Trinidad and Tobago Computer Society (TTCS) comments on 
TATT's Draft National Policy on 
Cable Television Networks and Services.
http://www.tatt.org.tt/ddocs/pctn.pdf (PDF ; 378K)

Below is the Trinidad and Tobago Computer Society comments on the 
aforementioned draft policy.

Dev Anand Teelucksingh
Trinidad and Tobago Computer Society at http://www.ttcsweb.org/
"networking local computer users!"

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Page 8 :
"Based on the market share alone, the cable TV market can safely be
categorized as a monopoly both in Trinidad and in Tobago. As a result of
this cable prices have been increasing rapidly since 1995."
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What evidence is there to support this conclusion (cable TV monopoly
is the cause of the cable price increase) ?
There may be other reasons for the price increase, for example :
- increase in the cost of licensing content
(cable TV channels and programmes)
- increase in maintenance of cable TV infrastructure
(lines and decoder boxes)
- expansion of cable TV infrastructure to provide
service to remote areas.

Table 3.1 is incomplete. It shows a comparison of CCTT prices for 3
years during a 10 year period. Only one year is shown for the other
providers (DirecTV, TRICO). Also, the CCTT pricing for the year 1994
is misleading as CCTT did not exist then and there were around five
cable TV operators in Trinidad.


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Page 10 :
"Build-out of network to rural and remote communities will be encouraged
through incentives including:
* A reduction in Universal Service Obligation (USO) for
identified coverage areas.
* Temporary waiver or reduction of licence fees for parts
of wireless network penetration into such communities.

GoRTT will put measures in place to reduce the existing digital divide
in the country consequent upon distance and/or difficult terrain. In
order to ensure remote communities are afforded fair and equitable
opportunities to ICT access and are not overlooked or disadvantaged by
service providers whose prime concern is to serve the more economically
viable market segments, network build out to disadvantaged communities
shall be encouraged.

The Authority shall identify these rural and remote communities to be
approved by GoRTT for system build-out and/or expansion."

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What criteria would be used to determine which communities are
selected for expansion? TATT may be accused of political favouritism
depending on which communities are selected for expansion if the
criteria is not made public. A suggested criteria for determining
communities to be selected for expansion should be based on the average
household income within the community.

Operators should not be forced to service rural and remote areas as a
condition of obtaining a license.

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Page 21-22

"8.4 Pricing
The market will determine price of services as competition develops.
In the initial stage, a cost based pricing regime will be developed by
the Authority in conjunction with service providers.
TATT shall institute an equitable and commercially fair pricing
mechanism, until such time that market forces enable a similar
structure. The criteria for equity and commercial
justice are determined by the relationship between service rates and
actual efficient cost of cable TV and broadband services offered by the
network."
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What if the cost of licensing programming content increases or the
cable operator introduces new services? Would a cable operator have
to apply to TATT to determine what price to charge? Wouldn't this be a
hindrance to competition in the marketplace?


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Dev Anand Teelucksingh
Trinidad and Tobago Computer Society at http://www.ttcsweb.org/
"networking local computer users!"