Posted on

PM-WANI: Business models

India, a large country with a lot of geographical and economic diversity, faces interesting challenges with last-mile connectivity for internet users. PM-WANI programme provides a powerful technical and policy framework towards the goal of broadband proliferation across the country.

iSPIRT Foundation has been involved with the PM-WANI programme right from its inception. Dr Pramod Varma, Siddharth Shetty and other volunteers, were involved with the technical framework for unbundling the internet access and ensuring interoperability among all participants

As of date, the Centre for Development of Telematics (CDoT) and Telecom Regulatory Authority of India (TRAI) has been ably managing the mantle with all aspects related to the PM-WANI framework.

The PM-WANI has a unique, distributed and unbundled architecture. It has the following participants:

PDO – Set up and maintain the access point (AP). Users connect to this AP to access the internet.

PDOA – Provides the technical backend for the PDO for Authentication, Authorization and Accounting (AAA). PDOA provides a facility for the PDO operator to define broadband sachet for their users (e.g. 1GB data for Rs 5). PDOA also stores the users’ usage data as per the government security compliance.

App-Provider – Operates a mobile application for PM-WANI. A user will use this mobile application to discover a PM-WANI-compatible network. The App-Provider maintains the user KYC.

Central-Registry – It maintains the details of every registered PDO, PDOA and App-Provider. It is generally used to validate requests made between the participants. 

PM-WANI facilitates the delivery of broadband access to users using PDO-operated WiFi access points (AP). A telecom/internet service provider provides the backhaul internet to this AP.

Instead of needing multiple licences and compliances to commercially distribute internet, in PM-WANI’s case, the PDO requires absolutely no compliance or licence to distribute internet locally! 

That does not mean the security is compromised in any way. The user KYC is handled by the App-Provider and the usage logs are maintained by the PDOA

User Flow

PM-WANI as an earning opportunity for small entrepreneurs

This programme offers great monetary opportunities for entrepreneurs. Multiple companies are coming up with varied plans for becoming a PDO / PDOA. Let us discuss some of them 

Case 1: Become a PDOA with a C-DoT software stack and onboard PDOs

This is for entrepreneurs to start their own PDOA business and create a network of PDOs (on their own or onboarding other small-business owners) 

The Centre for Development of Telematics (C-DoT) provides a complete PDOA software stack as Platform as a Service(PaaS). Here, it takes care of all the technical requirements (including software, server and regulatory requirements). This enables entrepreneurs to start their PDOA operations without getting into the technical nitty-gritty. They charge a very low fee of Rs. 15000 for 3 months.

Costs

Here is the cost breakdown for a PDO for Year 1:

Annual Internet pricing – 50 Mbps connectionRs.600/month = Rs 7200/-
Annual Electricity & Router MaintenanceRs.150/month = Rs 1800/-
Indoor AP which is CDoT PM-WANI compliant (WAYU)Rs. 5300/-
Total Investment for year 1 for a PDORs. 14300/-

Cost breakdown for a PDO Year 2 onwards:

Annual Internet pricing – 50 Mbps connectionRs.600/month = Rs 7200/-
Annual Electricity & Router MaintenanceRs.150/month = Rs 1800/-
Indoor AP which is CDoT PM-WANI compliant (WAYU)Already Purchased
Total Investment from year 2 onwards for a PDORs. 9000/-

In this business case, we consider that 95% of the voucher collection goes to the PDO and 5% goes to the PDOA

The annual investment for the PDOA is Rs. 60000

Value Proposition for PDO

A PDOA can create an excellent value proposition for a PDO using this model.

We have considered the average voucher cost for a user to be Rs 2, Rs 5, Rs 10 and Rs 15., eg. a user will buy an internet sachet/voucher of Rs. 2 for 1GB data a day.

The below table shows the cost-benefit analysis for Year 1 wherein a PDO charges Rs 2 per voucher. Annually, PDO breaks even with just 20 daily users and achieves 100% return-on-investment (ROI) with just 40 daily users in the first year itself! Year 2 onwards it’s just 13 users to break even and 25 users for 100% ROI.

