TRAI consultation paper on network testing before launching service

Mobile network testing by R&STelecom Regulatory Authority of India (TRAI) has floated a consultation paper on network testing before commercial launch of services.

TRAI’s latest consultation paper follows wide-spread criticism to Reliance Jio Infocomm that carried out testing of its 4G network on a very large scale and enrolled lakhs of subscribers as test users before commercial launch of its services. During the testing phase, networks of Bharti Airtel, Idea Cellular and Vodafone faced quality issues.

Telecom industry stakeholders can submit their comments by 29 May 2017 and counter-comments by 12 June 2017. They can send comments to Sanjeev Banzal, advisor (Networks, Spectrum and Licensing), TRAI on the email ID [email protected].

Reliance Jio told TRAI that LTE / VoLTE is a new technology and its throughputs are dependent on Signal to Noise Ratio (SNR) and it is conducting test trials to estimate optimal network parameters for best throughput in loaded condition.

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Some operators filed representations through their Industry Association expressing that this practice is unfair due to the following reasons:

# Enrolling of subscribers and provision of service before commercial launch of services free of cost is generating non-level playing field conditions.

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The volume of voice traffic generated by such test users, due to free offers, is choking Points of Interconnect, and impairing the quality of service of other operators.

# As per the prevailing practice, commissioning of initial Points of Interconnect (PoI) with 1-2 E1s (2 Mbps connectivity) is sufficient for testing.

Department of Telecommunications (DoT), through its letter dated 9 Sept 2016, communicated that at present, network testing is being carried out by licensees on the basis of erstwhile practices followed by DoT / BSNL and test SIM Cards are issued by such licensees to check the quality of network, before the commercial launch of services.

DoT requested TRAI to provide its recommendations on testing of network before commercial launch of services including enrolment of customers for testing purposes before commercial launch, duration of testing period etc.

TRAI said there is need to create test SIM cards for carrying out different functionality tests and to check the Quality of Service. If test cards are meant to be given only to the employees and/or business partners, there is a natural limit on the number of test SIM cards which can be issued.

If test SIM cards are issued in limited numbers and for limited period of time, then there may not be any point of contention between service providers. If a TSP deploying a new technology for mobile services, requiring extensive testing of network before commercial launch, enroll subscribers (other than its employees and business partners) as test users to test its network with sufficient loading, should it be allowed to do so? In that case, should there be any restrictions on the number of test users and the period of such use?

TRAI said one view is that 6 providing full-blown services during test phase may have implications on the IUC, pricing, QoS and other regulatory aspects and as such can be viewed against the spirit of level playing field.

Following may be some of the options:

# Testing may be restricted within own network of the concerned Licensee/TSP. For testing of processes/systems which may require connectivity with the other networks i.e. other TSPs, the same could be carried out using the test SIMs given to business partners or employees on a small scale.

# Put a limit on the time period for which any test subscriber can be provided the services during test phase.

# Provide a temporary number series to the TSP for testing of network before commercial launch of services, which would be withdrawn upon commercial launch by the TSP and a fresh number series would be issued for enrolling commercial subscribers. This would ensure that enrolment of subscribers prior to commercial launch is not exploited or misused by a TSP to circumvent the regulatory provisions and compliances.

# To limit the number of test subscribers by way of allotment of smaller chunks of numbers, say 10000, as against about 10 lakh per series, during test phase. The test subscribers may be enrolled purely on temporary basis. e) Perform intensive testing on the radio access network (RAN) in a relatively smaller geography, for which small number of test users/subscribers would be required.

# The TSP could perform load 7 testing in one city or a couple of cities and tune the network in other parts of the service area. In any case, the network tuning is a continuous exercise performed by the network providers so as to optimally meet the dynamic demand.