Chapter II: Full Mobile Number Portability
2.1 Presently mobile subscribers are availing the facility of MNP for
porting their mobile number within the same LSA. For example, if a
subscriber belongs to Andhra Pradesh LSA, he can port his mobile
number to any TSP of his choice within Andhra Pradesh LSA only.
Accordingly, in the present framework, MNP porting request is
processed amongst Recipient Operator, Donor Operator and the
MNPSP of the same LSA. Whenever a subscriber changes his LSA,
he needs to acquire a new mobile number of that LSA, otherwise he
will be under roaming, inviting higher call charges than a normal
subscriber.
2.2 The facility of pan-India portability will allow a subscriber to change
his LSA without change of mobile number. This means that a
subscriber of Andhra Pradesh LSA can port his number to any LSA
say Karnataka, Maharashtra, Haryana etc. Implementation of Full
Mobile Number Portability would therefore mean acceptance of a
porting request by the Recipient Operator from a mobile number
belonging to any of the LSAs of the country, irrespective of the fact
that the LSA from where the subscriber is porting his mobile
number and the LSA to which he wants to port his number belong
to the same or different MNP zones.
2.3 There will be regulatory and technical challenges in facilitating such
porting across LSAs. Some of the major challenges which need to
be deliberated are –
(i) how the request of the subscriber for porting will be
processed by the Donor Operator, Recipient Operator and
MNPSPs,
(ii) what changes are required in Number Portability Gateway
(NPG) of the operator and operator’s IT systems etc.; and 5
(iii) how much time will be required to complete the
modifications in the existing systems of the operators.
These challenges are discussed in the succeeding paras.
2.4 In the present framework on receipt of porting request, the
Recipient Operator forwards the same to the MNPSP of its MNP
zone. However, in full MNP scenario, the recipient operator will have
the following options which were described in the pre-consultation
paper dated 20th February, 2013.
Approach-1 : Recipient Operator forwards the porting request
to the MNPSP of its zone.
Approach-2 : Recipient Operator forwards the porting request
to the MNPSP of the other zone to which the Donor Operator
belongs.
Approach-3 : Recipient Operator forwards the porting request
to the MNPSP of the zone to which original number range holder
(the TSP to which the number originally belonged before its first
porting) belongs.
2.5 Stakeholders’ comments were sought on the most suitable approach
for implementation of Full MNP. The stakeholders were divided in
their opinion. While the TSPs supported Approach-1, the MNPSPs
supported Approach-3. None of the stakeholders supported
Approach-2. As there were differences in opinion between TSPs and
MNPSPs, meetings were held with the industry representatives viz.
COAI, AUSPI and MNPSPs. During the discussions, it emerged that
another approach, hereinafter called ‘modified Approach-1’, which
is a combination of Approach-1 and Approach-3, should also be
considered. These three possible approaches are discussed below:6
A. Approach 1: Recipient Operator forwards the porting request
to the MNPSP of its zone
2.6 In this approach, the Recipient Operator submits the porting
request to the MNPSP of its MNP zone. For example, if a subscriber
of Karnataka LSA wants to port his number from Karnataka to
Delhi LSA, he will submit his porting request to the Recipient
Operator of Delhi LSA, who in turn will forward the porting request
to MNPSP of MNP Zone-1. (which serves Delhi LSA) for porting.
2.7 On receipt of the porting request, the MNPSP of MNP Zone-1 will
verify the porting history of the mobile number by querying with the
MNPSP of MNP Zone-II(which serves Karnataka LSA). The query is
primarily to check whether the porting request meets the following
conditions:
(a) Completion of 90 days in its current operator’s network;
(b) No simultaneous porting is under process for the said
mobile number, in the other MNP zone.
If the porting request meets the above two conditions, the MNPSP of
MNP Zone-I will seek clearance from the Donor Operator of Karnataka
LSA. Further processing of porting request will take place as per the
existing porting process.