PDO Year 1

Daily Cost Per User(in Rs)No of daily users for breakevenNo of daily users for 100% ROI
22040
5816
1048
1536

PDO Year 2 onward

From year 2 onwards, the ROI starts getting even sweeter as the operating cost further reduces to Rs. 9000 for a year 

Daily Cost Per User(in Rs)No of daily users for breakevenNo of daily users for 100% ROI
21325
5510
1035
1524

Value Proposition for PDOA

The below graph shows the number of PDOs needed to be deployed for a PDOA to break even for different voucher costs and daily users

Case 2 – Become a PDO with other private players

There are quite a few companies that allow people to deploy their own PDO directly. They provide a PDO infrastructure (AP and allied software) for Rs 12000 a year

Costs

Here is the cost breakdown for a PDO:

Annual Internet pricing – 50 Mbps connectionRs.600/month = Rs 7200/-
Annual Electricity & Router MaintenanceRs.150/month = Rs 1800/-
AP which is PM-WANI compliantRs. 12000/-
Total Investment for year 1 for a PDORs. 21000/-

Value Proposition for PDO

Daily Cost Per User(in Rs)No of daily users for breakevenNo of daily users for 100% ROI
22958
51224
10612
1548

PM-WANI Challenges

Interoperability 

One of the major challenges that PM-WANI is facing right now is protocol compliance. Because of this, some of the PM-WANI Apps do not work interoperably with the PDO. 

Example: A PM-WANI app developed by company A is not compatible with a PDO of company B. A’s app only works with A’s PDO

Data Sharing 

The protocol, as of now, does not have a standard way to share usage data between the participants. Hence, the app provider does not get any incentive when a user buys a PDO/PDOA coupon due to this lack of data sharing. Also, for implementing roaming between PDOs, it is essential that there is some data-sharing standard available between multiple PDOAs.

Grievance Redressal

This is another area that is not regulated at the moment

What iSPIRT is up to

We are working on multiple fronts to solve the PM-WANI challenges. 

For the interoperability issue, we are developing a certification mechanism for PM-WANI that cthe PDOA or App-Providers can easily usewith minimal complexity.

We are developing a reference implementation for PM-WANI. The community can further build on it and come up with more interesting business models for PM-WANI.

We are also working on proposals for improving the protocol to address the challenges mentioned in the previous section.

Please feel free to write to Saurabh Chakrabarti at [email protected] for any questions.

Posted on

PM WANI – Empowering people with Wi-Fi Internet

Wi-Fi Access Network Interface (WANI) that was envisaged by TRAI Consultation papers has become a reality as Government approved it as PM WANI, on 9th December 2020, for exponential proliferation of public Wi-Fi networks.

PM WANI will make it possible millions of Wi-Fi hotspots to emerge across the country, giving easy access to internet to common man. New business models will emerge, making it possible to add another layer of Internet providers with access points being provided by corner shops and stores and others.

The Detailed Document about the Scheme can be downloaded and read at (Click to open) Department of Telecom Site.

The simplicity of the scheme is recognised by the very fact that DOT automatically recognised PDOA after application in 7 days.

PM WANI explained in a snapshot

This PolicyHacks Panel discussion with Dr. RS Sharma, Ex-Chairman TRAI, Pramod Varma, iSPIRT Volunteer, gave conceptual Architecture of WANI, Siddharth Shetty, iSPIRT Volunteer, Shubendu Sharma, Founder of Wifi Dabba and Dr. Ajay Data, Founder & CEO of a Class A ISP and other technology companies.

iSPIRT has been a protagonist of the concept of WANI with Pramod Varma, Siddharth Shetty and other volunteers involved in building the concept to unbundle another layer of broadband level Internet access to masses on the go and in far-flung areas.

Dr. RS Sharma explains,”we came to a conclusion that if we can create a technology architecture for some body to market and provide access by unbundling from ISPs like UPI has done, then it will become seamless and easy to implement and Kirana shops can also provide Wi-Fi without hassle”

“And that is how we came up with the concept of PDO like PCO of Telephone booths and PDOA etc”, he added explaining how PDOA will be a layer above PDO.

The main policy issue here was reselling of the bandwidth, which was addressed and then a consultation papers was evolved and a pilot done to test the concept on ground, he mentioned while explaining how TRAI was involved.

“It is a very asset heavy architecture if a Telco alone has to do all that physical investment till the last wire in your house or each hotspot in country” and “all the fiber in BHARATNET and others that we are laying no body knows at the the end, what we have to do and it requires an ‘entrepreneurial model’ to scale to be putting millions of connection” said Pramod Varma.

In Covid year, we have seen real hardship for people who are not privileged to have broadband access and education of children abruptly stop. “We have to make Connectivity a human right”, says Pramod Varma and explains, that is why, how essentials it is to invest into infrastructure and the last mile becomes people property.

