Subsequent to PTA's public solicitation, I've submitted my comments to the Consultation Paper on Bandwidth Tariffs issued by PTA on September 4th, 2006. I am re-producing the same here:
Following are my comments on the paper:
Additional Comments (besides the questions asked in the Paper):
- [Page 10]: Yes. The list of the countries sh ould be further expanded. While the current list contains neighbouring countries, we need to look up the tariffs in European and North America as well because this is from where (BPO, Call Center and Out-Sourcing) businesses are going to relocate to Pakistan if we can provide them with equal or comparable enabling environment.
- [Page 10]: Prices of the DPLC should be up to the landing station only. DPLC charges for local access should be separated to allow the DPLC sector to grow as a service market.
- [Page 10]: Price Multiples for E1:E3:STM1 should be 1:5:10. This is driven by the following logic: 5 E1s (10 MB) should justify the buyer to opt for a DS3 (45 MB) and 2 DS3 (90 MB) should justify a buyer to opt for an STM1 (155 MB)
- [Page 11]: Main POINT: IPLC tariffs for voice and data services should NOT be charged separately. This prevents companies from building high performance Internet networks within the country. As it happens, a high performing Internet infrastructure allows for various by-products of services.Making sure that the Internet IP Bandwidth is available for both Data and Voice uniformarly, this will be an incentive for all the operators to build out high quality Internet infrastructure in the country. Keeping two highways for data and voice will keep better Internet infrastructure from coming up. Note: Better Internet Infrastructure means a state of extensive internetworking, private peering and public traffic exchanges within the country to approach the ideal internetworking state. Currently, we do not have a specific policy and associated enablers for establishing and supporting public internet exchanges, private peering etc. The misnomer PIE is but a good business plan for one of the players.
- [Page 13]: Yes, PTCL should offer same tariffs for voice and data services. However, those requiring high quality voice should automatically go for the DPLC+IPLC combination if the Internet-voice quality (provided by PTCL and other operators) is not good enough for them.
- [Page 13]: Yes. PTCL should offer IP bandwidth on shared basis as is offered in other cuntries such as India. Reason being that we need to have one restrictions-free internet across Pakistan for the true promotion of its exciting applications. However, since the Internet is still a game of multiplexing packets, providers should be free to provide various shades of contention which suits various market segments. IMPORTANT: The lack of this highlighted scenario has lead to enormous costs being attached to what is reffered (erroneously) in the local market as CIR circuits - where the customers is made to pay through his/her nose on the promise of giving the full bandwidth despite the fact that in an internet (multiples of network), such a guarantee cannot be provided in any case (unless the claimer own every bit of the Internet infrastructure).
- [Page 15]: As mentioned earlier, since there should be NO separate tariffs for voice and data on the Internet, there should be one reasonable (i.e. compared with the neighbouring countries) rate formula for the DPLC services provided by PTCL. The logic here is to allow the greater development of the DPLC market in Pakistan. As more and more PTCL competitors energize their long haul capacities (NTC, Wateen/Warid, Multinet etc), this is one of the most critical segment totally focused on the 'national Internet infrastructure' part of the game. A stable and virbrant DPLC market is a guarantee for an healthy Internet infrastructure which is a key socio-economic driver of our times.
- The Authority should focus on a well-thought-out Internet development phase II in the coutnry. Currently, Internet is mistaken for the leisure and news contents that form a majority of Internet usage in Pakistan (like any other developing country). However, Internet, especially with the IPv6 incarnation of this amazing animal, we go beyond reading news and following show-biz events. The 'imported' Internet, i.e. where we just connect to the outside world for our misplaced infotainment needs, a local-Internet is where the true potentials reside. Being able to connect seemlessly, for an arbitrary application with both end-points anywhere in the country over a well-structured local Internet should be one of the prime objective of the Authority.
- To make 1. happen, the Authority needs to ingnite a competition within the country, to provide the best possible, diversified and high-quality Internet experience to the end users and enterprises. This will only happen once the Internet is considered by its users beyond its current misplaced infotainment value. Internet should be the same ever-extendable flexible low cost media in Pakistan that has left remarkable changes - even paradigm shifts - on other advanced societies.