2.8 From the TSP’s perspective, this approach requires minimal
changes in the TSP’s Number Portability Gateway (NPG) as the
Recipient Operator continues to forward the porting requests from
the subscribers desirous of porting out their numbers to the MNPSP
of its zone. However, this approach has the following implications:
i. It will add complexity to the MNPSPs’ system as it requires
connectivity between the two MNPSPs.
ii. It will require synchronization of the database of the two
MNPSPs for ported numbers, porting history, database tables
etc. During discussions, MNPSPs stated that since they used
proprietary software, synchronization between the two MNP
systems has never been done earlier and would require 7
extensive development efforts and such a design will be
susceptible to errors in a live scenario.
iii. The MNPSPs also stated that new software development work
would be required for:
(a) developing mutually agreed interface specification by both
MNPSPs for requesting and obtaining the required data;
(b) modification to the current process, including new
messages, timers, error codes and reports;
(c) changes in the database design to maintain the data
received from other MNPSP;
iv. Real time port-in-progress validation and sharing of broadcast
information between the MNPSPs will increases dependency
between the two MNP Clearing House (MCH) systems. This will
increase system complexity, storage needs and will affect the
system performance (in terms of time and processing).
v. Testing in the above approach would be time and resource
consuming and also very costly.
B. Modified Approach 1: Recipient Operator forwards the porting
request to the MNPSP of its zone and the Donor Operator is
responsible to check the condition of 90 days and simultaneous
port requests
2.9 In the modified version of Approach-1, the need for connectivity
between the two MNPSPs has been eliminated. In this approach, the
Donor Operator will be responsible for verifying whether the
subscriber fulfils the eligibility condition of 90 days in the existing
network and also if the subscriber has made any simultaneous
porting request for the same mobile number. As such the
responsibility to check the above mentioned two conditions by
querying with the MNPSP of the other zone (Approach 1) will move
to the Donor Operator. The Donor Operator will be required to build
this check in their Number Portability Gateway (NPG). This will
require software changes in all the TSP’s NPG. However, the
advantage of this method is that there will be comparatively fewer8
changes requirement in the MNPSP’s systems due to the elimination
of connectivity between the two MCHs.
C. Approach 3: Recipient Operator forwards the porting request to
the MNPSP of the zone to which number range holder of the
number belongs.
2.10 In this approach, the Recipient Operator submits the porting
request to the MNPSP in whose zone the Number Range network
belongs. As all TSPs already have connectivity with both the
MNPSPs they will not have to make any changes in communicating
with the MNPSP of the other zone. This approach also does not
require interaction between the two MNPSPs. Therefore, this
method eliminates the need for connectivity /synchronization
between the two MNPSPs. However, in this approach, intelligence
needs to be built-into the operator’s NPG so as to forward the
porting request to the concerned MNPSP based on the identity of
the number range holder network.
2.11 In this approach the control on porting the mobile number will
continue to be with one of the MCHs. Even after a subscriber moves
to other MNP zone, all his subsequent porting requests (whether for
intra-Circle porting or Inter-Circle porting) will continue to be
processed by the MNPSP where his number originally belong. For
example, if a subscriber port his number from Delhi (which is in
MNP Zone-I) to Bengaluru (which is in MNP Zone-II), he will
approach the Recipient Operator of Karnataka LSA for processing
his porting request. The Recipient Operator will process the porting
request through MNPSP of Zone-I. Subsequently, if the subscriber
ports his number within the Karnataka LSA then also, the Recipient
Operator to whom the subscriber approaches in Karnataka LSA will
process the porting request through MNPSP of Zone-I only.9
2.12 All three approaches described above have their pros and cons.
Therefore, before deciding the approach to be implemented for full
MNP, the Authority decided to form a Focus Group consisting of
representatives from MNPSPs and TSPs to give their views on :
a. the preferred approach for implementation of full MNP;
b. changes required in the existing MNP system;
c. cost and time involved in various methods;
d. any other optimal feasible solution for implementation of
full MNP.
2.13 The deliberations of the Focus Group was coordinated and
facilitated by TRAI. After deliberating on all the possible
approaches, the Focus Group has unanimously recommended
Approach-3 for implementation of Full MNP in the country. (Report
at Annexure-II)
2.14 According to the Focus Group, cost requirement in Approach-3 will
be the least for both the MNPSPs. For TSPs, there will not be a
significant difference in the cost to be incurred in any of the three
approaches.
