CUTS Comments on TRAI’s Consultation Papers

CUTS Comments on TRAI’s Consultation Papers

S.No.	Title	Submitted on	Description
	Consultation Paper on Unified Licensing Regime (Paper No. 6/2004)	30.04.2004	CUTS has provided its comments on the Unified Licensing Regime and the associated services.
	Consultation Paper on Fixation of Ceiling Tariff for International Private Leased Circuit (Half Circuit) (Paper No. 10/2004)	27.05.2004	CUTS has presented its comments to TRAI on fixating tariff ceiling for International Private Leased Circuit.
	Consultation Paper on Access Deficit Review (Paper No. 13/2004)	15.07.2004	CUTS has provided a detailed opinion about the methodology and estimates of the ADC regime to TRAI.
	Consultation Paper on Revision of Ceiling Tariff for Domestic Leased Circuits (Paper No. 12/2004)	15.07.2004	Comments on Revision of Tariff Ceiling for Domestic Leased Circuits was provided to TRAI.
	Consultation Paper on “Growth of Telecom Services in Rural India” (Paper No. 16/2004)	30.11.2004	CUTS strongly believes that provision of telecommunication services in rural areas should be based on the actual demand. This and other recommendations were sent to TRAI in response to the subject mentioned consultation paper.
	Consultation Paper on “Review of Quality of Service (QoS) Parameters of Basic and Cellular Mobile Telephone Services” (Paper No. 2/2005)	21.03.2005	CUTS recommends a systematic review of the Quality of Service (QoS) Parameters for Basic and Cellular Mobile Telephone Services in the country and consider it as necessary for ensuring improved quality of telecom services.
	Consultation Paper on “Interconnection Usage Charge Review” (Paper No. 4/2005)	15.04.2005	Detailed comments on “Interconnection Usage Charges” was sent by CUTS to TRAI.
	Consultation Paper on Billing Issues	31.05.2005	CUTS has welcomed TRAI’s initiative to establish ‘Code of Practice in Billing Accuracy in India’ and has provided comments on related issues.
	Consultation Paper on Mobile Number Portability (No. 7/2005)	30.08.2005	CUTS greets TRAI’s move to introduce “Mobile Number Portability”, as it would allow subscribers the choice to change their service provider while retaining their old telephone number. Portability is expected to benefit subscribers and increase the level of competition among service providers.
10.	Consultation Paper on Proposal for Amendment to the Tariff Order of 1.10.2004 on Broadcast and Cable Television Services (No. 9/2005)	09.12.2005	The proposal as it stands is a win-lose situation (win for MSOs, and lose for consumers). To make it a win-win situation for all, TRAI should mandate that all new pay channels should be introduced as individual channels AND through an addressable system. It is then that consumers would really benefit.
11.	Consultation Paper on Differential Tariffs for On-network calls (No. 3/2006)	25.01.2006	Differential tariffs on-network calls should be permitted. ‘On-network’ should be defined as the network of the same operator either within or outside the same service or within or outside the same service area. ‘On-network’ involving multiple operators should be outrightly disallowed, as it is anti-competitive in nature.
12.	CUTS’ Comments TRAI’s Consultation Paper on ‘Tariff Plans With Lifetime Validity’ (No. 4/2006)	31.01.2006	So-called ‘Lifetime Validity Offers’ indeed signifies the intense competition and imagination that Indian telecom sector offers today. TRAI must ensure that claims maid in such schemes are fully met in transparent manner. Such schemes, which are actually valid till the expiry of the license of related operator, may accelerate the pace of the efforts being made to increase tele-density in India.
13.	Consultation Paper on “Issues relating to commercial tariff for Broadcasting and cable television services” (No.05/2006)	13.05.2006	The key line of distinction between 'ordinary' and 'commercial' cable subscriber should be whether the broadcasting and cable services are being commercially exploited or not. ‘Consumer’ should be viewed as an ultimate user of goods and services. Therefore the distinction between ordinary cable subscriber and commercial cable subscriber should be on the basis of the nature of end use, which should be distinguished as whether the service is used for own use or packaged as a value added service with other services provided and sold to consumer at a charge.
14.	Consultation Paper on “Tariff Order for CAS Areas" (No.11/2006)	05.07.2006	CAS provides a tool to consumers to exercise their choice over channels they wish to view. By allowing bouquet(s), we are moving away from this very rationale for introducing CAS. Hence, forming of bouquets under CAS should not be permitted. TRAI should determine the price of individual pay channels, depending on the cost of carriage, and if carriage cost is difficult to calculate, then it should fix the ceiling price for each individual genre based on a simple average of historical prices of all channels falling under a particular genre.