By Sandeep Bhushan, Project Fellow – TAD
Paper presented at panel Policy Analysis of Television Distribution IAMCR, Hyderabad, 16-19 July, 2014
The present exercise is an attempt to map Government thinking and policy with regard to the market structure of the digital broadcast distribution sector through a decade long period that began in 2004 and ends tentatively in the year 2013.
The site of the evolving ‘Government mind’ on the cable distribution sector was the ‘independent’ broadcast regulator- the Telecom Regulatory Authority of India (TRAI) through its numerous Consultation Papers (CPs). The CPs, unveiled every now and then, related to specialized policy matters (viz. Interoperability) that involved the policy framework of the government and the emerging broadcasting sector. Methodologically it was designed to elicit viewpoints of diverse stakeholders which were then presented to the government in the form of concrete recommendations and policy options. Though the CPs were uneven in terms of quality of scholarship, they drew upon a range of stakeholder responses as well the global experience in the broadcast distribution sector. Some of the CPs were in the manner of clarifications of previous orders, while others were responses to specific issues flagged by the government through the ministry of Information and Broadcasting. A large number of them were specialized technical inputs that the government needed from time to time which made TRAI into some kind of an official expert group. TRAI also fixed the tariff rates whenever required.
Unlike other regulators like Federal Communications Commission (FCC) in the USA, the TRAI is not a completely independent regulator. Under Section 25 of the TRAI Act, the government has the power to issue directions that are binding. Moreover under section 35 of the Act, the central government has the power to make rules on various subjects and these are deemed as binding on the TRAI.
This is completely at odds with the initial spirit of TRAI which was established as an independent regulator following a Supreme Court order that was hearing a petition challenging the privatization of the telecom industry in the mid 1990’s. The point is a critical one since this had a bearing on the evolving cable market structure creating severe ambiguities in policy making.
What is Market Structure?
A word on what constitutes market structure and its centrality to the whole issue of access to technology. The more a market is asymmetrical, the more access to technology will be differential. Only those with the financial capacities can break in. And the more technology is concentrated with those who have resources the likelihood that the eventual consumer suffers, increases manifold. The likelihood of technology coalescing around social and class fault lines is something accepted even by TRAI reports creating major regulatory problems for a welfare state such as ours.
It follows that the role of the state as reflected in TRAI documents was ambiguous. It was not an easy option for the state sandwiched as it was between an unregulated cable market that was bleeding an important revenue source and the demands of modern distribution technology that demanded large capital outlay, economies of scale and a well-oiled regulatory framework that delivers within a federal framework.
As the media economist Gillian Doyle points out this is a worldwide phenomenon, ‘Convergence and globalization have increased trends towards concentrated media and cross-media ownership with the growth of integrated conglomerates whose activities span several areas of the industry.’
This will be examined in detail later on in this paper.
The basic hypothesis of this paper is that TRAI given its ambiguous status vis-à-vis the government failed to reconcile the contradictory demands of pushing for a relatively even market structure that would allow access to diverse stakeholders and the demands of digital technology that requires heavy investment in infrastructure that makes the market structure inherently uneven. There was yet another in-built contradiction. While analog technology is cheaper and therefore permits of wider access, it also creates conditions for the fragmentation of the distribution market leading to fewer channels for the viewer, under-reporting of the consumer base and loss of revenue for all stakeholders. Digitalization, while addressing most of the anomalies mentioned above had market asymmetries built into it.
These contradictions deep down reflected the government’s own ambiguity regarding liberalizations’ larger debate- how far should the state allow the play of market forces and at what point, if at all the state should intervene with the instrumentalities available to it. The government resolved this issue by initiating a coercive ‘digitalization from above’ policy(unprecedented and without parallel) starting 2011 whose unfolding results have been at odds with the stated objective of promoting competition that would benefit the consumer in the long run.
I take equality of access to mean the ability of diverse stakeholders to access digital technology both as a consumer and as a platform operator.
Methodologically though my focus will remain on TRAI papers that reflect the evolving telecom policies.
A Brief History
The initial mandate of TRAI was to regulate the telecommunication sector. According to the TRAI Act, 1997, the mandate of TRAI included regulating telecom services, including fixation of tariffs. In January 2004, the Government of India issued a notification whereby the scope of the expression ‘telecommunication services’ was expanded to include the broadcasting services and cable services also. Consequently the TRAI is now tasked with regulating cable and broadcasting services also. Through this notification, the Government under the TRAI act authorized TRAI to make recommendations on the parameters for regulating maximum time for advertisement in pay channels and the terms and conditions for addressable systems provided to subscribers. 
