Telecom Regulatory Authority

Telecom R ndia
of India

Recommendations
on
Regulatory framework for Internet Telephony

New Delhi

24th October 2017

Telecom Regulatory Authority of India

Mahanagar Door Sanchar Bhawan
Jawahar Lal Nehru Marg
New Delhi – 110002
 CONTENTS

Chapter Description Page No.

Chapter I Introduction 1
Chapter II Technical Aspects of Internet 7
Telephony
Chapter III Analysis of Issues and 19
Recommendations
Chapter IV Global Regulatory Practices in 44
Internet Telephony
Chapter V Summary of Recommendations 54
List of Acronyms 57
Annexure 59

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 CHAPTER-I

INTRODUCTION
1.1 Telephony networks have in the course of time undergone major
evolutionary changes, driven essentially by technological progress in
various fields (switching, transmission, access and maintenance). The
end purpose of a telephone network was always associated with the
provision of a universal communication service with a certain quality.
This has several implications for the technologies used and the mode of
interconnection between sub-networks.

1.2 Every telephone operator throughout the world operates a sub-network

of the global telephone network. In order to provide a universal
communication service to all of their respective subscribers, they have
an obligation to interconnect their networks and to agree on a single and
coherent system for designating their subscribers. The quality-of-service
requirement implies that adequate resources (circuit capacities,
transmission speeds, and management arrangements) must be
mobilized throughout the duration of a call in each of the sub-networks
involved in the call between the two communicating parties. This has a
bearing not only on the technology used to carry voice, but also, and
more fundamentally, in the design of the logic incorporated in the
network's active components (switches) and the language (signalling)
they use to ensure proper routing of a call between two or more
subscribers

1.3 The Public Switched Telephone Network (PSTN) has been supported
worldwide as the primary means of voice communication. The legacy
PSTN is a connection-oriented, circuit-switched network in which a
dedicated channel (or circuit) is established for the duration of a call.
Originally transmitting only analog signals, the PSTN has switched to

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 digital communication, which offered solutions to the attenuation, noise
and interference problems inherent in the analog system. The modern
PSTN uses Pulse Code Modulation (PCM) to convert all analog signals
into digital transmissions at the originating network and reverses the
processes in the receiving network.

1.4 In circuit switched networks, calls are routed through a hierarchy of

several layers of exchanges. A circuit-switched network creates a
dedicated path between two nodes in the network to establish a
connection. The established connection is thus dedicated for the period
of communication between the two nodes . It is based on the principle
that a resource (circuit) must be reserved for a call from the time of its
setting-up to its conclusion. The size of this resource – expressed as a
bit rate since the digitization of telephone networks – is 64 kbit/s. This
limit was chosen because it made for the efficient digitization of human
voice samples, the spectrum of which lies between 300 and 3400 Hz.
More recent voice coding techniques allow for a considerable reduction
in the 64 kbit/s defined for a circuit; however, since this is the rate that
is used in most of the active and transmission components throughout
the global telephony network, it would be difficult to change it without
incurring excessive costs and without jeopardizing one of the main
qualities of that network: the universal service. As a case in point, one
can mention that although modern wireless GSM networks use an
encoding that consumes as low as 8 kilobit/s on the radio part, this is
transformed to a 64 kbit/s encoding when voice reaches the mobile
switches.

1.5 Although highly rated for reliability and Quality of Service (QoS), Circuit
Switched Networks have two significant disadvantages:

(a) Expensive bandwidth, which results in high cost for the telecom
service providers as well the users of telecom services.

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 (b) Inefficient use of networking channels, which results from
dedicating an entire channel for each conversation.

1.6 Packet Switched Networks offer solutions to such problems and are
increasingly being used as alternative to the traditional circuit switched
telephone service. Major Telecom Service Providers (TSPs) in India have
implemented Internet Protocol (IP) based core transport network for
carrying voice and data traffic, by deploying IP/Ethernet elements
extending into access and aggregation networks. The high costs of
maintaining legacy networks alongside the requirement to upgrade to
intelligent networks with inherent monitoring and adaptive capabilities
are the key reason for the growing adoption of IP based Network. The
present world scenario indicates that IP has become a ubiquitous means
of communication, and the total volume of packet-based network traffic
has surpassed traditional circuit switched network traffic.

1.7 The use of IP-based networks continues to grow around the world due to
the multitude of applications it supports and particularly due to Voice
over Internet Protocol (VoIP). IP-based networks are capable of providing
real-time services such as voice and video telephony as well as non real-
time services such as email and are driven by faster Internet
connections, widespread take-up in broadband and the emergence of
new technologies.

1.8 VoIP enables users to make real time voice calls, transmitted over
packet switched network using the Internet Protocol. VoIP enables
network operators, service providers, and consumers to make significant
savings, by reducing the underlying costs of a telephone call. VoIP uses
network resources much more efficiently than conventional telephone
service, reducing the cost of providing a call (albeit with the loss of some
call quality and service features), and, creating opportunities for
regulatory arbitrage that enable TSPs and consumers to reduce or avoid

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 call charges. The volume of VoIP traffic is growing rapidly and the
potential exists for packet switched, Internet Protocol networks to
become the primary medium for most voice and data services.

1.9 The terms ‘IP Telephony’, ‘VoIP’, ‘Internet Telephony’ and other variants
often generate confusion as there are many different definitions used by
various organizations. Some use them interchangeably while others give
them distinct definitions. Further confusion is caused by using the
terms to refer to both the IP-based technologies and the services that are
enabled by these technologies.

1.10 Internet Telephony can be deemed to be a subset of Voice over IP, in the
sense that, when voice is carried over an IP network it can be termed as
Voice over IP. And if the IP network in this case is the public Internet
then it can be called Internet Telephony. The primary difference between
voice services on managed and unmanaged IP Networks is in quality of
speech. However, this difference is getting narrower with technological
advancement, new coding techniques and availability of higher
bandwidth broadband connections.

1.11 The existing licensing framework in India has been effective and has
contributed to growth of telecom sector. However, fast technological
development, convergence of networks, services and end-devices is
blurring the boundaries of scope of services among different licences.
Rapid changes are taking place worldwide with respect to business
models, service delivery platforms and regulatory frameworks to meet
the challenges posed by the convergence.

1.12 The present licensing framework permits Basic Service Licensee, Unified
Access Service Licensee (UASL), Cellular Mobile Telecom Service (CMTS)
licensees and Unified Licensee (access service) to provide unrestricted
Internet Telephony. These licences further permit that while providing

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 Internet Telephony Service, the licensee may interconnect Internet
Telephony network with PSTN/PLMN/GMPCS network. Despite the fact
that these licences allow to provide unrestricted Internet Telephony
since 10 years, the Internet Telephony service has not taken off in the
country. Perhaps understandably, as the existing operators do not wish
to cannibalize their higher-margin services offerings.

1.13 With a view to bring out all the aspects of the relevant issues and to
provide a suitable platform for discussion, TRAI issued a consultation
paper on “Internet Telephony (VoIP)” on 22nd June 2016. The objective
of the consultation paper (CP) was to identify issues in providing
Internet Telephony Services and address them in a holistic manner.
Some important issues like allocation of numbering resources for
Internet Telephony, Interconnection, Interconnection Usage charges,
Quality of Service and access to Emergency services were raised in the
consultation paper.

