On the need for citizen oriented growth in the telecom sector

IFF submitted comments to TRAI's Supplementary Consultation Paper on Roadmap to Promote Broadband Connectivity and Enhanced Broadband Speed. Here, we highlighted the need for direct performance based incentives and about issues with public wifi networks that must be addressed.

14 June, 2021
5 min read

Our comments on TRAI’s Supplementary Consultation paper on Broadband Access and Connectivity


IFF has submitted comments pursuant to the Telecom Regulatory Authority of India’s  Supplementary Consultation Paper on Roadmap to Promote Broadband Connectivity and Enhanced Broadband Speed. In our comments, we highlighted the issues with indirect incentives that illustrated the need for direct performance based incentives. Additionally, we spoke about issues with public wifi networks that hadn’t been adequately addressed and argued for the use of subsidies over direct benefit transfers.


In October last year, we submitted our comments on the Telecom Regulatory Authority’s (TRAI’s) Consultation Paper on Roadmap to Promote Broadband Connectivity and Enhanced Broadband Speed. Our submissions were centred around 2 main issues:

  1. Updating the current definition of broadband: The existing definition of ‘broadband’ is inadequate and may need revision to account for download and upload speeds. This would help overcome any attempts by ISP’s to reduce access to the internet by restricting and throttling upload speeds and help bring about a fuller advancement of user rights. Thus, we suggested that ‘broadband’ be defined as: Broadband is a data connection that is able to support interactive services including Internet access and has the capability of providing download and upload speeds which fall into one of the four categories mentioned herein to an individual subscriber from the point of presence (POP) of the service provider intending to provide Broadband service. The four categories of broadband speed are:
    1. Normal - 512 KBp/s to 2 MBp/s download speed , 256 KBp/s to 1 MBp/s upload speed;
    2.  Good - 2 MBp/s to 20 MBp/s download speed , 1 MBp/s to 10 MBp/s upload speed
    3. Fast - 20 MBp/s to 50 MBp/s download speed , 10 MBp/s to 25 MBp/s upload speed
    4. Superfast - 50 MBp/s download speed and above, 25 MBp/s upload speed and above
  2. Developing digital infrastructure: Alongside policy level changes, there is a need to develop digital infrastructure in a manner in which constant updation and revolutionsing is possible. Thus, we had submitted the ‘Dig Smart' model of public-private partnerships for creating broadband infrastructure, wherein the government would install the conduits wherever there was a need for public works network construction and subsequently lease out the conduits to broadband service providers.

With the outbreak of the Covid-19 pandemic, the world has been forced to recalibrate the everyday activities into the online mode. From our professional commitments to educational needs, from interpersonal communications to shopping, almost every facet of our social media functions have now been co-opted to the virtual world. Predictably, the relevance of online platforms for a multitude of activities shall continue in the near future which in turn necessitates access to reliable and affordable internet services for every citizen of the country. Given that the transformative milieu of digital communications is the driving force in today’s society, we must ensure that the benefits of high speed broadband are not limited to only a certain section of the society.

The Supreme Court of India, in Anuradha Bhasin v. Union of India, has also highlighted that the internet is a medium to exercise fundamental rights provided by the Constitution of India. This is echoed in the Department of Telecommunications’ “National Digital Communications Policy, 2018” and the PM-WANI scheme which promotes, “Broadband for All as a tool for socio-economic development, while ensuring service quality and environmental sustainability.” We must ensure that broadband infrastructure caters not only to needs based on connectivity and geography but also serves to alleviate sections of the society who have traditionally not been able to enjoy the benefits of access to the internet.


