Chapter 5: Issues for consultation Q1. Is there a need to mandate IP interconnection? If so, what should be the time frame for implementation of the same? Please comment with justifications. Cisco: The Internet Protocol (IP) has steadily gained widespread global acceptance as the preferred protocol not just for data traffic, of which the tremendous growth of the Internet traffic is in itself a primary example, but also for carrier voice transport. The share of international carrier traffic routed as VoIP has grown from 11% in 2002 to 36% in 2013 [1], and global service providers are steadily migrating their network infrastructure to IP. While the significance of circuit switching (TDM) is reducing globally, many established service providers still rely on their legacy TDM networks. Given the trends in the growth of internet data traffic, the IP-fication of the mobile radio access network (4G-LTE mobile technology is fundamentally based on an IP-core), and the growth of data centers and cloud computing, application & services have propelled service providers to adopt and migrate to IP networks. In India, most Service providers have to a large extent curtailed investing on the TDM-based network infrastructure and network expansions are being predominantly planned with NGN Voice over IP network. However, as it appears today, it is only due to requirements of regulatory compliance, that IP is being converted into TDM in the Media gateway at the POI. Hence, given the global trends, emergence and acceptance of IP as the preferred protocol for data and voice traffic, this is the right time to consider and permit IP interconnection in communication networks. Also, given the rapid adoption and growth of IP-based traffic, the time line for IP interconnection enablement should be ‘as soon as possible’. [1] Reference: Telegeography Report (2013) (Enclosed) Q2. Whether both TDM and IP interconnection should be allowed to coexist? If so, whether the existing regulation i.e. ‘Reference Interconnection Offer dated 12th July 2002’ addresses the requirements of IP interconnection also? Please comment with justifications. Cisco: Most service providers today are investing and expanding their IP NGN infrastructure, given that capital outlay required to transition to new generation IP networks and converged services is significantly lower compared to TDM-based infrastructure, and this is complemented and accentuated by the service provider’s requirement to support convergence and burgeoning data and voice traffic growth, including those originating from OTT players. It is also becoming imperative for mobility services providers to evolve their RAN infrastructure to IP, and evolve the end-to-end network architecture to natively support IP-based 4G services. However, service providers have already made significant investments on TDM-based network infrastructure in the past, and these investments also need to be protected while transitioning from TDM to all-IP that will require both financial investment and time To begin with, the increase capacity and also the new POIs shall use IP Interconnection. We expect on a long term, the traffic over IP interconnect will increase and TDM will reduce to very small. Hence, we recommend for coexistence of both TDM and IP interconnections. Q3. In case IP interconnection is mandated in India, whether the enforcement of interconnection agreements should rely on (i) Bilateral agreements and dispute resolution; or (ii) Mandatory reference offer Cisco: No comment. Q4. In an IP based network scenario, which mode of interconnection is preferable to carry traffic:- peer-to- peer, Interconnect Exchange or combination of both? Please comment with justifications. Cisco: Technically both models are feasible and have their own advantages. Telecom service providers (Operators) should be permitted to access direct interconnect (peer-to-peer) traffic, as well as at the Interconnect Exchange. The interconnect exchange could simplify and reduce overall cost for Telecom service providers for POI interconnect. The Interconnect exchange needs to be designed with carrier grade reliability and availability. ISOC (The Internet Society) has published a detailed document [2] “The Internet Exchange Point Toolkit and Best Practices Guide” which discusses several technical and economic issues related to maximizing the effectiveness of network interconnection. It is suggested that this document may be considered and reviewed in part to the answer to this question. It is also suggested that technical documents from the International Interconnection Forum for Services over IP (i3 Forum) that is supported by global service providers, may also be considered and reviewed in part to the answer to this question [3]. Potentially, multiple interconnect exchange could be planned across India for redundancy and also for supporting higher voice service quality by reducing network latency and jitter. [2] Reference: ISOC document “The Internet Exchange Point Toolkit and Best Practices Guide” Published February 2014. (Enclosed) [3] Reference: www.i3forum.org Q5. In case an Interconnect Exchange is required, should such Exchange be placed within each licensed service area or a single Interconnect Exchange will be adequate for the entire country? Please comment with justifications. Cisco: Interconnect Exchange(s) should be planned at every licensed Service area. Having peering at multiple interconnect exchange could increase reliability, help reduce latency, control jitter, and increase quality of service. The interconnect at every interconnect exchange should be made optional if an operator is able to manage same service levels with peering at few interconnect exchange and also by having direct peering (Peer to peer). References [2] and [3] suggested in response to Q4 may also be relevant to be considered and reviewed in part to answer to this question. Q6. Whether any regulatory intervention is required to mandate the locations and structure of points of interconnection (POI) for IP based network architecture? Please comment with justifications. Cisco: Regulatory could provide some guidelines in proportion to the traffic being handled by the POI. Link Speed, QOS, Redundancy / High availability etc. This will help the service providers to better plan for POIs. Q.7 what are your views on the migration from the existing interconnection regime-measured in terms of minutes of traffic to an IP interconnection regime replaced by measures of communication capacity? Please comment with justifications. Cisco: Between Service providers, Current measurement methods (Minutes) based shall continue with IP interconnect as well. Q.8 In an IP interconnection between networks, comment on the type of charging principles that should be in place- (a) Capacity based in terms of Mbps. (b) Volume based in terms of Mbps. (c) QoS based. (d) A combination of the above three. Cisco: Interconnect exchange could follow combination of Capacity, Volume and QoS for charging. However, between service providers, the charges shall be based on Voice minutes. Q9. What should be the criteria to estimate the traffic minutes in IP environment if interconnection charges continue to be minute based? Please provide justification in support of your answer. Cisco: This depends on the Voice Codec, Sample interval, MOS for every call. Giving below a links for estimating the IP/Ethernet bandwidth per voice calls for different Voice Codec. http://www.cisco.com/c/en/us/support/docs/voice/voice-quality/7934-bwidth-consume.html Q10. In addition to the above, any other modifications or components of IUC which are required to be reviewed in the IP based network scenario? Please provide all relevant details? Cisco: Carrier grade redundancy, Bandwidth/Links Scaling, High availability features to be considered. Also, the Network management system shall be planned for monitoring the KPI. Q11. Do you envisage any interconnection requirement for application & content service providers? If so, what should be the charging mechanism? Please provide all relevant details justifying your comments. Cisco: Yes, the same interconnect infrastructure could also be used to connect telecom service providers with Application & Content providers. They could reach to their customer through same infrastructure. However, there must be interconnecting agreement for application and Content service providers to avoid any dispute. Reference [2] ISOC paper gives some useful pointers in this direction, and hence may be considered and reviewed in part to the answer of this question. Q12. Whether the existing regulatory framework for measuring and reporting quality of service parameters as defined for PSTN/PLMN/Internet may continue to apply for IP based network services? Please comment with justifications. Cisco: Guidelines on Quality of service is very critical. Each operator may have different marking to classify the voice as priority traffic on their network. At POI level, honoring other operator marking and remarking is essential to prioritize the voice traffic. Documentation from Reference [3] is relevant here in part to the answer of this question. Q13. In the context of IP based network Migration, if the parameters in the existing QoS regulation are required to be reviewed immediately then please provide specific inputs as to what changes, if any, are required in the existing QoS regulations issued by the Authority. Please comment with justification. Q14. In case new QoS framework is desirable for IP based network, do you believe