Reply of National Cable & Telecom Association to Trai

Reply of National Cable & Telecom Association to Trai

National Cable & Telecom

NEW DELHI: Given below is the reply to the Telecom Regulatory Authority of India's (Trai) by the National Cable & Telecom Association (NCTA).

We are grateful to The Hon'ble Telecom Regulatory Authority of India for giving us the opportunity to express our views related to issues raised in aforesaid consultation note (no.3 of 2004). We represent the views of the cable service providers who have on their own individual and private investment contributed in the setting up of the cable industry without any governmental aid.

Before responding to the said issues and giving any suggestion, we feel important to mention in brief the conditions prevailing in the cable industry, which necessitates the effective implementing of CAS after regulating the pay TV broadcasters.

WHY CAS IS REQUIRED

The pay channel Broadcasters increased the rates of TV Channels, within two years by more than 400%. As of August 2002 the total rate of bouquet of pay channels was Rs. 219.50 (Rupees Two Hundred Nineteen and Fifty paisa only) per subscriber per month. The cable service providers pleaded that the subscribers are not willing to pay the full amount for Pay Channels, since that they do not watch all the pay channels hence why should they pay Rs. 219.50 for pay channels plus networking overheads, delivery cost, basic cable service charges and taxes to the cable service providers amounting to Rs. 360/- (Rupees Three Hundred Sixty only) P.M/ Subscribers.
The pay channels were arbitrarily increasing the subscription rate and forcing the Cable TV service providers to pay for subscriber's base than they actually have, almost every three months. The pay channel rates have increased by over 1200% in last five years. In the year 2003,January the Star TV and ESPN Star Sports announced an increase of another 50% in their subscription rates.

There was no price regulation from the government at all. Encouraged by the orphan like treatment of the Cable TV service providers, by the Indian government, the foreign based pay channels exceeded limits of abusive domination over the Indian Cable TV industry.

The pay channels continuously raised the bogey of under-declaration of subscribers' base by the Cable TV operators, yet they were the ones, who were and are still trying their best to stall the implementation of the mandatory conditional access system for the pay TV channels. This system would ensure 100% complete declaration of number of subscriber watching these pay TV channels of these foreign broadcasters and will also eliminate and prohibit unauthorized screening of pirated films by Cable TV networks.

Pay Channels were also not willing to link the subscription payments to the TRP rating, or agree to Conditional access system, to avoid accountability to the public for the quality and acceptability of their contents. Payments for watching pay TV channels are linked to viewer ship, which would be possible only by deploying conditional access system as is done world wide. In the absence of Conditional Access Systems (CAS), Television Rating Points (TRP) is the best possible measure of assessing and determining a channel's viewer ship and the chargeable subscription rate on the connectivity thereon.

All viewers in all regions do not view all channels at all times and therefore the demand to full declaration by the pay channels is unfair, improper and unjustified. It is similar to subscribing to The Times of India, Delhi edition but being forced to pay for all the newspapers and publications published by the Times of India Group irrespective of your choice, need or demand. The consumer in Cable TV industry has no choice but to pay for channels thrust on him by these pay TV channels and their associated agents. 

Several Pay Channels are openly flaunting the Indian value system, by showing nudity, excessive violence and corruption of the most humane values of honestly, integrity and fidelity. However, today the total lack of control on electronic media is now being cited (for exploitation of natives' value systems by foreign invader's of Indian values). The government knows this and is doing nothing to protect the consumer and regulate these broadcasters. Conditional Access System would solve this problem once and for all, but the government has failed in taking measures to make mandatory the Conditional access system for these pay TV broadcasters.

The pay channels do not pay any license fee, registration fee or entertainment taxes. The Cable TV service providers pay all. The pay channels that actually entertain are not asked to pay the entertainment taxes and whereas the Cable distribution system, which has no control over content of programs, is being taxed. Why are these pay channels being given preferential treatment when it is well known that in guise of buying foreign program content they are sending valuable foreign exchange abroad? Hard-earned money of the middle and lower class is being siphoned out of India while the Indian government restricts itself to taxing only the consumers and the Indian Cable TV industry.

On December 31 2002, Presidential assent was given to a key amendment to the Cable Network (Regulation) Act 1995 mandating provision of pay TV channels only through a set top box. Popularly known as Conditional Access System (CAS), the amendment was brought in essentially to empower the viewer to select and pay for only channels that he really wished to view at a price acceptable to him. 

