Response To TRAI – Consultation on Proliferation of Broadband through Public Wi-Fi

Observations and Comments

We would like to congratulate TRAI on a well researched consultation paper, with refreshingly open points of view and well framed questions for consultation

We would respectfully like to draw the Authority’s attention to the following points of concern

  1. The paper focuses largely on urban and commercial use cases. It assumes WiFi to be a service that will be provided by commercial providers and consumed by users who are able to prove their identity on the basis of possession of a device or documentation.
  2. It does not take into account the fact that since the advent of smartphones, which are becoming more and more common in rural and semi-urban areas, even the average cellphone user can become a provider of data services simply by turning on the “WiFi HotSpot” functionality that is built into their phone. This sort of WiFi can be used both for peer to peer sharing of content as well as for providing secondary data access.
  3. Community owned and operated networks are also not covered either as a class by themselves or under another class. With WiFi equipment fast becoming easier to purchase even in rural and semi urban areas, more and more households are now purchasing WiFi equipment. This equipment can be interconnected by the community themselves to share data, communicate internally and also access full or limited connectivity to the Internet by pooling bandwidth and storing data locally. These networks can also be linked (in the future, when policy permits) to GSM networks to provide last mile cellphone connectivity even to remote rural areas. The COWMesh community is currently working on several pilot use-cases to establish feasibility and costs of providing different communication based services within and among communities.
    e.g. COWMesh Ranikajal Kakrana (Madhya Pradesh), COWMesh Hale Kote (Karnataka), COWMesh Aruvikkara (Kerala)

A policy that allows communities to set up their own networks and possibly even gain acknowledgement and support for the same from the administration would be very welcome.

  1. Access Control –
    1. The  issue of access control to data services is an important one. However, present mechanisms in place to verify identity online are not reliable.
    2. Given that technical competence in India is still in its developing stages, particularly in the grassroots, and given the strong social norms in place, password and other access details are often shared among multiple users. Rather than curb this natural behavior and encourage alienation in the family/community unit, why don’t we support community identities online
    3. Intra community agreements can be enforced by digital contract
      1. e.g.  I change my password and give the changed password to a friend who is  willing to sign a digital contract (via SMS, via app, via voice  recording) and share liability for my account for the duration of the  digital contract
      2. Upon expiry or termination of the contract, I change my password again
      3. The password changes can be managed by single sign on software to enable ease of use.
      4. If the model is kept suitably generic multiple mechanisms can be created to implement it
    4. Communities in India already impose internal standards, which are often followed more diligently than legal ones. By allowing communities to assume identities online on behalf of their members, this internal discipline can be utilized in the service of national security.
    5. While each individual member of a community may not have access to means of identification, every community will certainly have some members (or can incorporate new members) who have access to such means. These individuals can then become the digital stewards for their community and also be accountable for the communities online conduct. This is similar to the model of peer selected systems administrators for early networks that later coalesced to become the Internet as we know it today.
    6. We believe that the issue of online identification is a deeper one and should not be lumped in with the question of public WiFi beyond reasonable areas of overlap. A separate consultation by the appropriate authority on the subject of online identity would be very welcome.
  2. The paper does not adequately address the differential costs of data in different locations across the country and the significance of this phenomena in the proliferation of local WiFi networks. For example, the cost of data acquisition in a major city such as Bangalore is approximately INR 11 per GB @ 15Mbps (over broadband) whereas in rural MP, the same data costs approximately INR 100-250 per GB to download at 7.2Mbps (over 3G/4G), provided the network provides coverage in the area. Under these circumstances, it is actually feasible for individuals to download large volumes of content in locations where data is cheaply available and physically transport it for distribution in locations where it is not, either as a voluntary service or as a commercial one. By using low cost, easily available WiFi hardware, households can connect their television sets to each other and share content that has been downloaded once, thereby negating the need to download the same content again and again.The paper does capture this to some extent in point 2.22 and Table 2.4. However, the costs of  infrastructure mentioned apply only to carrier grade commercial WiFi and not community owned/operated ones. The actual costs of infrastructure can be brought down significantly by adopting open source software and hardware.
  3. We fully support data sharing and reselling as described in section 3.25-3.27 (Fon example), provided that communities and individuals are allowed to participate.
  4. While discussing the possibility of linking WiFi to GSM networks, it is important to also note the policy in place that makes the setting up of PSTN to VoIP gateways illegal in India. If this policy can be reconsidered, WiFi can be used to also provide phone connectivity to rural areas that have not been connected so far.


