TRAI released the following press release on September 17th, 2007 seeking 'stakeholders' comments on Draft Recommendations on "Growth of Broadband" reproduced verbatim below.

Information note to the Press (Press Release No. 80 /2007)
TELECOM REGULATORY AUTHORITY OF INDIA
For Immediate release.
Tel. No : 011-23217914
Fax.No : 011-23211998
E-mail: skgupta@trai.gov.in or
guptask61@gmail.com
Website:www.trai.gov.in
TRAI seeks stakeholders’ comments on draft recommendations on ‘Growth of Broadband”
New Delhi, 17th September, 2007 – Telecom Regulatory Authority of India (TRAI) today issued its draft recommendations on ‘Growth of Broadband’ to solicit the comments of stakeholders. Based on the feedback of stakeholders, draft recommendations will be finalised and will be sent to the Government.
Government announced Broadband Policy in 2004 and made certain projections for broadband subscribers’ growth. It was expected that broadband growth would accelerate. In order to facilitate growth of broadband TRAI took certain regulatory initiatives from time to time. However, the Authority observed that even after taking various initiatives, the growth is slow and below expected level.
The Authority felt an urgent need to identify various impediments affecting the growth of broadband and adopted forward looking approach to address all such impediments in a time bound manner. Accordingly, the Authority has suo-moto undertaken an in-house study and analysed various
methodologies to provide broadband keeping in view the constraints and present regulatory framework. While framing the draft recommendations efforts have been made to identify all possible options to boost the broadband growth.
The salient features of TRAI’s draft recommendations are as follows:
• BSNL and MTNL should be encouraged to appoint franchisees for providing broadband services to supplement their efforts. Any procedural restrictions/ limitations to be addressed immediately.
• Standardisation of DSL customer premise equipments (CPEs) used to provide broadband should be done by TEC in time bound manner. Information of all such CPEs conforming to specifications to be put on TEC website for information of customers.
• Encourage Indian manufacturers to produce more CPEs to provide Broadband using DSL technology.
• Government should expedite decision on TRAI’s recommendations regarding mechanism and pricing of Spectrum for 3G & Broadband Wireless Access.
• Spectrum for 3G & WiMAX should be made available at the earliest to boost the deployment of broadband using these technologies.
2
• Streamlining RoW procedures
o Central Government may take-up with the state governments to adopt uniform Right of Way (RoW) procedures.
o A district level committee may be formed to study RoW requirement and to take measures to encourage service providers to share ducts.
• Govt. should ensure availability of more number of Ku band transponders to roll out broadband services through Direct to Home (DTH) platform.
• Utilise Universal Service Obligation (USO) fund to provide subsidy for providing broadband services through satellite in remote and hilly areas.
• Utilise USO fund to subsidise backhaul charges initially upto 40% to support the broadband rollout efforts.
• In order to increase the competition to provide broadband in rural areas at least two service providers seeking minimum subsidy should be identified.
• Encourage Municipal committees to include a clause for making Multiple Dwelling Units/ buildings broadband ready by adopting suitable internal wiring while giving clearance for the construction of all such buildings in future.
Detailed draft recommendations are available on TRAI’s website at www.trai.gov.in. Various stakeholders are requested to provide their comments on these recommendations on or before 28th September, 2007.
___________________________________________________________
Contact details in case of any clarification:
Shri S.K. Gupta, Advisor (CN), TRAI
Mahanagar Doorsanchar Bhawan,
Jawahar Lal Nehru Marg, New Delhi-110 002.
Authorised to issue:

The
77 pages of draft recommendations are an example of what is so disturbingly wrong at so many levels with our "planned" economy style implementation of anything which is of such great public importance.

Reading through the document and quoting the gems found.
Section 1.8 The details of Internet and broadband subscribers shown in Table 2 includes 31.30 million Wireless Internet users through mobile handset. YES THIS IS HOGWASH OF TRAI's consistent failure. What exactly is this number. Does TRAI think being able to chat and ability to check e-mail is equivalent to Internet use. At best these subscribers are able to connect to a limited subset of Internet through proprietary gateways provided by greedy GSM/CDMA operators and do not add any value to the economy in any significant way. On the other hand such hand wringing attitude causes the other problem of a total lack of urgency in solving the "problem".

Section 1.11.2
"Recognising the need to reduce Internet bandwidth cost, TRAI fixed ceiling tariffs for Domestic Leased Line and International Private Leased Circuits (IPLC). Cost of IPLC is one of the major inputs for providing Broadband and impacts broadband tariff."

Obviously something wrong with the assumptions above.
1. Fixed ceiling of tariffs is not a 'solution', its at best a band-aid akin to rationing in a drought situation.
2. Where are the numbers supporting the statement. What is the cost of termination, peering , transit between various international bandwidth hubs, and what component of that is cost of a broadband connection. What is the cost of expensive billing systems implemented by ISPs to measure the kilobyte by kilobyte and minute by minute scarce data flow, marketing costs, customer acquisition cost, support cost and plain old management expenses of selling overpriced products. And the national
What percentage of available bandwidth on International optical fiber sub-marine cables is actually being used and what is the effect of that on IPLC circuits. And what is preventing fall in costs of domestic leased circuits.

