Centre for Internet & Society

Comments to the Draft Digital Competition Bill, 2024

Posted by Abhineet Nayyar, Isha Suri, and Pallavi Bedi (in alphabetical order) at May 16, 2024 12:00 AM |

This submission is a response by researchers at the Centre for Internet and Society India (CIS) to the draft Digital Competition Bill, 2024, published by the Committee on Digital Competition Law (CDCL), Ministry of Corporate Affairs (MCA), (hereafter “draft DCB” or “draft Bill”).

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How the Telecom Act undermines personal liberties

Posted by Rajat Kathuria and Isha Suri at Feb 20, 2024 12:54 AM |
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In this article, Prof. Rajat Kathuria and Isha Suri analyse whether the law has enough safeguards and an independent regulatory architecture to protect the rights of citizens. The authors posit that the current version leaves the door open for an overenthusiastic enforcement machinery to suppress fundamental rights without any meaningful checks and balances.

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Comments to the Telecommunications Bill, 2023

Posted by Isha Suri, Nishant Shankar, Shweta Mohandas, and Vipul Kharbanda at Dec 22, 2023 06:00 AM |
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The Parliament has passed the Telecommunications Bill, 2023 which seeks to replace the Indian Telegraph Act, 1885. The Centre for Internet & Society (CIS) submits its comments to the bill.

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 CIS’ Comments to the (Draft) Indian Telecommunication Bill 2022

Posted by Abhishek Raj, Divyank Katira, Isha Suri, Shweta Mohandas, and Vipul Kharbanda at Nov 22, 2022 01:22 PM |
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The Department of Telecommunications, Government of India invited comments on the Draft Indian Telecommunication Bill, 2022. The Centre for Internet & Society (CIS) submitted its comments.

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Why spectrum needs a change in approach

Why spectrum needs a change in approach

Posted by Rajat Kathuria and Isha Suri at Oct 29, 2022 10:00 PM |
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Rajat Kathuria and Isha Suri write: It must be recognised that spectrum needs to be combined with other infrastructure to enable service delivery.

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An Overview of Telecommunications Policy and Regulation Framework in India

Posted by Abhishek Raj at Mar 25, 2022 02:06 AM |
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Abhishek Raj, a researcher at the Centre for Internet Society (CIS), has authored a document that provides an overview of the policy and regulatory environment surrounding telecommunications in India.

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Opinion: Delicensing 6 GHz, 60 GHz bands is crucial to improve Wi-Fi scenario in India

Posted by Abhishek Raj at Jan 03, 2022 03:30 PM |
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Recently, there has been growing demand from industry bodies and associations to delicense 6 GHz and 60 GHz bands in India.

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Gram Panchayat Development Plan (GPDP): An Opportunity for Funding Rural Internet Connectivity in India

Posted by Abhishek Raj at Dec 14, 2021 02:12 AM |
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A paper titled "Gram Panchayat Development Plan (GPDP): An Opportunity for Funding Rural Internet Connectivity in India" authored by CIS' researcher Abhishek Raj got published in the book "Community Networks: Towards Sustainable Funding Models". This book was released at the United Nations Internet Governance Forum(IGF) 2021, and is also the official outcome of the IGF Dynamic Coalition on Community Connectivity (DC3).

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Response to TRAI Consultation Paper on Broadband Connectivity and Speed

Posted by Shyam Ponappa at Dec 20, 2020 08:43 AM |
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CIS comments on Telecom Regulatory Authority of India’s Consultation Paper on Roadmap to Promote Broadband Connectivity and Enhanced Broadband Speed

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Unlock = Open, not Choked!

Posted by Shyam Ponappa at Jun 15, 2020 03:04 AM |
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Don't let a virus stall initiatives and weaken the economy.

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After the Lockdown

Posted by Shyam Ponappa at Apr 09, 2020 10:05 AM |

This post was first published in the Business Standard, on April 2, 2020.


