CompTel/Ascent urged the India Telecom Regulatory Authority (TRAI...

its members’ customers, “none of our members” had been able to enter it for reasons including “the high cost of entry, service obligations and the absence of pro-competitive regulations.” It said several of its member companies had made “significant investments” in telecom facilities and services in India. It urged the regulator to remove the limits on foreign investment and create a transparent licensing framework to encourage “more foreign participation in the development of India’s telecom sector.” CompTel said it was “prepared” to ask both TRAI and the U.S. Trade Representative to intervene if international capacity continued “in short supply because of anti-competitive practices of VSNL.” CompTel said: (1) A technology-neutral, open entry licensing framework was “the best option.” (2) “Removal of barriers to market access should be a priority.” CompTel urged the TRAI to “significantly” decrease the required license entry fees, which currently stand at $5 million for international long distance licenses and $20 million for domestic long distance licenses. It emphasized that “any operator, including those based in India, can and do provide comparable services in the U.S. for virtually no license fee, while U.S. companies continue to be required to pay the $5 million to enter the market in India.” (3) Licensing based on service coverage area was “no longer appropriate.” It said new entrants should be able to expand their networks and offer services “in such places and at such times as is economically rationale.” (4) “Pro-competitive regulation is required to stimulate effective competition.” It urged the TRAI to take steps to “prevent major suppliers from engaging in anti- competitive practices.” It said dominant operators should be “subject to close scrutiny and ex ante regulation over [bottleneck] facilities because of their incentive and ability to delay or degrade competition.” (5) “Early removal of the interconnection usage charge [and] access deficit charge is a necessity” for India to comply with its WTO commitments. (6) Elimination of the current prohibition on the resale of services and network elements is “essential.”