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NASSCOM response to TRAI Consultation Paper on Review of Scope of Infrastructure Providers Category – I (IP-I) Registration

NASSCOM recently made its submission on the TRAI Consultation Paper (CP) on review of scope of IP-1 registration. In our submission, we have  recommended TRAI to broaden the scope of the registration to allow IP registration to include provisioning of common shareable active infrastructure. We further suggested that scope of IP 1 registration should be broadened to include include the provision of end to end bandwidth for the purposes of intra-organisation connectivity. Given below is the brief summary of our responses to the questions raised in the CP.

Should the scope of Infrastructure Providers Category – I (IP-I) registration be enhanced to include provisioning of common shareable active infrastructure also?

We suggested that the scope of IP-I registration should be enhanced to include provisioning of common shareable active infrastructure.

What should be common sharable active infrastructure elements which can be permitted to be owned, established, and maintained by IP-I for provisioning on rent/lease/sale basis to service providers licensed/ permitted/ registered with DoT/ MIB? Please provide details of common sharable active infrastructure elements as well as the category of telecommunication service providers with whom such active infrastructure elements can be shared by IP-I, with justification.

Given the fast paced growth of technology, we suggested that the list of common shareable infrastructure elements should not be pre-defined. Instead, unless restricted, any new infrastructure element that may be created should be automatically permitted for sharing.

Should IP-I be allowed to provide end-to-end bandwidth through leased lines to service providers licensed/ permitted/ registered with DoT/ MIB also? If yes, please provide details of category of service providers to it may be permitted with justification.

And

Whether the existing registration conditions applicable for IP-I are appropriate for enhanced scope or some change is required? If change is suggested, then please provide details with reasoning and justification.

Currently, the provision of telecom connectivity constitutes a large part of the costs of IT/ITeS companies. This is particularly true for those companies which have several interconnected physical locations, where a large portion of their total bandwidth requirement is exclusively for internal communication. However, IT/ITeS companies are constrained to seek such services for private interconnectivity only from licensed TSPs and Internet Service Providers (“ISPs”). We therefore suggested that the scope of IP 1 registration should be enhanced to include the provision of end to end bandwidth for the purposes of intra-organisation connectivity as it would lead to a two-fold benefit:

  • it will improve the competitiveness of IT/ITeS service providers, cloud service providers, data center operators etc. thus, encouraging the provision of such services from India; and;
  • an increased customer base for IP-1 operators will improve revenue generation, thus encouraging increased spending on telecom infrastructure across the country

At the same time such enhancement would also enable:

  • the TSPs to concentrate on their core competency of providing telecommunication services to the end-users; and
  • the IP-1 to invest and create active infrastructure, as well as, passive infrastructure.
  • increased competition in the provision of active infrastructure services to TSPs would also lead to a trickle-down effect of reducing costs for end-customers.

Our detailed response is enclosed.


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