“We had the mental model that, if we can create self sustaining interesting parts of it” Said Pramod, explaining how the concept was evolved. Adding further, that a KYC done ones can give a KYC token that can be used to further to authenticate who the person is on access layer in the Model, without doing KYC again and again. “UPI will further provide the payment model, as we have already solved it”, said Pramod.

“You will have multiple providers come together to unbundle this” Said Siddharth Shetty, adding to the conversation.

Shubendu, from Wi-Fi Dabba who had been thinking this as a ‘business model’, deployed the pilot for testing the concept. Explaining his experience, he said, “we wanted to see if we draw a Internet cable from a router in our office to street side shop, how it is used by people, can people pay for it and use it and in a week we had people instead of buying eclairs asking for a Token to use Wi-Fi”.

“In 2016, we took it as a fulltime project, and this was the time when our problem started as ISPs stopped giving us connection, after knowing we were reselling bandwidth” said Shubendu.

He also explained that, “the kind of paperwork you have to maintain and additional costs you have to incur” does not make it viable for small business to apply for an ISP.

“This policy make life simpler for businesses like us” in entirety, added Shubendu.

Dr. Ajay Data, who founded a Class A ISP in Jaipur, was on panel and said, “I am ‘very positive’ about it and this can revolutionise many many things in this Country”.

He explained, how the product “Vedio Meet” they developed to solve local education problem did not work on HD quality for students in last mile and had to be downgraded to SD quality, because of bandwidth in last mile. “we need to have the internet of the ‘streaming quality’ across country, where HD streams can be delivered on any device and if we can achieve this, rest of the applications will work ” said Ajay Data.

He raised apprehensions, on how it will be regulated on ground without harassment of the PDOs by regulatory bodies, giving examples of how even licensed ISPs are harassed and ISPs are charged AGR even in on sale of Computers and routers. Similar legal issue should not be left unaddressed and should be taken care, in languages (including vernacular medium) for PDOs to be not harassed.

“May be a board (Certificate) can be out in each PDO point to ascertain that local police and enforcement does not harass them”, said Ajay Data.

RS Sharma, addressing concerns raised by Ajay Data, Said, “PM himself has tweeted about this” and leadership knows the exact importance of the policy.

He further explained that, “Retail sale of bandwidth has been made passthrough in the AGR Computation”, either the TSPs or ISP pays for the 8% AGR, retailer has nothing to pay, as it has been already paid for.

Dr. Sharma also explained further, that it can save lot of bandwidth, as content can be maintained locally at local access points and last mile user need not traverse through the upstream network for local content, which is a very useful concept for ISPs and TSPs, to decongest the upstream networks.

The PDOs will not have any problems, as the responsibility of who is accessing what by monitoring SSIDs will lie with PDOA (aggregator), not with PDO.

Shri Sharma added that, “what is important is this is implemented well” sharing the issue with Ajay that many a times polices are misused. And we all hope good intentions will prevail and country will be benefited, he had added further.

The panel discussion ended with note of thanks.

Disclaimer: The discussion and ideas expressed here should not be construed as legal advice. The discussion is conducted with Industry practitioners and experts for purpose of benefiting the Industry members in Software product, IT and Telecom sectors.

Posted on

New OSP Guidelines – a major reform (Ease of Doing Business)

The new guidelines on Other Service Provider (OSP) issued by DOT on 5th November is one big step taken by Government of India under leadership of Prime Minister Modi in Ease of Doing business for IT and ITeS sector.

You can find the DOT publication here https://dot.gov.in/sites/default/files/2020_11_05%20OSP%20CS.pdf 

iSPIRT Organised a Panel discussion in PolicyHacks to understand the changes that have been announced and how they impact the Industry.

The panellist included
1. Shri R.S. Sharma, Ex-Chairman TRAI
2. Rahul Matthan, Partner, Trilegal
3. Shanmugam Nagarajan, Founder and Chief People Officer, [24]7.ai
4. Chocko Valliappa, CEO, Vee Technologies
5. Sudhir Singh, Core Volunteer, iSPIRT, Policy Hacks Host

The panel discussion can be watched at below given Youtube video or you can read through the excerpts of the discussion given below in this blog.

Background

IT and ITeS companies looking for seamless cross border communication between the Indian Centers and their foreign counterparts centers use a telecom circuit service (IPLC, MPLS, Sip trunk), obtained from an Indian Telecom Service Provider (TSP). Traditionally, they were supposed to apply and get registered as OSP. The application and approval process were cumbersome and required them to submit detailed network diagrams and satisfy that authority of a legitimate use of the Circuits. The process was cumbersome, more bureaucratic than technical in nature and often subject to undue harassment by TERM cell even when use was fully legitimate.

