1. Regulation & Implementation of Mobile Internet Quality of Service: Role & Scope of Civil Society Organisations PRESENTATION BY: NEHA TOMAR, RESEARCH ASSOCIATE, CUTS INTERNATIONAL

2. Outline  Background  Definition of QoS  Relevance and Importance of Civil Society Representation in QoS  Civil Society Representation under TRAI  Role of Civil Society Representation – Current and Envisaged  Challenges Faced by CSOs  Points for Discussion

3. Background  Increase in usage of mobile internet – Average mobile internet bill accounted for 45% of the total bill in 2013, in 2014 the same accounted for 54% of the bill  Envisaged growth in mobile internet – In 2013, 174mn users, in June 2015, 213mn estimated users  Ongoing debate on net neutrality and digital inclusion, the forgotten deliberation on the importance of quality of service standards in this dynamic sector  Issues – irregular service, high tariff plans, lack of awareness among consumer’s regarding redressal mechanisms, etc

4. Definition of QoS  International paradigm: Collective effect of service performance, which determines the degree of satisfaction of a user of the service (ITU)  Telecom Regulatory Authority of India (TRAI): Main indicator of the performance of tele communication network and of the degree to which such network conforms to the standards of such quality of service, specified in the notification QoS Standards as per TRAI Name of Parameter Benchmark Regulation 2012 Service Activation/ Provisioning Within 4 hours with 95% success rate Successful Data Transmission Download Attempts > 80% Successful Data Transmission Upload Attempts > 75% Minimum Download Speed To be measured for each plan by the service provider and reported to TRAI Average Throughput for Packet Data > 75% of the subscribed speed Latency Data < 250 ms PDP Context Activation Success Rate ≥ 95% Drop Rate ≤ 5% Amendment 2014 Minimum Download Speed ≤ 80% of the usage time Source: TRAI Website, http://www.trai.gov.in/Content/Regulation/0_3_REGULATIONS.aspx

5. Relevance and Importance of Civil Society Representation in QoS  Who are CSOs – Institutions encompassing all organisations that exist outside the State  Why CSOs – Mobile internet, a market driven by consumer demand. A recent survey revealed that 89% of consumers in India are not satisfied with mobile internet services, while 43% complained of meek access. 77% surveyors maintained that TRAI had not taken adequate steps to address the issues which impede QoS

6. Civil Society Representation under TRAI  Guidelines for Registration of Consumer Organisations/ Non Governmental Organisations (NGOs) and their Interaction with TRAI, 2001 - For systematic representation of consumer groups  Guidelines for Registration of Consumer Organisations/ Non Governmental Organisations (NGOs) and their Interaction with TRAI, 2013 - To enhance transparency in the registration and interaction process  Current Status – 42 CSOs/ NGOs registered with the Consumer Affairs and Quality of Service Division, TRAI

7. Role of Civil Societies in QoS – Current and Envisaged  Regulation - Role of CSOs in providing comments and counter comments on draft regulations by TRAI (VOICE, NHSCE, AUTSPI, ISoc) - Need for further participation of CSOs in providing comments to TRAI - Need for periodic assessment of regulations pertaining to QoS  Implementation - Auditing of QoS reports - Publication of QoS reports - Bring out the challenges in implementing QoS

8. Challenges Faced by CSOs  Financial limitations – CSOs often face financial constraints as they often depend on external sources for funding  Lack of training and capacity building – As QoS is a niche subject and coupled with financial constraints, capacity of CSOs to comprehend issues becomes a challenge  Poor regulatory feedback – Although comments are provided by CSOs to TRAI, feedback mechanism by TRAI is missing  Information Asymmetry – While CSOs participate in providing comments, there is no unanimity in the process

9. Points for Discussion  Can CSOs play a strong role in monitoring and implementation of QoS? Does the architecture provide space for stakeholder engagement?  TRAIs procedure of addressing inputs of CSOs on draft regulations – Is there a need for further transparency and accountability? accountability?  Does the environment provide space for consumer voice at the level of decision making?  Auditing by TRAI is done via three “appointed agencies”. Can CSOs play a role in ensuring transparent and effective audits?  Should QoS be periodically reviewed?  How can we enhance the experience of CSOs registered with TRAI?

10. Thank you