.trai.gov.in/WriteReaddata/ConsultationPaper/Document/consultation27dec06.pdf </a></p>
<p style="text-align: justify;">(Please see heading 3.6 and 3.7). Therefore, if nothing else at least all information pertaining to this paper including the responses received to the question under Heading 3.7 <em>must be supplied to me</em>.</p>
<p style="text-align: justify;">You may also take note of TRAI's "Recommendations on Application Services" (available at URL: <a href="http://www.trai.gov.in/writereaddata/recommendation/documents/as140512.pdf"> http://www.trai.gov.in/writereaddata/recommendation/documents/as140512.pdf </a> ) dated 14.05.2014 where paras 1.29 - 1.31 pertain to net neutrality. This is another document that the CPIO failed to take notice of.</p>
<p style="text-align: justify;">The failure of the CPIO to even acknowledge the existence of TRAI's own papers as cited above shows that there has been no application of mind to my application and a mechanical denial has been issued.</p>
<p><strong>Prayer</strong> <strong>:</strong></p>
<p>In light of the grounds advanced above, I request that:</p>
<p align="left">i. My application for all information pertaining to 'network neutrality' be allowed and the relevant documents be released to me.</p>
<p align="left">ii. I receive a question-by-question response to each of my queries.</p>
<p><strong>List of Enclosures: </strong> 1. Original Application dated 08.10.2014</p>
<p>2. Reply of CPIO No. 1(658)/2014-RTI dated 10-11-2014</p>
<p><strong> </strong></p>
<p><strong> </strong></p>
<p><strong>Name of Appellant/Applicant and Address</strong> :</p>
<p>Tarun Krishnakumar</p>
<p>Centre for Internet and Society</p>
<p>194, 2nd C Cross Road, Domlur II Stage,</p>
<p>Bangalore - 560071</p>
</td>
</tr>
</tbody>
</table>
<p>____________________________________________________________________________________________________________________________________________________________________________________</p>
<p> </p>
<p>The appellate authority vide dated decision 12-01-2015 replied as follows:</p>
<table class="grid listing">
<tbody>
<tr>
<td>
<p align="center"><strong>BEFORE THE APPELLATE AUTHORITY UNDER THE RTI ACT, 2005</strong></p>
<p align="center"><strong> </strong></p>
<p align="center"><strong>F. No. 1(658)/2014-RTI</strong></p>
<p align="center"><strong> </strong></p>
<p align="center"><strong>Telecom Regulatory Authority of India</strong></p>
<p align="center"><strong>Mahanagar Door Sanchar Bhawan, Jawaharlal Nehru Marg</strong></p>
<p align="center"><strong>(Old Minto Road), New Delhi-110002.</strong></p>
<p align="center"><strong> </strong></p>
<p align="center"><strong>APPEAL in terms of Section 19(1) of RTI Act, 2005</strong></p>
<p align="center"><strong> </strong></p>
<p align="center"><strong>Date of Decision: 12th January, 2015</strong></p>
<p align="center"><strong> </strong></p>
<p align="center"><strong>In the Matter of:</strong></p>
<p align="center"><strong> SHRI TARUN KRISHNAKUMAR, CENTRE FOR INTERNET AND SOCIETY, 194, 2nd C CROSS ROAD, DOMLUR ll STAGE, BANGALORE (KARNATAKA)-560071 </strong></p>
<p align="center"><strong> </strong></p>
<p align="center"><strong>vs</strong></p>
<p align="center"><strong> </strong></p>
<p align="center"><strong>CPIO, TRAI.</strong></p>
<ol type="1">
<li style="text-align: justify;"> Shri Tarun Krishnakumar has preferred the present appeal dated 23.11.2014 against the reply of CPIO, TRAI, communicated to him vide letter No. 1(658)/2014-RTI dated 10.11.2014 in response to his application dated 08.10.2014 under the RTI Act.</li>