2.15 The Focus Group was also of the view that, irrespective of the
method adopted, TSPs will be required to upgrade their existing
backend systems such as CRM, mediation platforms, provisioning
systems / activation systems, billing systems, number
managements systems, recharging platforms, VAS management
systems etc, to support complete numbering plan and enable interLSA porting. Similarly, MNPSPs will also need to upgrade their MCH
to support complete numbering plan and enable inter-LSA porting
apart from enhancing billing system, Graphical User Interface (GUI)
etc.
2.16 The pros and cons deliberated by the Focus Group have been
examined by the Authority. The Authority agrees with the Focus
Group’s observation that the variation in the costs to be incurred in the three approaches will not be significant for the TSPs, whereas a
significant expenditure will be required for MNPSPs if Approach-1 is
adopted for implementation of full MNP. Further, the
implementation time for Approach-3 will be much less as compared
to Approach-1 or modified Approach-1. In addition,
2.17 Therefore, in the opinion of the Authority, Approach-3 will be the
most suitable approach for implementation of full MNP. Though the
Focus Group has not clearly mentioned the time frame for
implementation of the solution, the Authority is of the opinion that
6 months will be sufficient for operators to carry out the required
changes in their existing systems, complete inter-operator testing
and implement the solution.
2.18 Accordingly, the Authority recommends that Approach-3, as
described in para 2.10, should be adopted for implementation
of Full Mobile Number Portability. The TSPs may be given 6
months time to implement full MNP in the country.
Changes required in the MNP licence conditions:
2.19 For implementation of full Mobile Number Portability, following
licence conditions of MNP licence will require
modification/amendment:
(a). Scope of Licence:
In the scope of MNP license, the following condition will require
modification:
“12.5 The MCH and NPDB established by the licensee shall be
used by all telecommunication service providers (both existing &
new) (i.e. Basic, CMTS, UAS, NLD and ILD Licensee(s)) of the
licensed MNP zone for the purpose of supporting porting of mobile
numbers between mobile operators.”11
If full MNP is implemented with Approach-3, TSPs will have to
use the services of both the MNPSPs for processing the porting
request. Therefore, the restriction ‘the licensed MNP zone” in
clause 12.5 needs to be removed.
(b). Delivery of service:
The ‘Delivery of Service’ condition in clause 18.1 of the MNPSP
licence would require amendment -
“18.1 MNP is to be implemented in each intra Licensed Service
Area (LSA)……….”
In order to provide inter service area MNP service, the word
‘each intra’ may be modified to read as ‘inter and intra’
(c). Changes required in the DoT instructions dated 06th May
2009
DoT instructions dated 6th May 2009 regarding provisioning of
MNP will also require modification. Para 3(i) of the said
instructions is given below:
“ ….MNP is to be implemented in each intra license Service Area
(LSA) as per the schedule notified by the Licensor from time to
time…….”
The word ‘each intra’ in the para may be modified to read as
‘inter and intra’.
2.20 In view of the above, the Authority recommends that the DoT
should carry out the necessary changes as mentioned in the
above paras in the:
(i) existing MNP license; and
(ii) instructions of the DoT dated 6th May 2009, for
implementation of Full MNP.12
Upon acceptance of these recommendations, the Authority will carry
out necessary changes in the MNP regulations
Identification of inter-service area (STD) calls after implementation
of Full MNP
2.21 Presently, a calling subscriber can store the mobile number of the
called subscriber in one of the following possible ways in the
contact list of his mobile phone handset:
(a) Storing directly the mobile number of the called subscriber ;
(b) Storing the mobile number with prefix ’0’ ;
(c) Storing the mobile number with prefix ‘+91’ ,
2.22 In the Full MNP scenario, if a called number happens to be a ported
number that has been ported to a different LSA, a subscriber calling
that mobile number in the case of (a) above, will not be successful
as the called number has been ported out of the LSA and the caller
has to prefix ‘0’ to this called number – being an inter-service area
call. Therefore, by default, the calling subscriber will get ‘number
does not exist’ announcement. In the case of (b) and (c) above,
when a subscriber makes a call, though the call will be successful,
it will attract applicable STD charges instead of local charges (before
porting). There is a possibility that the calling subscriber may not
be aware that the number has been ported out to another LSA.
This may result in a subscriber complaining of higher charges.