Industry has been demanding this reform for long, as the Circuits were always subscribed through a licenses TSP in India. The Reform will give way to a new era of opening in telecom services. It is most likely to benefit IT and ITeS industry the most, boost innovation and synergistic alliance in Industry. Most importantly this will make India more attractive for FDI, as this was one major irritant in deploying most important part of the International operations i.e. International Communication.

The move will not only help large offshore IT and BPO Centers but also will empower domestic Software product companies. It will give a huge impetus to work from home and hence will be very instrumental in promotion of SaaS industry, both for their internal operations and also promote SaaS product adoption.

Some of the main highlights of this decision are.

1. No need for a Registration any more to operate as an OSP

2. Interconnection of multiple OSP centers and remote agents

3. Work From Home and Remote locations allowed

4. Centralised Infra and consolidated Traffic between Indian POP and International POP

5. Sharing of EPABX and PSTN lines by domestic and International Center

6. Distributed Architecture with main Infra at central POP and media gateways at other centers

7. CUG allowed for internal Communication

8. CDRs, access log, configurations of EPABX and routing tables to be maintained and aggregated for each media gateway for a period of one year

9. No toll bypass allowed and no telecom services to be provisioned

Excerpts of the Panel Discussions

The panel discussions started with a round of Introduction and inviting Rahul to summarise the new regulations.

Rahul Matthan started the panel discussion with a summary of the guidelines announced. He termed the new guidelines issued as Radically simplified.

Starting the introduction to new Guidelines, he said, “OSP or the Other Service Provider regulation in essence regulates Business Process Outsourcing companies and the definition of the types of entities that are regulated by this is very important. Earlier the definition used to include things like call centers, Business Process Outsourcing and other IT services, but also had very broad language at the end which included all IT enabled Services.

So, the first amendment is that it’s been restricted now to voice based business process outsourcing services.”

“The second very significant amendment that has happened is that the registration requirement has been entirely removed. Earlier you had to register with the TERM cell of DOT and that that requirement has been entirely removed,” Said Rahul.

He further mentioned that work from home (WFH) is allowed without any restriction of site or permissions and submission of network diagrams. He added. “it is work from anywhere” and “also, infrastructure sharing has been permitted there are some significant changes in the interconnectivity regulations have been permitted”.

“Bank guarantees used to run into crores for many large companies. The requirement for submitting performance bank guarantee has now been removed”, mentioned Rahul.

He also informed that the general provisions about penalty provisions with regard to inspection have been removed. “In fact, the entire chapter with regard to penalties and inspection has been removed”, mentioned Rahul.

Shri RS Sharma informed the panel how the consultation papers and discussion at TRAI on the subject progressed at TRAI. He informed that whereas the OSP regulation was very old, TRAI got a reference to start the consultation process in September 2018 and the Consultations were submitted by TRAI to DOT in 2019, which is exactly one year back.

“Essentially thought which we had was OSPs are the ones who are the customers of the TSPs telecom, they are paying money to the main service provider which is the TSP, so why should we really come in between and you know ask for all kinds of you know compliance” said Ex-TRAI chief, recalling developments.

He further informed that, next thing that was taken up is the definition, and as these are the entities which are taking resources from the telecom service providers or ISP and actually doing somebody’s work or providing services to some other entity, they should all be called application service providers (ASPs).

“Unfortunately, the OSPs also included those people who were actually providing services internally. We said any entity which provides service to itself after taking resources from the telecom service providers will not be coming within the definition of logical OSPs”, Said Shri Sharma.

He also recalled that it was recommended that everyone need not register, and only voice based OSPs need to be registered, Data based OSP need not be Registered.

The new definition given at chapter 1 point 7 states these recommendations. As said by Rahul earlier, the new guidelines limit OSP to voice-based processes only.

Shri Sharma further recalled that the TRAI recommended the removal of the requirement to submit network diagrams in OSP registration. He also further mentioned that TRAI also took a stand not to include hosted contact center service infrastructure or cloud hosted infrastructure, in OSP application scrutiny.

Shri Sharma said,” Interestingly in the last 10 years not even a single bank guarantee has been encashed.” He said bank guarantee was the most ridiculous part of the provision, as Govt. was not earning any revenue from OSP,

Similarly, he recounts the recommendations made on interconnectivity among the various OSPs, that also we said should be allowed. “I feel really satisfied”. Said shri Sharma, citing that most recommendations have been accepted.

In further discussion, Sudhir added that we were not having regulation at par with the developed world and called Rahul to give his perspective on regulatory aspects of OSP provisions.