The amendment was brought in to end an era of forced bundling of channels by pay TV broadcasters who had indulged in frequent price rises, forced bundling of channels and frequent switching off of its channels to cable service providers and MSOs to extort more and more money from an unwilling viewer base. 

The CAS regulations had been brought in on the basis of exhaustive deliberations of a multi dimensional task force consisting of consumer groups, broadcasters, cable service providers and multi system operators which unanimously recommended the bifurcation of TV channels into free to air channels (FTA) basic tier and pay TV channels.

WHY PAY CHANNEL BROADCASTERS ARE AGAINST IMPLEMENTATION OF CAS 

A high-voltage media campaign by a strong lobby of pay TV broadcasters against the Conditional Access System (CAS) was launched, designed to obstruct the implementation of CAS. This attempt was to raise public anger against the CAS mandated by the Indian Parliament that was designed to regulate the cable TV industry in the interest of its consumers.

The CAS regime is threatening the pay TV broadcaster's advertising revenues in the short run, as it will expose the true extent of their viewer-ship to the advertisers. It is also threatening the lucrative pay-TV subscriber revenues, which these broadcasters are virtually 'extorting' from the Cable service providers on most unreasonable terms. 

For example, channels have been 'bundled' into bouquets of channels and the Cable service providers and the consumers have to buy all or nothing. As of January 03, the Star bouquet consisting of 8 channels is priced at Rs.60/- per subscriber. The Sony discovery bouquet consisting of 8 channels is priced at Rs.55/- and the Zee turner bouquet consisting of 16 channels is priced at Rs.55/- per customer. ESPN-Star Sports bouquet of two channels is priced at Rs.32/- per subscriber. Other bouquet of Pay channels distributed by Modi Entertainment Network is priced at Rs.27/-and B4U at Rs.10/- Total of all these comes to Rs.240/-.(Per subscriber per month)

To this, one needs to add the entertainment tax and service tax being charged by the State and Central Government on an average comes to Rs.40/-. After accounting for the operating expenditure of the Cable service provider, copyright charges and collection charges the total cost of service amount to around Rs.460/-. The average subscription charge for Cable TV in the four Metros is in the region of Rs.175/- to Rs.275/- inclusive of all taxes. This results in a totally losing proposition for the Cable service provider, which is being subsidized by the service provider who understands the market and how much a consumer can afford to pay for cable TV service. The broadcasters argue that the operators under-declare their subscriber numbers whereas it is the same broadcaster owned MSOs that highly under declares subscriber base to make there own business model viable and earn unaccounted profit margins.

This mounting attack on the CAS proposal is well orchestrated by a powerful lobby of pay TV channels like Star, Sony, ESPN-Star Sports and others. These foreign-owned broadcasters have immense clout in the media because of cross-ownership between the entertainment channels and the news channels. They command immediate attention in the print media because of vast amounts of money the broadcasters spend on advertising in newspapers and magazines. 

These pay TV broadcasters can hardly be expected to protect the interest of the common Indian consumers. In whatever devious manner these broadcasters try to camouflage it, the CAS dispute is not about public interest. It is about control, private control of airwaves in India's entertainment space and also over the Cable TV distribution system. 

Public memory is short and the broadcasters are taking advantage of this. They need to be publicly reminded of the 1995 judgment of the Supreme Court of India, where the Court has held that "the airwaves are public property. The use has to be controlled and regulated by an independent autonomous public authority in the interest of the public and prevent the invasion of their (people's) rights". 

The attack on the GoI's proposal for introduction of CAS was being done under the guise of helping the consumer. The common man is being frightened by saying that they would have to pay much higher subscriptions if CAS was to be introduced. The reality is quite different. After CAS, the consumer will have a choice of deciding which of the pay channels he wishes to watch and pay extra for after subscribing to the basic cable TV service {consisting of minimum of 30 FTA channels} 

Further a bogey was raised on the channels itself "that the Digital Set-Top-Box (a device to regulate Pay TV at the consumer's premises) would cost Rs 7, 000/- which is false as the cost would not exceed Rs 4000. This totally ignores the fact that analogue boxes would cost much less than Rs 2700. If the total number of pay channels is about 60. In reality, the consumer would have a choice such as renting the same, buying it on hire purchase, buying it outright; depending on each one's financial capacity. "Those too only if he wishes to subscribe to niche pay TV channels". The Set-Top-Box is only an attachment to enable him to choose and pay for premium channels that he chooses to watch. 