<li style="text-align: justify;">I have gone through the appellant's application dated 08.10.2014 addressed to the Central Public Information Officer, Telecom Regulatory Authority of India (TRAI), the reply dated 10.11.2014 given to the appellant by the CPIO and the present appeal. The appellant had requested for information regarding Network Neutrality and related matter. Since the said information was not available with the Public Authority, TRAI, the CPIO. TRAI informed this to the appellant. The appellant, however, not being satisfied with the reply has filed this appeal.</li>
<li style="text-align: justify;">Upon examination, it was noticed that the consultation paper on "Review of Internet Services" issued on 27'" December, 2006 has a reference to Net Neutrality in Chapter 3-Emerging Trends. Therefore, the concerned division has uploaded the comments received in response to the 2006 consultation paper for the information of stake holders, the same is available in TRAI website under the link <a href="http://www.trai.gov.in/content/consultation_ViewCommentDescription/144_11_ViewCommentDescription.aspx"> http://www.trai.gov.in/content/consultation_ViewCommentDescription/144_11_ViewCommentDescription.aspx </a> . Further, the "Recommendations on Application Services" was issued on 14.05.2012 and is available on TRAI website. There is no additional information which can be provided to the appellant at this stage.</li>
<li>In view of the above, the appeal is accordingly disposed.</li>
<li>Let a copy of this order be sent to the appellant. </li></ol>
<p align="right">Sd/-</p>
<p align="right"><strong>(Suresh Kumar Gupta)</strong></p>
<p align="right"><strong>Appellate Authority, TRAI</strong></p>
<p align="right"><strong>Under RTI Act, 2005</strong></p>
</td>
</tr>
</tbody>
</table>
<p style="text-align: justify;">This reveals the extent of TRAI-produced output on the issue of 'net neutrality'. Besides a reference to Neutrality in 2006 paper TRAI did not disclose any other instance where it had discussed the issue.</p>
<p style="text-align: justify;"> </p>
<p style="text-align: justify;">_________________________________________________________________________________________________________________________________________________________________________________________</p>
</div>
<h3><strong>Targeted Keyword Searches of the trai.gov.in website</strong></h3>
<div><strong><br /></strong></div>
<div>
<p style="text-align: justify;">This leg of the survey consisted of conducting targeted keyword searches of the trai.gov.in website to gauge the engagement with the subject of Network Neutrality either in the form of TRAI Output, Submissions to TRAI or other outputs (from seminar, conferences etc.). The results - aggregated using Google and Bing - have been tabulated.</p>
<p><strong>Note: </strong> The results do not include the OTT Consultation Paper of 27-03-2015.</p>
<p><strong>Methodology</strong> : Keyword searches of specific website using the advanced search / site-search search operator ("KEYWORD + site:<URL>"); Repeated Hits were not tabulated.</p>
<p><strong>i. </strong> <strong>Keyword: "Net Neutrality"</strong></p>
<p>Total No. of search results returned = 10 (Google), 6 (Bing)</p>
<p>Relevant Hits: 8</p>
<table class="grid listing">
<tbody>
<tr>
<td>
<p><strong> </strong></p>
</td>
<td colspan="2">
<p><strong>Hit URL</strong></p>
</td>
<td>
<p><strong>Name of Document </strong></p>
</td>
<td>
<p><strong>Date</strong></p>
</td>
<td colspan="2">
<p><strong>Relevant Page</strong></p>
</td>
<td colspan="2">
<p><strong>Remarks</strong></p>
</td>
</tr>
<tr>
<td>
<p>1.</p>
</td>
<td colspan="2">
<p>http://www.trai.gov.in/WriteReaddata/ConsultationPaper/Document/consultation27dec06.pdf</p>
</td>
<td>
<p>Consultation Paper on "Review of Internet Services" (No. 19/2006)</p>
</td>
<td>
<p>26-12-2006</p>
</td>
<td colspan="2">
<p>References at Pg. 27-28.</p>
</td>
<td colspan="2">
<p style="text-align: justify;">Views were sought in relation to emerging trends one of which outlined was 'Net Neutrality.'</p>
<p>Selected Extracts:</p>
