India’s government culture is among the most open to consultation in the region. Consultation is a legal requirement for TRAI. There is no equivalent of the Administrative Procedures Act, but nevertheless the Department of Telecom has given a month for comments to be submitted on the National Telecom Policy 2011 draft. All good.
The problem is the online interface through which comments have to be submitted. It does not work. Our first hypothesis was that the problem was being caused by the fact that out comments came from an IP address outside India. Odd to exclude comments from outside the border (after all the objective is to get the best input). But anyway, we then tried to submit through an Indian IP address, that of our Senior Policy Fellow, located in New Delhi itself. Still no success: the requisite code was not being sent. (What is the point of codes? I recently ran an online consultation process for the city of Colombo, which used off-the-shelf technology and worked fine. I realize Colombo is not on the scale of India. But surely, there is no real danger of David Headley submitting comments. Even if he does, DoT can simply ignore them).
Anyway, here are the comments that may or may not reach the authorities at DoT. We will keep trying. IT is supposed to make life easier. Sometimes it does not. But we will persevere.