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Trial Run: TRAI paper seeks to bring clarity in service testing before commercial launch

May 30, 2017
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By Akanksha Mahajan Marwah

The telecom landscape has evolved significantly in the past few years. The introduction of new technologies, mass adoption of data services and changing sector dynamics call for a relook at the existing set of policies and regulations, and their current relevance. One such area that needs immediate attention is the testing of mobile services before their commercial launch and the role of regulations in this regard.

The issue came into the spotlight in 2016, when an operator carried out testing of its long term evolution network on a massive scale, enrolling millions of subscribers as test users before the services were commercially launched. The move was opposed by the incumbent operators as they believed that it was resulting in a non-level playing field. Besides, the high voice traffic volume generated by the test users (owing to the free offers) choked the points of interconnection of other operators, thus affecting their quality of service (QoS).

Against this background, the Department of Telecommunications has asked the Telecom Regulatory Authority of India (TRAI) to review the various aspects related to the testing of mobile services by telecom operators before commercial launch. Accordingly, TRAI has released a consultation paper, “Network Testing before Commercial Launch of Services” to discuss the issues involved, the possible solutions and a framework to bring clarity on the matter.

Issues for consultation

Registering subscribers as test users

In the past, only a limited number of test cards were issued for a specific period to select employees and/or business partners. However, with new technology standards being introduced in the sector, it becomes important to consider whether subscribers too should be registered for testing, to check the networks for sufficient loading. The question is, should an operator who is deploying a new technology for mobile services, which requires extensive network testing before commercial launch, be allowed to enroll subscribers other than its employees and business partners as test users? Further, suggestions have been invited regarding whether or not there should be a limit on the number of test users and the period of testing.

Demarcation of test phase from commercial launch

Recently, the issue regarding whether an operator can provide all services free of cost to test users/subscribers before their commercial launch came to the forefront. Several industry stakeholders are of the opinion that providing full-fledged services during the test phase may have implications on interconnection usage charges, pricing, QoS and other regulatory aspects, which, in turn, may result in unhealthy competition in the sector. Therefore, a broader framework should be put in place to protect the interests of subscribers, while ensuring a level playing field for operators. At the same time, it becomes important to make sure that such testing systems do not allow operators to circumvent regulatory requirements. To this end, TRAI has in its consultation paper suggested some options and sought the industry’s perspective on them. The options include restricting the testing within the operator’s own network; putting a limit on the time period for which services are being offered; providing a temporary number series to the operator for testing, which is withdrawn upon commercial launch; limiting the number of test users; and allowing intensive radio access network testing only in a small geography.

Time limit for commercial service launch

The existing licence terms and conditions do not prescribe any time period for the test phase post which an operator has to start commercial services. This means that on acquiring spectrum, it is the operator’s call as to when it wants to launch services commercially. Compliance with the roll-out obligation is linked to coverage testing alone.

In the past, there have been instances when operators technically complied with the roll-out obligations, but chose to either not start commercial services or installed negligible number of base transceiver stations. In such a scenario, even though the roll-out obligations are met, the objective of effective spectrum utilisation gets defeated. TRAI has invited comments on whether there is a need to define a timeline for testing beyond which an operator is required to start offering commercial services.

Meeting licence requirements during the test phase

There are certain licence requirements that are linked with the commencement of services. In case the government allows subscribers to be enrolled as test users, the question is whether the operator should be bound to follow regulatory requirements such as reporting. Another issue is whether the mobile number portability facility should be made available to test users.


Bringing clarity on mobile service testing will help the licensor to establish a refined testing framework. This is relevant in today’s environment to encourage a level playing field amongst operators and ensure that quality services are launched in a timely and appropriate manner.

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