Telecom service providers (TSPs) often opt for network testing before commercially launching new services. This is necessary to ensure that they meet the quality of service (QoS) standards and comply with the directives of the telecom regulator. However, it is important for the industry as a whole to adhere to certain guidelines during the testing phase so that there is a level playing field for all stakeholders.

In the past, the Telecom Regulatory Authority of India (TRAI) has released guidelines for testing wireless services. However, wireline services remained largely untouched. To this end, in July 2019, the Department of Telecommunications (DoT) requested TRAI to provide its recommendations on network testing before the commercial launch of wireline access services. Following DoT’s request, TRAI initiated a fresh consultation process to frame its recommendations. Since most of the issues for wireline services were similar in nature to those for wireless services, TRAI issued draft recommendations on December 31, 2019 to solicit views of stakeholders. After considering the written submissions of stakeholders and examining key issues, TRAI has now released its recommendations on network testing before the commercial launch of wireline services.

A look at TRAI’s key recommendations in this regard….

Need for guidelines

Since wireline networks are at great variance from mobile networks, the testing requirements also differ. TSPs provide wireline access services under the basic service licence, unified access service licence (UASL) and unified licence (UL) with access service authorisation. After obtaining the licence, a licensee is responsible for and is authorised to own, install, test and commission all the applicable systems for providing services.

However, before the commercial launch of any telecom service, extensive testing of the network is necessary. A TSP is required not only to meet the laid down QoS standards but also to ensure that the subscribers’ experience is good. Testing of systems and ensuring QoS is also important from a commercial point of view as the subscribers’ experience is an important factor that leads to demand generation in the telecom industry. Since all aspects of the subscriber experience cannot be tested using simulation tools/testers, licensees use test users to check the quality of their network before the commercial launch of services.

However, the problem arises because the basic service licence, UASL and UL do not provide clear guidelines on testing of the network and processes such as timeline of testing, acquisition of subscribers during test-phase and limit on the number of test users.

Enrolling test users 

If a TSP decides to conduct extensive testing of network before its commercial launch and enrols subscribers (other than its employees and business partners) as test subscribers under sufficient load condition, an unaddressed issue is whether the TSP should be allowed to enrol test subscribers before the commercial launch of the service. In this regard, TRAI recommends that a TSP should be allowed to enrol test users in the testing phase to carry out network testing before the commercial launch of its wireline access services. The TRAI is of the view that it is always better that services are launched after due testing and trials so that customers are not inconvenienced.

Demarcation of test phase from commercial launch

Another key issue is whether a TSP should be allowed to provide all services free of cost to test users even before the commercial launch of services. Further, the number of test users allowed is also a problem as the requirement of test users could vary, based on the size of the network and the technology being deployed. Moreover, having a specific timeline for the testing phase has also been a largely debated issue.

In view of the above issues, TRAI recommends that there should be no restriction on the time limit, if the network testing is conducted using wireline telephone test connections given to employees and business partners for test purpose only. Further, the number of test users that can be enrolled by a TSP in a licensed service area (LSA) should be limited to 5 per cent of its installed network capacity for that LSA. The service provider will also need to submit detailed capacity calculations of the network to DoT and TRAI at least 15 days before commencing the enrolment of test users. Moreover, TRAI recommends that there should be a limit of 90 days on the test phase involving test users. However, if the TSP fails to conclude network testing due to valid reasons, it may make a representation to the licensor, seeking additional time for network testing giving detailed justification, which may be decided by the licensor on a case-to-case basis. The requisite norms to be followed for an extension of the timeline for network testing may be formulated by the licensor. However, the total time period for network testing provided to the TSP will not exceed 180 days.

Fulfilment of conditions during test phase

There are certain subscriber acquisition related conditions and regulatory reporting requirements, which are linked with the commencement of services and subsequent acquisition of customers. These include provisions related to observing confidentiality of customer information and ensuring verification of each customer before enrolling him/her as a subscriber, among other security conditions. A TSP is bound to follow these provisions after the commercial launch of its services. However, an issue of discussion is whether the TSP should be bound to follow these regulatory requirements during the test phase when test users are enrolled.

In this regard, the TRAI recommends that if a TSP wants to enrol test users on its network before the commercial launch of services for testing purpose, it should give prior intimation to DoT and TRAI at least 15 days before commencing the enrolment of test users. Further, all licensing provisions related to security and privacy such as ensuring adequate verification of each and every customer before enrolment as a subscriber, protection and privacy of communication, maintaining CDR (call detail record)/IPDR (IP detail record), confidentiality of information, lawful interception and monitoring must be complied with by the licensee. The TRAI also recommends that the licensee should be bound to submit test user related statistics and their usage, and other information as per prevailing instructions of DoT/TRAI during the test phase.

Information dissemination to users during test phase

During the test phase, it is also important to ensure that the enrolment of test users by a TSP before the commercial launch is done in a fair manner. Further, test users should be informed that they are being enrolled as test users only, that too for a defined period of time. Additionally, as the TSP is still conducting test trials, it cannot be expected to provide a commitment on the QoS. Therefore, any charges (even if nominal) imposed on the test users, may not be appropriate.

To this end, TRAI recommends that if a TSP wants to enroll test users, it should transparently inform them at the time of enrollment that the TSP is not mandated to adhere to a specified level of QoS during the test phase. Therefore, there may be a sub-optimal level of network performance. Further, TSPs should inform users about the scope of services during the test period and should not ask for any charge (fixed or usage based) during the test. In fact, TRAI recommends that CPE (customer premises equipment) should also be provided free of charge. Moreover, TSPs should inform users about the likely date of the commercial launch.

By Kuhu Singh Abbhi