Our submissions were based on the following core points:

  1. Issues with indirect incentives and the misappropriation of revenue: We submitted that for the purpose of incentivising the proliferation of fixed line broadband networks, providing indirect incentives to the licensees can lead to several issues, misappropriation of revenues being the most prominent among them. Indirect incentives fail to guarantee that ISP’s would invest the increased monies into expanding the user base, especially in rural and far flung areas. This is because indirect incentives provide licensees with significant amounts of discretionary power, as the very nature of indirect incentives allows licenses to choose how to deploy increased resources. It would not be unreasonable to expect ISPs and telecom companies to channelise the surplus revenues from licence fee exemptions to clearing their outstanding AGR dues rather than investing on expanding the user base.
  2. The need for direct performance linked incentives: As an alternative to licence fee exemptions, we see direct performance linked incentives as a more effective incentive mechanism. There is evidence based merit in opting for post facto incentives based on the growth of the user base as the indisputable metric to determine the benefits of direct benefits. Direct incentives provide a concrete pathway towards increasing the user base. Direct incentives, if linked to investment, also provide a good boost to capital expenditure in the sector, thus enabling the development of infrastructure in under-serviced areas.
  3. Key problems with public wifi networks: The biggest threat posed by the public wifi networks is the immense potential of data breaches and violation of the citizens’ right to privacy. Public Wi-Fis are known to be susceptible to attacks and breaches, especially in the absence of data protection norms. The security architecture used in public Wi-Fis may often not possess sufficient security standards, and so may leak data. Furthermore, many websites, including government portals, may not always have security credentials such as HTTPS or SSL certificates, and so accessing such websites through public Wi-Fis may be even more dangerous. In absence of a robust and comprehensive data protection law, the deregulated environment of internet usage including both usage data and any personal or sensitive information entered for the purpose of authentication runs the risk of compromising the security of one’s personal data. We also highlight that in the installation of small cell wifi infrastructure, it must be ensured that not only is high speed internet connectivity provided, but also that it is done so at low rates to facilitate ease of access for all. For this purpose, only public sector players must be deployed since private sector players stakeholders often do not have the economic viability to offer affordable rates.
  4. Subsidies over Direct benefit transfers(DBT): We highlighted the benefits of usage-linked subsidies over the direct benefit transfers to promote the proliferation of broadband services. There are several structural issues with direct benefit transfers including lack of infrastructure, difficulties in identifying beneficiaries, influence of local power brokers over DBT deliveries, DBT schemes have not been envisioned to be accompanied by an expansion of state services to provide low cost supply boosts and finally, economic factors like threats of inflationary pressures. We recommend that direct subsidies be provided that would involve subsiding the monthly packs purchased by subscribers, along with accompanying subsidies for installation charges incurred.

Important Documents

  1. TRAI’s Supplementary Consultation Paper on Roadmap to Promote Broadband Connectivity and Enhanced Broadband Speed (link)
  2. IFF’s comments on TRAI’s ‘Supplementary Consultation Paper on Roadmap to Promote Broadband Connectivity and Enhanced Broadband Speed’ dated June 13, 2020 ( link)
  3. IFF’s comments on TRAI's ‘Consultation Paper on Roadmap to Promote Broadband Connectivity and Enhanced Broadband Speed’ dated October 19, 2020 (link)
  4. IFF's Explainer on the PM-WANI Scheme dated February 10, 2021  (link)

Subscribe to our newsletter, and don't miss out on our latest updates.

Similar Posts

Your personal data, their political campaign? Beneficiary politics and the lack of law

As the 2024 elections inch closer, we look into how political parties can access personal data of welfare scheme beneficiaries and other potential voters through indirect and often illicit means, to create voter profiles for targeted campaigning, and what the law has to say about it.

6 min read

Press Release: Civil society organisations express urgent concerns over the integrity of the 2024 general elections to the Lok Sabha

11 civil society organisations wrote to the ECI, highlighting the role of technology in affecting electoral outcomes. The letter includes an urgent appeal to the ECI to uphold the integrity of the upcoming elections and hold political actors and digital platforms accountable to the voters. 

2 min read

IFF Explains: How a vulnerability in a government cloud service could have exposed the sensitive personal data of 2,50,000 Indian citizens

In January 2022, we informed CERT-In about a vulnerability in S3WaaS, a platform developed for hosting government websites, which could expose sensitive personal data of 2,50,000 Indians. The security researcher who identified the vulnerability confirmed its resolution in March 2024.

5 min read

Donate to IFF

Help IFF scale up by making a donation for digital rights. Really, when it comes to free speech online, digital privacy, net neutrality and innovation — we got your back!