TO;
Shri Wasi Ahmed
Advisor/BCS/TRAI
07.05.2013
Dear Sir
Please find as under
COUNTER COMMENTS submitted on behalf of Sarbajit Roy to Consultation Paper on "THE TELECOMMUNICATION (BROADCASTING AND CABLE) SERVICES (_____) (DIGITAL ADDRESSABLE CABLE TV SYSTEMS) TARIFF ORDER, 20
1) Counter-Comments to Comments of "Cable Vision Network"
a) These comments seem to be mainly lifted verbatim from the comments of "COFI". The Ld. Authority may kindly factor this in. We feel that this person is a proxy for COFI.
b) The Ld. Authority may also take with a large pinch of salt the claims that the STBs cost Rs. 1,100 or Rs. 1,700. There is no basis for such statements. The value of these STBs (Std. Definition) should be around Rs.500 or Rs 600 only. This is a SCAM and involves HAVALA.
c) We agree that CPE/SPE must be made TECHNICALLY Inter-operable and be based on OPEN Standards only in the CONSUMER INTEREST. We deplore TRAI's biased proposal to have only COMMERCIAL Inter-Operability and say this is clearly designed to financially benefit MSOs, possibly for corrupt reasons.
d) We oppose any Activation / Smartcard / ViewCard etc charges being levied by MSOs on consumers, and we call for complete transparency in this behalf.
e) There is complete confusion in minds of customer as to who is providing the CPEs – ie. MSO or LCO and will get the payment for the same. As per the CATV Act it is the LCO who is to install the CPE in his network. We suggest that the consumers are known to the LCO and not to the MSO, so the CPEs must be installed by LCO only and must be inter-operable. The point to be noted is that MSO means "Multi-System Operator" so MSO must be able to offer wide variety of DAS platforms and encryption technologies irrespective of what CPE the LCO has installed.
f) We disagree with the commentor that MSO will provide STB to LCO. We say that LCO can easily procure the same from open market and it should be left to market forces. Presently STBs are being supplied by a cartel of MSOs and the prices have been raised by at least 4 or 5 times.
g) We agree with the commentator that TRAI is biased against LCOs when it comes to revenue sharing. LCOs are the 2nd weakest stake-holder after consumers, and we deplore the attitude of TRAI to gouge and tyrannise the weaker stakeholders. This is unfair, Unequals cannot be treated equally. We suggest that LCOs must get at least 33.33% of all revenue.
2) Counter-Comments to Comments of "AsiaNet Satellite Comunications"
a) We disagree that STB cost, including cost of deposits, should be placed on consumers.
b) We disagree that cost of STBs is Rs. 2,000. We feel that there is huge padding of these costs involving havala. IAC feels that STB scheme has been introduced to enable large scale transfer of Forex outside the country by havala and other anti-national means.
c) We feel that SPE cost should devolve on those stakeholders who are the financial beneficiaries. The consumers are only the hapless victims.
d) All the STBs being provided are shoddy and sub-standard. They are likely to have a high failure rate. Hence their repair and maintenance cost should not devolve on consumers.
3) Counter-Comments to Comments of "DIGI Cable"
a) The IAC generally objects to the entire content of this commentor.
b) Only one SPE should be sufficient for decoding all subscribed channels to feed as many TV receivers as are installed at the subscribers premises.
c) Previously I was on this network for 2 months and my STB had to be replaced because they were not providing bills or a-la-carte and were doing piracy.
d) Considering para 3, it is desirable that the SPE be securely installed by the LOC OUTSIDE the consumer premises, so that the consumer is not liable for its loss or damage. There is no basis for FALSE allegations that STBS are tampered with. This is just an anti-consumer device to prevent returning the security deposits when consumers apply to move out of this MSO.
e) Para 4 clearly shows that the STBs being supplied by DIGI are poor quality and substandard. The BIS standard is a very tough standard to meet and DIGI's boxes are obviously poor quality if they cannot operate without voltage stabilisers and ventilation etc.
f) Para 5. Consumer has no control over where these SPEs are sourced from. Why should consumer have to be saddled with unrepairable items being forced on them ? Kindly chastise this MSO for raising such frivolous comments.
g) Pare 6 – 13. No specific comment at present due to their vagueness. IAC generally says that MOS is being moré than fairly rewarded / compensated by the disproportionate revenue ratio he gets vis-à-vis the LCO.
h) Para 14. IAC totally disagrees with this. SPEs must be provided free of cost without any down payment.