Questions from TRAI for consultation and response


Q1. Are  there  any  regulatory  issues,  licensing  restrictions  or  other factors that are hampering the growth of public Wi-Fi services in the country?

TRAI itself in 2008 had issued some recommendations on restricting public wi-fi in the aftermath of the 2008 Mumbai terror attacks. After these recommendations, public wi-fi is linked to a cell phone number (sign-in/verification done via cell phone number). So perhaps there is a need to reframe public wifi not in terms of terrorism but perhaps as an extension of existing Broadband policy or universal access to information production, distribution and consumption or reception.

The cellphone number requirement also does not cover rural/community use cases adequately. For example, there is no policy coverage for the scenario where a group of households use their TVs to connect to a shared WiFi network, which hosts local content.

Re-framing in the context of access instead of security should work ground up, i.e. distinguish between different categories of public WiFi, e.g. i) complimentary WiFi provided by a commercial establishment to patrons/customers, ii) public internet access provided either commercially or pro bono to individuals who may register directly with the provider, iv) community owned and operated WiFi networks with limited or service based connectivity to the Internet and iii) non internet connected public wifi that provides access to “offline” downloaded content. Each would need to be considered separately and then a common policy framed with specific extensions to each category. Ideally, community owned and operated networks such as networks run by groups of individuals in small villages and apartment complexes in cities should be regulated only by the community operating them subject to the rules of the ISPs providing Internet connectivity to such networks.

Q2. What regulatory/licensing   or   policy   measures   are   required   to encourage  the  deployment  of  commercial  models  for  ubiquitous city-wide  Wi-Fi  networks  as  well  as  expansion  of  Wi-Fi networks in remote or rural areas?

Bharat Broadband (BBNL) is a special purpose vehicle to implement country wide optic fibre network. This is public money to ensure internet connectivity to the public. Could public wi-fi be a part and extension of the BBNL mandate? If parts of this unlit pipe could be made available to community wifi networks, then it might be of great help. If we are to encourage ubiquitous city-wide Wi-Fi networks, then community based Wi-Fi mesh networks should be allowed (including but not limited to individuals who wish to share their home internet connection with others). It would also be helpful if WiFi equipment (transmitters, antenna, receivers etc.) could be exempt from import duties – as a move to encourage growth of ubiquitous public wifi.


Q3. What  measures  are  required  to  encourage  interoperability  between the  Wi-Fi  networks  of  different  service  providers,  both  within  the country and internationally?  

We do not see an immediate concern regarding the interoperability of WiFi networks as the WiFi standard is is quite well defined and widely publicised. The concerns in this area appear to be around seamless roaming and unified payment. We believe that imposing more standardisation at this time would serve only the urban elite users of WiFi networks by providing some minor conveniences, but the resulting increase in baseline cost of compliance will prevent smaller players from participating effectively. Therefore at this time we do not suggest any more measures to encourage interoperability, beyond conforming to the WiFi hardware and broadcasting standards.

However, as the medium becomes more popular, it would be useful to encourage mechanisms that allow individual and community owned WiFi networks to partner with existing ISPs to provide multipath internet connectivity.


Q4.What  measures  are  required  to  encourage  interoperability  between cellular and Wi-Fi networks?

The policy in India regarding GSM has been quite restrictive so far. Many open source and low cost platforms such as Software Defined Radio (SDR) and OpenBTS are being developed internationally the availability of which for research purposes would allow more people to use cellular technology. However these developments often take more than the expected time to reach India due to trade and policy restrictions.  If these regulations can be eased up, then new links can be explored along the lines of Rhizomatica in Mexico.