2.23 This issue was raised in the pre-consultation paper and inputs
were sought from stakeholders on the need to inform the calling
subscriber through announcement prior to connecting the call. In
response, some TSPs suggested that identification of inter-service
area ported numbers and playing an announcement thereof, will
burden their network resources and will increase call set up time.
It was suggested that the subscribers may be made aware
of/educated to dial numbers in the +91 format which is the
standard dialing format, after Full MNP is implemented.
2.24 On the issue of higher call charges and possible subscriber
complaints, most TSPs were of the view that STD rates have
plummeted to almost the same level as local call rates; hence, it is
not a major issue. Further, in most cases, the calling party may
already be aware that the called party has moved to another LSA.
Therefore, the onus should lie on the calling party to bear the STD
charges, if applicable. One of the suggestions was to have a website
so that a query for a given telephone number can be given which
will provide information about the current serving operator/LSA for
the called number. This facility can be developed by the MNPSPs.
The Authority agrees with the above comments of the TSP and is of
the opinion that no action is required on this issue
UPC generation in J & K LSA in Full MNP Scenario:
2.25 As per the existing MNP process, a subscriber is required to
generate a UPC before submitting a porting request to the Recipient
Operator. In the Full MNP scenario, the location of the Recipient
Operator being in a different LSA, the Donor Operator will have to
ensure generation of UPC for subscribers under roaming. During
the pre-consultation, TSPs informed that UPC can be
requested/generated from any LSA (except in Jammu & Kashmir
LSA where roaming of pre-paid subscribers is not permitted).
2.26 In the J&K LSA, post-paid subscribers can generate a UPC as in
any other part of the country. However, pre-paid subscribers of
J&K can generate a UPC only by making a call to ‘1900’ instead of
sending an SMS. Therefore, in a full MNP scenario, the issue of
generation of a UPC while in another LSA may arise for pre-paid
subscribers of J&K as such subscribers are not permitted roaming.
2.27 The solution to this problem is that the subscriber of J&K LSA who
wants to port his number to any other LSA can generate the UPC in
J&K LSA and then apply for porting to any desired LSA.
Alternatively, he can convert his subscription from pre-paid to 14
post-paid which will enable him to generate a UPC under roaming,
and then request porting in any LSA.
Testing Fees for Acceptance Testing
2.28 During the consultation process, the TSPs and MNPSPs have stated
that apart from network implementation costs, significant testing
costs would be incurred by them.
2.29 The TSPs have requested to waive the testing fee by the DoT for
acceptance tests to be conducted for implementation of Full MNP.
2.30 On 24th November 2011, the DoT specified the Acceptance Testing
fee to be charged for various types of networks as follows:-
S.
No.
Fee to be charged from
TSP/ ILDOs/ MNPOs
Unit Price (per network/ per LSA.
Per gate way, per site)
1 UASL /CMTS Service
Provider
Rs. 307228 (per network per LSA)
2 Basic/ WLL Service
Provider
Rs.189360 (per network per LSA)
3 International Long Distance
Operator (ILDO)
Rs.189360 (per Gateway)
4 MNPO Rs.279800 per site (Production/
Disaster)
Rs.60360 per network per LSA
(GSM/ CDMA)
2.31 Before the launch of MNP, DoT had already conducted acceptance
test through respective TERM cells of DoT for which testing fee had
already been charged as per the above said circular. Now, Full MNP
is being mandated pursuant to NTP-2012 and testing is to be
carried out for various scenarios due to a change in the process.
Therefore, the Authority recommends that the DOT may
consider the request of the operators and reduce the
Acceptance Testing Fee to 25% of the Current Fee.15
Chapter III: Summary of recommendations
3.1 The Authority recommends that Approach-3, described in the
relevant para (2.10), should be adopted for implementation of
Full Mobile Number Portability. The TSPs may be given 6
months time to implement full MNP in the country. ( ¶2.18)
3.2 The DoT may carry out the necessary changes in the:
(i) existing MNP license; and
(ii)instructions of the DoT dated 6th May 2009, for
implementation of Full MNP. (¶2.20)
3.3 The DoT may consider the request of the operators and reduce
Acceptance Testing Fee to 25% of the Current Fee. (¶2.31)
2.1 Presently mobile subscribers are availing the facility of MNP for
porting their mobile number within the same LSA. For example, if a
subscriber belongs to Andhra Pradesh LSA, he can port his mobile
number to any TSP of his choice within Andhra Pradesh LSA only.
