The objectives of current consultation are:-
a). To develop an unified QoS regulatory framework for all addressable TV Platforms (DTH/ Cable TV/ HITS/ IPTV) bringing in enhanced efficiency and transparency.
b). To ensure protection of consumer’s interests by making them aware of the choices of services, terms and conditions of services, ease of subscription and speedy redressal of complaints.
c). To ensure orderly growth and a level playing field for overall development of the broadcasting sector
d). To encourage the use of Information Communication Technologies (ICT) towards improving the QoS.
Although it is an excellent move on the part of the Regulator, many issues are yet to be attended to befor we think of a common QoS code. India is at a very critical stage in adopting the digital technologies where many problems hinder us in going forward. It is too early to equate all the addressable systems and expect them to provide the same quality of service at the consumers end. Academically, it may be possible as International standards for broadcast services are the same for all technologies however; we have to keep in mind that different technologies in broadcasting are at different level of development in the country and may not be ready to provide similar service quality to the consumer. The state of various distribution technologies in the country is given below.
Digital Cable/ HITS: This is still in an unorganized shape with only seeding of STBs completed in the first three phases. About 60 million households are still in Analogue mode and thus not addressable. Also, just by putting an STB in a household does not make it addressable in the real sense as consumer still does not enjoy any choice of channels and bouquets of channels are still being forced upon him. Consumers are not even aware what the government wants to give them through Digitisation. Some of the major factors affecting the quality at the consumer end are:-
a)There are no quality specs for broadcasters’ signals at the Cable TV headend.
b)SMS and billing systems are still not operational. No consumer gets a computer generated itemized bill like in mobile service.
c)Consumers are not given a choice and are unable to control their individual bills like a mobile consumer can do.
d) There is no interoperability giving opportunity to consumer to change his service provider whenever he wants.
e)Consumers have no choice to select the STB of their own make and features.
f)Indigenous manufacturing of STBs has not yet taken off. We mostly depend on imports and poor quality of STBs have been imported to save money and earn more profits.
g)STBs are not available in the open market which the regulations demand.
h)BIS standards are not being implemented till date.
i)Activation Fee which is not permitted by the Regulator is the biggest source of revenue for the cash strapped MSOs.
j)Because the regulations have failed to lead the industry to a viable business model, no investments are coming in. Inspite of 100% FDI only the large international media groups are able to attract investments from their own group companies only to encourage further monopolies.
k)Since cable operators are being forced to change to new digital technology involving heavy investments on infrastructure, they are still struggling to manage finances.
l)Due to lack of resources with the MSOs and local factors like power shortages, economic conditions, geographical layout and lack of organized infrastructure in the region, it may not be possible to provide a consistent quality of service to every consumers.
m)Consumers are not aware of channel prices. MRP of a channel is not declared.
n)All regulations made in the last five years are not implemented as challenged in various courts.
o)Even quality of service regulations like the ‘ad cap’, are in the courts and being flouted blatantly.
p)Stakeholders in Cable TV industry are still struggling to survive. No one has time to think about the consumer.
a)DTH is generic digital service and in service for the last twelve years compared to digital cable which is still in infancy. The technology is much advanced in quality where as digital cable technology has not even stabilized.
b)Still DTH does not follow the guidelines of interoperability. c)All DTH players are deep pocketed corporate who have well established supply chains and distribution networks. So, have sufficient time to focus on new services and quality issues.
d)Have shortage of transponders, and services are limited.
a)These are very few and not yet popular in India.
b)They are owned by large telecom companies in Cable TV sector.
c)But IPTV has inherent bandwidth problems and telcos have failed to provide a quality broadband service required for IPTV. Hence the service has not yet picked up d)Very low broadband penetration limits the scope of expansion.
a)Not yet picked up as broadband speeds are extremely low. Even basic voice service has problems. b)Smartphones are increasing quality of mobile communications leave much to be desired, spectrum and infrastructure being the real problem.
a)This service is under trial by Prasar Bharati for the last 13 years and there is no hope of its taking off, considering the state of Prasar Bharati, funds with the government and efficiency of the Prasar Bharati Staff.
b)Standards have just been changed to DVB-T2 and commercial service has not yet started. It will take years for the service to stabilize.
c)We have no manufacturing of DTT STBs in India and condition will remain the same as in Cable TV digitization.
d)Being a government funded service, there will be no control on its quality.