Q5.Apart  from  frequency  bands  already recommended  by  TRAI  and  DoT, are there additional bands which need to be de-licensed in order to expedite  the  penetration  of broadband  using   Wifi   technology?

Please  provide  international  examples,  if  any,  in  support  of  your answer.

There is of course 2.4 GHz already reserved for Wi-Fi, but if we see long term possibilities, then TRAI needs to consider developing hardware and software ecology around 5 GHz as well. Further, the government has earned a lot of revenue from 700 MHz for 4G networks via auctions and bidding by telecom operators. So a part of that revenue could be used to provide free and public wi-fi.


Q6. Are  there  any  challenges  being  faced  in  the login/authentication procedure  for  access  to  Wi-Fi  hotspots?  In  what  ways  can  the process  be  simplified  to  provide  frictionless  access  to  public  Wi-Fi hotspots, for domestic users as well as foreign tourists?

As described above in the observations as well as the answer to Question 1, linking of public WiFi access to mobile phone numbers is restrictive on users and inadequate from a security point of view. Alternative methods of verification could be used. Perhaps a coupon system, where authorized access providers register via mobile phone and then are authorized to allow other users on to the network based on a  set of coupons linked to the access providers ID. So all users are still associated to one phone number or the other, but even people without cellphones or electronic payment methods can participate.

We should avoid making public WiFi access dependent on cellphone ownership or infrastructure to generate OTPs or access to electronic payment mechanisms.


Q7. Are there any challenges being faced in making payments for access to   Wi-Fi   hotspots?   Please  elaborate   and   suggest   a   payment arrangement  which  will  offer  frictionless  and  secured  payment  for the access of Wi-Fi services.  

It is difficult for cash users and users without electronic payment options to use public WiFi. The coupon system would resolve this as well. This is important to ensure proliferation of WiFi services in rural and semi urban areas. There are two many different scenarios in which WiFi access may be paid for to assume that a unified payment model will work for all of them. In the case of WiFi services, there are two kinds of access that a user will always have to pay for. One is the access to the medium itself, which is controlled by the entity who owns the equipment to which the user is connecting. This is a local transaction and is not dependent on electronic means as the user and the service provider are in the same location. The second question is the question of access to the Internet while connected to the WiFi. The Internet services may not be provided to all users on a WiFi network and may be controlled based on role or payment.

In either case, any provider who has the technical competence to set up a restricted access network with connectivity to the Internet should also be expected to set up a viable payment gateway so as not to inconvenience the user. The current model allows the equipment owner to choose in what manner to allow users access, whereas mandating a centralized payment standard may not. In our opinion there is no need for policy intervention on this matter.


Q8.Is there a need to adopt a hub-based model along the lines suggested by  the  WBA,  where  a  central third  party  AAA  (Authentication, Authorization  and  Accounting)  hub  will facilitate interconnection, authentication  and  payments?  Who  should  own  and  control  the hub?  Should  the  hub  operator  be  subject  to  any  regulations  to ensure service standards, data protection, etc?

More centralization should certainly not be encouraged as it slows down adoption if the central agency has to be approached by each provider and is particularly detrimental to smaller providers. Instead each network should be allowed to manage its own authentication and work out partner agreements with other networks to facilitate roaming between partner networks. This way smaller operators can partner with larger ones or amongst themselves to extend connectivity, rather than needing to go to a central authority for each agreement. Payment between operators should be left out of the purview of wifi regulation as it falls in the category of electronic payments which is independently being dealt with by different laws (RBI/SEBI)

For authentication, a distributed model is needed. Multiple aggregation services should be encouraged to syndicate authentication and user data between networks rather than maintaining one central system.


Q9.Is  there  a  need  for  ISPs/  the  proposed  hub operator to  adopt  the Unified Payment Interface (UPI) or other similar payment platforms for  easy subscription  of  Wi-Fi  access?  Who  should  own and  control such payment platforms? Please give full details in support of your answer.