1.14 Written comments on the consultation paper were invited from the
stakeholders by 21st July 2016 and counter comments by 4th August
2016. On the request of some of the stakeholders, the dates were
extended to 5th September 2016 for comments and 13th September 2016
for counter comments. This consultation elicited many responses.
Comments were received from 34 stakeholders and counter comments
were received from 6 stakeholders. Subsequently, a letter dated
26.12.2016 was received from DoT with a request to expeditiously
submit the recommendations on Internet Telephony. An Open House
discussion was also conducted on 12th January 2017 at New Delhi.
Based on the written submissions of the stakeholders and the
discussions in the open house the issues have been examined in depth
and the recommendations have been framed.

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1.15 This chapter provides a background to the subject. The technical
aspects of Internet Telephony are covered in the second chapter. A
detailed analysis of the issues raised in the consultation paper along
with the responses given by the stakeholders is contained in the third
chapter. Some peripheral issues raised by the stakeholders are also
discussed in the same chapter. The responses were widely divergent and
the Authority has taken a holistic view of the different facets of Internet
Telephony service to arrive at the recommendations. The fourth chapter
describes some of the global practices in Internet Telephony. The fifth
chapter gives the summary of the recommendations.

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 CHAPTER II

TECHNICAL ASPECTS OF INTERNET TELEPHONY

A. Definition and Meaning

2.1 International Telecommunication Union-Telecommunication

Standardization Sector (ITU-T) Study Group 2 (SG2) issued the following
explanation of the term "IP Telephony":

"IP is an abbreviation for Internet Protocol. It is a communications protocol

developed to support a packet-switched network. The protocol has been
developed by the Internet Engineering Task Force (IETF). IP telephony is
the exchange of information primarily in the form of speech that utilizes a
mechanism known as Internet Protocol."

2.2 The many different ‘flavours’ of IP Telephony provide, to varying degrees,

alternative means of originating, transmitting, and terminating voice
which would otherwise be carried by the public switched telephone
network (PSTN). While the emergence of IP Telephony is often associated
with the rise of the Internet itself, it is important to appreciate that IP
Telephony often does not involve the public Internet at all – but rather
only its underlying technology, the Internet Protocol suite.

2.3 Globally, there are primarily two methods for voice transmission over IP
networks; based on type of IP network used. When voice is transmitted
over public Internet, it is termed as Internet Telephony. Similarly when
voice is transmitted over managed IP networks, it is termed as Voice over
IP (VoIP).

2.4 Traditional telephony uses circuit-switching technology while VoIP uses

packet switching. In circuit-switched networks, network resources are
dedicated to the circuit during the entire conversation, and the entire
information follows the same dedicated path. In packet switched
networks, the message (voice data) is broken into packets, each of which

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 can take a different route to the destination, where the packets are
recompiled into the original message. As such, packet switching is
supposed to be a much more efficient and cost effective way of sending
voice messages and data.

B. Evolution of Internet Telephony

2.5 The history of Internet Telephony began with conversations by a few

computer users over the Internet. Initially, Internet Telephony required a
headset to be plugged into the computer, and the participants could only
speak with others who had a similar set up. They had to phone each
other ahead or send a text message, in order to alert the user at the
other end of the incoming call and the exact time.

2.6 As early as November’ 77, the Internet Engineering Task Force (IETF)
published the “Specifications for the Network Voice Protocol (NVP)”. This
was primarily aimed for supporting Advanced Research Projects Agency
(ARPA) Network’s Secure Communications project to demonstrate the
feasibility of secure, high-quality, low-bandwidth, real-time, full-duplex
(two-way) digital voice communication over packet-switched computer
communication networks. However, actual growth of Internet Telephony
started in mid-90’s with the extensive growth in the use of personal
computers. This was aptly supported by rise in deployment of IP
Networks.

2.7 IP Telephony is used as a generic term for many different ways of

transmitting voice, fax and related services over packet-switched IP-
based networks. Internet Telephony is a form of IP telephony, which uses
Internet Protocol (IP) for transmitting IP packets over Internet cloud. The
basic steps involved in originating an IP telephone call are conversion of
the analog voice signal to digital format (binary data) at subscriber
premise itself and compression/translation of the data into IP packets for
transmission over the Internet. The process is reversed at the receiving

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 end. The communication usually takes place in real time. Thus, the main
difference between IP Telephony and normal telephony is that while in
normal telephony, circuit-switching technology is used (particularly in
the access network), whereas IP Telephony is based on packet switching
technology. As per present service models three main deployment
scenarios for IP Telephony are possible:

 PC-to-PC Internet Telephony

 Phone-to-Phone over IP

 PC-to-Phone and Phone to PC Internet Telephony

The details have been discussed below.

2.8 PC-to-PC Internet Telephony: In this scenario, the calling and called
parties both have computers or similar devices that enable them to
connect to the Public Internet (refer Figure1). Both end-users are able to
establish communication (Data or voice communication) only by prior
time fixation, as they have to be connected to the Internet at the same
time and use compatible software. Presently, large numbers of VoIP
applications are available on Internet to make PC-to-PC Internet
Telephony possible. The Internet Service Provider (ISP)'s role in such
scenario is limited to providing access to the Internet. The ISP network is
transparent to such application used by the subscribers. The voice
application used by the customer is transparent for the ISP, which takes
no specific measures to guarantee the quality of the voice service but
merely of the use of a voice application via the Internet. Today, PC
equivalent devices like tablets or smartphones are available, which can
also run such software supporting Internet Telephony. This type of
Internet Telephony is permitted under existing ISP licence. It is also
considered to be an ‘Over the Top’ (OTT) application service.

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 Figure 1: PC to PC Internet Telephony

2.9 Phone to Phone over IP: In this case, the calling and called parties are
both subscribers to the public telephone network (fixed or mobile) and
use their telephone set for voice communication in the normal way.
There are two methods for communicating by means of two ordinary
telephone sets via an IP based network. One or more telecommunication
players have established gateways that enable the transmission of voice
over an IP based network in a way that is transparent to telephone users.
What we have in this case is not the Internet but a "managed" IP
network, i.e. a network which has been dimensioned in such a way so as
to enable voice to be carried with an acceptable quality of service. Such
types of calls are not Internet Telephony calls. Figure 2 below illustrates
such a scenario.

Figure 2: Phone to Phone over IP

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 In this scenario, the gateways and managed IP network could belong to
different players, depending on whether we are looking at:

a) the purely internal use of VoIP within the network of a single

telephone operator, which owns and manages the entire operation,
handling both users A and B;

b) the provision of a long-distance voice service by a long-distance

operator using VoIP technology (users A and B in this case
belonging to different networks), in which case the whole operation
belongs to and is managed by such a long-distance operator.

The present regulatory framework allows for this type of telephony and is
normally termed as VoIP because the public Internet is not coming into
picture.