Accordingly, in the present framework, MNP porting request is
processed amongst Recipient Operator, Donor Operator and the
MNPSP of the same LSA. Whenever a subscriber changes his LSA,
he needs to acquire a new mobile number of that LSA, otherwise he
will be under roaming, inviting higher call charges than a normal
subscriber.
2.2 The facility of pan-India portability will allow a subscriber to change
his LSA without change of mobile number. This means that a
subscriber of Andhra Pradesh LSA can port his number to any LSA
say Karnataka, Maharashtra, Haryana etc. Implementation of Full
Mobile Number Portability would therefore mean acceptance of a
porting request by the Recipient Operator from a mobile number
belonging to any of the LSAs of the country, irrespective of the fact
that the LSA from where the subscriber is porting his mobile
number and the LSA to which he wants to port his number belong
to the same or different MNP zones.
2.3 There will be regulatory and technical challenges in facilitating such
porting across LSAs. Some of the major challenges which need to
be deliberated are –
(i) how the request of the subscriber for porting will be
processed by the Donor Operator, Recipient Operator and
MNPSPs,
(ii) what changes are required in Number Portability Gateway
(NPG) of the operator and operator’s IT systems etc.; and 5
(iii) how much time will be required to complete the
modifications in the existing systems of the operators.
These challenges are discussed in the succeeding paras.
2.4 In the present framework on receipt of porting request, the
Recipient Operator forwards the same to the MNPSP of its MNP
zone. However, in full MNP scenario, the recipient operator will have
the following options which were described in the pre-consultation
paper dated 20th February, 2013.
Approach-1 : Recipient Operator forwards the porting request
to the MNPSP of its zone.
Approach-2 : Recipient Operator forwards the porting request
to the MNPSP of the other zone to which the Donor Operator
belongs.
Approach-3 : Recipient Operator forwards the porting request
to the MNPSP of the zone to which original number range holder
(the TSP to which the number originally belonged before its first
porting) belongs.
2.5 Stakeholders’ comments were sought on the most suitable approach
for implementation of Full MNP. The stakeholders were divided in
their opinion. While the TSPs supported Approach-1, the MNPSPs
supported Approach-3. None of the stakeholders supported
Approach-2. As there were differences in opinion between TSPs and
MNPSPs, meetings were held with the industry representatives viz.
COAI, AUSPI and MNPSPs. During the discussions, it emerged that
another approach, hereinafter called ‘modified Approach-1’, which
is a combination of Approach-1 and Approach-3, should also be
considered. These three possible approaches are discussed below:6
A. Approach 1: Recipient Operator forwards the porting request
to the MNPSP of its zone
2.6 In this approach, the Recipient Operator submits the porting
request to the MNPSP of its MNP zone. For example, if a subscriber
of Karnataka LSA wants to port his number from Karnataka to
Delhi LSA, he will submit his porting request to the Recipient
Operator of Delhi LSA, who in turn will forward the porting request
to MNPSP of MNP Zone-1. (which serves Delhi LSA) for porting.
2.7 On receipt of the porting request, the MNPSP of MNP Zone-1 will
verify the porting history of the mobile number by querying with the
MNPSP of MNP Zone-II(which serves Karnataka LSA). The query is
primarily to check whether the porting request meets the following
conditions:
(a) Completion of 90 days in its current operator’s network;
(b) No simultaneous porting is under process for the said
mobile number, in the other MNP zone.
If the porting request meets the above two conditions, the MNPSP of
MNP Zone-I will seek clearance from the Donor Operator of Karnataka
LSA. Further processing of porting request will take place as per the
existing porting process.