<p style="text-align: justify;">" <em> 3.6.2 The situation may also rise in India as Internet access providers may use their market power to discriminate against competing applications and/or contents. </em> "</p>
<p style="text-align: justify;">" <em> 3.6.3 The issue of net neutrality in the long term can threaten popularity of Public Internet based Internet telephony and similar 28 other applications as all the intermediate Internet providers may start asking commercial agreements in absence of which they may refuse to carry the content and provide desired quality of service. The future developments are likely to have new applications and contents. The business models of ISPs are concentrated around useful application. In this background views of stake holders are required whether regulatory intervention is needed to ensure net neutrality in India in times to come or it may be left to market forces. </em> "</p>
</td>
</tr>
<tr>
<td>
<p>2.</p>
</td>
<td colspan="2">
<p>http://www.trai.gov.in/WriteReadData/ConsultationPaper/Document/201410221229242471860Vodafone_Delivering%20Broadband%20quickly_Counter_21Oct2014.pdf</p>
</td>
<td>
<p>Vodafone's counter-response to TRAI's Consultation paper on 'Delivering Broadband Quickly'</p>
</td>
<td>
<p>22-10-2014</p>
</td>
<td colspan="2">
<p>References at Pg. 3-4.</p>
</td>
<td colspan="2">
<p style="text-align: justify;">Here, Vodafone pledges support for an 'open internet' for all however comments " <em>net neutrality has long been a solution in search of a problem</em>" and criticises EU framework.</p>
</td>
</tr>
<tr>
<td>
<p>3.</p>
</td>
<td colspan="2">
<p>http://www.trai.gov.in/WriteReadData/ConsultationPaper/Document/20120730022807389860713.Etisalat[1].pdf</p>
</td>
<td>
<p>Response of Etisalat DB to Pre-consultation paper on "IMT-Advanced (4G) Mobile wireless broadband services"</p>
</td>
<td>
<p>15-04-2010</p>
</td>
<td colspan="2">
<p>References at Pg. 2 (Paragraph 12).</p>
</td>
<td colspan="2">
<p style="text-align: justify;">Etisalat notes that net neutrality is a topic that requires deliberation in reference to the proposed consultation paper on 4G.</p>
<p style="text-align: justify;">It defines neutrality as "<em>Avoiding blockage of any specific web site on a particular network</em>".</p>
</td>
</tr>
<tr>
<td>
<p>4.</p>
</td>
<td colspan="2">
<p>http://www.trai.gov.in/WriteReadData/Recommendation/Documents/recom18aug08.pdf</p>
</td>
<td>
<p>TRAI Recommendations on "Issues relating to Internet Telephony"</p>
</td>
<td>
<p>18-08-2008</p>
</td>
<td colspan="2">
<p>References at Pg. 46 and 78</p>
</td>
<td colspan="2">
<p style="text-align: justify;">At Pg. 46: " <em> The very popularity and success of the Internet is due to Net neutrality, i.e packets of all services and applications shall be processed and delivered without any discrimination by the intermediate service providers." </em></p>
<p style="text-align: justify;">At Pg. 78: " <em> Regulation in Argentina considers IP as a mere way to offer telecommunication services, such as telephony in the form of VoIP, thus there are no legal barriers that impede market access or any plans to regulate different types of the service. Any provider is free to offer telecommunication services with different technologies and network architectures, based on the network neutrality principle…"…" The foreign investment policy is liberal and there are no distinctions between local and foreign companies. According to the network neutrality principle, there are no regulated technological standards or protocols for VoIP </em> "</p>
</td>
</tr>
<tr>
<td>
<p>5.</p>
</td>
<td colspan="2">
<p>http://www.trai.gov.in/WriteReadData/ConsultationPaper/Document/201412300449107784040Dr%20Rohit%20Prasad.pdf</p>
</td>
<td>
<p>Response to the Consultation Paper (No: 13/2014) on "Interconnect Usage Charges" filed by (i) Dr. Rohit Prasad, Professor, Management Development Institute, Gurgaon</p>