This is a time when, as the authorities deal with a lockdown, there needs to be an equal emphasis on providing for large numbers of people without the money for food and necessities, while the rest of us wait it out. Hard as it is, an MIT scholar writes that after the Spanish flu in 1918, cities that restricted public gatherings sooner and longer had fewer fatalities, and emerged with stronger economic growth.1 It is likely that costs and benefits vary with economic and social capacity, and we may have a harder time with it here. Going forward, government action to help provide relief, rehabilitate people and deal with loss needs to be well planned, including targeting aid to the urban and displaced poor.2
As important now as to ensure the lockdown continues is to plan on how to revive productive activity and the economy, and restore public confidence. A systematic approach will likely yield better results.
A major element of the recovery plan is steps such as liberal credit and amortisation terms, perhaps much more than the three-month extension the Reserve Bank of India (RBI) has announced. A primary purpose is the re-initiation of large-scale activities such as construction, of which there are reportedly about 200,000 large projects around the country. These have to be nursed back to being going concerns. The RBI may need to consider doing more, including lowering rates.
An ominous development that has grown as the economy slowed is financial stress that could swell non-performing assets (NPAs). At the half-year ending September 2019, about half of non-financial large corporations in India, excluding telecom, showed financial stress (see table).


Source: Krishna Kant: "Coronavirus shutdown puts Rs 15-trillion debt at risk, to impact finances", BS, March 30, 2020:


These include some of India’s largest companies, producing power, steel, and chemicals. The 201 companies have total debt of nearly Rs 15 trillion, more than half of all borrowings. There is also the debt overhang of the National Highways Authority of India, and of the telecom companies. Ironically, the telecom companies are our lifeline now, despite having nearly collapsed under debt because of ill-advised policies in the past, which have still not changed. Perhaps our obvious dependence telecom services now will spark well conceived, convergent policies for this sector, so that we can function effectively.  
A start with immediate changes in administrative rules for 60GHz, 70-80GHz, and 500-700MHz wireless use, modelled on the US FCC regulations as was done for the 5GHz Wi-Fi in October 2018, could change the game. It will provide the opportunity in India for the innovation of devices, their production, and use, possibly unleashing this sector. This can help offset our reliance on imported technology and equipment. However, such changes in policies and purchasing support have eluded us thus far. Now, the only way our high-technology manufacturers can thrive is to succeed internationally, in order to be able to sell to the domestic market. Imagine how hard that might be, and you begin to get an inkling of why we have few domestic product champions, struggling against odds in areas such as optical switches, networking equipment, and wireless devices. For order-of-magnitude change, however, structural changes need to be worked out in consultation with operators in the organisation of services through shared infrastructure.

For the longer term, a fundamental reconsideration for allocating resources is needed through coherent, orchestrated policy planning and support. What the government can do as a primary responsibility, besides ensuring law and order and security, is to develop our inadequate and unreliable infrastructure, including facilities and services that enable efficient production clusters, their integrated functioning, and skilling. For instance, Apple’s recent decision against moving iPhone production from China to India was reportedly because similar large facilities (factories of 250,000) are not feasible here, and second, our logistics are inadequate. Such considerations should be factored into our planning, although Apple may well have to revisit the very sustainability of the concept of outsize facilities that require the sort of repressive conditions prevailing in China. However, we need not aim for building unsustainable mega-factories. Instead, a more practical approach may be to plan for building agglomerations of smaller, sustainable units, that can aggregate their activity and output effectively and efficiently. Such developments could form the basis of numerous viable clusters, and where possible, capitalise on existing incipient clusters of activities. Such infrastructure needs to be extended to the countryside for agriculture and allied activities as well, so that productivity increases with a change from rain-fed, extensive cultivation to intensive practices, with more controlled conditions.

The automotive industry, the largest employer in manufacturing, provides an example for other sectors. It was a success story like telecom until recently, but is now floundering, partly because of inappropriate policies, despite its systematic efforts at incorporating collaborative planning and working with the government. It has achieved the remarkable transformation of moving from BS-IV to BS-VI emission regulations in just three years, upgrading by two levels with an investment of Rs 70,000 crore, whereas European companies have taken five to six years to upgrade by one level. This has meant that there was no time for local sourcing, and therefore heavy reliance on global suppliers, including China. While the collaborative planning model adopted by the industry provides a model for other sectors, the question here is, what now. In a sense, it was not just the radical change in market demand with the advent of ridesharing and e-vehicles, but also the government’s approach to policies and taxation that aggravated its difficulties.