The Regulation for Cable TV industry in India started with the promulgation of the Cable TV Network (Regulation) ordinance in Sept 1994 which was converted into Cable Television Networks (Regulation) Act in March 1995. In the next ten years or so the bed rock of the cable distribution structure was in place with the distribution hierarchy of Broadcasters, MSO’s and their franchisees and Independent cable operators. According to the ‘Consultation Paper’ of 2004, 49 of the 249 million households were receiving cable TV signals, though these were entirely analogue at this point.
But despite a rapid growth rate, the CP expressed concern the ‘unregulated manner’ in which the cable market had grown since the 1991 Gulf war.
The problem according to the document was that most pay channels initially came as Free-to-Air channels (FTAs) which has made the Indian experience, ‘very different’. What it implies is that broadcasters had a tough time trying to sell FTA channels to a huge swathe of consumers who were used to getting it free. In the more mature democracies of the West pay channels came along with Set Top Boxes (STBs) which carried the digital distribution market in a more economically rational direction. This anomaly has been compounded with steady customer disempowerment especially with regard to having a say over what they prefer watching. Finally there was a spike in Pay Channel rates with almost an 1100 per cent increase in some cases in the mid 1990’s. ‘The combination of increasing pay outs to broadcasters, the lack of competition in the last mile and inability to choose between alternative platforms and channels has led to increasing consumer dissatisfaction and a demand for regulation.’ Availability of channels at competitive rates is the ‘ultimate’ objective of the government.
It was in this context that the government of India issued an order under the TRAI act that announced the beginnings of an ‘Addressable system’ at the customer end in order to achieve the triple aim of- regulating pricing (for content chosen), programming choice and their empowerment.
Implementing the ‘Addressable Systems’
The lag between technology and policy defined much of early digitalization efforts. By and large TRAI responded to the emerging technology regime rather than anticipated it. As TRAI documents suggest the technology to distribute TV broadcast signals (analog cable TV) first found a toe-hold in Mumbai high-rises surreptitiously. The policy regime to monitor it however came much later. This pretty much became the template with the government intervening mostly on a case-to-case basis, driven by the demand for increased revenue (for itself and other stakeholders), often lacking a holistic and long term vision.
The TRAI vision was spelt out for the first time in 2004 almost a decade after cable television began in this country. The salient points included:
- Facilitate Competition
- Freedom to choose content and the option of exiting from one operator/platform to another one.
- Competition would free cable tariffs from government control in the long run.
In November 2000, the government laid down the conditions for providing DTH services. Under this license was to be issued for 10 years under the Indian Telegraph Act 1885. The licensee was to be an Indian and total foreign equity was not to exceed 49%. But the entry fee was made stiff at Rs 10 crore, an annual revenue share license fee amounting to 10% of gross revenue and royalty to the government for the use of spectrum.
But DTH failed to take off and four years later. The reasons for this have not been discussed at length by TRAI, but a report conceded that, ‘some broadcasters have refused to come under DTH platform.’ Some like the licensees ASC Corporation (owned by the Zee group) has commenced services but many popular channels are not available on its DTH platform.’ 
Clearly broadcasters of popular channels were not willing to share their content with platforms that had very few takers.
A similar fate befell the Conditional Access System (CAS) though the reasons for their failure were different and even discussed at length by the TRAI papers.
CAS was introduced in four metro cities- Chennai and certain areas of Kolkata, Mumbai and Delhi in 2002 and made operational in 2003 to bring order within the chaotic cable market. Under CAS the ‘addressable’ Set Top Box (STB) was introduced for the first time with both digital and analog option. The stated reason for its introduction was to provide choice of programs to the consumer. But it soon ran into legal complications with stakeholders moving the courts because of arbitrary tariff rates across cities.
The whole idea behind introducing CAS was to empower the consumer by giving them more control over the programming content, without having to pay for programs that a customer did not want to watch. CAS would also make transparent the cable rates. Further it was expected to provide a more accurate indication of the customer base so that everyone involved in the distribution chain benefited from increased revenues.
But CAS fell short of government expectations largely, as TRAI documents indicate, because of people’s unfamiliarity with CAS. Pricing of STBs was yet another issue as it appeared arbitrary from operator to operator. Also STBs were non-interoperable and consumers saw little sense in opting for technology that was expensive and that did not allow them access to all the available content. Which is why CAS progressed slowly as tariff rates charged by the analog operator was much lower in comparison. The selling point of CAS- empowering of customers by giving them a choice over pricing of programs did not also take off. A-la-carte channels were priced so high vis-à-vis the bouquet that the consumer saw little sense in opting for the former.