<p>(ii) Mansi Kedia, Researcher, Indian Council for Research on International Economic Relations (ICRIER)</p>
<p>(iii) Dr. V. Sridhar, Professor, International Institute of Information Technology Bangalore</p>
</td>
<td></td>
<td colspan="2">
<p>Reference at Pg.7</p>
</td>
<td colspan="2">
<p>Raises the question of Net Neutrality with reference to OTT services.</p>
<p style="text-align: justify;">At Pg. 7: "… <em> Since an Internet Telephony call is a partial OTT service (i.e. from the origin until it hits the IP-Telco gateway), should Net Neutrality principles (as and when drafted) should be applicable for this as well. The above question, can be taken up when the Net Neutrality rules or OTT regulation rules are framed by the regulator. </em> "</p>
</td>
</tr>
<tr>
<td>
<p>6.</p>
</td>
<td colspan="2">
<p>http://www.trai.gov.in/WriteReadData/ConsultationPaper/Document/2.Infotel_Broadband..pdf</p>
</td>
<td>
<p>Response of Infotel Broadband Services Ltd to Consultation Paper on "Mobile Value Added Services" (CP 05/ 2011)</p>
</td>
<td>
<p>11-08-2011</p>
</td>
<td colspan="2">
<p>Reference at Pg. 3</p>
</td>
<td colspan="2">
<p style="text-align: justify;">Opposition to Licensing regime for Internet Content and Application Providers:</p>
<p style="text-align: justify;">At Pg. 3: " <em> 3. Internet/ Data Applications do not depend on Telecom Operator, and are not licenced in open mature countries The need to exercise restraint on regulation is stronger in the case of data/ internet services. In the case of VAS on data/ internet services, VASPs have no technical dependence on Telecom/ Internet Service Provider for providing the service, as the data connection is generally a dumb pipe. For some services, VASPs choose to partner Telecom Operators for billing convenience (as in the case with currently provided Games-on-Demand service and Anti-virus services over Broadband). Globally, Internet Application Companies and Regulators mostly operate on a net neutrality approach, wherein a broadband application is accessible across Telecom/ Internet Service Providers. Thus, especially in the case of data services, there is no case to govern a relationship/ arrangement that has no technical necessity. Licencing Regime for Internet Content and Application providers, like portals, e-commerce, etc is not in practice in any of the open countries and should not be introduced in India too." </em></p>
</td>
</tr>
<tr>
<td>
<p>7.</p>
</td>
<td colspan="2">
<p>http://trai.gov.in/WriteReadData/ConsultationPaper/Document/201308221249488827971vodafone-final3.pdf</p>
</td>
<td>
<p>Response to Vodafone to Consultation Paper on "Valuation and Reserve Price of Spectrum"</p>
</td>
<td>
<p>21-08-2013</p>
</td>
<td colspan="2">
<p>Reference at Pg. 11</p>
</td>
<td colspan="2">
<p>Reference irrelevant / not-substantive.</p>
</td>
</tr>
<tr>
<td>
<p>8.</p>
</td>
<td colspan="2">
<p>http://www.trai.gov.in/writereaddata/recommendation/documents/as140512.pdf</p>
</td>
<td>
<p>TRAI Recommendations on "Application Services"</p>
</td>
<td>
<p>14-05-2012</p>
</td>
<td colspan="2">
<p>References at Pg.18 and 19.</p>
</td>
<td colspan="2">
<p style="text-align: justify;">At Pg. 18: " <em> 1.29 Net neutrality advocates no restrictions by Service Providers on content, sites, platforms, on the kinds of equipment that may be attached, and no restrictions on the modes of communication allowed. Issue of net neutrality started in early 2007 when it was revealed that Comcast, a provider of broadband Internet access over cable lines intentionally blocked the traffic of peer-to-peer (P2P) applications and gave other Internet traffic preferential treatment. </em> "</p>
<p>At Pg.19:" <em>1.31 The issue of net neutrality for ASPs providing services on OTT model will be dealt as and when required.</em>"</p>