Access to/ adoption of the UPI should be optional and not mandatory. Inclusion of UPI as a payment option is welcome provided there are multiple options and that options are not excluded in order to include UPI. It should not be assumed that WiFi networks will only be operated by ISPs. Communities and individuals may also operate networks.  If a mandate is imposed, it will negatively impact the ability of local providers to compete. Currently they have a stronger market position in rural areas since telecom infrastructure extension is not cost feasible for operators. Therefore local operators should be encouraged by providing benefits to the smaller players rather than mandates that benefit the existing corporations. Payment for WiFi access, if needed, must be made through the owner of the equipment. This allows the owner of the equipment to control the mode of access and sharing of data, which is essential as the liability for any misuse of the equipment by the users is also borne by the owner of the equipment.

If a centralized payment platform is mandated, this may hamper the ability of the equipment owner to control access. Further, not all public WiFi networks may be connected to the Internet. Local networks are possible where content is hosted by a community, an individual or a commercial provider for which they may choose to charge a fee. A centralized payment mechanism mandate excludes this use case and other similar ones.


Q10. Is it feasible to have an architecture wherein a common grid can be created  through  which  any  small  entity  can  become a  data  service provider and  able  to  share  its  available  data to  any  consumer  or user?

Yes, given that even smartphones today can be used to create local small range WiFi networks and low cost computing devices such as Raspberry Pi are available to act as servers, even a village household can become a data service provider by simply taking a smartphone to a connected zone, downloading some content and bringing it back to the village to share with other friends over WiFi. Existing data connections on the phone can also be shared via the WiFi hotspot option on Android phones.

Given this ability, we should make it viable for people to start tracking and benefiting from the data that they deliver. Perhaps in the future blockchain and similar technologies will help track data transfers and reduce the duplication in the transfer of content.


Q11. What  regulatory/licensing  measures  are  required  to  develop  such architecture?  Is  this  a right  time  to  allow  such  reselling  of  data  to ensure  affordable  data  tariff  to  public,  ensure ubiquitous  presence of Wi-Fi Network and allow innovation in the market?

Any regulatory measures that are taken should be taken towards promoting reselling of data. It is important here to distinguish the term data into two components i.e. bandwidth and content. Individuals, communities and small businesses should all be allowed to resell both bandwidth and content. For example, a cellphone owner who downloads a video (which he is entitled to download, i.e. a non copyright video) is already allowed to use the WiFi HotSpot functionality of his phone to reshare that content with multiple users. This is sharing of content. However, the same device can also be used to provide direct access to the internet by multiple users.

This would qualify as sharing of bandwidth.

In this case, the liability for access rests on the user providing the hotspot, and there is no way to transfer that liability to the actual user by accepting payment for value of connectivity service rendered by contract (i.e. resale of data services).

The same applies to owners of home WiFi equipment who have unused bandwidth that they could resell. For example, many urban households have broadband connections with fair use limits far above their own consumption. If they could resell this excess connectivity and devolve the liability from the use of said connectivity by accepting payment via contract, this would help increase household incomes as well as bring more affordable connectivity to the masses.

If this can be encouraged, individuals, communities and businesses would be able to develop more effective ways to get information to remote locations by re-trading both bandwidth as well as content in the most efficient way possible.


Q12. What   measures   are   required   to   promote   hosting   of   data   of community  interest  at local  level  to  reduce  cost  of  data  to  the consumers?

There are now several free and open source platforms that allow communities to host content offline, such as WordPress (text and multimedia), Kolibri (educational content), ClipBucket (video hosting) and so on. These platforms can be hosted on user level devices such as laptops and single board computing systems such as RaspberryPi which can also be used to connect regular CRT television sets to the WiFi network.

The television is a device that stays within the household and accessible to women and children, as opposed to smartphones which are usually owned and almost exclusively operated by the man of the house. The goal of connecting households rather than individuals can be well supported by the local hosting model.

In order for full utilization of community resources and to maintain participation, community members should be encouraged to host local content and share/provide access to their neighbours.  This model can be used to promote good quality independent content in addition to commercially made content at the grassroots level.