2.10 PC-to-Phone or Phone-to-PC Internet Telephony: In this scenario, one

of the users has a computer by which he connects to the Internet via an
access network and an ISP while the other user is a ‘normal’ subscriber
to a fixed or mobile telephone network(refer Figure 3).

PC-to-Phone

In this scenario User A has to use the services of an ISP to get

connected to the Internet via the network of his ISP. Once
connected, he uses the services of an Internet Telephony service
provider (ITSP) operating a gateway which ensures access to the
point that is closest to the telephone exchange of the called
subscriber. It is this gateway that will handle the calling party's
call and all of the signalling relating to the telephone call at the
called party end. User A runs software (Dialer) installed at his PC
(Equivalent device) to dial the number of the user B.

It should be noted that the ITSP provides a one-way PC-to-phone

service and does not manage subscribers as such; in fact, the PC
subscriber uses the ITSP's services solely for outgoing calls. It

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 should also be noted that the ITSP has a managed IP network,
thereby ensuring a certain quality of service for voice as far as the
gateway closest to the called subscriber, and that the ITSP also
manages the interconnection with the latter's telephone operator.
The provision of Internet access and provision of Internet
Telephony service may be done by the same service provider or by
different service providers, meaning thereby that the ISP and ITSP
may be same or different.

Phone-to-PC

In this case, the calling party is the telephony user and the called
party is the PC or equivalent device user. Since a telephony user
can essentially dial an E.164 number to reach the called party,
then somehow the PC user should have an E.164 number by an IP
telephony operator.

Figure 3: PC-to-Phone or Phone-to-PC Internet Telephony

In India ISPs are presently permitted to provide one-way PC-to-Phone

Internet Telephony service for International long distance outgoing calls
only on PSTN/PLMN to such countries where termination of Internet
Telephony calls are permitted. The ISPs are not permitted to have
PSTN/PLMN connectivity and are not allowed voice communication to

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 and from a telephone connected to PSTN/PLMN in India. The present
regulatory framework permits Unified Access Service Licensee(UASL),
Cellular Mobile Telecom Service (CMTS) licensees and Unified Licensee
(access service) to provide unrestricted Internet Telephony which means
both PC to Phone and Phone to PC calls within India as well as abroad.
However, as stated earlier, this service has not picked up because the
access service providers do not want to cannibalize their higher margin
voice services over PSTN/PLMN.

2.11 In addition to the type of scenarios discussed above, it is also possible to

provide a hybrid or a mix of Internet Telephony and PSTN/PLMN in
which the last mile access network can be conventional last mile
wireline/wireless access or/and Public Internet(refer Fig. 4 and Fig. 5).
The subscriber will be able to dial using his conventional fixed line
telephone or by using a software application (app) running on his PC or
Smartphone when he is connected to the Public Internet. Similarly a
mobile subscriber will also have an option to dial through the
conventional 2G/3G/4G access network of his mobile service provider or
by using a software application (app) on his smartphone or using native
voice over WiFi capability of his smartphone connected to Public Internet
by any Internet access network (by WiFi or Internet data services of any
mobile service provider). In this case the access to Public Internet may be
provided by any Internet Service provider including the one who is
providing the PSTN or PLMN service. The same E.164 number which has
been allocated for PSTN/PLMN service may be used while using the
Public Internet for originating or terminating the calls. The choice of the
last mile access network (PSTN/PLMN or Public Internet) may depend on
the network availability or may be chosen /pre-decided by the customer.
However, in this scenario Internet Telephony is an additional service over
and above the normal conventional PSTN/PLMN service using the same
E.164 number. This type of service can increase the call completion rate.

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 Figure 4: Hybrid/Mix of Fixed line and Internet Telephony

Figure 5: Hybrid/Mix of Mobile and Internet Telephony

C. Quality of Service
2.12 Quality of Service of an IP network used for telephony is the most
important issue. The packet mode of data transmission used by IP
networks may introduce degradation in speech quality due to following
factors:

 Packet Loss: Possible disappearance of packets during the

communication. Highly stable media like optical fiber reduces
packet loss to virtually zero.

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  Delay: This refers to transit time, including the time taken to
reassemble the packets upon arrival and compensate for
fluctuations in transit times (this overall transit time must be lower
than 400 ms.). Such delays are network dependent and are taken
care in network designing.

 Jitter: Variation in the packet arrival delay. Synchronization of

network is very important to reduce such jitter.

 Echo: This refers to the delay between the transmission of a signal

and receipt of the same signal as an echo. Effective echo
cancellation can be used in well-planned networks.

2.13 In the planning of the managed IP networks these quality of service

parameters are taken into consideration to ensure a good quality of real
time services. However these parameters may be difficult to manage over
Public Internet which may involve network of different ISPs for a real
time voice service like Internet Telephony.

D. E.164 Number to URI Mapping (ENUM)

2.14 Global practices adopted by different countries advocate use of E.164

Number to URI Mapping (ENUM) being defined by Internet Engineering Task
Force (IETF) in RFC3761. Internet Architecture Board (IAB), in concurrence
with ITU, has selected e164.arpa domain specifically for this purpose. Under
IAB supervision .arpa is considered to be a well-managed, stable and secure
operational environment. A Single domain structure under e164.arpa
becomes the authoritative “root” for E.164 telephone numbers. ENUM
makes extensive use of the Naming Authority Pointer Resource Records
(Defined in RFC 2915) in order to identify available ways and services for
contacting a specific node identified through E.164 number. In nutshell,
ENUM involves the following steps:

 ENUM turns a phone number into a fully qualified domain name

(FQDN). It does this by first adding the city, or area, and country

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 code. For example, 2925-4780 of Delhi, becomes +91-11-2925-4780,
where 11 is the area code, the 91 represents the country code for
India, and the + indicates that the number is a fully qualified E.164
number. Then ENUM removes all the characters except for the digits
and reverses the order (e.g.,+91-11-2925-4780 becomes
087452921119). Finally, it places dots between the digits and
appends the domain E164.ARPA at the end of the string (e.g.,
0.8.7.4.5.2.9.2.1.1.1.9.E164.ARPA).

 Use of ENUM issues a DNS query on the Fully Qualified Domain

Name (FQDN) created in the first step.

 DNS returns a list of Uniform Resource Identifiers (URIs) that

contains information about what resources, services, and
applications are associated with that specific phone number.

 ENUM protocol can store more than one type of contact information
in the DNS record that belongs to a specific ENUM number. An
ENUM record associated with an Organization www.xyz.in might
contain instructions for

a. VoIP call (e.g., h323: identity@server.xyz.in or sip:

identity@sip.xyz.in )

b. A FAX call (e.g., fax: identity@fax.xyz.in)

c. E-Mail communications (e.g., mailto:identity@xyz.in).

 Additional services can be developed in future and included in the

ENUM name records. A phone number in ENUM can therefore be the
single contact number for multiple types of communication to a
particular entity, irrespective of type of services like voice call, fax, e-
mail, mobile, text messaging, location-based services, and Web pages
etc.

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2.15 One potential source of confusion, when talking about ENUM, is the
variety of ENUM implementations in place today. Quite often, people
speaking of ENUM are really referring to only one of the following:

Public ENUM: The original vision of ENUM as a global, public directory-

like database, with subscriber opt-in capabilities and delegation at the
country code level in the e164.arpa domain. This is also referred to as
user ENUM.

