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Consumer VOICE’s Rejoinder to TRAI White Paper on Measurement of Internet Data Speeds

TRAI White Paper
TRAI White Paper

April 03, 2018

VOICE being an active consumer advocacy group, consistently working in the direction of consumer welfare and empowerment, recently studied a white paper released by TRAI on “Measurement of Wireless Data Speeds”. It is observed that the regulator has adopted a myopic view while addressing the needs of consumers when it comes to better internet speeds. Please find below, the general and para-wise comments prepared by VOICE on white paper on. We have studied this paper and support the way forward proposed by TRAI with some reservations that are explained below.

General Comments

In the whole, the view taken in this paper is myopic as it focuses on the limited question of comparison of apps to measure internet speeds. The bigger question of steps to be taken to ensure high broadband speeds corresponding to 4G speeds of 100-150 mbps in the mobile network has been largely ignored. TRAI does not seem to appreciate the role of high speed network with 4G speeds for creating a digital India. It neither has a roadmap nor a vision to ensure that broadband networks provide high quality and faster networks with 100-150 mbps (4G) speeds. It also ignores the status of current speeds of existing operators and fails to motivate them to provide better connectivity and faster speeds.

Reference is drawn to our Memorandum along with the three volumes of our study {Assessment of impact of Quality of Internet Service (QoIS) on internet users: Concept, Scope and Dimensions (Vol I), Assessment of Quality of Internet Service (Vol II) and Impact of Quality of Internet on Internet Users (Vol III)} presented to you at our meeting at TRAI in the month of October, 2017 in which we had asked TRAI to take the steps to improve internet speeds.

Not for common user

The paper throws light on the speed testing methodology adopted by TRAI in its TRAI MySpeed app. It also makes a comparison of the methodologies adopted by a few other speed testing app providers such as OpenSignal, Ookla and 4G Mark. While we appreciate TRAI on disclosing more details on the working of this app on request of various stakeholders, it is disappointing to see that the regulator has long been silent on the much significant issue of poor internet speeds. It seems that this paper has not catered to the needs of most important stakeholders, i.e., consumers, who are more concerned with getting better internet speeds rather than understanding the methods of measuring speed.

Narrow Focus (Para 3.6 of the white paper)

Also, the paper majorly focuses on the methodology adopted and results of TRAI MySpeed app. A very brief comparison of the TRAI’s approach with that of other speed test app providers has been given. This comparison should have been given in a more clear and elaborate manner.

Misleading advertisements

Many of the telecom service providers offering 4G services advertise internet speeds as high as 100-150 mbps. But a recent study by OpenSignal showed that India ranks at the bottom out of 88 countries in terms of average internet speeds which was found to be at 6 mbps in India. If consumers are getting such low speeds, then why are they being lured to buy costlier plans on the promise of delivering such unrealistic speeds? TRAI needs to issue specific guidelines to curb such misleading advertisements and show the consumers what they actually get.

Role of Uncontrollable factors in network performance (Para 2.1 of the white paper)

The paper also points out that large variations in the actual broadband speeds may be experienced by users due to a number of factors that have a bearing on speed. It becomes essential for TRAI to list out all such factors (exogenous or endogenous) and make consumers aware of them so that they do not expect very high speeds at all points of time. Also, a provision should be made to issue a disclaimer about these factors, while advertising promised speeds. Uncontrollable factors must be accounted for while laying down the standards. The exogenous factors exist not just in India, but across the globe and are more or less the same. Instead of making the comparisons across methodologies of the various speed measurement applications, comparisons of speeds and other QoS parameters across countries would be more meaningful. The paper gives all the excuses as to why QoIS cannot be improved and consumers must not expect the measurements results equal to the standards. We encourage TRAI to drop this pessimistic approach.

Inter-national comparisons

The exogenous factors exist in every country and the speed methodology adopted by speed testing apps, remains same for each country. Then how can these exogenous factors be blamed as a reason of low speed? A recent study by OpenSignal revealed that India ranks last amongst 88 countries in terms of internet speed with average 4G speeds of 6 mbps. Even Pakistan and Algeria recorded better speeds than India.

Acknowledging the differences (Para 2.5 of the white paper)

We support the claim that “there are significant differences between TSPs but there are not significant differences among speed measurement results using different apps”, as we had found similar results in a study conducted by VOICE. The small study was conducted in VOICE office at New Delhi, to measure internet speeds of the mobile telecom networks and wireline broadband services. It was found that local wireline ISPs are providing better internet speeds as compared to their national/international counterparts. There were differences in speeds but not much difference in the results using different speed testing apps. (Article is attached for reference as Annex I).

Advanced methodology (Para 2.4 of the white paper)

4G Mark which uses ‘quality oriented crowd-sourcing’ as against the ‘speed-centric crowd sourcing’ so that test results are at par with the actual experience of consumer, appears to be a better methodology. But it seems to be a little early to jump into this method when most of the time people are not even able to open a particular application due to the poor quality of internet. We encourage TRAI to consider speed test methodology adopted by 4G Mark for future use.

Provide information on technologies adopted

To make consumers more aware of their purchases, TRAI should make it mandatory for Internet Service Providers (ISPs) to give detailed information about the technology used (LTE/WCDMA) in their networks. It should clearly specify the strength, efficiency, advantages and disadvantages of each technology so that consumer is in a position to make better informed decision. These terms should be defined in the regulation and operators be bound to use these terms in their communication with consumers. This should be done in area-wise manner (by regulator as well as the ISPs) which will help the consumer to choose the best performing network in his/her area. This way a consumer will be able to choose the network best suited to his/her needs.