Q13. Any other issue related to the matter of Consultation


Silicon vs Carbon – Comparing Facebook Advertising with Organic Outreach

Keyshav Mor from Pune asked us how to leverage Facebook to market an event he was recently promoting. We suggested a comparison between Facebook’s paid publicity feature and organic outreach (i.e. silicon vs carbon). Here’s what he found –

How often does one get an amazing idea for a business but gets stuck in the marketing and advertising part of it? Then comes the idea of running the advertising campaign through Facebook and other social media websites. Even I got the idea at one point out of sheer curiosity and why not? You pay Facebook a certain amount amount of money for a fixed time period and get to sit back and relax without worrying much about advertising and the struggles involved with it. But sorry my friends, that is not how it works and it definitely isn’t productive. So Arjun Venkatraman of Mojolab and I decided to partner up for the experiment to prove how Organic Marketing trumps social media advertising.

Organic marketing is marketing through a chain of friends whom you explain the concept and product you are looking to promote. So the basic need for organic marketing is to make friends. You make sure that you are useful in someway to your friends so that they are willing to help you in return. Initially, this takes time. But as you practice it over a period of time, organic marketing gets easier. On the other hand social media advertising is simple. For example on Facebook, you decide the product you want to promote, you choose the target audience, you choose the currency and the budget along with the duration and then you are set.

The Product/Event :

personal healingposter

To conduct the experiment, we chose the “Personal Healing Workshop” conducted by Personal Healing Institute, Pune under the Guidance of Ashwin Mohan and Anomit Ghosh of Forge Mixed Martial Arts, Pune. Ashwin and Anomit carried out the organic marketing part while I was involved in the Facebook advertising campaign. Lets look at the quantitative aspects of both the approaches .

Organic Marketing :

The 3 important resources in any marketing are : Time, Money and Friends. So these resources remain constant in this experiment too . Anomit and Ashwin approached the organic marketing part in two different ways. Anomit approached people and explained them the concept over telephone calls and by meeting them whereas Ashwin demonstrated the actual healing demo. We will quantify these efforts in terms of time and money spent while keeping in mind that time is also money.

Anomit had concentrated efforts of about 10 hours spread over a week. These included calling up people as mentioned earlier along with preparing content. Now when we talk of organic marketing, it doesn’t mean offline marketing alone. It also includes Facebook posts and the subsequent sharing of the post by the friends and followers of Forge MMA Facebook page. As a result this Facebook activity is also included in the 10 hours of efforts put into marketing the event.

Ashwin on the other hand promoted the event on Facebook and also by demonstrating healing in a demo class of two hours attended by around 30 people. Both didn’t travel anywhere to promote the event so travel time and expenses are not included. On a safer side we assume that a total of 24 hours of efforts were put in.

Anomit put in a recharge of Rs. 400 in his Vodafone cellular prepaid connection. Along with this we assume additional expenses of Rs. 600 on Internet,Power and refreshments offered to prospective participants. Mind you these expenses are spread over a time period of 7 days. So in all Rs. 1000 are assumed to be spent along with combined efforts spanning 24 hours.

Now lets get down to actual number of people reached through this campaign. A research by TechCrunch has found out that an average Facebook post reaches only 12 % of your friends. For simplicity we assume a reach of 10 % . This too when your posts are visible to “Friends of your Friends”. Anomit and Ashwin have a total of around 1000 friends on Facebook. Forge MMA which served as a platform for promotion had around 350 followers before the start of workshop. Thus it is safe to assume Anomit and Ashwin reached around 100 people through their posting about the workshop. Average number of Friends people have on Facebook is 338. As a result by the 10 % rule, number of people reached by the 100 people who saw Anomit and Ashwins post totals up to 3380. Following this rule, it is quite logical to assume the post can reach around 114244 people if the 10 percent rule is followed. But since not everyone’s profile and posts are exciting enough to repost the updates, it is safe to assume that along with the 3480 people reached, some 6000 people also see the promotional poster of the healing workshop over a period of 1 week. Assuming a standard 5 min conversation call at 2 p/ sec through Vodafone prepaid around 66 people were reached by Anomit through calling them on cellphone. These people were requested to suggest the workshop to 20 more of their friends. Assuming half of the people did their work sincerely, around 660 people were made aware of the workshop. Thus in all its safe to assume that around 10000 people across Pune city and even the state and the country were reached through the organic marketing campaign at the cost of Rs 1000 and a 24 hour timeline spread over a week.

