Feedback on Pre-Consultation Paper for Formulation of “National Broadcasting Policy”

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Feedback on Pre-Consultation Paper for Formulation of “National Broadcasting Policy”

Sudipto

@Sudipto

November 10, 2023

Public Policy

The Telecom Regulatory Authority of India had issued a pre-consultation paper to solicit initial comments from stakeholders to formulate the India’s first national broadcasting policy (NBP). Our principal recommendations are as follows:

1. The NBP must acknowledge the distinction between different services: With the changing technologies, the manner of delivering/distribution and viewing content is evolving. The NBP is an opportunity to acknowledge these differences with a focus on creativity which is the founding pillar of broadcasting.

We have demonstrated that often bundling of different services like cable TV and broadband in offerings to consumers leads to the assumption that there is a convergence of technology. To elucidate further, while e-commerce services and video streaming services could be accessed and viewed from the same mobile handset, they are surely not similar services. Hence, this distinction should be clearly understood before initiating a discussion for converged regulatory framework.

Our submission is given clear technical distinctions between telecom, broadcasting, and digital services, including the infrastructure and mode of transmission, their separate treatment is justified.

2. The NBP should outline policy principles and avoid prescriptive measures.

The NBP should be a policy document, which sets out principles and that regulators and other authorities can later use to develop rules and guidelines to meet their objectives within the NBP goal-framework. This is particularly important as the broadcasting sector involves diverse stakeholders operating in a rapidly changing technological environment. Prescriptive measures or strategies will prevent the NBP from being a future-proof policy that can guide the broadcasting sector through 2047 and beyond.

Please see the attachment for the detailed submission. On this discussion, you may also refer our past position/submission Response to the TRAI Consultation Paper on Regulating Converged Digital Technologies and Services – Enabling Convergence of Carriage of Broadcasting and Telecommunication Services (March 27, 2023).

For any queries on the said submission, please write to sudipto@nasscom.in with a copy to policy@nasscom.in.

broadcasting Convergence

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Sudipto