Open ENUM: An effort of mobile carriers and other parties involved in

mobile numbering plans to generate complete, public database of all
international numbering plan, available via public DNS (e164num.eu)

Private ENUM: A carrier, VoIP operator or ISP may use ENUM

techniques within its own networks, in the same way DNS is used
internally to networks.

Carrier ENUM: Groups of carriers or communication service providers

agree to share subscriber information via ENUM in private peering
relationships. The carriers themselves control subscriber information,
not the individuals. Carrier ENUM is also referred to as infrastructure
ENUM, and is being the subject of new IETF recommendations to
support VoIP peering.

2.16 The SIP based Internet Telephony using Public Internet cloud and ENUM
database is one of the most popularly used technique to process Internet
Telephony calls. In this method, the Internet Telephony provider (ISP)
allocates one E.164 number to its subscriber. He also provides a Session
Initiated protocol device (SIP Device) properly configured and pointing to
the Internet Telephony service provider. An Internet Telephony call from
a particular service provider to a destination telephone number served by
another service provider comprises of sending a Session Initiated
Protocol (SIP) INVITE message from an originating device to SIP server of
its provider. The SIP server queries a Telephone Number Mapping

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(ENUM) server of service provider(s) (first, second or a third provider).
ENUM server maintains Uniform Resource Identifier (URI) details of
subscribers. The ENUM server may be internal or external to the service
provider. The query of ENUM server gives details of Uniform Resource
Identifier (URI) associated with the destination E. 164 telephone number.
The service provider queries a Domain Name Server (DNS) based on the
URI information received from ENUM server and receives Internet
Protocol (IP) address of SIP server of the called party service provider. The
originating service provider’s SIP server and called party SIP server are
used to set up a bearer path for the Internet Telephony call between the
originating and destination switch. If no match is found for domain name
of the ENUM server having URI details of destination telephone number,
the ENUM server returns a no-record-found message to the SIP server. In
this case, the SIP server defaults to a PSTN/PLMN gateway or another
default route to further process the call.

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 CHAPTER III

ANALYSIS OF ISSUES AND RECOMMENDATIONS

A. Regulatory and Licensing Framework

3.1 Internet services in India were first launched in 1995 by erstwhile VSNL,
then a Government owned PSU. However, at that time, Internet
Telephony in any form was not permitted. Later in November 1998, the
Government issued new guidelines for Internet services and ISP licences
to private operators. Even at this stage, Internet Telephony was not
envisaged as a service.

3.2 In the New Telecom Policy 1999 (NTP 1999), announced by the
Government in March 1999, various steps were taken to support the
Internet services, however even at this stage Internet Telephony was not
allowed.

3.3 Later, Department of Telecom announced the guidelines for opening of

Internet Telephony w.e.f. 1st April 2002 with restricted use. Existing
ISPs were permitted to offer Internet Telephony services (ITS) only after
signing the amended ISP licence called “Internet Telephony Service
Provider” (ITSP) licence. Internet Telephony was permitted only in
limited way, as there were restrictions on the type of technology and
devices, which could be used. ITSPs were not permitted to have
connectivity with PSTN/PLMN in India. Internet Telephony calls from
such devices to PSTN/PLMN in India was not permitted.

3.4 In March 2006, Unified Access Service Providers (UASPs) were permitted
to provide Internet Telephony service. In August 2007, all ISPs were
permitted to provide Internet Telephony and separate category of
Internet Telephony Service Providers (ITSPs) was done away with.

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3.5 The present regulatory framework permits access service licensees to
provide voice services within country. They have been permitted to
provide unrestricted Internet Telephony. The relevant clauses of UASL ,
CMTS and US(access service) licences are reproduced below:
Clause 2.2 (a)(i) of UASL
“… Access Service Provider can also provide Internet Telephony, Internet
Services and Broadband Services. If required, access service provider can use
the network of NLD/ILD service licensee.”
Clause 2.1 (a) of CMTS Licence
“… The Licensee can also provide Internet Telephony, Internet Services and
Broadband Services. If required, the Licensee can use the network of NLD/ILD
service licensee …”.
Clause 2.1 (a) (i) of UL (Access Service)
“……The Licensee can also provide Internet Telephony, Internet Services
including IPTV, Broadband Services and triple play i.e voice, video and data.
While providing Internet Telephony service, the Licensee may interconnect
Internet Telephony network with PSTN/PLMN/GMPCS network…..”

3.6 Internet Telephony in the above licences has been defined as “Transfer
of message(s) including voice signal(s) through public Internet”.

3.7 Internet Telephony has also been permitted to Internet Service Providers
(ISPs) in restricted manner, under ISP licensing conditions, issued by
Government in October 2007. As per ISPs licensing provisions, there is
no restriction on PC-to-PC Internet Telephony calls. PC or adapter can
be used to call PSTN/PLMN abroad; however Internet Telephony calls
from such devices to PSTN/PLMN in India are not permitted under ISP
licence. ISPs are also not allowed to have interconnection with
PSTN/PLMN networks.
3.8 Under the scope of service in UL with the Internet Service authorisation
the condition for provision of Internet Telephony in Clause 2.1(ii) is
reproduced below:
“The Licensee may provide Internet Telephony through Public Internet by the
use of Personal Computers (PC) or IP based Customer Premises Equipment
(CPE) connecting only the following:
a) PC to PC; within or outside India

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 b) PC / a device / Adapter conforming to TEC or International Standard in
India to PSTN/PLMN abroad.
c) Any device / Adapter conforming to TEC or International Standard
connected to ISP node with static IP address to similar device / Adapter;
within or outside India.

Explanation: Internet Telephony is a different service in its scope, nature and

kind from real time voice service as offered by other licensees like Basic
Service Licensees, Cellular Mobile Telephone Service (CMTS) Licensees,
Unified Access Service (UAS) Licensees, Unified Licensee (Access Service),
Unified Licensee with authorization for access services.”

Interconnection under Clause2.2 (iii):

“The Internet Telephony, only as described in condition (ii) above, can be
provided by the Licensee. Voice communication to and from a telephone
connected to PSTN/PLMN/GMPCS and use of E.164 numbering is prohibited.”

Addressing under Clause 2.2 (iv):

“Addressing scheme for Internet Telephony shall conform to IP addressing
Scheme of Internet Assigned Numbers Authority (IANA) only and the same
shall not use National Numbering Scheme / plan applicable to subscribers of
Basic / Cellular Telephone service. Translation of E.164 number / private
number to IP address allotted to any device and vice versa, by the licensee to
show compliance with IANA numbering scheme is not permitted.”