4) Counter-Comments to Comments of "INDUS Media"
a) We agree that life of SPE must be taken at least 5 years fully warranted. These devices have no moving parts except some easily reparable switches/buttons. Hence the life of a SPE shall well exceed that of a TV set which is at least 8-010 years.. Unfortunately the MSOs are procuring the cheapest and most sub-standard STBs to dump on consumers at exorbitant prices. We disagree that life of STB is 12-18 months. The undersigned makes electronic devices which are still in service for over 20 years on 3 shift basis, so it is complete nonsense that SPEs will last for not more than 3 years if used for long hours. They are sourcing cheapest STBS, usually from China, which are underdesigned. At para (d) he has admitted that they are sourcing the lowest quality STBs. As I am an IMCL subscriber, my STB is clearly not meeting the BIS standard and has already started falling apart in 3 months of use. Their STB seems to be somewhat better than that of DIGI-Cable.
b) We disagree with IMCL's self serving logic that Subscribers must pay for SPEs. We stress that SPEs must be provided free of cost and free of any deposits to the subscribers. This is the mandate of the CATV Act.
5) Counter-Comments to Comments of "Prakash B V"
a) We generally agree with the commentor.
b) We disagree that consumers must pay for SPEs.
c) We agree that channels and boquets are being forced on consumers by MSOs using clever tactics and hiding the true costs of a-la-carte channels.
d) We completely agree with him that Hindi channels are being forced on subscribers.
e) We completely agree that a large number of good quality English channels of all genres need to be given in Basic tier package. We agree that to get say 10 English channels, he has to forcefully buy 280 channels for Rs. 280 by monopoly behaviour of LCO and MSO. To break this cartel, IAC demands that MSO "MUST PROVIDE" at least 50 FTA and 50 Pay channels of consumers choice in any language for Rs.150 plus taxes.
f) We further suggest that all religious and advertising channels be banned on FTA. There is a very disturbing trend that top pay channels are functioning as religious and advertising / home-shopping channels for at least 12 hours every day. Due to globalization, consumers now have different life-styles and time zones, so every pay channel must function 24 hours and not only during so-called "prime time". IAC is concerned that foreigners are like USA's Christian Evangelists and Saudi Fundamentalist Islamists are grossly abusing our Cable TV networks for conversion. IAC is equally concerned that so called religious TV channels like Paras TV are regularly broadcasting disturbing visuals of fully naked men with flaccid penises cavorting in front of Indian housewives, during daytime when children are watching.
6) Counter-Comments to Comments of "Sekhar Banerjee"
a) We generally agree with the commentor.
b) We agree that MSOs have been gouging the consumers, indulging in underhand tactics and not providing proper bills and documents.
C) We agree that life of STB is at least 5 years and should be fixed as not less than 5 years
D) We agree that TRAI needs to pull up its socks more to protect the consumers.
7) Counter-Comments to Comments of "Praveen Chitnis"
a) We generally agree with the commentor.
b) We are confused why an LCO is being treated as an individual.
c) We agree with many points made by him.
d) We agree that LCOs must take in revenue of at least Rs. 100 per month per subscriber to survive. In this if they can give 100 channels in analog mode in addition to DAS where is the harm. He is correct that small LCO is being deliberately wiped out to hand over cable industry on a platter to few large MSOs who will then increase prices by 600%. TRAI is miserably failing to protect this small LCO sector which generates employment and provides cheap services.
e) We agree that proprietory DAS/CASs like NDS and CONAX etc should be banned.
E) We reiterate that the BIS standard mandates that all digital STBs must bypass the FTA signals in analogue mode.
8) Counter-Comments to Comments of "NSTPL"
a) We generally disagree with the views of this commentor. In interests of brevity IAC s not repeating its submissions.
b) They seem to be a high end HITS operator selling hi-fi expensive STBs.
c) Their views are completely self-serving and anti-consumer. IAC fails to see why they should be given special treatment. IAC reiterates that no cost burden should fall on consumer, directly or indirectly for DAS hardware. The DAS does not financially benefit the consumer but only the MSOs and Broadcasters who should be compelled to pay for the same without any additional impact on tariff costs. NSTPL should resolve their matters with the MSOs and Broadcasters instead of gouging the consumers through such tariff orders or through the back door.
9) Counter-Comments to Comments of "Kable First India"
a) We oppose the prayers of this commenter to pass on the cost burden of STBs to subscribers. We support his comments that cost can be lowered on STBs by certain Govt actions which were recommended by TRAI but are not carried out – this will benefit the industry generally.
10) Counter-Comments to Comments of "COFI"
a) We support the allegations made by COFI against the MSOs. These deserve to be enquired into and our members have experienced the same.
b) TRAI has miserably failed as regulator if consumers are being told to go to consumer court to resolve POLICY and SYSTEMIC problems.
c) We support COFI that these Proposals / Orders have to be completely reworded and revisited. LCOs will only survive if consumers survive.
d) We agree that LCOs are being under-shared in the revenue chain hence they are indulging in all kinds of malpractices.
e) IAC reiterates that SPEs must be free of charge with no cost burden on poor consumer.
11) Counter-Comments to Comments of "Sarbajit Roy"
a) It seems one email is missed out which is reproduced below.
