TTCS comments on “Towards the Treatment of Over The Top (OTT) services” policy document submitted to Telecom Authority of Trinidad and Tobago



The Trinidad and Tobago Computer Society (TTCS ; has submitted its comments on the Telecommunications Authority of Trinidad and Tobago (TATT) document “Towards the treatment of Over The Top Services”

The TTCS comments can be viewed at TTCS-comments-on-TATT-Towards-the-treatment-of-OTT-services-public-July20-2015 (PDF ; 369K)

A general comment:

“For the past two decades, TATT has presided over a telecommunications sector which has experienced significant and ongoing growth for all commercial actors. The TATT “light touch” approach is one of the main factors contributing to the success of the sector. The status quo, as facilitated by TATT, should be maintained as the market can and will continue to innovate in the provision of value added services as it has already done for the benefit of clients, consumers, service providers and the country as a whole.

The TTCS fears that any change in the status quo *at the present time* will lead to a stifling of innovation and lead to significantly reduced domestic competition overall.

The treatment of Over The Top (OTT) services is *fundamentally* a Network Neutrality (NN) issue. Once the Telecommunications Authority makes a final decision on where it stands
regarding NN/zero rating of services, its way forward on topics such as OTT becomes much less complex and simple to execute. Over the top services (OTT) can be broad enough to
apply to any service provided over the Internet as a whole, or any future network. If TATT is to consider competition described by providers as “unfair,” then Zero Rated services should also be considered by the Authority in greater detail.

Attempting to make a final decision on OTT without any final decision on NN issues may needlessly complicate the country’s future regulatory landscape, and create precedents
which may limit future regulatory agility and sector innovation and growth. One of the realities of a competitive marketplace is that service providers must innovate constantly or else perish.

The TTCS believes that any regulator should have no vested interest in stifling future sources of innovation in order to preserve revenue streams for service providers. More significantly, any request by service providers that TATT *must* intervene in the regulatory environment in order  to mitigate any loss or potential loss of revenue as a result of technological changes in the sector misunderstands the responsibility of a regulator for the entire sector, and not just one part of it. Increased and differentiated competition and innovation in the telecoms space is to be encouraged, not stifled.