Equally importantly, ‘cable operators were unwilling to make large investments due to uncertainty in the implementation of CAS and also because of the lack of capital available with the number of operators.’
Digitalization: First Attempts
But the failure of CAS did not deter the government, as it pressed ahead with its policy of introducing ‘addressability’ in the unwieldy cable market. In 2004 itself, TRAI reiterated addressability unequivocally even as it laid down the guiding principles of digitalization:
- A gradual transition to addressability is a must.
- Uniform and identical solutions are not possible
- Consumer interests have to be protected
- Any change can only come through consultations.
For the first time the TRAI attempted to examine ‘enforced addressability’ as one of the goals of the cable distribution industry. But since this was easier said than done, it suggested three ‘transitory’ models.
The first model it discusses is largely ‘voluntary’ in nature. Under this there is no compulsory CAS and STBs for watching pay channels, but there is regime of strict price regulation (with rates frozen at 26.12.03) and a tier of ‘premium channels that is accessible only through the STBs. Pay channels would have the right to migrate to ‘premium channel’ status. This is one way that would create the conditions for migration to CAS platform by the mass of people.
TRAI also suggests a second model where ‘traps’ are used to provide limited choice, that was eventually rejected by MSOs and broadcasters; and finally a model where mandatory CAS and STB for viewing pay channels. But the government chose not to press ahead with this at this point.
But the issue of ‘Addressability’ was not just about STBs.
Addressability had a context and that was candidly stated by the document,’ the cable TV industry is fragmented at the last mile, yet it is characterized by a few dominant broadcasters and large MSOs who have a degree of vertical integration resulting in disparities in bargaining power.’ But the recommendations do not advocate a redressal of the situation. Instead it justifies the unequal nature of the market structure, ‘The option of not allowing vertical integration at the root would impede investment and would not facilitate the objective of promoting competition.’
It therefore unambiguously stated that the alternative route of intervention should be only resorted to, ‘when the situation warrants’ and at an ‘appropriate time’. But for this to appear reasonable, regulations have to be framed.  This has been the major conundrum within which the government has been conducting its digital distribution policy.
Coupled with the lessons from the failure or at best limited success of CAS and the nascent DTH regime, TRAI now pushed for Interconnection and revenue share agreements among the various stakeholders in order to usher in ‘addressability.’
On an immediate basis the CP recommended-
- ‘Rationalization of fee and taxes’ and flagged promoting competition from DTH operators as the best way forward to make pay channels sustainable for broadcasters.
- The document acknowledged that if there has to be competition between two platforms then license fees, taxes should be made uniform. It therefore suggested a 2% reduction in the revenue share license fee for DTH in line with concessions given to telecom players.
- It also suggested that state governments consider cable TV and DTH services at par and impose the same entertainment and service tax.
- Finally Customs and Excise duties on DTH hardware should be similar to those given to telecom services.
But TRAI refused to get into the specifics of revenue share arrangements between MSOs and LCOs and reiterated that this was a matter that would be sorted out by the market.
Govt’s Digitalization Policy is announced
There is little to indicate why the TRAI suddenly decide to take the ‘great leap forward’ towards ‘digitalization’ of the cable industry despite the limited success of its CAS ‘addressability’ project. But the continuing failure of its policy that ‘market would usher in ‘addressability’ could well be one of the reasons. The basic principle that underlined the success of the ‘addressability’ project was its acceptance by the mass of consumers. It was this that was proving to be a non-starter.
The new policy had at least two key elements. First was an admission that the government will play an active role. ‘While the bulk of the actions would have to be taken by the private sector the Government and the Regulator can play a facilitating role,’ TRAI said. For the first time it also posed the question whether there was a need to fix a timetable for digitalization- a policy that was subsequently launched in 2011.
Second, digitalization entails larger issues which it proceeded to spell out. There are ‘important linkages’ between digitalization and other ‘policy issues’ like FDI, licensing issues, taxation, competition, quality of services etc.  For the first time the government spelled out that the issue of digitalization was a holistic one and included elements that are mentioned above.
The new policy of digitalization was reiterated as essential in view of the ‘rapid multiplication’ of TV channels and the ‘limited carrying capacity’ of the cable networks. It stated that for every one channel on the analogue platform, 12 digital channels could be shown with better picture quality and other add-ons. While digitalization was offered as a solution, there was a caveat, ‘Higher channel relaying capacity requires heavy investments, which many cable operators are incapable of making.’