The orchestrated criticism of CAS, using the services of pliable editors, Members of Parliament, Consumer Action Group, a Media Research Agency from Hong Kong (Home of Star), a Rating Agency in India which feel threatened by the CAS regime, etc., were being used in a spate of misinformation in the Indian print media in order to save the pay broadcasters from losing advertisement and pay revenues. 

These broadcasters know fully well that CAS is the only acceptable method of running Pay TV services in other countries, particularly in the West. They submit to the discipline in those jurisdictions without murmur. In India, they are behaving like colonialists by telling the 'natives' what to do and to pay up without asking any questions for their services. If the GOI succumbs to this pressure, it will ensure the demise of the independent Cable TV operation in India and the control of the same will pass into the hands of these pay TV broadcasters who have shown their clout in manipulating news to suit the agenda of their Western masters. 

Due to lack of standard regulations, absence of any regulatory authority and above all the unquestioned and abusive monopoly of pay channel broadcasters and their final onslaught to actively invade the ground cable distribution has sounded the death knell of independent cable service providers. Now in addition to broadcasting signals from abroad, the foreign Pay channels have also set up their agents on the Indian soil who operate Cable TV distribution networks. These agents act on the dictate of these foreign pay TV broadcasters and these collaborations have resulted in vertical monopoly. These foreign pay TV channels through their joint venture Cable TV networks have usurped the power of the Indian government of controlling and regulating the distribution of signals of the pay TV channel in India at the cost of consumers and still not in consumer interest.

These pay TV broadcasters have also gradually spread their tentacles into the Cable TV distribution business in India by buying out substantial chunks of Cable distribution networks in major cities like Mumbai, Delhi, Bangalore, Hyderabad and Chennai, etc. {TRP Cities} These broadcasters are now trying to gain domination, both of TV content as well as the distribution activity of Cable TV. Their clear intention is to create a vertical monopoly that benefits their vested interest. 

Till the time basic guidelines, terms and regulations on issues related to conditional access system and day to day functioning of the industry are being defined, issues like, pay TV price regulation, unbundling of bouquets, content regulation, must provide and must carry content, and above all cross media restriction cannot be neglected.

In a large democracy like ours, pay channel broadcasters have been permitted to control the print media by way of advertisements to them and have directly come into ground distribution. With launch of DTH, pay channel broadcasters will have the capacity of transmitting directly to any desiring viewer in this country. There are no cross media restrictions on the pay channel broadcasters and this becomes a sensitive issue and a matter of national concern, when we understand and learn that the signals of the pay channel broadcaster originates from abroad and outside the territorial, legislative jurisdiction. One single wrong and unwanted broadcast from abroad can have far reaching implications for the unity of our country. Cross media restrictions are important to check the hold of pay channel broadcasters over cable distribution, DTH, print media and other delivery mediums.

The independent Multi-System Operators and medium and small Cable service providers in different towns and cities of India are being squeezed by broadcasters like Star TV, Sony, Zee and ESPN star sports who want to control and dominate the Cable distribution business as well. These Pay TV broadcasters have formed a cartel and are denying access/ switching off Cable service providers on the pretext of non-payment of their ever-increasing pay channel charges or under declaration knowing fully well that the Cable service providers are losing money heavily in order to meet the demands of these pay channels but are still continuing to provide the entertainment to the masses at an affordable price. 

Today, the cable service providers have been forced either to join the ground distribution company of pay channel broadcasters or close down business.

The above are certain broad concerns to which we request TRAI to look into and consider while laying down regulations for broadcasting and cable. 

Further, we have endeavored to respond to various issues raised under section II of the above mentioned Consultation Note as also give some suggestions as under:-

1. Till date the step taken has been to fix the price/ rate of free to air channel [basic cable service]. The same has been done arbitrarily and without taking into consideration the actual cost and expenses incurred by the cable service providers. The free to air (basic service charges needs to be revised to minimum Rs175 per month per subscriber "otherwise a low and unreasonable basic service charge will result in deficiency of service to the end consumer"

2. The pricing of the pay channels or ceiling rates for pay channels has been left untouched. We should learn from the experiences of Pakistan, China and others where the pricing of the pay channels were fixed after due consultation. We are annexing herewith the paper by which the proposed tariff for pay channels was fixed in Pakistan. The contents therein throws light on the methodology and the logic which should be adopted at the time of fixing of tariff of pay channels, on bundling etc. and periodic revision of rates. These rates once fixed by TRAI should be uniform for the CAS and non-CAS areas same as for the rate of "Basic cable service" there can be some variation in rates payable in metros, smaller cities / towns and villages.