Rahul emphasised in past Data was scarce and a licenced kind of regime was brought in with some sort of a performance guarantee to ensure compliance. Data today is not scarce and with the advent of smartphones and choices one has to make calls, the OSP regime was just giving comfort to the Inspector raj of the TERM cell.

“Country ran out of static IP Addresses”, said Rahul, when it tried to tackle the work from home during the Pandemic. Although DOT cooperated in providing relaxation, the actual need was to remove regulations relating to logical separation between Voice and Data and the need for physical EPABX.

S. Nagarajan, joined the discussion and said, “antiquated rules only hurt the industry by not letting us expand freely within the country. We are in other countries like Colombia, Philippines, Guatemala and none of these countries have these regulations”.

“So this has many benefits for us in all the dimensions, one leading to the other.. ease of doing business, geo competitiveness, location diversity, workforce diversity, talent pool expansion and increased quality of delivery through reduced attrition, (taking it back to geo competitiveness) and there by increasing our business potential for the country, creating millions more direct and indirect jobs for the nation. Thus, it is a better stimulus to the economy than just a monetary stimulus.”

Extending the panel discussions further,

Chocko Valliappa, recalled how the Government brought in Texas Instrument to Bangalore and facilitated them with a Red Carpet but in due course with such regulations the Red Carpet became Red Tape.

He mentioned that, “We employ 6000 employees between US, India and Philippines and in US for example 95% of our work is done work from home and that’s how we always operated and but in India, we are operating in just 3 cities, Bangalore Chennai and Salem and I’m sure this (the new OSP guidelines) would give us a big footprint across India and set up offices across other places.”

“In the next 35-40 years India will be capable of handling 15% of the global economy. By 2050, India will be poised to become the manufacturing hub of the world replacing China by harnessing 3D design and printing capabilities.  I think India engineering talent would be sought after much more, so I think its a step in the right direction”, he further added.

Shri RS Sharma spoke further in response to a question by Rahul on whether the OSP regulation will fully go away in future. He recalled his experiences and how and why bureaucracy could not implement the ease of doing business issues easily.

Shri Sharma said, “TRAI had given two sets of recommendations, one to Ministry of Information and broadcasting another to the Department of Telecom, where we actually targeted ease of doing business.”

He also said that he has seen that the honourable Prime Minister is passionate towards ease of doing business and ease of living. He wants it, but I think we all need to come together, and we all need to sort of continuously work towards it.

“It’s a great thing which has been done actually and I was so happy, and I complimented each one of the people who are involved including the Department of Telecom”, mentioned Shri R.S Sharma at the end.

Discussion ended thanking all participants.

Disclaimer: The discussion and ideas expressed here should not be construed as legal advice. The discussion is conducted with Industry practitioners and experts for purpose of benefiting the Industry members in Software product, IT or ITeS Industry.

Posted on

Understanding National Digital Communication Policy For Startups And Cloud Telephony Players

iSPIRT has been actively engaged in pursuing the favourable policy for the Cloud Telephony sector in Telecom Industry, an amalgamation of the various IT and Communications technologies.

National Digital Communication Policy has been announced recently and it is encouraging to see the announcements in the policy on some common issues to do with Startup ecosystem and digital communication aspects of the Cloud Telephony Players.

We are expecting the Department of Telecom (DOT) to further work on implementation and framing of rules and regulation in light of policy in near future. Despite many positive directional changes, there is a need to develop a regulatory framework for the Cloud Telephony players. Cloud Telephony players are adding value to communication and hence to the economy in several innovative ways. In addition, they also add a good revenue stream to licenses Telecom Service Providers (TSPs).

This PolicyHacks session is devoted to the critical analysis of the NDCP for this sub-sectoral player. Some of the entrepreneurs involved in the discussion are Gurumurthy Konduri of Ozonetel, Ujwal Makhija of PhoneOn, Gaurav Agrawal of Exotel and Gaurav Sawhney of Knowlarity.

A recording of this discussion is given below. Please feel free to click and watch. (About 20 seconds lost in the opening frame, apologises for the error)

The main point covered in the discussion is summed up below as are the some of our recommendations and good work is done (while the Policy was in the draft stage and during various consultation processes), which have been reflected in the policy under respective sections as under:

Page 7

1.1.(f)   – Encourage and facilitate sharing of active infrastructure by enhancing the scope of Infrastructure Providers (IP) and promoting and incentivising the deployment of common sharable, passive as well as active, infrastructure

1.1.(g).iv.  –  Allowing benefits of convergence in areas such as IP-PSTN switching.