2.8 From the TSP’s perspective, this approach requires minimal
changes in the TSP’s Number Portability Gateway (NPG) as the
Recipient Operator continues to forward the porting requests from
the subscribers desirous of porting out their numbers to the MNPSP
of its zone. However, this approach has the following implications:
i. It will add complexity to the MNPSPs’ system as it requires
connectivity between the two MNPSPs.
ii. It will require synchronization of the database of the two
MNPSPs for ported numbers, porting history, database tables
etc. During discussions, MNPSPs stated that since they used
proprietary software, synchronization between the two MNP
systems has never been done earlier and would require 7
extensive development efforts and such a design will be
susceptible to errors in a live scenario.
iii. The MNPSPs also stated that new software development work
would be required for:
(a) developing mutually agreed interface specification by both
MNPSPs for requesting and obtaining the required data;
(b) modification to the current process, including new
messages, timers, error codes and reports;
(c) changes in the database design to maintain the data
received from other MNPSP;
iv. Real time port-in-progress validation and sharing of broadcast
information between the MNPSPs will increases dependency
between the two MNP Clearing House (MCH) systems. This will
increase system complexity, storage needs and will affect the
system performance (in terms of time and processing).
v. Testing in the above approach would be time and resource
consuming and also very costly.
B. Modified Approach 1: Recipient Operator forwards the porting
request to the MNPSP of its zone and the Donor Operator is
responsible to check the condition of 90 days and simultaneous
port requests
2.9 In the modified version of Approach-1, the need for connectivity
between the two MNPSPs has been eliminated. In this approach, the
Donor Operator will be responsible for verifying whether the
subscriber fulfils the eligibility condition of 90 days in the existing
network and also if the subscriber has made any simultaneous
porting request for the same mobile number. As such the
responsibility to check the above mentioned two conditions by
querying with the MNPSP of the other zone (Approach 1) will move
to the Donor Operator. The Donor Operator will be required to build
this check in their Number Portability Gateway (NPG). This will
require software changes in all the TSP’s NPG. However, the
advantage of this method is that there will be comparatively fewer8
changes requirement in the MNPSP’s systems due to the elimination
of connectivity between the two MCHs.
C. Approach 3: Recipient Operator forwards the porting request to
the MNPSP of the zone to which number range holder of the
number belongs.
2.10 In this approach, the Recipient Operator submits the porting
request to the MNPSP in whose zone the Number Range network
belongs. As all TSPs already have connectivity with both the
MNPSPs they will not have to make any changes in communicating
with the MNPSP of the other zone. This approach also does not
require interaction between the two MNPSPs. Therefore, this
method eliminates the need for connectivity /synchronization
between the two MNPSPs. However, in this approach, intelligence
needs to be built-into the operator’s NPG so as to forward the
porting request to the concerned MNPSP based on the identity of
the number range holder network.
2.11 In this approach the control on porting the mobile number will
continue to be with one of the MCHs. Even after a subscriber moves
to other MNP zone, all his subsequent porting requests (whether for
intra-Circle porting or Inter-Circle porting) will continue to be
processed by the MNPSP where his number originally belong. For
example, if a subscriber port his number from Delhi (which is in
MNP Zone-I) to Bengaluru (which is in MNP Zone-II), he will
approach the Recipient Operator of Karnataka LSA for processing
his porting request. The Recipient Operator will process the porting
request through MNPSP of Zone-I. Subsequently, if the subscriber
ports his number within the Karnataka LSA then also, the Recipient
Operator to whom the subscriber approaches in Karnataka LSA will
process the porting request through MNPSP of Zone-I only.9
2.12 All three approaches described above have their pros and cons.
Therefore, before deciding the approach to be implemented for full
MNP, the Authority decided to form a Focus Group consisting of
representatives from MNPSPs and TSPs to give their views on :
a. the preferred approach for implementation of full MNP;
b. changes required in the existing MNP system;
c. cost and time involved in various methods;
d. any other optimal feasible solution for implementation of
full MNP.
2.13 The deliberations of the Focus Group was coordinated and
facilitated by TRAI. After deliberating on all the possible
approaches, the Focus Group has unanimously recommended
Approach-3 for implementation of Full MNP in the country. (Report
at Annexure-II)
2.14 According to the Focus Group, cost requirement in Approach-3 will
be the least for both the MNPSPs. For TSPs, there will not be a
significant difference in the cost to be incurred in any of the three
approaches.
