DPOs suggest modifications to TRAI’s draft regulations on system audit

MUMBAI: Distribution platform operators (DPOs) have made certain suggestions to the Telecom Regulatory Authority of India (TRAI) on the Draft Amendment of the interconnection regulations.

The authority has proposed a draft amendment to modify certain aspects of the technical and system requirements of DPOs (as per the Schedule III of the Interconnection Regulations) basis certain concerns that have been gathered during the various meetings with the stakeholders with TRAI.

On the issue of generating itemised bills for each subscriber through subscriber management system (SMS), direct to home (DTH) operator Tata Sky has submitted that bill generation is a Postpaid concept.

DTH operators including Tata Sky do not have a Postpaid platform and are completely Prepaid. Therefore, the DTH operator has suggested that a suitable clarification be inserted in the Regulations as well as the Audit Manual to avoid any understanding gap between the DTH Operators and the Auditors.

On locating each and every set top box (STB) and viewing card (VC) installed, Tata Sky has said that the STBs and VCs are issued against a CAF to a subscriber and the subscriber’s address are captured in our systems.

“Consequently, the Auditor can check our systems on a random sample basis, however, we will not hand-over our entire database along with addresses to the Auditor in compliance with this requirement. We would, therefore, suggest that a suitable clarification be inserted in the Regulations as well as the Audit Manual to avoid any understanding gap between the DPO and the Auditors.”

Bharti Telemedia also made certain suggestions on the draft amendments.

The Section C Clause 8 of the draft amendment states that CAS and the SMS should be able to activate or deactivate services or STBs of at least 5% of the subscriber base of the distributor within 24 hours.

In its response, Airtel has submitted that the capacity of the CAS and SMS should be linked to the volume of transactions rather than the subscriber base. The rationale for the same is that each subscriber can generate multiple volumes of transactions and hence to handle these transactions of a single customer, the system is equally consumed and therefore, the correct assessment of the system capacity should be linked to the transaction count instead of subscriber base.

It further stated that the subscriber base may not be the appropriate criteria to assess the capacity of CAS and SMS, more so, in the current framework when a single customer can generate more than one transaction in terms of activation/deactivation of channel, recharge etc. We, therefore, suggest that the criteria of 5% should be measured in context to total volume of transactions.

On Section C Clause 10 which states that the CAS and SMS should be capable of individually addressing subscribers, for the purpose of generating the reports, on channel by channel and STB by STB basis, the DTH operator stated that the generation of reports by the SMS and CAS is the functionality available for a date which is prospective. Therefore, with a prior reasonable notice, the data may be extracted. Any extraction of data for the past period is only possible for such times and frequencies as has been pre-defined in the system.

Airtel also submitted that all the VC and STB numbers identified and involved in piracy are deactivated from the CAS and they reflect as “Deactivated” cases in the CAS. We submit that the intent of the clause is that CAS should be equipped to deactivate VC and STB as an action against piracy. Therefore, CAS supports this requirement and also ensures that such deactivated VC or STB’s are not re-deployed. We trust that the same is aligned with the spirit of the clause.

On itemised bill generation, the DTH operator submitted that the requirement of generation of bills is applicable for the post-paid services and we, therefore, suggest that clause must specify the same to avoid any confusions.

The DTH operator also stated that once the subscriber is deactivated it is ensured that all the channels/services are discontinued however, these consumer related channels may continue even post deactivation. “Apart from linear channels, there are some of the channels which contains customer care related information /features being played viz; customer care programming channels.”

The All India Digital Cable Federation (AIDCF) and multi system operator (MSO) DEN Networks have welcome the draft interconnection amendment regulations.

“We would like to express our deepest gratitude to the Authority for floating the Draft Interconnection (Amendment) Regulations 2017, bringing about an amendment in Schedule III dealing with the Scope and Scheduling of Audit and Addressable Systems Requirements and seeking views of the stakeholders on the same,” AIDCF stated.

“It is submitted that the provisions relating to watermarking, fingerprinting and Digital Rights Management along with CAS and SMS, is a step in the right direction and AIDCF wholeheartedly supports the same. With respect to amendments proposed to be introduced by TRAI in the schedule III of the Interconnection Amendment Regulations 2019, AIDCF stands in agreement with the same and supports TRAI in bringing about the amendments in the regulations.”

GTPL Hathway submitted that the authority needs to consider and address the usage of legacy CA Systems by various distributors. For such CA Systems, a written declaration of the distributor should suffice. It also asked the authority to prescribe a reasonable time period for phasing out such legacy CA Systems.

It is stated that the SMS and the CAS should be integrated in such a manner that activation and deactivation of STB happens simultaneously in both the systems. However, GTPL noted that for all practical purposes it requires to be noted that there is always a system lag of few minutes which the Authority needs to acknowledge.

The draft regulations prescribe that the distributor of television channels shall validate that the CAS has the capability of upgrading STBs over-the-air (OTA) so that the connected STBs can be upgraded.

GTPL has stated that the term OTA is applicable mainly for DTH service providers. For cable platform it would mean over the cable (OTC) and such term should be recognized and included into the regulation.

The regulation mentions that the CAS and SMS should be capable of individually addressing subscribers, for the purpose of generating the reports, on channel by channel and STB by STB basis.

GTPL has stated that the term “subscriber” should be replaced by “STB” in this context since CAS contains details of only STBs and VCs (if applicable) and not of the subscribers.

On the availability of historical data, GTPL has submitted that in the past audits the auditors have demanded generation of such historical data for all subscribers and from inception which has put undue stress on the systems of the distributors and the resultant inconvenience to the customers.