NASSCOM’s response to TRAI Consultation Paper Enabling Unbundling of Different Layers Through Differential Licensing

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NASSCOM’s response to TRAI Consultation Paper Enabling Unbundling of Different Layers Through Differential Licensing

Deepak Arora

@deepakarora

November 2, 2020

Public Policy

336

NASSCOM submitted its response to the consultation paper issued by Telecom Regulatory Authority of India (TRAI) on October 30, 2020 on unbundling of differential layer through differential licensing. In our response, we have recommended the need to unbundle the Unified License (UL) into separate licensing regime to bring in greater competition at various layers.

Currently, only one Unified License (“UL”) is required to procure network, infrastructure, and provide all telecom services. However, because of technological developments, we suggested that there is a need for delinking the underlying networks from the provision of services. We further stated that any regulatory framework for the service layer should not attract a high compliance cost which may be a deterrent to the healthy development of the industry.

The primary purpose of unbundling therefore should be to bring in greater competition at various layers and hence there is an immediate and dire need to evolve a regulatory framework that enables unbundling of the current UL which can foster:

Efficient utilization of the network infrastructure already available and that can be effectively exploited and productively used;
Promotion of niche application services to be developed and provided by such new breed of service providers who can just subscribe the access resources, in capacities as may be required and grow at such capacities, without any regulatory overheads whatsoever (including any light touch mechanism); and
Building captive / shared platforms and application services by such bulk users / aggregators, without the need for any regulatory overheads.

Our detailed submission is enclosed for your kind reference.

Kindly write to us at deepak@nasscom.in and indrajeet@nasscom.in in case you have any feedback.

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Deepak Arora