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To
Shri Wasi Ahmed,
Advisor BCS/TRAI
Date: 26-April-2013
Sir
Sub: Consultation papers on Tariff Orders for SPE for DAS and DTH dt. 11.04.2013
Further to my 9 previous emails appended below, I wish and desire to further comment to TRAI's cited consultation papers as follows:
That India Against Corruption ("IAC") is receiving tremendous number of complaints against the DAS scheme which has been rolled out in a tearing hurry simply because some Big Broadcasters went to court.
IAC DAS ought not have been rolled out till all the teething issues and legislations and orders were in place and at 1 year was given for a "soft launch" where all the kinks can be ironed out.
Persons all over the country where DAS is being installed are AGGRIEVED that their viewing rates have gone up by 2 or 3 times in the last 6 months. Family budgets, already stretched to breaking point, are having to give up TV viewing, resort to piracy or come out on the streets or worse. It is a social problem which cannot be wished away.
India Against Corruption therefore additionally suggests as follows:-
1) ALL FTA channels be priced at maximum Re.1 per channel.
2) ALL Pay Channels be priced at maximum Rs.2 per channel;
3) That the subscribers should be allowed to select any 100 or more FTA channels of their choice for Rs. 100, or a mix of 100 or more FTA & Pay Channels (including all pay) of their choice for Rs.150. Taxes etc.
3) That FTA channels must include at least 5 quality channels of the 7 genres in the 3 languages (Hindi, English, regional), ie. making 105 channels. Provided that if no genre channel is avail in FTA, the Authority can declare any Pay channel of that genre+language as a FTA Channel in public interest.
4) That all the net revenue paid by subscribers should be EQUALLY divided between LCO, MSO and the broadcasters (as per subscriber's selections).
5) The IAC is concened to note that a few broadcasters have put up large number of dummy channels which are merely repeating very old programs and shows to "game" the Tariff orders. This must be stopped. The quality of FTA channels must not be allowed to slide.
6) It must also be kept in mind that a functioning TV system is needed for public broadcasts and emergency use and for Civil defence / national disasters. For the sake of a few greedy private broadcasters the entire national resource cannot be frittered away and privatised like this while the regulators stand and preside over its dismantling.
With best wishes
yours faithfully
Sarbajit Roy
National Convenor
"India Against Corruption" jan andolan
B-801, Paarijat Apts
Plot 28 Sector 4 Dwarka
New Delhi 110078
Tel : 09311448069
http://www.indiaagainstcorruption.net.in/
http://www.indiaresists.org/
https://lists.riseup.net/www/indiaresists
Date: 26-April-2013Tohttp://www.trai.gov.in/
Shri Wasi Ahmed,
Advisor BCS/TRAI
Sir
Sub: Consultation papers on Tariff Orders for SPE for DAS and DTH dt. 11.04.2013Further to my 9 previous emails appended below, I wish and desire to further comment to TRAI's cited consultation papers as follows:That India Against Corruption ("IAC") is receiving tremendous number of complaints against the DAS scheme which has been rolled out in a tearing hurry simply because some Big Broadcasters went to court.
IAC DAS ought not have been rolled out till all the teething issues and legislations and orders were in place and at 1 year was given for a "soft launch" where all the kinks can be ironed out.
Persons all over the country where DAS is bieng installed are AGGRIEVED that their viewing rates have gone up by 2 or 3 times in the last 6 months. Family budgets, already stretched to breaking point, are having to give up TV viewing, resort to piracy or come out on the streets or worse. It is a social problem which cannot be wished away.
India Against Corruption therefore additionally suggests as follows:-
1) ALL FTA channels be priced at maximum Re.1 per channel.
2) ALL Pay Channels be priced at maximum Rs.2 per channel;
3) That the subscribers should be allowed to select any 100 or more FTA channels of their choice for Rs. 100, or a mix of 100 or more FTA & Pay Channels (including all pay) of their choice for Rs.150. Taxes etc.
3) That FTA channels must include at least 5 quality channels of the 7 genres in the 3 languages (Hindi, English, regional), ie. making 105 channels. Provided that if no genre channel is avail in FTA, the Authority can declare any Pay channel of that genre+language as a FTA Channel in public interest.
4) That all the net revenue paid by subscribers should be EQUALLY divided between LCO, MSO and the broadcasters (as per subscriber's selections).
5) The IAC is concened to note that a few broadcasters have put up large number of dummy channels which are merely repeating very old programs and shows to "game" the Tariff orders. This must be stopped. The quality of FTA channels must not be allowed to slide.
6) It must also be kept in mind that a functioning TV system is needed for public broadcasts and emergency use and for Civil defence / national disasters. For the sake of a few greedy private broadcasters the entire national resource cannot be frittered away and privatised like this while the regulators stand and preside over its dismantling.
With best wishes
yours faithfully
Sarbajit Roy
National Convenor
"India Against Corruption" jan andolanhttp://www.indiaagainstcorruption.net.in/
B-801, Paarijat Apts
Plot 28 Sector 4 Dwarka
New Delhi 110078
Tel : 09311448069
http://www.indiaresists.org/
https://lists.riseup.net/www/indiaresists
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