3. We strongly feel that the rates of the channels should be uniform in CAS and non-CAS areas or otherwise there would be chaos in monthly charges and pay channel broadcasters will continue to monopolize and extort money from the cable service providers by arbitrarily hiking subscription rates. There is continued direction required for freezing the rates in non-CAS areas, till CAS is made operative there. Any change in monthly cable charges in CAS or non -CAS areas should only be permitted with the permission of TRAI which must see there are sufficient reasons for any hike and the maximum percentage change to be allowed at one time in Basic service charges, Pay channel charges and applicable Taxes.

4. Cable service providers have from their own investment laid down cables, maintain it, bear infrastructure costs for providing cable services, pay salaries, taxes, service charges, maintain SMS, raise individual invoices, collect subscription, maintain accounts and upgrade technology periodically for the same. The pay channel broadcasters must be asked to pay to cable service providers delivery cost, carriage and margins for usage of cable distribution plant, its maintenance, infrastructural cost and cost of collection and billing incurred on their behalf for, on the basis of per subscriber of the pay channel services. " Internationally the norm is to share 50:50" as distribution and collection cost. 

5. It is important that strict regulation must be laid down for the pay channel broadcasters for stopping transmission of services/ channels to any cable service providers. It must be regulated that any broadcaster can only stop transmission to any cable service providers after due permission from TRAI. This regulation could be drawn in the lines of regulation contained in the Delhi co-operative societies Act for cancellation of membership of co-operative society.

6. In order to make any party liable for payment of compensation or sharing of any compensation it is pertinent to find out who have or are responsible for any omission or commission. Till date, the pay channel broadcasters have never stood accountable and responsible to their viewers for their own channels though they have earned billions from them. In fact, in all the service contracts between the pay channel broadcasters and a cable service provider, the pay channel broadcasters have stated that they have no privity of contract with the viewers and the consumers and they are in no manner responsible and accountable to any third party other than the cable service provider. Pay channel broadcasters have blatantly overlooked the fact a common man has been watching and subscribing to pay channels ignorant or oblivious of the arrangement between the cable service provider and a pay channel broadcaster. They in pursuit of their profits and to abusively dominate the cable service providers have wrongly been treating the contracts with cable service providers as strictly commercial contract and have ignored the public interest attached thereto. "TRAI should also ensure that "Uniform, balanced service contracts/ agreements are executed between the parties"

7. Bundling of pay channels should not be allowed as a viewer thereof losses his right of choice and often is thrust upon contents he does not desire to watch. Individual pay channel should not cost more than the bouquet. For pay channels bouquet pricing, the individual channel should not be priced individually in a manner that the individual rate of the channel exceeds unreasonable the bouquet price example: 5 channels for Rs 50 per subscriber / per month in CAS or non- CAS area, so 1 channel cannot be Rs 25, if 4 channels are subscribed the price should not be charged beyond Rs 40. 

8. The proposed terms and conditions for sale/rental of set top boxes and for refund of charges deemed appropriate; conditions under which consumers may return set top boxes sold or rented to them by service providers and ask for a refund could be as mentioned in annexure -B. " Maximum time for refund as per the refund policy of the service provider should be specified and adhered to" 

9. The broadcaster, cable service providers and other parties in the cable and broadcast industry can be made liable to pay compensation individually or together depending on whose end the fault lies. In case of interruption the broadcaster or cable service provider or even the consumer can be responsible. However, to remove difficulty and problems regarding disconnection/ interruption the pay channel broadcasters must be directed to continue their services to a cable service provider until it takes permission from TRAI. " Cable service provider can only be in a position to compensate the consumer if the basic service charges are reasonable/ viable [Rs. 175/ Per month]. TRAI can issue guidelines for the permissible interruptions in case of system outrage or permissible interruption in service due to periodic network up gradation and maintenance being conducted only after notifying the consumers. (Refer to our Annexure-C-"Proposed operational standards for Service Provider" Clause-10 (2) and (3))