On Section 1.11.6 related to NIXI.

Comments:
No NIXI's current clueless implementation doesn't help anything unless the problem of high-cost of domestic leased line circuits is fixed. Un-less policies friendly for setting up of domestic datacenters and carrier neutral Telecom Hotels with pricing competitive with world's best are setup NIXI will only be a visible remainder of the glaring failure of policy makers sitting in ivory towers of TRAI.

Section 2.3 "TRAI in its recommendation on “Accelerating Growth of Internet and Broadband Penetration” dated 29th April 2004 recommended for unbundling of local loop. This recommendation has not been accepted by the Department of Telcom."
There is massive conflict of interest in Department of Telecom directly being reported to by BSNL/MTNL bosses and having the power to accept or deflect TRAI's recommendations.

Section: 2.5
"Even at the end of March 2007 BSNL and MTNL together have provided just 1.45 million broadband connections using DSL technology."

Yes that is the most potent argument for un-bundling of last mile not just for BSNL/MTNL but all the last-mile telcos.
There is no good reason that cost of a city spanning copper pair be more than rental for 2 POTS connections.

Section 2.7
"The delay in deploying/rolling out broadband by BSNL and MTNL is mainly due to nonavailability of equipments"
Really, that is indeed a telling commentary on usage of proprietary , outdated telecom equipment instead of depending on modern open systems where the cost of re-implementing the terminating equipment with high speed IO equipment on a flat-rate billing principle would be far less than the cost of maintaining the legacy equipment.

Section 2.8
"Inspite of affordable tariff, the growth has been poor."

Obviously you guys at TRAI are smoking crack, the consumers in India are not fools. They will pay for improvement in Internet connectivity not for the pathetic speeds billed byte for byte and second by second of usage at 100 times the cost of Internet in developed countries.

Section 2.9
"Since dialup cost is comparatively high, such subscribers should have migrated to broadband."
There is exists demand but no one is servicing it. So there is obviously something that the regulator/goverment needs to fix.
Stop depending on BSNL/MTNL and oligopoly of telecom/ISP players currently entrenched in India for meeting the national goals, give free market a chance by creating the right kind of regulatory environment.

In various sections TRAI keeps on harping on various technologies , that is not your job. Your job is to "not try to understand" technology but create a technology neutral level playing field.

Section: 3.5.1
"State Wide Area Networks (SWANs): Scheme for the establishment of State Wide Area Networks (SWANs) has been approved in 22 States/UTs with total outlay of Rs.3,334 crore over a period of 5 years, extending data connectivity of 2 Mega bits per second up-to the block level in all States and Union Territories in the country."
This is a criminal and massive waste of resources given the fact that most of this money is spent not on creating infrastructure but on buying up Domestic leased line capacity where Internet connectivity could have been used directly at 1/30th the cost of leased line circuits. Open Source Softwares like FreeSWAN/OpenSSLVPN etc. can be used to implement Secure-WAN over Broadband Internet instead of wasting thousands of crores of Rupees on Domestic Leased lines and VSAT terminals.

Section:3.5.2
"Common Services Centres (CSCs): The Government has approved a Common Services Centres (CSCs) Scheme for providing support for establishing 100,000 Common Services Centers in 600,000 villages of India."

Section 3.5.3
"State Data Centres (SDC): It is proposed to create State Data Centres (SDC) for the States to consolidate services, applications and infrastructure to provide efficient electronic delivery of Govt. to Govt. (G2G), Govt. to Citizen (G2C) and Govt. to Business (G2B) services."

It is not government's business to establish datacenters. Look at the state of datacenters managed by NIC a government organization. It is full of high cost, un-secure proprietary hardware and proprietary software legacy equipment open to hackers around the world.

Chapter 5
"Impediments to the Growth of Broadband"

There is no discussion of actual problems here, there are no solutions here in this whole chapter. The TRAI fumbles from advocating how BSNL should run its business, to advocating the old world "export substitution" economics.

5.1.9 Streamlining Right of Way (RoW):
Again TRAI provides the typical bureaucratic gobbledygook here on committee formation.
"RoW costs should be non-discriminatory, reasonable. RoW procedures should be transparent and publicly available."
Laudable goals. What is important to consider is that the cable networks(basically monopoly muscle networks) never needed the regulation on RoW.

The recommendation on broadband enabled buildings in section
5.1.11.5 doesn't include principle of carrier neutral provisioning by buildings/housing societies and that is a dangerous precedent without the safeguards for ensuring that multiple providers can access subscribers in a building. I am not totally convinced that municipalities should get into wiring standards for buildings. Leaving structured ducts in place instead of actual copper/fiber and additional terminating equipment might be a better idea.

All in all these are basically a meddlesome set of recommendations with a lot of discussion on minutiae and not really based on any actual useful numbers or any useful engagement with experts on various Internet fora.