Both of these are encouraging moves however it is to be seen how further rules and framework make easy for Small and Startup companies to use them without licensed TSPs creating a barrier for them.

Page 8

1.1.(j) – By encouraging innovative approaches to infrastructure creation and access including through resale and Virtual Network Operators (VNO)

This is a very encouraging announcement for the Cloud Telephony startups.

Page 14

2.1. (c ) iv. – Improving the Terms and Conditions for ‘Other Service Providers’, including definitions, compliance requirements and restrictions on inter-connectivity

2.1.(c ).viii. – Creating a regime for fixed number portability to facilitate one nation – one number including portability of toll-free number, Universal Access numbers and DID numbers

Again very encouraging but needs some boost up. Audiotex regime must go most speakers feel and all the players in Cloud telephony are treated as ASP. These provisions will help cloud telephony to deliver better value propositions in their offerings.

Page 15

2.2.(a) iv:  – Encourage use of Open APIs for emerging technologies

2.2. (b) – Promoting innovation in the creation of Communication services and network infrastructure by Developing a policy framework for ‘Over The Top’ (OTT) services.

2.2.(f) ii.  – Enabling a light touch regulation for the proliferation of cloud-based systems

2.2.(f).iii. – Facilitating Cloud Service Providers to establish captive fibre networks.

A welcome move to encourage Open APIs. However, licenses TSP should be given one standard that is governed by DOT to implement any APIs that let them monitor cloud telephony or ASPs on their network, instead of allowing them to create a regime of their own.

Generally, an OTT policy is recommended in reforming the sector. However, OTT framework should not be mixed with ASP or Cloud Telephony providers. It is better to keep a distinction between the two.

Page 17:

2.4.(a).ii: – Promoting participation of Start-ups and SMEs in government procurement

2.4.(b).  – Reducing the entry barriers for start-ups by reducing the initial cost and compliance burden, especially for new and innovative segments and services.

Acceptance of these issues is very encouraging. The Government can be a very big user of the Cloud Telephony industry also. And we hope this will turn out to be a winning proposition for the Cloud Telephony industry in near future.

Conclusion

Whereas this policy announcement reflects a positive change, it is yet to be seen how DOT look at Cloud Telephony and provides it with a recognition as a sub-sector with easy and proper regulatory framework for same.

Note: The above article is co-authored by Gurumurthy Konduri of Ozonetel with Sudhir Singh of iSPIRT

Posted on

Cloud Telephony Startups seek support from TRAI

This write-up should be read along with the previous blog – The Value Added Service Providers in Cloud Telephony. These blogs help us to accumulate the progressive development in discourse on policy for this segment of Industry. It is important for our common understanding and help Software product industry innovating in telecom sector in general and cloud telephony in specific terms.

The Startups providing Value Added Services also refereed to as Cloud Telephony submitted their response to Consultation Papers by TRAI on Voice Mail/Audiotex/Unified Messaging Services Licence. 

TRAI also received responses from other service providers (which includes licensed Telecom Operators and ISPs) and Industry Bodies and Individuals. iSPIRT response was also submitted on the due date and can be accessed here from TRAI website.

The responses have been analysed and as required the counter comments have  been filed with TRAI.  Given below is our Response submission.

Counter Comments to responses received on Consultation paper by TRAI on Voice Mail/Audiotex/Unified Messaging Services Licence. Dt. 08/08/2016

After reading the responses to consultation papers, it is evident enough, that there is a clear divide between the Startup or SME players and the Telcos or the industry bodies representing them.

As previously described by us, almost all companies presently providing the services in this (voice mail/Audiotex) space are startups or SME players who have built their own Software products. Unified license operators are already allowed to provide these service. So, there is no barrier for them to enter in to these services, except creating specialisation around these services and building the requisite Software that runs the service.

The licensed Telecom operators in their responses to consultation paper have blindly favoured a license regime in this space, as well as attempted to make the case of revenue loss and breach of license. This is clearly an attempt to hog the telecom sector landscape.

We believe the approach taken by the large players in the Industry is contrary to the direction, thought and objectives of present Government. It confronts the principles of building an innovative society and multiplying growth opportunities for the enterprising youth of our country.

Recognize them as value added Services

We already stated this in our response earlier submitted. However, it seems there is a need to reinforce the point.

The services provided in this space are highly specialised “Value Added Services”. They are by no means either the carriage services or network services. It is a layer on top of the existing mobile and basic telephony that delights the consumer by fulfilling their needs that basic/mobile telephony cannot.