Set up benchmarks

TRAI, through its regulations, has set up different benchmarks for the quality of service of various telecom services. These benchmarks are revised from time to time. Similar benchmark should be defined for minimum download and upload speeds along with the consistency of service, for various Radio Access Technology (RAT). These benchmarks should be adhered to at all points of time so that a consumer does not face any detriment due to unavailability of internet even after having paid for it.

Create testing infrastructure

TRAI needs to create a robust testing infrastructure in the country, to make speed testing more efficient which shall produce more credible results.

Specify standard test conditions (Para 4.1.2 of the white paper)

TRAI should define standard test conditions for speed measurement (such as location, time, network, network state, frequency, device state, etc.) so that the results are comparable and more realistic. This will also reduce the difference in results achieved by different speeds measuring apps and consumers can have a better picture of real internet speeds. Also, both types of tests, automated as well as manual should be done in order to have a bigger and varied dataset.

Standardize network sub-systems(Para 2.1.1 of the white paper)

The paper outlines various sub-systems such as access networks, aggregation networks, core networks and gateways to the external world, that have an impact on the performance of any network. These sub- systems should also have some performance standards to ensure at least an average performance of the network. Maintenance and control of these sub-systems should be strongly emphasized upon.

Make way for real-time speeds

Currently, the TRAI Analytics Portal shows average speeds on the basis of the data collected in past 4 months. TRAI should make efforts to provide area-wise real time average speeds, although we appreciate that users are able to zoom-in to a particular area and view average speeds of most of the service providers. The MySpeed app needs to be modified to show average speeds of all operators in a micro zoomed area relevant to the consumers’ routine daily pattern.

Myopic vision of the regulator

When it comes to strength and quality of a network, a number of factors have a role to play such as connectivity, reliability/ consistency, speed, help services, etc. But the vision of TRAI seems to be myopic in this regard as this paper focuses on speed only which is only one of the parameter of quality of internet. It should adopt a comprehensive view that subsumes all these factors.

No mention of the poor speeds being delivered

It appears that a disproportionate amount of time and money has been spent on preparing this paper as it only talks about the methodology adopted by TRAI for measuring speed in India. The focus should have been on what is actually being delivered to the consumers who pay for internet services against the claims made by various ISPs.

Outdated benchmarks and regulations (with reference to table 1.1 in the white paper)

The Quality of Service (QoS) benchmarks mentioned in the Standards of Quality of Service for Mobile Data Services Regulations, 2012, have become outdated. No ISP specifies minimum download speed for any of their plans which should be available to the consumer at all times. In the wake of new technologies entering Indian markets, these standards need to be overhauled to keep up with the current customer demands.

Create Conformity Assessment Procedure

TRAI should also put in place a ‘Conformity-Assessment procedure’, which ensures that ISPs are adhering to the rules and maintaining the service standards.

Support for suggestions

VOICE supports all the points of suggestion mentioned in section 4.2 of chapter-4 (4.2.1, 4.2.2, 4.2.3, 4.2.4) of the white paper.

Network performance dependent upon user device (Para 2.1.4 of the white paper)

The paper also claims that the “performance of mobile data network experienced by a user is also dependent upon capabilities of user’s device”. From a layman’s perspective, it may imply that a user with ‘not so capable device’ will get poor internet speed as compared to the person who has a ‘more capable’ device, even if they both have spent the same amount. This further implies that, to access the full potential of a network and high internet speeds, a user should have a good quality smart phone (which is generally costly). In a country like India, where a big chunk of population is still deprived of basic necessities such as electricity, these ISPs expect them to spend their money on smart phones to get what they paid for. This is clear tyranny in a democracy! In such a case, it should be made obligatory for the ISPs to mention devices compatible with their so-called hi-speed 4G technology.

While submitting these comments for the perusal of TRAI, VOICE would like to underline its concerns over faster internet speeds in India that have already been highlighted in a recommendation shared with TRAI earlier. Following were the recommendations-

  • Resume Assessment of Quality of Service through Third Party Assessment
  • Compensate for Loss of Time and Money to consumers
  • Simpler and Easier Consumer Complaint System
  • Promote Internet Applications among Rural and Lower Income Consumers
  • Need for Autosave feature on e-governance sites to avoid loss of data due to reduced speed or disconnection
  • Mandatory Minimum Download Speed
  • Robust and User-friendly TRAI MySpeed App
  • Information about Signal Loss

As an active participant in the field of consumer welfare and related concerns, we would like you to consider the above mentioned recommendations, our comments on your white paper and the results of our study, to take necessary steps in the direction of consumer education and empowerment.

Ashim Sanyal
COO and Secretary
Consumer VOICE

Prof. Sri Ram Khanna
Principal Researcher and Managing Editor
Consumer VOICE



VOICE initiated a study on ‘Assessment of Impact of Quality of Internet Services on Internet Users’, in September 2016, supported by Ford Foundation, which was based on a sample of 52,000 across 19 states of India. The purpose of this study was to assess the impact of quality of internet services delivered to its consumers. It found several shortcomings/impediments which require attention for further enhancing quality of internet. Read More


The report subsumes 3 volumes:

  • Volume 1: Concept Scope and Dimensions
  • Volume 2: Assessment of Quality of Internet Service
  • Volume 3: Impact of Quality of Internet Service on Various Aspects of Life

Findings of the Study

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Divya Patwal


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