A new outlook to usher in Pan India Telecom and Unified Licensing.
Author: P. Abraham Paul. (Original wrote in 2002 and published in 2003, hence some of the points may be irrelevant now. Reproduced now as things are still in a muddled state as far as Governments/Regulators policies on telecom)
Introduction: Even after 16 years of privatization there is much to be desired in the the Telecom evolution in India with regards to government policies and regulatory methods. Streamlining Telecom Regulation in a country like India is an extremely complex process. It is more so when the basics itself went wrong from the beginning. Decisions were made looking from the commercial angle only and not the common interest of the country. Pleas of other stakeholders in the game were ignored and then naturally, they were only keen in protecting their own interests. If it goes on like this, it may take many more years for the Government Telecom Body to overcome the inadequacy of the initial policies and for the Regulators to take positive steps to apply corrective measures.
2. The main issues:
2.1 Scrap Boundaries, allow Level Playing Field.
Scrap Boundaries, allow Level Playing Field to remove the major impediment to developmental process: One of the crucial flaws in the initial policy is the misconstrued idea of making the license areas of GSM Public Land Mobile Networks (PLMN) and also subsequently licensed Public Switched Telephone Networks (PSTN), co-terminus with the service areas of ex-DoT’s existing Telecom Circles. These erstwhile DOT Telecom service areas were limited to the area of the States merely for administrative convenience and not based on any technology limitations such are direct inter connects between the circle telecom networks. With privatization, the whole set up became neither here nor there; by adopting the policy of issuing operating licenses on Telecom Circle basis, and then not allowing direct interconnects between the private networks both within the circle and between circles, a lackadaisical set up that was done without looking into possible implications such as its disruptive outcome on the global telecom architecture of the country.
As a result of this, many GSM Network Operators who had obtained license for operation in different States were not able to use common equipments such as Switching systems, Value added services, Customer care and Billing & administrative systems and were forced to replicate unnecessary costs on investments on equipment, human resource and administration. Also they were not allowed direct own interconnects between these replicated systems to provide service, even between their networks in adjacent States. Even direct interconnects were not allowed between the GSM service providers within a city. This is contradictory to the fact that the whole world was becoming smaller and smaller with advent of modern technology enabling cheaper bulk connectivity and faster means of communication between far distant places ensuring fairly open architecture.
These policies were counter-productive and jeopardized the benefits of privatization as a whole, resulting in poor business viability for the Stakeholders and less comforts and benefits for the end users. In fact, this is the basis of most of the litigation that resulted in unresolvable regulatory issues and conflicts between various groups of stakeholders, that caused delays in overall development process.
The better way was to treat the networks licensed to one Network Operator in different States as one service area for the purpose connectivity and service delivery. Fact being that in GSM network, such restrictions have no meaning as every user is always in roaming condition even within his home network, and service could be extended to any network, in own service providers or others by roaming feature.
Ironically, when BSNL entered GSM market as third operator, no such boundaries and interconnect restrictions were imposed on them and such partisan attitude and contradictions in the basics of the policies had naturally left other Fixed Network and GSM operators high and dry. As an attempt to offset these, polarization had happened fast within the existing Operator Groups, which was at least a positive business approach.
2.2. GSM vs. CDMA WLL conflict: A muddle being raked up afterwards was the conflict of interest between the group of GSM Wireless and CDMA Wireless Service Providers and also for users in the way of reduction in tariff.
The country’s interest being the prime consideration, there is no doubt that WLL using CDMA or other Wireless technologies are the right substitute for modernization and quick growth of the Fixed Network/wired line services and therefore, need full support from Government and Regulators. The question arises now is whether the CDMA Service Providers who are licensed to provide basic service only with limited mobility within the Short Distance Charging Area (SDCA), can provide mobility beyond that. But then the other side of the issue is that it is definitely in the interest of the country to allow CDMA based WLL service providers to give higher level of utility to end users by providing mobility beyond the SDCA and if technically feasible, even beyond the licensed area. No body can stop advancement of technology, perhaps can be delayed for some time but eventually the technology cannot be held back by mutually colliding vested interests or by retrograde regulations restricted by commercial policy implications.
The facility is identical to Number Portability in Fixed Network. In GSM, the Operators are providing service outside their licensed area by ‘roaming’. Actually the distinguishing factor is only the cost. If operators decide to extent business in other networks using ‘roaming’ at same or lower cost, it will be also violation of existing license conditions.?
Therefore, these need to be resolved quickly in the interest of the country. If it was not covered in the initial license, the way out is to modify the licensing policy as suggested herein below.
2.3. Conflicts about Optimal Routing of GSM Calls direct to visited network.
Another hot issue is the DoT’s objection about Optimal Routing of GSM calls directly to the called party visiting network through own or others carrier. Earlier due to some technology glitches, it was necessary to route all incoming calls to a Mobile subscriber visiting in other network through his home network. Inevitably the call has to use the monopoly operator BSNL’s carrier which involved long distance charges even for the call made from a caller to a visiting subscriber in the same network.