Value Addition is done on the services hired from licenses telecom operators, which have already been subject to revenue share mechanism. Hence, the very claim that these services can be sold at a cheaper rate than the local calls is squarely an imagination. So, also the revenue loss story does not stand any ground.

Therefore, the need to recognize this aspect of “Value Added Service” providers, is primary to any policy framing under consideration on the subject.

Regulate doesn’t imply inevitability of license

There is a serious need to catch up with technological advancements. A large country like India can’t be left to mercy of few companies on this account. This calls for reform and further deregulation of the telecom sector to a degree that it is accommodates the changes from time to time.

In order to allay any doubts of the stakeholders in this sector and better value to the consumer, there may be need to regulate this sub-sector of Value Added Service provider.

Regulation does not always mean “a license”. This value added service sub-sector does not hurt the incumbent licensees in any way. Hence, a simplified regulated regime with lower administrative burden and lowers costs is desirable for suitability to this segment of the telecom sector.

Hence, a registration system with period monitoring and control rather than a license regime has been recommended by us.

Promote Innovation in Digital economy

Indian is entering in to a ‘Digital Economy’ era. Digital India is also not just about connectivity and switching networks. So, a ‘Digital India’ cannot be created by just handful of licensed Telecom players. The consumer in a digital economy is going to consume variety of data and application. Innovative Software products can power up the Digital India to make it a functional ‘Digital Economy’.

Innovation is going to be the lubricant of future digital economies

This segment of the Value Added Service has been born out of innovation of individual entrepreneurs and service provision works on Software products. So, also the commercial part of the service in integrated manner.

At this juncture, when India is wanting to unleash the innovative power by its StartupIndia policy, the license raj or barrier created by large Telcos can be counterproductive to digital economy or the Digital India dream.

Telecom sector and telecom policy at large has to imbibe this need to create friendly promotional environment for innovation to happen. It is not hidden from any one that innovation worldwide is being driven by individuals and small players.

All stakeholders in telecom sector including the licensed telecom operators should contribute to Innovation. Hence, the need to support these small Value Added Service providers and welcome the new ones to emerge.

iSPIRT Request

We seriously feel that growth cannot come from fixing ourselves to status quoist approach. There is a need to further add value to the telecom sector and hence a need to create scope for number of small players to contribute to the overall telecom sector.

There is a huge opportunity for Indian Software industry to innovate and contribute to telecom sector. We from iSPIRT, request that TRAI takes the above points and our earlier response submitted in to consideration and create an enabling environment for India to grow.

Posted on

The Value Added Service Providers in Cloud Telephony

Industry discussion on response to Consultation Papers by TRAI on Voice Mail/Audiotex/Unified Messaging Services Licence

TRAI floated a consultation paper to review the license of Voice Mail/Audiotex/Unified Messaging Services. The consultation paper throws light along with an in-depth analysis of various issues involved.

Many call these companies as Cloud telephony companies. Cloud telephony is a wider terms. Plus its creates confusion on switching happening from cloud. This can be problematic for a dialog with TRAI or DOT. Hence, We have called them as Value Added Service Providers. This argument is justified in this discussion below.

For iSPIRT this sector is important as

  1. Most of these companies have a Software product at the core developed by them
  2. They are mostly startups and
  3. There is enough scope in  this sector for more innovation to happen.

iSPIRT conducted a discussion on important issues of this segment of the Industry. The discussion was to touch on important aspects of the consultation papers of TRAI. The discussion is organized in 4 parts as follows:

  1. License issues
    • License v/s no license, separate licenses Technology and license mapping
    • Entry Fees, Revenue Share, License Period
  2. Issues like conferencing, dial out, point-to-point conferencing
  3. Unified License – how to tackle this
  4. Focus on innovation, Startups, Ease of Business (compliance)

Following people from Industry joined the Discussion:

  1. Ambarish Gupta, Sandeep Upadhyay and Sriram from Knowlarity
  2. Gurumurthy Konduri from Ozonetel
  3. Shivakumar Ganesan – Exotel
  4. Anik Jain – Myoperator
  5. Ujwal Makhija  – Phonon

Those interested can watch the video embedded here. Also the text below the video describes the common points and agreements of the essence of the discussion.

License issues

There are several questions asked in consultation paper on, What kind of licensing is required for various services. (Q1 to Q8)

At iSPIRT we feel most of these providers fall under one category. And they all should get recognition under one category name. This will include all, those who provide Voice mail, Audiotex, Audio Conferencing service etc. They can focus on one set of service or the entire suit of services.