</td>
</tr>
<tr>
<td colspan="9">
<p><strong> </strong></p>
<p><strong>ii. </strong> <strong>Keyword: "Network Neutrality"</strong></p>
<p>Total No. of search results returned = 16 (Google), 8 (Bing)</p>
<p>Relevant Hits: 11.</p>
<p><strong> </strong></p>
</td>
</tr>
<tr>
<td colspan="2">
<p><strong>S.No. </strong></p>
</td>
<td>
<p><strong>Hit URL</strong></p>
</td>
<td>
<p><strong>Name of Document </strong></p>
</td>
<td colspan="2">
<p><strong>Date</strong></p>
</td>
<td colspan="2">
<p><strong>Relevant Page</strong></p>
</td>
<td>
<p><strong>Remarks</strong></p>
</td>
</tr>
<tr>
<td colspan="2">
<p>1.</p>
</td>
<td>
<p>http://www.trai.gov.in/WriteReadData/Events/Presentation/PPT/201111291232282048929Matthias_Ehrler_Migration_NGN.pdf</p>
</td>
<td>
<p>Presentation titled "Regulatory implications of migrating to NGN" made at the TRAI - Seminar on Next Generation Networks by Matthias Ehrler</p>
</td>
<td colspan="2">
<p>25-08-2011</p>
</td>
<td colspan="2">
<p>Pgs. 6 and 15</p>
</td>
<td>
<p style="text-align: justify;">Presentation by expert covers neutrality implications of migrating to next generation networks.</p>
</td>
</tr>
<tr>
<td colspan="2">
<p>2.</p>
</td>
<td>
<p>http://www.trai.gov.in/WriteReadData/Events/Presentation/PPT/201111291229152361429Scott_Marcus_QoS.pdf</p>
</td>
<td>
<p>Presentation titled "Management of QoS" made at the TRAI- Seminar on Next Generation Networks by J. Scott Marcus of wik consult.</p>
</td>
<td colspan="2">
<p>25-08-2011</p>
</td>
<td colspan="2">
<p>Pgs. 10, 11, 15 etc.</p>
</td>
<td>
<p style="text-align: justify;">Presentation by expert covers neutrality in the context of QoS.</p>
</td>
</tr>
<tr>
<td colspan="2">
<p>3.</p>
</td>
<td>
<p>http://www.trai.gov.in/writereaddata/consultationpaper/document/3agust.pdf</p>
</td>
<td>
<p>Response of Microsoft to Consultation Paper on "National Broadband Plan"</p>
</td>
<td colspan="2">
<p>27-07-2010</p>
</td>
<td colspan="2">
<p>Pgs. 1-2</p>
</td>
<td>
<p>Extract:</p>
<p style="text-align: justify;">" <em> 2. Network Neutrality Openness has been the key to the ever-expanding nature of the Internet. We would urge that the Authority adopt a light-touch regulatory approach to network neutrality that appropriately balances the needs of consumers, network operators, and those of content/ application / service providers as well as those of device vendors. Some respondents have called out the Authority's attention towards this aspect and it is important for the Authority to chart a course that harmonizes the interdependent values of innovation and continued evolution of a robust network infrastructure while promoting consumer choice and freedom online. e suggest that the Authority undertake the following three steps in this regard: a. First, adopt the widely-accepted principles that consumers have the right to access and use the content, applications, services and devices of their choosing and to receive reasonable information about their Internet access provider's practices; b. Second, adopt a behavioral standard intended to prohibit Access Provider discrimination that is anticompetitive or harms consumers, and bar Access Provider conduct that violates the other core, open Internet principles, such as allowing access to lawful content, applications, and services of the user's choosing; and c. Third, implement an expert and efficient enforcement mechanism to identify and prohibit unlawful forms of discrimination. This framework would achieve a sensible balance by allowing Access Providers the flexibility to not only appropriately manage their networks by distinguishing, if necessary, among different types of traffic but also enter into business arrangements with content providers that are transparent and do not discriminate in a manner that is anticompetitive or harms consumers </em> ."</p>
</td>
</tr>
<tr>