2.15 The Focus Group was also of the view that, irrespective of the
method adopted, TSPs will be required to upgrade their existing
backend systems such as CRM, mediation platforms, provisioning
systems / activation systems, billing systems, number
managements systems, recharging platforms, VAS management
systems etc, to support complete numbering plan and enable interLSA porting. Similarly, MNPSPs will also need to upgrade their MCH
to support complete numbering plan and enable inter-LSA porting
apart from enhancing billing system, Graphical User Interface (GUI)
etc.
2.16 The pros and cons deliberated by the Focus Group have been
examined by the Authority. The Authority agrees with the Focus
Group’s observation that the variation in the costs to be incurred in the three approaches will not be significant for the TSPs, whereas a
significant expenditure will be required for MNPSPs if Approach-1 is
adopted for implementation of full MNP. Further, the
implementation time for Approach-3 will be much less as compared
to Approach-1 or modified Approach-1. In addition,
2.17 Therefore, in the opinion of the Authority, Approach-3 will be the
most suitable approach for implementation of full MNP. Though the
Focus Group has not clearly mentioned the time frame for
implementation of the solution, the Authority is of the opinion that
6 months will be sufficient for operators to carry out the required
changes in their existing systems, complete inter-operator testing
and implement the solution.
2.18 Accordingly, the Authority recommends that Approach-3, as
described in para 2.10, should be adopted for implementation
of Full Mobile Number Portability. The TSPs may be given 6
months time to implement full MNP in the country.
Changes required in the MNP licence conditions:
2.19 For implementation of full Mobile Number Portability, following
licence conditions of MNP licence will require
modification/amendment:
(a). Scope of Licence:
In the scope of MNP license, the following condition will require
modification:
“12.5 The MCH and NPDB established by the licensee shall be
used by all telecommunication service providers (both existing &
new) (i.e. Basic, CMTS, UAS, NLD and ILD Licensee(s)) of the
licensed MNP zone for the purpose of supporting porting of mobile
numbers between mobile operators.”11
If full MNP is implemented with Approach-3, TSPs will have to
use the services of both the MNPSPs for processing the porting
request. Therefore, the restriction ‘the licensed MNP zone” in
clause 12.5 needs to be removed.
(b). Delivery of service:
The ‘Delivery of Service’ condition in clause 18.1 of the MNPSP
licence would require amendment -
“18.1 MNP is to be implemented in each intra Licensed Service
Area (LSA)……….”
In order to provide inter service area MNP service, the word
‘each intra’ may be modified to read as ‘inter and intra’
(c). Changes required in the DoT instructions dated 06th May
2009
DoT instructions dated 6th May 2009 regarding provisioning of
MNP will also require modification. Para 3(i) of the said
instructions is given below:
“ ….MNP is to be implemented in each intra license Service Area
(LSA) as per the schedule notified by the Licensor from time to
time…….”
The word ‘each intra’ in the para may be modified to read as
‘inter and intra’.
2.20 In view of the above, the Authority recommends that the DoT
should carry out the necessary changes as mentioned in the
above paras in the:
(i) existing MNP license; and
(ii) instructions of the DoT dated 6th May 2009, for
implementation of Full MNP.12
Upon acceptance of these recommendations, the Authority will carry
out necessary changes in the MNP regulations
Identification of inter-service area (STD) calls after implementation
of Full MNP
2.21 Presently, a calling subscriber can store the mobile number of the
called subscriber in one of the following possible ways in the
contact list of his mobile phone handset:
(a) Storing directly the mobile number of the called subscriber ;
(b) Storing the mobile number with prefix ’0’ ;
(c) Storing the mobile number with prefix ‘+91’ ,
2.22 In the Full MNP scenario, if a called number happens to be a ported
number that has been ported to a different LSA, a subscriber calling
that mobile number in the case of (a) above, will not be successful
as the called number has been ported out of the LSA and the caller
has to prefix ‘0’ to this called number – being an inter-service area
call. Therefore, by default, the calling subscriber will get ‘number
does not exist’ announcement. In the case of (b) and (c) above,
when a subscriber makes a call, though the call will be successful,
it will attract applicable STD charges instead of local charges (before
porting). There is a possibility that the calling subscriber may not
be aware that the number has been ported out to another LSA.
This may result in a subscriber complaining of higher charges.