But this shortcoming could be overcome, firstly by removing the 49% cap on Foreign Direct Investment and second, by delivering other spin-offs to the MSOs who could recoup investments through value added services like gaming, movies, educational content- that will accompany the digital STBs. Taken together this would increase competition among the players as well as undercut the market in ‘placement’ fees paid by the broadcaster to the MSO owing to paucity of space in the prime bands. The CP also called for a more efficient licensing regime in line with international practices.
In the next year or so, TRAIs main concern was to transform the nascent DTH into a mass platform that could compete with CAS. ‘The popularity of DTH will depend on whether it can provide content at par with the cable operators at comparable prices and with an acceptable level of Quality of Service (QoS).’ Already DTH is emerging as an alternative to cable TV and there is a certain degree of competition ‘between CAS providers and DTH operators’ apart from competition in non-CAS areas. In order to give a competitive edge to DTH, there is a need to strictly enforce QoS. ‘Subscribers have the right to get a standard of service as value for money. Therefore there is a need to look at the tariffs and issue directives to enforce QoS. Also who will be responsible for enforcing QoS?
But the one big issue anticipated by TRAI as early as 2004 had begun to rear its head- this was the perils of vertical integration with the distribution of cable TV hostage to the market power of a few dominant broadcasters and large MSOs. Some of these players had re-enforced their positions with strong vertical integration linkages- now there was evidence of broadcasters buying up stakes in the cable distribution business. The Last Mile Operators (LMO) on the other hand remained highly fragmented and therefore, ‘there are large disparities in the bargaining power of various players.’
In this context TRAI recommended that there should be a ‘Must Provide’ clause in the Interconnect agreements between the broadcaster and the distributor. Given the logic of vertical integration the government had to ensure that broadcast companies that produced content shared it with all distribution platforms and not just the one’s in which they had invested.
‘A New Regulatory Framework’
But despite repeated assertions there is very little to indicate in TRAI documents that the techno-economic-administrative framework was falling in place. In fact there is appears to be an increasing realization that the cable sector was not attracting the sort of investment required because of its fragmented and unwieldy nature. Moreover this was sitting oddly with the growing environment for convergence in the media distribution space.
It is in this background that TRAI taking suo motu cognizance, released a CP exclusively on this issue in 2008, calling for a ‘new regulatory framework’ with the customer and increased revenue to the government as the central focus. Flagging the core issues, the CP says, ‘Though the physical spread of cable TV is increasing, the sector in its present form is subjected to least control and supervisory guidance. The present provision for registration, information system for monitoring of cable TV industry, consumer grievance redressal and quality of service etc need immediate attention.’ These anomalies have impacted the inflow of investment that is the key for network up-gradation and introduction of new technologies. Secondly digital technology is heading towards convergence that has made information transmission sophisticated and empowered customer premises equipment.
All these technological developments call for fresh consultations. This will not only require much higher investments to compete but also better technological knowledge and experience to run such services. Therefore financial and technical background of the entity seeking registration is relevant. In the fast moving world of technology therefore competition and efficiency is the key to survival.
TRAI therefore recommended that registration of cable operators should be replaced by a licensing requirement which was subsequently accepted by the government. Secondly, it recommended a separate licensing provision for MSOs thus recognizing them as an entity separate from cable operators. Both were accepted by the government. In both cases TRAI recommended a hike in license fees. While a cable operator would continue to register with the local post-office, he would now pay Rs 10,000 for a five-year license at the district level, an MSO would pay a corresponding amount of Rs. 1,00,000 and additionally possess a net worth of Rs. 5,00,000.
Four Phase Digitalization and its Aftermath
In November 2011 the inevitable happened. Faced with at best a limited success, the government passed an order amending the Cable TV Network (Amendment) Act that made it obligatory for each cable operator to transmit or re-transmit programs of any channel in encrypted forms through DAS. It was this amendment which resulted in the government unveiling a four-phase stage of digitalization.
Despite all the efforts spanning close to a decade, including the four-state digitalization drive cable distribution market continues to be analog- ‘Presently cable TV in large parts of the country is analog and non-addressable.