<td colspan="2">
<p>4.</p>
</td>
<td>
<p>http://www.trai.gov.in/WriteReadData/Events/Presentation/PPT/201301080620033272892NGN-Migration-Session6-Licensing-Issues-NGN_rev.pdf</p>
</td>
<td>
<p>Presentation titled "Migration to Next Generation Networks" made at the Workshop on Migration to NGN by Martin Lundborg, Stephan Wirsing Martin Lundborg, Stephan Wirsing</p>
</td>
<td colspan="2">
<p>29-11-2012</p>
</td>
<td colspan="2">
<p>Pgs. 30-36.</p>
</td>
<td>
<p style="text-align: justify;">Presentation by expert covers Network Neutrality in the context of content and licensing.</p>
</td>
</tr>
<tr>
<td colspan="2">
<p>5.</p>
</td>
<td>
<p>http://trai.gov.in/WriteReadData/Events/Presentation/PPT/201111291222335017679NGN_Dr.pdf</p>
</td>
<td>
<p>Presentation titled "NGN: UK and European Frameworks" made at the TRAI Seminar on NGN by Rekha Jain.</p>
</td>
<td colspan="2">
<p>25-08-2011</p>
</td>
<td colspan="2">
<p>Pg.18</p>
</td>
<td>
<p style="text-align: justify;">Presentation by expert covers network neutrality as implemented by European authorities.</p>
</td>
</tr>
<tr>
<td colspan="2">
<p>6.</p>
</td>
<td>
<p style="text-align: justify;">http://trai.gov.in/WriteReadData/Events/Presentation/PPT/201111291226086423929NGN_Interconnection.pdf</p>
</td>
<td>
<p>Presentation titled "NGN Interconnection" made at the TRAI- Seminar on Next Generation Networks by J. Scott Marcus of wik consult.</p>
</td>
<td colspan="2">
<p>25-08-2011</p>
</td>
<td colspan="2">
<p>Pg. 41, 43 and 46</p>
</td>
<td>
<p style="text-align: justify;">Presentation by expert covers neutrality in the context of QoS.</p>
</td>
</tr>
<tr>
<td colspan="2">
<p>7.</p>
</td>
<td>
<p>http://www.trai.gov.in/WriteReadData/Events/Presentation/PPT/201301080612503134332NGN-Migration-Session1-Introduction-to-NGN_rev.pdf</p>
</td>
<td>
<p>Presentation titled "Migration to Next Generation Networks" (Introduction to NGN) made at the Workshop on Migration to NGN by Martin Lundborg, Stephan Wirsing Martin Lundborg, Stephan Wirsing</p>
</td>
<td colspan="2">
<p>29-11-2012</p>
</td>
<td colspan="2">
<p>Pg. 25</p>
</td>
<td>
<p style="text-align: justify;">Cursory reference to important regulatory aspects of NGN Migration</p>
</td>
</tr>
<tr>
<td colspan="2">
<p>8.</p>
</td>
<td>
<p>http://www.trai.gov.in/WriteReadData/Events/Presentation/PPT/201111291221446111429NGN_Case_Studies%20-%20Scott%20marcus.pdf</p>
</td>
<td>
<p>Presentation titled "Migration Studies Challenges and Migration Studies, Challenges, and Implementation Case Studies" made at the TRAI- Seminar on Next Generation Networks by J. Scott Marcus of wik consult.</p>
</td>
<td colspan="2">
<p>25-08-2011</p>
</td>
<td colspan="2">
<p>Pg. 6.</p>
</td>
<td>
<p>Cursory reference to public policy challenges in NGN Migration</p>
</td>
</tr>
<tr>
<td colspan="2">
<p>9.</p>
</td>
<td>
<p>http://www.trai.gov.in/WriteReadData/ConsultationPaper/Document/Auspi.pdf</p>
</td>
<td>
<p>AUSPI's Response to the TRAI Consultation Paper No. 6/2011 on "IMT Advanced Mobile Wireless Broadband Services"</p>
</td>
<td colspan="2"></td>
<td colspan="2">
<p>Pg.10</p>
</td>
<td>
<p style="text-align: justify;">At Pg.10: " <em> In an effort to encourage network neutrality, Google asked that the spectrum be free to lease wholesale and the devices operating under the spectrum be open. Google's specific requests were the adoption of certain policies such as open applications, open devices, open services and open networks. Currently many providers such as Verizon and AT&T use technological measures to block external applications. In return, Google guaranteed a minimum bid of $4.6 billion. However, this model of broader eco-system players playing a part in spectrum auctions has not seen significant success, with Google in this instance not winning any licenses. Even if regulator wants to keep the market open for non-telecom players, broader eco-system players can participate through M&As which are likely to be permitted under the new telecom policy. </em> "</p>