Going forward, policies that are more congruent in terms of societal goals, including employment that support the development of large manufacturing opportunities, need to be thought through from a perspective of aligning and integrating objectives (in this case, transportation). Areas such as automotive and other industries for the manufacture of road and rail transport vehicles need to be considered from the perspective of reconfiguring the purpose, flow, and value-added, to achieve both low-cost, accessible mass transport, and vehicles for private use that complement transportation objectives as also employment and welfare.
Systematic and convergent planning and implementation across sectors could help achieve a better revival.
Shyam (no space) Ponappa at gmail dot com


India’s ‘Self-Goal’ in Telecom

Posted by Shyam Ponappa at Apr 09, 2020 07:18 AM |


This post was first published in the Business Standard, on March 5, 2020.




The government apparently cannot resolve the problems in telecommunications. Why? Because the authorities are trying to balance the Supreme Court order on Adjusted Gross Revenue  (AGR), with keeping the telecom sector healthy, while safeguarding consumer interest. These irreconcilable differences have arisen because both the United Progressive Alliance and the National Democratic Alliance governments prosecuted unreasonable claims for 15 years, despite adverse rulings! This imagined “impossible trinity” is an entirely self-created conflation.
If only the authorities focused on what they can do for India’s real needs instead of tilting at windmills, we’d fare better. Now, we are close to a collapse in communications that would impede many sectors, compound the problem of non-performing assets (NPAs), demoralise bankers, increase unemployment, and reduce investment, adding to our economic and social problems.
Is resolving the telecom crisis central to the public interest? Yes, because people need good infrastructure to use time, money, material, and mindshare effectively and efficiently, with minimal degradation of their environment, whether for productive purposes or for leisure. Systems that deliver water, sanitation, energy, transport and communications support all these activities. Nothing matches the transformation brought about by communications in India from 2004 to 2011 in our complex socio-economic terrain and demography. Its potential is still vast, limited only by our imagination and capacity for convergent action. Yet, the government’s dysfunctional approach to communications is in stark contrast to the constructive approach to make rail operations viable for private operators.
India’s interests are best served if people get the services they need for productivity and wellbeing with ease, at reasonable prices. This is why it is important for government and people to understand and work towards establishing good infrastructure.

What the Government Can Do

An absolute prerequisite is for all branches of government (legislative, executive, and judicial), the press and media, and society, to recognise that all of us must strive together to conceptualise and achieve good infrastructure. It is not “somebody else’s job”, and certainly not just the Department of Telecommunications’ (DoT’s). The latter cannot do it alone, or even take the lead, because the steps required far exceed its ambit.

Act Quickly

These actions are needed immediately:

First, annul the AGR demand using whatever legal means are available. For instance, the operators could file an appeal, and the government could settle out of court, renouncing the suit, accepting the Telecom Disputes Settlement and Appellate Tribunal (TDSAT) ruling of 2015 on AGR.

Second, issue an appropriate ordinance that rescinds all extended claims. Follow up with the requisite legislation, working across political lines for consensus in the national interest.

Third, take action to organise and deliver communications services effectively and efficiently to as many people as possible. The following steps will help build and maintain more extensive networks with good services, reasonable prices, and more government revenues.

Enable Spectrum Usage on Feasible Terms

Wireless regulations

It is infeasible for fibre or cable to reach most people in India, compared with wireless alternatives. Realistically, the extension of connectivity beyond the nearest fibre termination point is through wireless middle-mile connections, and Wi-Fi for most last-mile links. The technology is available, and administrative decisions together with appropriate legislation can enable the use of spectrum immediately in 60GHz, 70-80GHz, and below 700MHz bands to be used by authorised operators for wireless connectivity. The first two bands are useful for high-capacity short and medium distance hops, while the third is for up to 10 km hops. The DoT can follow its own precedent set in October 2018 for 5GHz for Wi-Fi, i.e., use the US Federal Communications Commission regulations as a model.1 The one change needed is an adaptation to our circumstances that restricts their use to authorised operators for the middle-mile instead of open access, because of the spectrum payments made by operators. Policies in the public interest allowing spectrum use without auctions do not contravene Supreme Court orders.