10. Further, pay channel broadcaster in the past have been refusing to provide services to cable service providers for many reasons which has finally affected the consumer. Most Broadcasters targeting Indian TV Audience also have their own/Joint venture Cable TV Head End Control rooms. These Cable TV control rooms of broadcaster owned MSO (Multi system operators) have been monopolizing the Cable TV Market in India as "Satellite Decoders" which are required for receiving and re-distributing Pay channels of these pay TV broadcasters are not provided/sold to Independent Indian Entrepreneurs in the Cable TV business, but provided to their joint venture MSO's. This led to Independent Indian Entrepreneurs in the Cable TV business closing down or selling away or forcibly operating as the franchisees of such MSOs and has resulted in creation of monopoly and reduction of options available to the consumers.

11. In favour of these monopolistic practices, the pay channel broadcasters argue that all Independent Indian Entrepreneurs and MSOs in the Cable TV business are under declaring connectivity & viewer ship details. In fact, it is their own joint venture partners who after gaining major control over ground distribution are under declaring and earning unaccounted profit margins in connivance with their broadcasting partners. However even after the Indian Governments initiative to Pass a bill and make CAS- Conditional Access System Mandatory for pay Channels; the broadcasters have been pursuing the same monopolistic practice, and are denying to provide/sell "Satellite Decoders" to Independent Indian Entrepreneurs in the Cable TV business who are willing to implement CAS and provide service to the consumers falling in the are dominated by the MSOs such as Hathway/ Win and Siti Cable. Broadcasters sell/provide these "pay channel receiving Satellite Decoders" for their Pay channels either directly or through a distributor network to avoid legal hassles. These distributors on verbal orders from the broadcasters do not sell/provide the pay channel access device," Satellite Decoders" and tell (only verbal, nothing in writing) the Independent Indian Entrepreneurs in the Cable TV business to operate as a franchise of the broadcaster owned MSO instead. This combination of Broadcasters - Distributor - MSO all related to each other have in the past few yeas grown in size purely using this monopolistic practice for their growth and in the few years have grown from 0% of market share to over 70% of Urban India's Cable Subscribers. 

12. The rural Cable TV industry do not provide all pay channels as pay channel broadcasters to maintain their profits offer (rural bouquets/ packages) containing only popular channels in the bouquet at lower prices compared to the bouquets made available in urban India, However the MSO have been making inroad to rural markets too now, and once these broadcaster owned MSO's with the help of their locally dominant distributors get their foothold in the rural markets by denying pay TV content and extending exclusive patronage to chosen / favourite distributor/ operator who can guarantee them maximum returns. If this not timely checked rural viewer will also face onslaught of arbitrary price hike in cable TV subscription and frequent blackouts of popular pay TV channels. 

13. TRAI must now ensure the end of such Monopolistic Practice, by either Implementation and enforcement of CAS or by way of regulating the pricing for pay TV channels with the emphasis that the individual pay channel should be proportionately priced as compared to the price of bouquet which will discourage forced bundling and "bouquetization" as practiced by the pay TV broadcasters. TRAI should ensure that all broadcasters provide their pay TV content access device "satellite Decoders" to any business that implements CAS irrespective of the number of the subscribers attached to the cable network, as CAS mandates that consumer shall pay for the content he subscribes to watch using a addressable Set-Top-Box. Pay channel broadcasters must be directed to provide services to all desiring cable service providers upon fulfillment of minimum conditions, which can be finalized by this Hon'ble TRAI. Directions should be given to the broadcasters- both pay TV and free that they must provide services/ content to all cable service providers. In no condition whatsoever, the consumer should be denied any content.

14. Laying down and ensuring the standards of quality of service to be provided by the cable operators / Multi Service Operators / Broadcasters and for ensuring the quality of service can be done with the help of standards already laid by Bureau of Indian Standards; periodic survey by committees/ commissioners appointed by TRAI. We have drafted " Proposed Operational standards for Cable TV Service Providers of India" - ANNEXURE-C- The said draft contains provisions which are relevant to address various issues touching the day to day functioning of this industry which have not been taken into account by BIS {Bureau of India standards} while formulating standards for the cable industry.