Optimal routing is a wonderful technology and therefore, should be encouraged as better utility at less cost will benefits the users. The Operators also will be benefited by higher usage and reduced operational cost. In fact the same type of facility need to be developed and deployed in the WLL Fixed Network scenario also.
2.4. Access Deficit Charge vs. Revenue Sharing:
Need for Telecom Penetration in the sub-urban and rural areas is of at most importance for growth of the nation. Currently BSNL only has any significant presence in this area. Other Fixed and Wireless service providers also need to step in and share the burden. However, the ADC is definitely a controversial issue. Other means such as Revenue Sharing with the help of ‘Charging Gateways’ need to be explored for ensuring more transparent methods.
3. Suggestion to overcome the issues:
3.1. It is possible to resolve these issues by bringing openness in regulation: Major change in Licensing policy, Regulatory decisions and the Business approach of Stakeholders are necessary to bring back the country under common telecom platform with congenial Telecom architecture. The aim shall be to ensure level playing field for all with minimum boundaries and limitations so that the Service Providers can operate with less constraints and more openness to pass on the benefits to end users to choose and use the facilities more economically and without undue limitations.
While considering a Pan India Telecom scenario, following are the issues to be considered:
– It is difficult to fully undo or deregulate the already established licensed regime.
The most important issue is the fulfillment of service obligations in rural areas, which require more sops for Service Providers as well as users.
It cannot be expected that other than BSNL, many other private Telecom Network Operators would take on operation in all the 24 Telecom Circles in the country.
It is also unwise to suggest bringing BSNL, which has been fulfilling the social obligations in this country during the development phase for decades, fully at par with other licensed FN/GSM operators.
Issues about roaming. Another issue is about roaming between non-Pan India service provider and PAN India service provider’s network. According to roaming concept, roaming within the networks of own service provider is regional roaming, whereas roaming into another service provider network within the country is National Roaming and outside the country is International roaming. Therefore, for a PAN India service provider’s subscriber, the entire country becomes home network, and therefore will be in regional roaming mode within the home network. For a non-Pan India service provider’s customer, roaming into a PAN India Network customer will be National roaming.
There are similar issues to be addressed in the Fixed Network and other technology oriented services, which will come up later.
The existing Network operators/service providers licensed for regional services should not be handicapped.
In Public Land Mobile Network (PLMN) it is mandatory that subscribers of every PLMN shall be able to access any other subscriber in any PLMN across the world leaving aside how the call will be charged.
3.2. Concept and Philosophy of “Pan India Telecom Service Provider” (PITSP). The suggestion herein is to bring in the concept and philosophy of Pan India Telecom Service Providers (PITSPs) for all India service as one part segregating conceptually and in principle, the existing and prospective Network Operators licensed for region wise operation as the other part of the telecom business.
Also the basis for this suggestion is that running the Telecom commercial business with appropriate marketing tactics is entirely a different ball game when compared to Technology part in setting up the network and running it with best quality and efficiency. Conceptually and in practice this can be realized by segregating Commercial Business Oriented All India Service Providers and Technology Service Oriented Network Operators allowing each to co-exist and inter-work without boundaries and undue regulatory constraints.
3.3. Licensing of Pan India Telecom Service Providers: To arrive at this, there need to be freshly licensed Pan India Service Providers (PITSPs) who are allowed and made mandatory to provide Commercial Telecom Services to end users at All India level without any defined boundaries and limitations.
To begin with, all existing Operators or their consortia including BSNL/MTNL shall be licensed as Pan India Telecom Service Providers at par for providing Commercial Telecom service across the country. Later bringing in fresh entrants can be thought of. These PITSPs need not have own networks in every State, but it shall be made mandatory for them to have agreement and understanding with the Network Operators all over the country for ensuring network related services to their Pan India customers at all India level.
The Pan India Business systems can be different in their function from the existing region wise Network Operator business. For example, in the GSM scenario, there can be PITSP systems who own only common Home Location Registers (HLRs) and Billing & Administration Systems. They shall be licensed to produce and market SIM cards under their Pan India label with common all India Numbering plan for open sale and manage the commercial side of the business leaving the network part to various existing technology network operators. So their customers as end users can avail network related service from any network in the country by purchasing the SIM from various outlets of the PITSP and logging into any Network according to their will, choice, convenience and situation.
License for Pan India Telecom Service shall be provided at soft terms for the existing licensees who come forward to become PITSPs. With this Pan India license, the PITSPs get freedom to arrange with the network operators to route the service related signals, data and voice across the country including optimal routing on own or others carrier’s without any restrictions. Same philosophy can be adopted for the CDMA or other technology based WLL services once the technology is ready for this.