Inequality in Cable Market Structure
But from the standpoint of the market structure, the key issue was the emerging inequality in the distribution market. Digital cable distribution had grown exponentially (both analogue and digital) in comparison to the DTH market – from about 4 lakhs to more than 9.4 crore households by March end 2012 with the distribution chain comprising nearly 60,000 LCOs, 6000 MSOs and 7 DTH/satellite operators. The growth of the digital cable distribution was acknowledged by TRAI as a consequence of ‘packet switch digital technology’ that had made possible, ‘internet access as well as telephone services’ over cable TV network. TRAI also cautioned that the predominance of cable operators could translate into increased cable monopolies in the future since broadband and voice services would be carried on this infrastructure.
Considering that TRAI had to suggest ways and means to curb MSO monopoly in cable distribution, it appeared to push for just the opposite often citing high costs of technology and benefits of economies of scale. In the old analog system LCOs took signals straight from the broadcaster or from MSOs in the case of pay channels. But under the Cable Television Network (Amended) Act 2012, in the Digital Addressable System (DAS) areas, the only MSOs were authorized to receive signals from broadcasters. Here both FTA and pay channels received from broadcasters are transmitted to LCOs in encrypted form. The MSOs are required to maintain the Subscriber Management System (SMS). This changed business model means, ‘the issue of dominance in the cable TV sector needs to be addressed at the MSO level.
The exact market shares of MSOs are not available since in analogue platform the exact number of subscribers cannot be ascertained. But figures indicate that some MSOs are controlling more than 80% of the DAS market in some cities. Typically MSOs have increased their market share by buying out LCOs and MSOs increasing their size and presence in the market.
Large MSOs by virtue of economies of scale, ability to buy content cheaply and the clout to demand higher carriage and placement fees from broadcasters are in a much better position to offer a better deal to the LCOs. But this market power cuts both ways making it possible for larger MSOs to literally buy out LCOs and smaller players. Finally they can incentivize LCOs to move away from smaller MSOs to them. Such MSOs also make it difficult for the broadcaster to gain access to the distribution network for reaching the customer. Though DTH has emerged as an alternate to cable TV and its subscriber base is growing at a faster rate compared to cable TV, the percentage of cable TV homes is significantly higher as compared to DTH. The former constitute approximately 60% of the total TV homes. While DTH operators work on a national basis, cable TV networks operate on a regional basis and can choose channels for supply depending on local demand.
The level of competition in the MSO business is not uniform across the country. Certain states like Delhi, Karnataka have large number of MSOs, whereas others like Punjab, Tamil Nadu, Andhra Pradesh have a situation of monopoly/duopoly. However the same MSO is not dominant in all the states. But this monopoly has spawned uncompetitive practices in the regional markets.
But it is not just private players. In Tamil Nadu the government owned Tamil Nadu Arasu Cable TV (TACTV) has moved into the distribution business taking over 27 head-ends at one go. In utter violation of the TRAI mandated Interconnection Agreement between the broadcaster and the cable operator, TACTV has refused to carry the rival Sun TV on its platform. And as if this was not enough the state government by entering the cable business violates a TRAI recommendation that no government entity should be allowed into cable distribution business.
Hence the monopoly/market dominance issue in cable continues to be of significance, if only because of the sheer size of the cable TV market in the overall distribution market.
Measuring Monopoly and Market Domination
TRAI favours the concept of relevant market as a unit to measure monopoly and dominance. Relevant market means a market comprising the area in which the conditions of competition for supply of goods and provision of services or demands of goods or services are distinctly homogeneous and can be distinguished from the conditions prevailing in neighbouring areas. In this context, it is the state rather than the whole country that should comprise the basic unit for defining relevant market.
With MSOs the key players in the market, there is a need to frame restrictions on monopoly formation. One of the ways to do this would be prescribe restrictions on the geographical area served by an individual MSO. By restricting MSOs to specific areas more and more players could get to play in the market. But this may not be feasible since the licensing conditions contained in the Cable TV Act does not restrict a player to a given area.
A second way would be to prescribe reasonable restrictions on market share in the relevant market. As an example a cap of 40% market share will ensure that at least 3 MSOs operate in the relevant market and no single MSO becomes dominant or assumes monopoly. But what would happen to those who are already players in the market? Finally will it adversely impact efficiency?
But there is a major problem in all this- identifying who ‘controls’ the MSO. It is entirely possible that, ‘an association or body of individuals or a group of companies may try to gain dominance in a state by registering as MSO with different names. Also a person or a company may acquire substantial control in other MSOs in the same regional market. Therefore the legal definition of ‘controls’ has to be made comprehensive. For instance if a MSO ‘controls’ another distributor these should be treated as interconnected undertakings and part of a single group.