The task the TRAI is taking upon itself is very tough under the circumstances given above. TRAI has taken several measures in protecting the consumer interest and making affordable tariffs but stakeholders are not following that. Stakeholders refuse to even share their financials with TRAI to help them frame consumer friendly tariffs. We already have the case of 27.5% inflation linked hike that has been withdrawn but the regulator is unable to make broadcasters reduce their rates.
Major factors affecting the quality of service in the addressable market are:-
Existence of Large Monopolies. There is no check on monopolies, vertical integration and cross media holdings allowing the monopolizing companies to provide the worst quality of service at high cost. Even if TRAI recommends cancellation of the defaulters, government will not cancel their licenses considering public interest. Taking action against small stakeholders is very easy but generally it is the smaller companies who avoid violating any rules and regulations and thus do not affect the quality of service at a large scale.
Broadband infrastructure is very poor with low speeds. Cloud services are still very costly in India to be used for quality experience and save on infrastructure.
The QoS standards are a must requirement for any service industry. However, we feel that they need to be different in each type of distribution network as explained above. Also, the standards have to be framed for the following:-
a)Content uplink, downlink and reception at the headend. This is the responsibility of the Broadcasters.
b)Distribution Headend and distribution network, responsibility of the MSO/ HITS/ DTH operator
c)Quality of Service at the consumer premises- Responsibility of the Last mile providers.
As brought out in the last Task Force meeting held in July in the MIB, consumer awareness is not adequate regarding the mandatory process of digitization. Much more effort by the government is needed to make the public aware of its rights.
a) FTA Package: TRAI tariff order clearly states that consumer has the right to choose any 100 FTA channels to form the basic package of Rs 100. Not even a single MSO is following that. Consumers must be made aware of this by the stake holders as well as TRAI in its Consumer reach programme.
b) Activation Fee is not permitted still every MSO and DTH operator charges that. In some cases it is equivalent to the cost of the STB itself.
c) Ownership of the STB : Consumers are kept in dark regarding the ownership of the STB. They are not given the Bills to avoid VAT.
d) Availability of STBs in the open market: The regulations require every MSO to inform their consumers about the vendors in open market who sell compatible STBs. This is not being done.
e) Interoperable STBs: DTH guidelines mandate this but none of the STBs in India are interoperable.
i) STBs with CAM and CI must be permitted so that STBs are available in the open market at competitive prices to subscribers, broadcasters also must provide CAMs.
ii) Quality of Smart cards for STBs: These must be made from good durable plastic to withstand prolonged use. Vendors have been seen to provide low quality plastic cards that break after some time giving a chance to the broadcasters to make more money from replacements. This is adding additional burden on subscribers.
f) Manual of Practice: MoP must contain list of all FTA and pay channels, their a-la-carte rates, packages with rates, standards of quality of service in brief as laid down by TRAI, details of network nodal officer, details of government nodal officers for DAS, contacts of the company call centre, relationship officer and method of complaint redressal.
Quality of the Equipment: All equipment for digital cable transmissions imported or manufactured locally must be of standard quality. BIS standards will require to be revised/ made anew for digital equipment and digital services where revised standards do not exist.
Equipment Testing Labs. Some government/ private labs having test facilities and specially trained manpower for the purpose may be specified for testing the samples of the equipment and vendors to certify adherence of international/ BIS standards for each equipment. Also government should register private auditing labs to audit digital systems and software of the DAS networks if need be.
Standards for triple play technologies and hybrid STBs (QAM, GPON, IPTV, EoC etc.) should be defined.
A lot of work is being done for digitizing the country and Government is fully committed to a DIGITAL INDIA, however much is needed to be done at the ground level to achieve the target. Also, cable TV is in a very early stage of digitization and needs to stabilize before it we expect it to offer the quality of international standards. It is similar to our broadband industry where countries are moving to speeds in Gbs where as we still maintain a standard of 512 Kbps.