2.23 This issue was raised in the pre-consultation paper and inputs
were sought from stakeholders on the need to inform the calling
subscriber through announcement prior to connecting the call. In
response, some TSPs suggested that identification of inter-service
area ported numbers and playing an announcement thereof, will
burden their network resources and will increase call set up time.
It was suggested that the subscribers may be made aware
of/educated to dial numbers in the +91 format which is the
standard dialing format, after Full MNP is implemented.
2.24 On the issue of higher call charges and possible subscriber
complaints, most TSPs were of the view that STD rates have
plummeted to almost the same level as local call rates; hence, it is
not a major issue. Further, in most cases, the calling party may
already be aware that the called party has moved to another LSA.
Therefore, the onus should lie on the calling party to bear the STD
charges, if applicable. One of the suggestions was to have a website
so that a query for a given telephone number can be given which
will provide information about the current serving operator/LSA for
the called number. This facility can be developed by the MNPSPs.
The Authority agrees with the above comments of the TSP and is of
the opinion that no action is required on this issue
UPC generation in J & K LSA in Full MNP Scenario:
2.25 As per the existing MNP process, a subscriber is required to
generate a UPC before submitting a porting request to the Recipient
Operator. In the Full MNP scenario, the location of the Recipient
Operator being in a different LSA, the Donor Operator will have to
ensure generation of UPC for subscribers under roaming. During
the pre-consultation, TSPs informed that UPC can be
requested/generated from any LSA (except in Jammu & Kashmir
LSA where roaming of pre-paid subscribers is not permitted).
2.26 In the J&K LSA, post-paid subscribers can generate a UPC as in
any other part of the country. However, pre-paid subscribers of
J&K can generate a UPC only by making a call to ‘1900’ instead of
sending an SMS. Therefore, in a full MNP scenario, the issue of
generation of a UPC while in another LSA may arise for pre-paid
subscribers of J&K as such subscribers are not permitted roaming.
2.27 The solution to this problem is that the subscriber of J&K LSA who
wants to port his number to any other LSA can generate the UPC in
J&K LSA and then apply for porting to any desired LSA.
Alternatively, he can convert his subscription from pre-paid to 14
post-paid which will enable him to generate a UPC under roaming,
and then request porting in any LSA.
Testing Fees for Acceptance Testing
2.28 During the consultation process, the TSPs and MNPSPs have stated
that apart from network implementation costs, significant testing
costs would be incurred by them.
2.29 The TSPs have requested to waive the testing fee by the DoT for
acceptance tests to be conducted for implementation of Full MNP.
2.30 On 24th November 2011, the DoT specified the Acceptance Testing
fee to be charged for various types of networks as follows:-
S.
No.
Fee to be charged from
TSP/ ILDOs/ MNPOs
Unit Price (per network/ per LSA.
Per gate way, per site)
1 UASL /CMTS Service
Provider
Rs. 307228 (per network per LSA)
2 Basic/ WLL Service
Provider
Rs.189360 (per network per LSA)
3 International Long Distance
Operator (ILDO)
Rs.189360 (per Gateway)
4 MNPO Rs.279800 per site (Production/
Disaster)
Rs.60360 per network per LSA
(GSM/ CDMA)
2.31 Before the launch of MNP, DoT had already conducted acceptance
test through respective TERM cells of DoT for which testing fee had
already been charged as per the above said circular. Now, Full MNP
is being mandated pursuant to NTP-2012 and testing is to be
carried out for various scenarios due to a change in the process.
Therefore, the Authority recommends that the DOT may
consider the request of the operators and reduce the
Acceptance Testing Fee to 25% of the Current Fee.15
Chapter III: Summary of recommendations
3.1 The Authority recommends that Approach-3, described in the
relevant para (2.10), should be adopted for implementation of
Full Mobile Number Portability. The TSPs may be given 6
months time to implement full MNP in the country. ( ¶2.18)
3.2 The DoT may carry out the necessary changes in the:
(i) existing MNP license; and
(ii)instructions of the DoT dated 6th May 2009, for
implementation of Full MNP. (¶2.20)
3.3 The DoT may consider the request of the operators and reduce
Acceptance Testing Fee to 25% of the Current Fee. (¶2.31)
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