3.9 In year 2007/08, when unrestricted Internet Telephony for ISPs were
deliberated, the main argument given by TSPs was that they have paid
huge entry fee and have made heavy investments to create
infrastructure. Opening up of unrestricted Internet Telephony to ISPs
will impact their business model to a great extent as they apprehend
reduction of voice traffic on their networks. They argued that as access
providers are subjected to higher regulatory levies, huge upfront entry
fee and have sunk-in investments on infrastructure development; their
overheads will be higher as compared to ISPs. As per them, it would
disturb level playing field among different licensees. They also argued
that infrastructural developments can be impacted due to reduced
margins, if ISPs start unrestricted Internet Telephony. Access providers
were of strong opinion that in case ISPs want to offer unrestricted

21
 Internet Telephony then ISPs should also pay the same entry fees and
levies as paid by access service providers.

3.10 After due consultation process and detailed deliberation, TRAI on

18.08.2008 recommended to the Government that ISPs may be
permitted to provide Internet Telephony calls to PSTN/PLMN and vice-
versa within country and necessary amendments may be made in the
licence provisions. However, Government did not accept this
recommendation of TRAI.

3.11 Since then, there have been significant changes in telecom licensing
framework of the country. Now allocation of Spectrum has been delinked
with the grant of Licence. Unified licence has been introduced with entry
fee of 15 crore rupees for the whole country.

3.12 In the recent past, BSNL had proposed to introduce Fixed Mobile
Telephony (FMT) value added services for its customers. BSNL informed
the licensor and TRAI that FMT service will be an extension of their fixed
line service using IMS based NGN core switch and IP based access
network. Their Subscribers were assigned a SDCA based number from
the number series allocated to BSNL for their fixed line service. Using
this service, customer could move anywhere in the world and will be
able to receive /make calls from his fixed telephone. The calls would
have been originated or received under Wi-Fi environment and 2G/3G
Internet anywhere across the world. FMT service essentially needed
Internet access to reach BSNL’s NGN equipment for registering SIP
subscriber for making voice call. However, this service was put on hold
by BSNL when the licensor stated that this service cannot be treated
within the scope of Basic Service licence (Annexure I). Subsequently,
BSNL proposed another service termed as LFMT (Limited fixed mobile
telephony) in which the mobility was restricted to the customer
premises.

22
3.13 In view of the number of changes in the licensing and regulatory
framework, the Authority issued fresh consultation on the Internet
Telephony services.

3.14 During the consultation process, some of the stakeholders have raised
the issue that as per present licence condition Basic/UASL/CMTS/UL
(Access Services) are allowed to provide Internet Telephony on their
networks only. These stakeholders were of the view that licence requires
the Access providers to use their own network to provide Internet
Telephony services. Hence, Internet Telephony service allowed under
access service licences is bundled along with the Internet bearer
provided by the licensee. In other words, the Internet Telephony service
and Internet access service should be provided by the same access
service provider. They were of the view that the form of Internet
Telephony riding on other operator’s network is against the prevalent
telecom licensing ecosystem of the country.

3.15 These stakeholders were holding the view that access to the telecom
services of TSPs by the subscriber through public Internet (Internet
access of any other TSP) is not permitted and should not be permitted
as it would facilitate bypassing of the STD/ISD calling mechanism and
tariffs, as each and every call would be initiated as a local call.

3.16 These stakeholders have cited the Clause 2.1 (a) (i) of Chapter-VIII of
Access Service authorisation under UL which says that:
“The Access Service under this authorization covers collection, carriage,
transmission and delivery of voice and/or non-voice MESSAGES over Licensee’s
network in the designated Service Area. The Licensee can also provide Internet
Telephony, Internet Services including IPTV, Broadband Services and triple play
i.e. voice, video and data. While providing Internet Telephony service, the
Licensee may interconnect Internet Telephony network with
PSTN/PLMN/GMPCS network. The Licensee may provide access service, which
could be on wireline and / or wireless media with full mobility, limited mobility
and fixed wireless access.”

23
 They argued that UL (Access Services Authorisation)/ Basic/UAS/CMTS
Licence are ACCESS licences. Only in capacity of ACCESS Licensees,
have they been permitted to provide Internet Telephony on their Access
Networks and the licence requires “collection, carriage, transmission and
delivery of voice over Licensee’s Network”. Therefore, Internet Telephony
over other Access Provider’s Network is not permissible.

3.17 These stakeholders have further submitted that Internet Telephony, if

provided over public network, will entail huge losses to the TSPs who are
providing conventional voice services as there will be a shift of voice
traffic from the conventional PSTN/PLMN network to Public Internet.
They are of the view that huge capital and operational expenditure in
creating and maintaining the last mile access network will not be
compensated adequately, if Internet Telephony becomes popular. They
have argued that with increased proliferation of Smartphones and
Tablets, the shift in SMS and voice traffic to App based services has
already started affecting the revenues of the Telecom Service Providers.

3.18 In their support, these stakeholders have also submitted that the
provision of Internet Telephony requires the conversion of E.164
numbers to IP addresses and vice-versa. As per them, DoT did not
allocate any numbering series/blocks for Internet Telephony and hence
numbering resource allocated by DoT for Basic Services or Cellular
Mobile Services cannot be used for providing Internet Telephony Service.

3.19 On the other hand, some of the stakeholders have submitted that
Internet Telephony has been defined for UL, UASL, CMTS and BSO as
“Transfer of message(s) including voice signal(s) through public Internet”.
The definition of Internet in the licences is as below:

“ INTERNET: Internet is a global information system that:

(i) is logically linked together by a globally unique address, based on

Internet Protocol(IP) or its subsequent enhancements/upgradations;

24
 (ii) is able to support communications using the Transmission Control
Protocol/Internet Protocol (TCP/IP) suite or its subsequent
enhancements/upgradations, and all other IP compatible protocols;”

They argued that when the licence itself defines ‘Internet’ as a global
information system, the term ‘public Internet’ cannot have more
restrictive meaning than the definition of ‘Internet’ itself as laid out in the
licence. The use of the word ‘also’ in Clause 2.1(a)(i) of the UL (as cited in
the above paragraph) means that the Licensee can do what is permitted
in the first sentence and also do what is permitted in the second
sentence. This means, any restrictions in the first part of the clause will
not apply to Internet Telephony since it is an added service that can be
provided by the Licensee over and above the rights granted to it by the
first sentence. In a similar vein, it has also been pointed out by some
TSPs that the second sentence of Clause 2.1(a)(i) says the Licensee can
also provide Internet Telephony, Internet Services including IPTV,
Broadband Services and triple play i.e. voice, video and data. In this
sentence it is clear that ‘Internet Telephony’ and ‘Internet Services’ are
mentioned as separate services and hence the licence itself assumes that
these two services maybe provided separately and are not mandated to
be provided together.

3.20 These TSPs were of the view that the very definition of Internet
Telephony in the licence implies that the last mile for Internet Telephony
can be over public Internet as opposed to the private network elements
of the TSP. They argued that if Internet Telephony service is bundled
with last mile of the service provider, it will defeat the basic purpose of
Internet Telephony. They were also of the view that the existing
numbering resources provided to the licensee can be used for the
purpose of Internet Telephony.

3.21 It may be noted that a complaint related to inter-connection was

received in TRAI from a licensee who has recently acquired UL (Access

25
 service) licence for Mumbai Service area. This licensee has been allotted
numbering series ‘797’ for providing basic telephone services in Mumbai
service area. The licensee was facing difficulty in signing of inter-connect
agreement for providing Internet Telephony with some other Telecom
Service providers having access services licence. During the meetings
held with them, the service providers have stated that they are ready to
sign agreements for fixed wire-line services but not for Internet
Telephony services because the service has not been defined with clarity
by the licensor.