Out of the number of people reached 12 decided to participate in the current workshop while 12 others decided to join the workshop which would be conducted in future. Thus out of the 10000 people reached 24 people signed up. That is a conversion rate of 0.024 %. If we reduce the value of people reached the percentage obviously increases. But a Facebook advertise with Pune as its defined area of promotion and customised interests pertaining to Yoga, Fitness and Arts with a budget of Rs 1000 spanned over a week fetches you a reach of around 15000 . Thus 10000 is still a safe value to work with. The conversion rate might seem dismal, but when you consider a course fees of Rs 12000 per head and 24 interested participants, the organic campaign fetches a total of Rs 288000 against an investment of Rs 1000. Even though the returns are spread out over a period of 6 months, the profit percentage is a magical 28800 %. Now you may think this is exaggeration. So lets put in some additional expenses. In the second scenario, lets say that the teachers invested Rs 12000 learning these techniques themselves before teaching. That results in a total investment of Rs 13000 in planning and marketing the course over a period of time. Even this scenario results in a profit percentage of 2215 %. Mind you the place where the workshop was conducted was free from rent .( That is where friends come into play .)

Facebook Ad Campaign :

Running a Facebook ad campaign is fairly simple as stated earlier. You decide the product type you are looking to promote, in this case an event. You give a suitable name and title to the ad campaign to monitor it from your own Facebook account. Later on you set the desired radius area, which was set as “Pune+ 10 miles”. The interests varied from sports to arts to fitness and well being to healing and yoga. All possible categories were included keeping in mind the target audience which was : Urban corporate,artistic , sporting and student population. The budget was set at Rs 300 for 48 hours. The bid was set at Rs 5 per click on the advertising campaign. The following picture gives an overall result of the campaign :

keyshav report

After first 24 hours , the bids were changed at regular intervals of 8 hrs each from Rs 5 to Rs 10 to Rs 15 in order to increase the reach. Finally the number of people reached were 2720 with no online response although one participant came to attend the workshop after seeing the Facebook ad. That is a conversion rate of 0.00036 % spanning 48 hours. Way less compared to 0.024 % conversion rate through organic marketing. Talking in monetary terms, considering the first scenario the Facebook ad campaign reports profit percentage of 4000 % and through the second scenario the campaign reports a loss of 2.5 %. So if Rs 1000 were invested in Facebook ad campaign, a total of 15000 would have been reached with 5 people attending the workshop considering the conversion rate. That is a profit percentage of 6000 % in first scenario and the second scenario results in profit percentage of 461 %.

Thus looking at above stats, it is concluded that Organic marketing wins hands on against Facebook advertising on every front for an equivalent reach and investment. In the event of organic marketing having lesser reach, it only results in better conversion rate and better profit percentage per person reached. So these are the stats which support our theory that Facebook advertising doesn’t work. So how does this happen?

Simple. Facebook has a lot of fake profiles. These profiles increase at an alarming rate daily. By fake profiles, I don’t mean that the people are fake in profiles, the people are real but they are paid by agencies contracted by Facebook to click and share on the advertises commissioned the Facebook. Thus Facebook gets the work done for cheap and makes its profits anyway and you have no way of questioning the modus operandi since you got your likes,shares , clicks and the estimated reach, never mind the fact that it didn’t result into anything of importance.

Solution? Make friends. How to make friends ? Helping people out and sharing or renting out stuff you don’t really need on daily basis. That is how organic marketing works. That is how organic marketing triumphs !