Commenting on the Draft Regulation of Telecommunication (Broadcasting And Cable) Services Interconnection (Addressable Systems) (Amendment) Regulations, 2019 dated 27th August 2019, Tata Sky and Airtel has pointed out some issues which may become a concern at a later stage and asked for clarification on them,
Section C clause 17 of the draft released by TRAI says that the Subscriber Management System (SMS) should generate “Bills” having a detailed explanation of all charges. Both Airtel and Tata Sky have demanded clarification on this point as the generation of bills is applicable for the post-paid services while DTH operators provide prepaid service only.
Airtel disagreed with Section C clause 8. This clause says that conditional access system (CAS) and 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. Airtel said that these systems are linked to volume of transactions, not with subscriber base and recommended TRAI that the criteria of 5% should be measured in context to total volume of transactions instead of subscriber base.
Clause 20 of section C says that upon deactivation of any subscriber through SMS all channels and services should be immediately stopped. Airtel replied that they stop all channels and services upon deactivation of any subscriber but some customer care programming channels containing important customer care related information may continue.
Tata Sky asked for clarification on clause C 12 (b) and clause F 10 (b) which says that CAS, SMS, and Digital Rights Management should be able to locate each and every STB and VC installed. Tata Sky said that Address of STB and VC is captured at the time of installation which the auditor can check on random sample basis but Tata Sky denied to hand over their complete database and asked the regulator for suitable clarification with audit manual.
Airtel agreed with clause 2 and 15 of section C. Clause C-2 says that SMS shall be independently capable of generating, recording, and maintaining logs, for the period of at least immediate preceding two consecutive years, while the clause C-15 says that CAS shall be able to tag and blacklist VC numbers and STB numbers that have been involved in piracy in the past to ensure that such VC or the STB cannot be re-deployed.
Clause 10 and 13 of section C states that SMS and CAS should be capable of individually addressing subscribers, for the purpose of generating the reports (about subscribers, channels and packs), on channel by channel and STB by STB basis. Airtel replied saying that this feature is available for a date which is prospective and data can be extracted with a prior notice.