MUMBAI: Distribution platform operators (DPOs) have shared their comments to modify Telecom Regulatory Authority of India (TRAI)’s draft on The Telecommunication (Broadcasting And Cable) Services Interconnection (Addressable Systems) (Amendment) Regulations, 2019.  The industry has welcomed TRAI’s move to amend Schedule III of the regulation and believes that provisions related to watermarking, fingerprinting and digital rights management along with CAS and SMS is in right direction.

AIDCF said, “It is submitted that the provisions relating to watermarking, fingerprinting and digital rights management along with CAS and SMS, is a step in the right direction and AIDCF wholeheartedly supports the same. With respect to amendments proposed to be introduced by TRAI in the schedule III of the Interconnection Amendment Regulations 2019, AIDCF stands in agreement with the same and supports TRAI in bringing about the amendments in the regulations.”

However, Bharti Telemedia (Airtel), Tata Sky and GTPL recommended a few changes in the draft of interconnection addressable regulations.

Airtel, with regard to Section C Clause 8 of the regulation, recommended that the capacity of the CAS and SMS should be linked to the volume of transactions rather than the subscriber base. The rationale for the same is that each subscriber can generate multiple volumes of transactions and hence, to handle these transactions of a single customer, the system is equally consumed and therefore, the correct assessment of the system capacity should be linked to the transaction count instead of subscriber base.

It further commented “The subscriber base may not be the appropriate criteria to assess the capacity of CAS and SMS, more so, in the current framework when a single customer can generate more than one transaction in terms of activation/deactivation of channel, recharge etc. We, therefore, suggest that the criteria of 5 per cent should be measured in context to total volume of transactions.”

The company in its comments to TRAI also raised concern over generating customised bills. It said, “We submit that the requirement of generation of bills is applicable for the post-paid services and we, therefore, suggest that clause must specify the same to avoid any confusion.”

Similarly, Tata Sky also expressed that bill generation is a postpaid concept. DTH operators do not have a postpaid platform and are completely prepaid. “Therefore, it is suggested that a suitable clarification be inserted in the regulations as well as the audit manual to avoid any understanding gap between the DTH operators and the auditors,” said Tata Sky.

Tata Sky also suggested, “The STBs and VCs are issued against a CAF to a subscriber and the subscriber's address is captured in our systems. Consequently, the auditor can check our systems on a random sample basis, however, we will not hand-over our entire database along with addresses to the auditor in compliance with this requirement. We would, therefore, suggest that a suitable clarification be inserted in the regulations as well as the audit manual to avoid any understanding gap between the DPO and the auditors.”

The draft’s Clause 12(a) & 12(c) states that it is mandated that amongst other things SMS should also be capable of viewing and printing of historical data in terms of the activations and the deactivations of STBs and generating historical data of changes in the subscriptions for each subscriber and the corresponding source of requests made by the subscriber.

GTPL on the same commented, “It has been observed in the past audits that the auditors have demanded generation of such historical data for all subscribers and from inception which has put undue stress on the systems of the distributors and the resultant inconvenience to the customers. It is suggested that the Authority limit the generation of historical data to reasonable percentage of the total as a sample size. We suggest a sample size of 5 per cent of the active sub base for platforms which have more than 5,00,000 average active subscribers while for platforms which have a lesser active subscriber base the sample size can be 25 per cent.”