</td>
</tr>
<tr>
<td colspan="2">
<p>10.</p>
</td>
<td>
<p>http://www.trai.gov.in/writereaddata/consultationpaper/document/201304090446122006799casbaa.pdf</p>
</td>
<td>
<p>Response of the Cable and Satellite Broadcasting Association of Asia to TRAI Consultation Paper on "Issues relating to Media Ownership"</p>
</td>
<td colspan="2">
<p>8-04-2013</p>
</td>
<td colspan="2">
<p>Pg.30</p>
</td>
<td>
<p style="text-align: justify;">At Pg.30: " <em> Convergence: Despite convergence, there remains fragmentation in the approaches adopted by regulators towards intervention in telecoms and other sectors. However, issues of access, network neutrality, non-discrimination and protection of intellectual property rights ("IPR") are recurrent themes. These are issues that are familiar to competition authorities. Moreover, technological changes may break down these demarcations further. However the real challenge that convergence poses is increased uncertainty in respect of the speed of technical change and its effects in the short and longer runs. Regulators/competition authorities run the risk of 'getting it wrong' either by applying old style/stringent regulations and/or mistaking transitory profitability for abuse. A cautious and flexible approach is required. The application of old style regulations to such evolving markets is not recommended; it may stifle investment and innovation. Regulation should be flexible enough to take account of the evolving market dynamic and be informed by the best assessment of how markets are likely to evolve. TRAI's proposed intervention does not even come close to this dynamic approach since it is predicated on an assessment which is four years out of date. It does not take account of the increased diversity and competition currently prevailing and likely to develop in India over the next 3 to 5 years and beyond. </em> "</p>
</td>
</tr>
<tr>
<td colspan="2">
<p>11.</p>
</td>
<td>
<p>http://www.trai.gov.in/WriteReadData/ConsultationPaper/Document/201306240358500637086RCOM_CC.pdf</p>
</td>
<td>
<p>Counter Comments of Reliance Communications to TRAI Consultation Paper on "Interconnection Usage Charges"</p>
</td>
<td colspan="2">
<p>25-05-2011</p>
</td>
<td colspan="2">
<p>Pgs. 230 (Internal Pg. 41 of appended document)</p>
</td>
<td>
<p style="text-align: justify;">Appended ERG DRAFT Common Position on Next Generation Networks Future Charging Mechanisms / Long Term Termination Issue document analyses questions in relation to QoS and Network Neutrality in the US and other jurisdictions.</p>
</td>
</tr>
</tbody>
</table>
<div>
<hr />
<div id="ftn1">
<p style="text-align: justify;"><a name="_ftn1" href="#_ftnref1">[1]</a> See http://telecomtalk.info/airtel-starts-charging-for-voip-data-viber-skype-charges/128118/ (Last visited on 08-03-15).</p>
</div>
<div id="ftn2">
<p><a name="_ftn2" href="#_ftnref2">[2]</a> See http://telecomtalk.info/airtel-voip-rs75-75mb-with-a-validity-of-28-days/128216/ (Last visited on 08-03-15);</p>
</div>
<div id="ftn3">
<p><a name="_ftn3" href="#_ftnref3">[3]</a> See http://www.medianama.com/2014/12/223-net-neutrality-violation-airtel-introduces-differential-pricing-for-type-of-mobile-internet-usage (Last visited on 08-03-15); http://yourstory.com/2015/01/net-neutrality-startups-in-india-airtels-voip-charges/ (Last visited on 08-03-15)</p>
</div>
<div id="ftn4">
<p style="text-align: justify;"><a name="_ftn4" href="#_ftnref4">[4]</a> See http://articles.economictimes.indiatimes.com/2015-01-15/news/58109002_1_net-neutrality-internet-governance-model (Last visited on 08-03-15); http://gadgets.ndtv.com/telecom/news/government-to-look-into-airtels-plan-to-charge-for-internet-calls-ravi-shankar-prasad-639713 (Last visited on 08-03-15)</p>