3.22 The Authority took note of all the submissions made by stakeholders
and advancement of technology used for Internet Telephony service and
observed that in the initial stage, Internet Telephony was generally
provided through SIP enabled devices or Personal computer (PC) and
was alternate to fixed line telephony with some more features. Internet
telephony was limited to fixed line as fixed line was able to support a
high speed Internet service, which was essential requirement of Internet
telephony. Now with the passage of time, three major developments took
place (a) cellular mobile network is able to support high speed Internet
(b) Smartphones have become a very fast and efficient computing
devices (c) New voice coding techniques require low data rate for Internet
Telephony. These technological developments have enabled TSPs to
provide Internet telephony through Smartphone through an application
(app).

3.23 The Authority analysed the present access service licence conditions and
observed that definition of Internet telephony envisages the transfer of
message(s) including voice signal through public Internet and therefore
submission of some stakeholders that Internet Telephony can be
provided only on their network does not represent correct position of the
licence. Public internet is a very general term and narrow interpretation

26
 taken by some of the TSP does not represent the correct position. If the
interpretation of these TSPs is taken as correct then it will defeat the
basic purpose of the Internet Telephony. If Internet Telephony service is
provided by the Access provider, over its own network only, it is
basically managed VoIP service which cannot be intent of licensor when
Internet telephony service has been allowed as a separate service. But,
Internet Telephony is a different service and it should not be equated
with managed VoIP. It is apparent from the prevailing international best
practices that Internet Telephony service is not bundled with last mile
network of the Access provider. So, the Authority is of the view that as
per the present licensing framework, Internet Telephony service can be
provided independent of the Internet access Service. In other words, the
Internet Telephony service is un-tethered from the underlying access
network.

3.24 The Authority examined the arguments of some stakeholders on revenue

loss to existing operators and is of the view that the Internet use is
growing at an unprecedented high rate and existing providers will
generate revenue from data services which will be required by a
subscriber to make even an Internet Telephony call. In any case, voice
has already become an application over data services. The Authority is
of the view that the increasing revenue realizations from data services
due to increasing Internet traffic will not only compensate for the loss of
conventional voice traffic but will also increase the revenue potential of
the last mile access networks. This symbiotic relationship will increase
broadband proliferation and will also contribute to the overall health of
the telecom sector along with increase in consumer choice. The
separation of network and service layers of telecom service offerings is
the natural progression of the technological changes in this domain .It is
now possible to separate provision of service contents, configuration and

27
 modification of service attributes regardless of the network catering to
such service.

3.25 The Authority is also of the view that the regulatory framework in the
country should enable technological developments, innovations and
growth of the telecom sector for the benefit of the common masses while
ensuring that the business models of the telecom service providers are
not adversely affected.

3.26 In the consultation paper, the opinion of the stakeholders was sought
about the additional entry fee, Performance Bank Guarantee (PBG) and
Financial Bank Guarantee (FBG) for Internet Service Providers, if they
are allowed to provide unrestricted Internet Telephony. Some of the
stakeholders were of the view that it should not be allowed. They were of
the view that only access service providers can be allowed to provide
Internet Telephony. On the other hand some of the stakeholders were of
the view that the ISPs should be allowed to provide Internet Telephony
without any additional financial liabilities.

3.27 In 2008, when TRAI recommended unrestricted Internet Telephony for

ISPs the concept of Virtual Network operators(VNO) was in infancy. The
present licence for VNO with access service authorisation allows Internet
Telephony using the Interconnection framework of the parent Network
Services Operator (NSO). Moreover, Internet Telephony is an important
service and creating conducive environment for VNO to provide Internet
Telephony will help the proliferation of Internet Telephony service. It will
also fulfill the purpose of the introduction of VNO as it will amount to
separation of service from the network.

3.28 The licence for VNO has been introduced in the country for delinking of
licences for networks from the delivery of services. There may be some
operators who may not be willing to set up complete PSTN/PLMN

28
 network for providing Basic Services or Cellular mobile services. In such
cases, the operators may choose to become the VNO of an access
provider to provide Internet Telephony service.

3.29 The Authority is of the view that to promote Internet Telephony, it is

necessary that the entry barriers to new entrants should be eased and
at the same time the existing players may be encouraged to provide
Internet Telephony service. The Authority is also of the view that there
can be two type of scenario while offering Internet Telephony service
over Public Internet. It can be an additional service over and above the
conventional wireline/wireless service by the access service providers or
by a virtual operator wherein last mile for origination/termination could
be on Public Internet also. However, in both the scenarios, the Internet
Telephony service can be un-tethered from any underlying network. This
will increase the call success rate particularly in indoor poor coverage
areas where Public Internet may be available but signal of a particular
TSP is not available.

3.30 The Authority further examined whether existing ISP should be allowed
to provide unrestricted Internet Telephony service and observed that in
2008, there was an UAS licence which with an entry fee of Rs. 1,658
crore. However, presently the entry fee for access service licence with
National service area for providing unrestricted Internet Telephony is Rs.
15 Crore only. Moreover, VNO licence with access authorisation for
National area can be obtained by paying only 7.5 crore rupees. The
Authority is of the view that any ISP can provide unrestricted Internet
Telephony either by obtaining UL with authorisation to access services
or can become VNO of any existing Access provider.

3.31 Therefore, the Authority is of the view that necessary clarification may
be issued by DoT that Internet Telephony service is un-tethered from the

29
 underlying access network. VNO of access service providers may also be
allowed to provide un-tethered Internet Telephony service.

3.32 The Authority further observed that present licensing framework has
been designed wherein service provision is an integral part of the
network provision. However, in case of Internet Telephony the service
provision is done by Internet Telephony Service Provider (ITSP) and
access such as underlying Internet will be provided by different
access/Internet service provider. In the present licensing framework,
subscribers availing limited mobile facility (WLL), the mobility is
restricted to the local area i.e. Short Distance Charging Area (SDCA) in
which the subscriber is registered. However, for full mobility subscribers
mobility is provided for the licensed service area (LSA). Mobility can also
be offered to the fully mobile subscribers beyond the service area by
undertaking roaming arrangements with other telecom service providers.
However, Internet Telephony service is different in nature as it is
providing voice as an application and therefore, mobility is not being
provided by the ITSP but by the operator who is providing underlying
Internet. It means, if one operator has a licence for a LSA and his
subscriber roams/moves to another LSA, it may be very difficult to verify
the location of subscriber as he will be able to access the Internet
Telephony service whenever he gets Internet access. As the IP addresses
in the country are also not allocated LSA wise it is very difficult to stop
user to use services in the other LSA wherein his service provider is not
authorized to provide service. During the consultation process some
TSPs suggested that with technology such as GPS etc. it is possible to
limit mobility within LSA. Other stakeholders argued that while making
Internet Telephony calls user may like to use his laptop/desktop or may
switch off their GPS in the Mobile phone; therefore limiting mobility by
GPS location is not the right solution. One solution could be that only
the Access providers who have National area licence are allowed to

30
 provide Internet Telephony services with full mobility and for other TSPs
to have introduction of separate National area licence for Internet
telephony. However, at this stage wherein a number of LSA wise licences
have been issued and all these licences provide for Internet Telephony, it
will be not be a good idea to introduce new National area licence. Other
solution could be that Licensee can provide service over its network to
the subscribers falling within its Service area.