Finally a way has to be found for more effective monitoring of these and other issues. There is a need to collect information from MSOs on a periodic basis. Transparency should be ensured with regard to the structure of the entity/company; its shareholding pattern; FDI investments and Interest of other entities having a shareholding beyond a threshold in the cable TV entity; details of key executives and Board of Directors; details of subscribers and details of revenue generation.
Looking back and ahead, this paper presently in a draft form, will conclude by raising questions that I hope to answer later.
A decade after digitalization of cable distribution began, travelling the distance from tentative suggestions by TRAI to a full blown policy initiative, have the aims of digitalization as envisaged in Consultation Papers been achieved? Even government documents accept that the gains have been meager. Why is this so? By way of a hypothesis I suggest that the reasons for this lie outside the remit of TRAI. It was the Government that appeared to drive digitalization, in the final analysis. This will have to be meaningfully explored.
This is best exemplified in the manner in which the government dragged its feet on TRAI recommendations that suggest a more pro-active engagement at the policy level with the developing iniquitous cable market structure.
Again was consolidation within the cable market deliberately allowed by the government? How does one explain the perpetual ambiguity in TRAI documents where perils of consolidation and the need for one in view of techno-economic imperatives, co-exist?
Finally what are implications of this on diversity- political, economic and cultural? The issue figures in repeatedly in TRAI documents but there is little by way of policy based solutions.
Notes & References
 Snehashish Ghosh, ‘The Telecom Regulatory Authority of India Act, 1997’, Centre for Internet and Society, Mar. 15, 2013.Section 25(2) of the TRAI Act states that Government orders are binding on TRAI, while section 35 empowers the Government as the final authority on all policy matters. Accessed on 20/5/14
 Gillian Doyle ‘Media Ownership- The economics and Politics of convergence and Concentration in the UK and European Media’ London, Sage Publications, 2002, 4.
 TRAI, ‘Consultation Note on Issues Relating to Broadcasting Services And Cable Services’, January 15, 2004 url: http://www.trai.gov.in/WriteReaddata/ConsultationPaper/Document/Consultation%20note.pdf Accessed 02/05/14
 TRAI, ‘Recommendations on Issues Relating to Broadcasting and Distribution of TV Channels’, Oct. 1, 2004, 26 url: http://www.trai.gov.in/WriteReadData/Recommendation/Documents/01octcable%5B1%5D.pdf. Accessed 02/05/14
 Ibid, P.4
 TRAI, ‘Consultation Paper on Issues Relating to Broadcasting and Distribution of TV channels’, April 20, 2004, 5 url: http://www.trai.gov.in/WriteReaddata/ConsultationPaper/Document/Consultation%20Paper%20-20th%20april%202004.pdf Accessed 09/04/14
 Ibid. P.17.
 Ibid. P. 27
 op.cit TRAI Consultation Paper (henceforth CP), Oct. 1, 2004, 9.
 Ibid. P.17.
 Ibid. P.17
 Ibid. P.20
 TRAI, ‘Consultation paper on Digitalization of Cable Television’, Jan. 3, 2005, 3.url: http://www.trai.gov.in/WriteReaddata/ConsultationPaper/Document/consulpaper3jan05.pdf Accessed 30/05/14
 The cost of a large head-end with a capacity to carry 210 channels catering to about 2,00,000 people will be around 13.93 crores according to ‘Consultation paper on Digitalization of Cable Television’, Jan. 3, 2005, 1- 3. TRAI papers also note the virtually ‘unaffordable’ cost of digitalization for smaller networks.
 TRAI, ‘Issues Relating to DTH’, March 2, 2007, 2. url: http://www.trai.gov.in/WriteReaddata/ConsultationPaper/Document/cpaperDTH.pdf.Accessed on 15/05/14
 ‘Restructuring of Cable TV Services’, Mar.4, 2008 url: http://www.trai.gov.in/WriteReaddata/ConsultationPaper/Document/cpaper4mar08.pdf Accessed 18/06/14
 Ibid. pp.10-11
 Ibid. P.4
 TRAI, ‘Consultation Paper on Monopoly/Market Dominance in Cable Services’, June 3, 2013, 6 url: http://www.trai.gov.in/WriteReaddata/ConsultationPaper/Document/C_Paper_Cable_monopoly__3rd%20JuneFINAL.pdf Accessed 01/06/14.
 Ibid. p.1
 Ibid. p.7
 Ibid. P.12
 Ibid. P.28.