15. Cross media restrictions must be imposed to facilitate competition. "Must carry" and "Must provide" content, clause and fixing of tariff of pay channels like in Pakistan will promote and encourage wider consumer affordable choice in the operation of Broadcasting and Cable services so as to serve consumer interests. Prices/ monthly basic service charges and Pay TV charges must be fixed in the CAS, non CAS areas and also rural and remote areas;

16. Guidelines laid down by the Prasar Bharati must be followed regarding maximum advertising time on TV channels. TRAI must differentiate among popular pay channel content, premium pay channel content and FTA [Free TO Air] content. Accordingly, Cap on advertisement should be put: For reference we can take example of Prasar Bharati {Doordarshan} where maximum 3 minutes of FCT [free commercial time] is allowed in 30 min of program, so we can impose cap for FTA channels as same on the lines of Prasar Bharati. For popular pay TV channels it is automatically lower than FTA channel. On premium pay TV channels no advertisement should be permitted at all as they are priced high and generate enormous subscription revenue. It is pertinent to mention that the popular pay TV channels are those which are coveted by viewers the most and their absence or blackouts creates the most of the hue and cry among consumers.[ e.g. STAR PLUS, ZEE TV, SONY TV and SPORTS channels when cricket is being telecast] Premium pay channels are those which are priced high but targeted at a selective audience. [e.g. HBO, STAR MOVIES, AXN, Sports channel showing live boxing, etc.] We understand that premium pay channels like HBO have never been provided as FTA as the content they air is acquired for telecast as pay TV, the content acquisition price is much higher if these channels are aired in clear [FTA] mode.

17. It is requested that some sports events such as National sports and cricket be provided in clear as FTA to the Indian Masses. {As done in Australia} as enormous revenue is generated through sponsorships and advertising on sports events that has no advertising or very minimal advertising can only be popular Pay TV or Premium Pay TV. In fact, there should not be any advertisement permitted on premium pay TV channels. {As followed by Canadian Government} Even in non-CAS areas advertisement should not be permitted on the pay channels. Since the pay channels are generating crore by beaming advertisements and sponsorships they ought to charge reasonable subscription rates from the Indian consumers in the interest of citizens of the country and the low per capita income. The pay channels in their pursuit to make more profits conveniently ignore this fact.

18. The entire Hue and Cry among consumers is for Star Plus, Zee TV, Sony TV and whenever there is popular sports or cricket event on the sports channels. That is so b'coz people have become habitual of watching serials, which they have been following for last few years. There is lot of advertisement on these channels same is with cricket events, something should be done in consumers interest to make these channels / programs available in the basic tier. We feel inclined to invite the attention of TRAI to the fact that popular soap operas like Santa Barbara and The Bold & the Beautiful are telecast and provided in the Basic cable service in USA since they are popular and being watched for more than a decade. Unfortunately popular soap operas here like KyunKi SAAS bhi Bahu Thi, Jassi etc, contribute to the high TRP and viewer ship and increased advertisement revenue for the respective pay TV broadcaster to the detriment of the consumers/ viewers

19. All Pay broadcast channels unlinked from abroad should be licensed like any other service provider so as to bring them in the Indian regulatory fold. 

20. Cross Media Restrictions should be imposed, for example a broadcaster's stake should be restricted in cable or DTH or any other mode of delivery.

21. Today DTH services are not under the realm of service tax or entertainment tax. This must be done to create a level-playing field. Since cable TV is a Small Scale Service & Business Enterprise, it should be adequately protected from competing services like DTH, broadband delivery etc. In fact, the last mile of all broadband services should be the responsibility of cable service providers.

22. Cable TV as an industry has been created with private investment of individuals with no support or subsidy from the Government. The Government of India has declared it a Small Scale service & Business Enterprise but still no help has been provided by any Government Agency. All other industries which have been declared small scale are protected from competition by big industries and given benefits/barriers in form of tax holidays, subsidies etc. Some protection has to be given to the Indian Cable TV industry.

23. The above is a brief response to the consultation note and some pertinent suggestions for the consideration of TRAI. We strongly feel that the time has come when the regulations in the broadcast and cable industry urgently needs to be defined, and CAS must be implemented or the pricing for the pay TV channels must be regulated/ fixed and also regulations regarding norms for advertisements on pay TV channels be defined and the same are in the interest of all the parties concerned and above all in the interest of the Indian consumers at large.

24. At this stage, where there are almost no regulations in the cable industry and when DTH has been launched, we feel a beginning has been made to regulate the industry. Empowering of the Hon'ble Telecom Regulatory Authority of India to regulate the cable industry is a welcome and long awaited step.