Nomenclature – Call them Value Added Service providers

Cloud Telephony means a telephony service provided from cloud hosted infrastructure. simple reason that the service offered from cloud. Present policy regime of India calls them content providers. Now this may be difficult to digest for remaining IT industry. This include  provider licensed under the Voice Mail/Audiotex/Unified Messaging Services License.

Application service provider (ASP) and Communication application service provider (CaaS) are other nomenclatuers ascribed.

These providers are not supposed to carry telecom traffic or provide switching of telephony. In essence these providers are “Value Added Service” (VAS) providers. These value added services can range from be voice mail box, an IVR, a virtual PABX, a virtual call center to analytics based services.  There can be lot of innovative ways to deliver services. The VAS operator charges for their value added part. The VAS operator does not have its own network but relies on network resources of the Telcos for the basic or mobile telephony.

Weather a license or a simple Registration process

Everyone in the panel agreed that licensing cumbersome and costly. There is no need for a license and that there should be a simplified registration process.

The registration should be under one category e.g. Value Added Service Providers. This can cover all Voicemail, Audiotex along with Audio conferencing and the Unified messaging.

The registration helps DOT to keep track of fair use of the policy, with complete neutrality and level playing field. DOT can keep watch the registered VAS providers through a simple compliance process.

License issues – Entry Fees, Revenue Share, License Period

There was common agreement in the discussion on fees and charges. Presently there is a bank guarantee of 3 lakhs for Voice Mail/Audiotex licenses. A policy to either keep it at same level or evolve to simplify further is welcome.

License/registration period of 10 or 20 years are good enough.

Issues like conferencing, dial out, point-to-point conferencing

The consultation paper deals at length these issues. For the industry they are of high importance as most confusions arise from them. Often the threats of inspection and service disruption from TERM cell arise from these provisions. There is always a doubt that the VAS operator may be involved in routing call traffic for business motives or running a switching service clandestinely.

In such a dubious doubtful environment this budding segment of Industry cannot grow. The VAS operators addes lot of value to both their suppliers and clients. The customer pays for the value they add not for the telephone calls. For suppliers (Telcos), the VAS operator is a bulk service customer

The common agreement was that this area needs a serious look from TRAI and DOT.

When industry is complying with all required prohibited clauses of the policy such as

  1. No VOPI integration
  2. No toll bypass
  3. No number masking

When the Call deail record (CDR) are all tapped in the Telco’s network;

AND

When there are further detail logs and records that are avaialable from VAS provider;

there does not arise a chance of

  1. Security  breach by VAS operators and
  2. Revenue loss to Telcos

The revenue of Telcos increase happen to increase even when they VAS providers buy from Telcos at a discounted rate. VAS operators increase the size of Pie.

In view of above, the common agreement in the discussion was that

  1. There should be clarity on conferencing, bridging call out provisions
  2. There is nothing like point to point conferencing
  3. The policy should allow VAS operators to use telecom resources from multiple operators. The limiting principle should be dial out to same operator from where incoming call comes.  Multiple operators are the need for reliability or redundancy.

OSP like provisions or OSP should be allowed for VAS providers?

There was an opinion on OSP being allowed to VAS operators. This will give them more flexibility to operate and grow their presence. The opinion attempts to justify the OSP based on analogy of large Captive call center operators allowed OSP with network spanning country wide with a central logic running.

iSPIRT’s opinion is that this may create conflict with other areas of policy under TRAI and also face sever resistance. It is advisable to take up this issue in a phased manner. May be first limiting OSP to one telecom circle at a time. Plus it advisable to approach it, after due consultative interactions with TRAI and DOT.

Unified License – how to tackle this

There are number of questions on Telcos operating under unified license to offer VAS. The questions also point to inclusion of “Voice Mail/Audiotex/Unified Messaging Services” in unified license.

The common opinion that emerges out from discussion is that the Value Added Services is a different ball game. The market should be free for all. Eventually there is a unique Software Product existing behind these services. The quality of service is highly dependent on this core product.

There does not seem to be any apposition to Unified license getting extended to the value added service suit.

Focus on innovation, Startups, Ease of Business (compliance)

This fourth part got truncated from the recording, perhaps for time limit getting crossed unnoticeably.

For benefit of the community. A very short discussion on how this small industry could further be boosted by perhaps giving more access to domestic market through promotional policy measures.

Certainly there is agreement that there is lot of scope to innovate and do more within this segment of the Industry.

The discussion ended by a Thank you note.