3.33 Similar issue of mobility arises when subscriber is roaming out of

Country and able to make the call through public internet. However it
was informed that this may be distinguished by the access provider on
the basis of IP address. This problem can be solved by handing over call
to terminating operators through ILDO. The access service provider’s
Internet Telephony service has to ensure that International out-roamer
calls terminating in India will have to be handed over at the gateway of
licensed ILDOs and International termination charge should be paid to
the terminating access service provider. It is possible to ascertain from
the public IP address of origination of Internet Telephony calls that
whether the subscriber is located in India or abroad. It is also possible in
GPS enabled handsets to ascertain the location with accuracy. In case it
is not feasible to bring this type of calls through gateways of licensed
ILDOs, International out-roamer calls for Internet Telephony subscribers
should not be allowed.

3.34 In view of the above, the Authority recommends that:

i. As per Authority’s understanding of present Access service

licences, Internet Telephony service is un-tethered from the
underlying access Network. In other words, Internet
Telephony Service can be provided by Access service provider
to its subscriber who may be using Internet of other Access
service providers. DoT should issue a clarification to the

31
 effect. If DoT has a different understanding, the Authority
recommends that the DoT may issue amendment to Access
service licences so that Internet Telephony service is un-
tethered from the underlying access Network.

ii. The UL (VNO) licensee with access service authorisation

should also be allowed to provide un-tethered Internet
Telephony in the designated service area.

iii. Internet Telephony calls originated by International out

roamers from international locations should be handed over
at the International gateway of licensed ILDOs and
International termination charges should be paid to the
terminating access service provider. In case the Access
provider is not able to ensure that Internet Telephony call
originated outside of the country is coming through ILDO
gateway, International out-roaming to Internet Telephony
subscribers of the access provider should not be allowed.

B. Numbering:

3.35 Numbers always play a central role in telecommunications and their

importance is well recognized. A well designed numbering for any service
ensures structured growth of any service. Number is basically a unique
identity of the subscriber. National Numbering plan 2003 provides two
types of the numbering schemes (a) non geographical i.e. mobile number
series and (b) Geographical i.e. SDCA linked numbering series.

3.36 To ascertain the views of the stakeholders on the desired framework for
allocation of numbering resources in the consultation paper, they were
requested to comments on following:

32
 “Question 10:
What should be the framework for allocation of numbering resource for Internet
Telephony services?
Question 11:
Whether Number portability should be allowed for Internet Telephony numbers?
If yes, what should be the framework?”

3.37 Some of the stakeholders have suggested that the numbering series
being used for mobile or basic services may be used for Internet
Telephony. Some of the stakeholders have also suggested that separate
11 digit or 13 digit numbering may be used for Internet Telephony
service.

3.38 Regarding number portability most of the stakeholders in the

consultation process were of the view that it is too early to deliberate
upon number portability. The issue of number portability can be taken
up at a later stage when the service matures.

3.39 Unified Licence, however, mentioned that IP Address assigned to a

subscriber for Internet Telephony shall conform to IP addressing Scheme of
Internet Assigned Numbers Authority (IANA) only. Relevant is as follows:
“2.5 IP Address assigned to a subscriber for Internet Telephony shall conform to
IP addressing Scheme of Internet Assigned Numbers Authority (IANA) only.
Translation of E.164 number / private number to IP address and vice versa by
the licensee for this purpose shall be as per directions/instructions issued by
the Licensor.”

3.40 It is worth noting that outgoing only Internet Telephony can be offered
without allocation of number resources from E.164 numbering plan.
However, it is not possible to call an Internet Telephony subscriber from
an existing PSTN/PLMN network without allocation of a number, which
can be recognized, by the traditional fixed and mobile telecom network.
This will greatly restrict the scope and popularity of the Internet
Telephony services.
3.41 As explained in chapter II, there are basically four types of ENUM
implementation which take care of conversion from E.164 number to IP
address. (a) Public ENUM: The original vision of ENUM as a global,

33
 public directory-like database, with subscriber opt-in capabilities and
delegation at the country code level in the e164.arpa domain. This is
also referred to as user ENUM. (b) Open ENUM: An effort of mobile
carriers and other parties involved in mobile numbering plans to
generate complete, public database of all international numbering plan,
available via public DNS (e164num.eu) (c) Private ENUM: A carrier, VoIP
operator or ISP may use ENUM techniques within its own networks, in
the same way DNS is used internally to networks. (d) Carrier ENUM:
Groups of carriers or communication service providers agree to share
subscriber information via ENUM in private peering relationships. The
carriers themselves control subscriber information, not the individuals.
Carrier ENUM is also referred to as infrastructure ENUM.

3.42 The clause 2.5 of UL also mentions that “Translation of E.164 number /
private number to IP address and vice versa by the licensee for this
purpose shall be as per directions/instructions issued by the Licensor”.
However, DOT did not issue any direction in this regard. In fact, there
could be a type of translation especially private ENUM wherein a carrier,
VoIP operator or ISP may use ENUM techniques within its own
networks. The Authority feels that the conversion from E.164 number to
IP address and vice versa is essential for providing any form of Internet
Telephony with Caller ID and incoming calls. The ambiguity regarding
the translation of E.164 number to IP address needs to be removed. It is
also prudent in the present scenario to use a private ENUM database for
this translation.

3.43 UL/UASL/CMTS/Basic licences allow licensee to provide unrestricted

Internet Telephony but it is not clear that whether TSP can use same
numbering resource or it will be given separate numbering resource for
providing Internet Telephony.

34
3.44 A clarification regarding numbering series was sought from DoT. In its
reply DoT stated that: “in case of Internet Telephony service, the physical
location of the subscriber may be anywhere which is akin to mobile
services and the numbering series allocated for cellular mobile services
can be used for Internet Telephony service. However, the numbering
series allotted for Basic Services cannot be utilized for providing the
Internet Telephony service.”

3.45 DoT has stated that Basic Services numbering series cannot be used for
Internet Telephony. However, DoT has allowed Basic Service Licensee to
provide Internet Telephony vide amendment dated 14.12.2005
(Annexure II).It shows that intention of DOT was to allow Basic Service
Licensee also to provide Internet Telephony service. However, due to the
advancement in technology used for providing Internet telephony
physical location of the subscriber may be anywhere which is akin to
mobile services, the DOT has stated that numbering series allocated for
cellular mobile services only can be used for Internet Telephony service

3.46 The Authority examined that the above position of DoT is not in line
with the prevailing global best practices. Globally, most of the countries
allowed Internet Telephony service initially by allocating non-geographic
and separate numbering series. However, some of the countries have
also started allocating geographical numbering series for this service.
Some countries do not have separate numbering series for Internet
Telephony and the numbering series used for conventional services is
also being used for Internet Telephony. In some countries the
geographical links associated with telephone numbers is also being done
away with.