</div>
<div id="ftn5">
<p><a name="_ftn5" href="#_ftnref5">[5]</a> See http://www.medianama.com/2014/12/223-a-response-to-airtels-statement-justifying-net-neutrality-violation/</p>
</div>
<div id="ftn6">
<p style="text-align: justify;"><a name="_ftn6" href="#_ftnref6">[6]</a> See http://indianexpress.com/article/business/companies/airtel-move-to-charge-voip-calls-not-illegal-khullar/ (Last visited on 09-03-15); For a video of the interview, see http://youtu.be/d6QyapRBPXA (Last visited on 09-03-15).</p>
</div>
<div id="ftn7">
<p style="text-align: justify;"><a name="_ftn7" href="#_ftnref7">[7]</a> See http://www.medianama.com/2014/12/223-airtel-withdraws-voip-charges-for-now-after-forcing-trais-hand-on-net-neutrality-consultation/ (Last visited on 08-03-15).</p>
</div>
<div id="ftn8">
<p><a name="_ftn8" href="#_ftnref8">[8]</a> See http://www.financialexpress.com/article/industry/companies/airtel-to-roll-back-higher-voip-charges/24057/ (Last visited on 08-03-15)</p>
</div>
<div id="ftn9">
<p style="text-align: justify;"><a name="_ftn9" href="#_ftnref9">[9]</a> See NDTV report dated 16-02-15 at http://gadgets.ndtv.com/telecom/news/trais-paper-on-ott-players-to-also-cover-voip-calls-net-neutrality-in-india-661111 (Last visited on 09-03-15).</p>
</div>
</div>
</div>
<p>
For more details visit <a href='https://cis-india.org/telecom/blog/trai-ing-times-the-story-so-far'>https://cis-india.org/telecom/blog/trai-ing-times-the-story-so-far</a>
</p>
No publishertarunTelecomNet Neutrality2015-03-30T13:32:13ZBlog EntryTRAI Telecommunication Tariff Orders
https://cis-india.org/telecom/resources/trai-telecommunication-tariff-orders
<b>This section will deal with the Telecommunication Tariff Order, 1999 which was issued by the Telecom Regulatory Authority of India, in order to put a cap on the call rates and other allied services.</b>
<p style="text-align: justify; ">The Tariff order mandates that transparency is tariff and consumer protection. The Telecommunication Tariff Order, 1999 has gone through numerous amendments due to changes in the technology and the competition in the market. The Telecommunication Tariff Order, 1999 has gone through 53 amendments as on October, 2012. The TRAI also has laid down tariff orders for broadcasting and cable services.</p>
<p>The main highlights of the Telecommunication Tariff Order, 1999 are:</p>
<ul>
<li style="text-align: justify; ">Review of Tariffs: The TRAI has the authority to review and modify the tariff of any telecommunication service.</li>
<li style="text-align: justify; ">Standard Package: The telecom service provider has to provide a standard package to all its consumers.</li>
<li style="text-align: justify; ">Limits on Tariff: In case there is a specific ceiling on the tariff of a certain telecommunication service, then the service provider has to fix any rate above that ceiling. Similarly, if the TRAI sets a tariff as the floor then the operator cannot provide such service below the rates specified by the authority.</li>
<li style="text-align: justify; ">Reporting Requirement: The telecom operator has to report to the TRAI about the introduction of tariff and the changes subsequent to it.</li>
<li style="text-align: justify; ">Transparency and Consumer Protection: Tariffs charged by the operators should be published along with the terms and conditions attached to it in a manner as prescribed by the TRAI from time to time. It should also project the tariffs in a comparison table and the charges to be paid by the subscriber vis-a-vis the specified standard packages.</li>
</ul>
<p>
For more details visit <a href='https://cis-india.org/telecom/resources/trai-telecommunication-tariff-orders'>https://cis-india.org/telecom/resources/trai-telecommunication-tariff-orders</a>
</p>
No publishersnehashishTelecom2013-03-15T07:04:18ZPage