3.4 Centralized Billing by PITSPs.
Tariff, Subscriber Administration, Billing and Revenue collection are to be done by PITSPs on Post paid or Pre-paid basis. The revenue generated is shared with other PITSPs/Network Operators according to the usage of their systems and networks based on the mutual understanding and agreement.
Such Billing method can also remove the ADC method by bringing in Revenue Sharing.
4.1 Role of existing and prospective Network Operators/Region wise Service Providers:
The existing and prospective Network Operators/Service Providers part shall be to provide Network and Technology related features, facilities and services at regional or all India level according to their business plans, licensing and understanding with PITSPs. It is mandatory for all these network operators to provide service to end users belonging to any and every Pan India Service Provider under mutual agreement. The network operators are given freedom to interconnect and inter-work with other networks according to their requirement without restrictions.
The Network Operators basically can concentrate on Technology oriented business strategy for setting up and maintaining the best quality Networks and advanced technology service leaving the Pan India business to the PITSPs.
Existing Operators need not fear about losing business:
There need not be any fear for the existing licensed Network operators of losing customer base and control on business as they can continue with existing mode of regionalized business and can use the option to take license and go under the banner of a Pan India Telecom Service Provider System. The regulators and Government shall ensure that such Pan India licenses are provided to the existing Network Operators/Service Providers on soft terms to give them level playing field at par with BSNL and others.
In effect, by getting under the banner of a PITSP license, the boundaries are opened out and Network Operator can do network related business with own PITSP banner within their own networks in the licensed region as well as in other’s licensed regions through the PITSP as already being done by roaming now. The advantage that there will be no restrictions on interconnects etc. This way only the licensing and operational philosophy changes to induct the Pan India Concept and all the Stakeholders get the benefit of a fully open structure and level playing field to operate across the country without limitations. In fact they will get more revenue from the use of their network work by other PITSP customers as far as they are able to provide high quality network and service.
5. Benefits for the end users: The most important advantage is that the end users are fully benefited by getting maximum flexibility and freedom to choose and use the best quality networks and carriers according to their situation and requirement.
6. A new numbering plan for bringing in the Pan India concept:
Please see my blog on ‘Segregation of Service Provision from Network operation / Universal Numbering Plan’. in the link http://wp.me/p1ZsI2-t
To make PAN India Telecom philosophy and concept workable, a more flexible numbering plan is required:
Basically the numbering should look for the Service Provider identity and not any Geographical area or the network operator as the Customer belong to a Service Provider and not to any Network operator. The Customer is given freedom to use any network and any carrier for inter-network calls. Optimal Routing is envisaged to optimize direct routing of calls to the destination network. I have suggested a new Universal numbering plan based on such concept few years back to TRAI and DoT. Please see my article in the above mentioned link. Basically the plan suggested looks into the Service Provider identity and not the network operator. In effect the Customer will belong to a Service Provider and not to any Network operator. The Customer is given freedom to use any network and any carrier for inter-network calls. Optimal Routing is envisaged to optimize direct routing of calls to the destination network.
Conclusion: It appears that every one in the game want to provide more than what was contracted which seems to be a positive attitude beneficial to the country. (Whether they are fulfilling their intended obligations is another issue.) The benefit on these intentions can be consolidated only if regulation is also sensible and positive. Country’s interest shall be of prime consideration and not the commercial issues. The idea emphasized here is that the boundaries need to be scrapped for all Service Providers in the interest of the country as a whole giving them enough freedom to adopt independent business strategy as appropriate for the Commercial Telecom Business and Technology oriented Network Business.
To enable this, the Government bodies and Regulators shall not bind the Service Providers and end users with irregular regulations imposing undue constraints and limitations just because of bungled commercial issues. Perhaps, they need to look more closely else were for better models.
As far as the issue of opening out more mobility to WLL, there is enough scope in this country for both GSM and CDMA technology based and other WLL services to co-exist and grow. If the end users are benefited by getting mobility in the land line substitute using CDMA, such technology options need to be welcomed and encouraged further to develop and provide full roaming features. After all, the whole idea of privatization is to ensure better telecom facility for the masses especially at the lower levels in the rural areas and thereby attain overall development of the Country. Nevertheless, it is necessary to ensure that right technology is implemented such as roaming with CDMA and not something hodgepodge like Multiple Registrations with Call Forwarding etc. as being propagated now just to cross cut GSM. Optimal routing in GSM and WLL should be encouraged.
To certain extent, WLL will restrict GSM growth, but then it is more a threat to the incumbent Wired Line FN operators also. It is high time that BSNL and FN service providers gear up their operation in WLL to combat this challenge. 3G is a far cry and definitely not much of a use for developing countries like India, much can be done better by enhancing the Fixed Network and converging it with Wireless and Packet Data Network.
In addition to licensing of PITSPs, a new outlook is required in the inter-connects, routing plans and a numbering plan suitable for bringing in the Pan India concept.
Contact: P. Abraham Paul. e-mail: firstname.lastname@example.org Tweet @PA_Paul