Policies: Revenue sharing for spectrum

A second requirement is for all licensed spectrum to be paid for as a share of revenues based on usage as for licence fees, in lieu of auction payments. Legislation to this effect can ensure that spectrum for communications is either paid through revenue sharing for actual use, or is open access for all Wi-Fi bands. The restricted middle-mile use mentioned above can be charged at minimal administrative costs for management through geo-location databases to avoid interference. In the past, revenue-sharing has earned much more than up-front fees in India, and rejuvenated communications.2 There are two additional reasons for revenue sharing. One is the need to manufacture a significant proportion of equipment with Indian IPR or value-added, to not have to rely as much as we do on imports. This is critical for achieving a better balance-of-payments, and for strategic considerations. The second is to enable local talent to design and develop solutions for devices for local as well as global markets, which is denied because it is virtually impossible for them to access spectrum, no matter what the stated policies might claim.

Policies and Organisation for Infrastructure Sharing

Further, the government needs to actively facilitate shared infrastructure with policies and legislation. One way is through consortiums for network development and management, charging for usage by authorised operators. At least two consortiums that provide access for a fee, with government’s minority participation in both for security and the public interest, can ensure competition for quality and pricing. Authorised service providers could pay according to usage.
Press reports of a consortium approach to 5G where operators pay as before and the government “contributes” spectrum reflect seriously flawed thinking.3 Such extractive payments with no funds left for network development and service provision only support an illusion that genuine efforts are being made to the ill-informed, who simultaneously rejoice in the idea of free services while acclaiming high government charges (the two are obviously not compatible).
Instead of tilting at windmills that do not serve people’s needs while beggaring their prospects, commitment to our collective interests requires implementing what can be done with competence and integrity.

Shyam (no space) Ponappa at gmail dot com
1. https://dot.gov.in/sites/default/files/2018_10_29%20DCC.pdf
2. http://organizing-india.blogspot.in/2016/04/ breakthroughs- needed-for-digital-india.html
3. https://www.business-standard.com/article/economy-policy/govt-considering-spv-with-5g-sweetener-as-solution-to-telecom-crisis-120012300302_1.html

The Telecom Crisis is an NPA Problem

Posted by Shyam Ponappa at Dec 15, 2019 07:26 AM |
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After interim relief for telecom, structural reforms must follow.

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Traffic Rules, Mindset and On-Time Payments

Posted by Shyam Ponappa at Sep 26, 2019 03:05 PM |
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There's no alternative to following the rules and working together with discipline for our common interests.

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Fix Problems Before Complete Failure

Posted by Shyam Ponappa at Jul 31, 2019 02:43 AM |
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We need some real solutions on the ground. Examples - Jet Airways post mortem findings applied as the way forward for difficult NPAs; and a radical change of course a

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Fostering Strategic Convergence in US-India Tech Relations: 5G and Beyond

Posted by Justin Sherman and Arindrajit Basu at Jul 05, 2019 02:19 AM |

The 2019 G-20 summit underscores the importance of fostering strategic convergence in U.S.-India tech relations.

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5G Aspirations and Realities

Posted by Shyam Ponappa at Jun 06, 2019 10:00 PM |
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What the government can do for 5G and Digital India with a Systems Approach.

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The Huawei bogey

Posted by Gurshabad Grover at May 30, 2019 03:00 PM |
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India needs to prove company aids Chinese government, or risk playing into US hands.

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Democracy, Digital India and Networks

Posted by Shyam Ponappa at May 01, 2019 10:00 PM |
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Digitisation and democracy are ruled by the ineluctable dynamics of networks.

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Delayed Cash Flows and NPAs

Posted by Shyam Ponappa at Apr 28, 2019 04:36 AM |
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We need to rid ourselves of a tolerance of delayed payments to avoid their consequences.

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