3.47 The Authority is of the view that numbering series allocated for Basic
Services should also be used for providing Internet Telephony service.
In other worlds Basic Service licensee may be allowed to provide only

35
 non-nomadic Internet Telephony Service using SDCA linked numbering
series allocated for Basic services. This is possible by binding the
Internet Telephony service with the public IP allocated to the customer.
Since almost all the TSPs providing Basic/Fixed services have migrated
to Next Generation IP based networks, this type of service can be
provided. This will increase the value of the Basic Service and will also
retain the geographical nature of the SDCA linked numbering scheme.
Not allowing SDCA linked numbering series for Internet telephony will
discourage Basic services licensee to migrate to Next Generation IP
based network.

3.48 In view of the above, the Authority recommends that :

i. The mobile numbering series should be used for providing
Internet Telephony by a service provider. TSPs should be
allowed to allocate same number to the subscriber both for
Cellular Mobile service and Internet Telephony service.
ii. The SDCA linked numbering series may also be used for
providing Internet Telephony by a service provider.
However, in this case, mobility should be limited to
consumer premises.

iii. The clause 2.5 in UL (access service) related to translation

of E.164 number to IP address may modified as below:

Present Clause Amended Clause

“IP Address assigned to a “IP Address assigned to a
subscriber for Internet Telephony subscriber for Internet Telephony
shall conform to IP addressing shall conform to IP addressing
Scheme of Internet Assigned Scheme of Internet Assigned Numbers
Numbers Authority (IANA) only. Authority (IANA) only.
Translation of E.164 number /
private number to IP address and
vice versa by the licensee for this
purpose shall be as per
directions/instructions issued by
the Licensor.”

36
 Similar clause in other access licences (BSO, CMTS, and
UASL) should also be amended.
iv. The access service licensee should use private ENUM in its
network for Telephone number mapping from E.164 to
SIP/H.323 addresses and vice-versa.
v. In case of provision of Internet Telephony by VNO with
access service authorisation, the numbering resource
allocation should be done by the parent NSO.
C. Security issues

3.49 Some of the stakeholders have raised apprehensions about the

violations of security conditions in the licence because of the nomadic
nature of the service. The clause 8.5 in the UL (access service
authorisation) related to location details specifies the desired accuracy
for location details of mobile customers in the form of latitude and
longitude besides the co-ordinate of the BTS which is already one of the
mandated fields of CDR. The licence also specifies the lawful
interception and monitoring requirements to be complied by the licensee
which may be amended by the licensor from time to time. The licence
specifies that CLI Restriction (CLIR) is also not to be provided normally.
Even while providing CLIR it has to be ensured that CLI is carried from
end to end on the network.

3.50 The Authority is of the view that the licensees should comply with all the
interception and monitoring related requirements as specified in the UL
(access services) as amended from time to time. In case of VNO, the
licensee should comply to the security and monitoring related
requirements as specified in the UL (VNO) licence. As far as the location
of nomadic Internet Telephony subscribers is concerned, it is possible to
capture the location details in case GPS service is enabled in GPS
enabled Smartphone. However, in case of Internet Telephony using

37
 desktop PC and laptop PC only the IP address can be captured which
may not provide the desired granularity for locating a mobile subscriber
even after using the IPDR of the Internet access service provider(in case
the Internet Telephony service provider and Internet access service
provider are not the same). So, the Authority is of the view the Public IP
address used for originating/terminating Internet Telephony calls
should be made a mandatory part of CDR in case of Internet Telephony.
The location details in form of latitude and longitude should also be
provided wherever it is feasible.

3.51 In view of the above, the Authority recommends that

i. The licensees should comply with all the interception and
monitoring related requirements as specified in the licence as
amended from time to time for providing Internet Telephony.

ii. The Public IP address used for originating/terminating

Internet Telephony calls should be made a mandatory part of
CDR in case of Internet Telephony. The location details in
form of latitude and longitude should also be provided
wherever it is feasible.

iii. CLI Restriction (CLIR) facility should not be provided for

Internet Telephony Subscribers.

D. Interconnection and Interconnection Usage Charges (IUC)

3.52 Interconnection is the most important aspect of the telecom network.

The existing Interconnection framework in India ensures that licensees
such as access service providers, NLDO and ILDOs interconnect so that
consumers of one TSP can talk to the subscriber of other TSP.

3.53 During the consultation process, some stakeholders submitted that as

per the present licensing framework Internet Telephony should be

38
 provided by an access service provider on its own last mile network and
therefore existing Point of interconnection (POI) framework should
continue to apply on Internet Telephony calls also.

3.54 Some of the stakeholders were of the view that Internet Telephony
service should be treated like mobile service for the purpose of
Interconnection. They have opined that SDCA based POI should not be
mandated for Internet Telephony service. Some of the stakeholders have
also expressed the view that IP based Interconnection should be
mandated.

3.55 The Authority observed that present recommendations are limited to

provisioning of Internet Telephony by access licensees and they are
handing over Internet Telephony call to other service providers like any
other voice call and therefore there is no need to prescribe separate
Interconnection framework at this stage and the extant POI framework
and Interconnection Usage Charges may continue for provision of
Internet Telephony services also. Moreover, as mentioned in the
paragraph 3.44, DOT has already stated that Internet Telephony service
is akin to mobile service. However, if any change is required in the
Interconnection regime , the Authority will issue separate amendment/
clarification in this regard.

E. Access to Emergency Services

3.56 The facility to call nearest authority like police, fire station, hospital, etc
has been termed as access to Emergency Service. Accurate identification
of geographical location of subscriber is a must for availing emergency
services. The concept of emergency number calling has changed with
introduction of the mobile services. It is envisaged that accurate location
of the caller will also be available to the authority (Hospital, Police, Fire-

39
 station) handling emergency situation along with emergency number
calls.

3.57 Different telecom networks adopt different technologies to facilitate

emergency number calling. In case of usage of Internet Telephony
services from a fixed location, it is possible to map the position
information and route emergency calls to appropriate agency. However,
one of the promising features of Internet Telephony services is the
nomadic use. In the nomadic use, it may be difficult to accurately map
position information while originating the emergency call.

3.58 The prevailing International scenario to facilitate emergency number

calling is different in different countries. Some of the countries have
gone ahead with Internet Telephony services without mandating
emergency number calling facility. They have emphasized the issue of
transparency and desired that Internet Telephony service provider shall
inform their subscribers that Internet Telephony service will not support
emergency numbers calling.

3.59 In India, when subscriber calls from fixed line, the call goes to nearest
police/fire station which has been mapped to corresponding location.
For mobile, TSPs provide the information of SDCA to BSNL/MTNL along
with CLI of calling party and call is routed by BSNL/MTNL to nearest
Police station in that very SDCA.

3.60 The following questions were asked to ascertain the view of the
stakeholders on matter related to calling Emergency numbers:
Question 12:
Is it possible to provide location information to the police station when the
subscriber is making Internet Telephony call to Emergency number? If yes, how?
Question 13:
In case it is not possible to provide Emergency services through Internet
Telephony, whether informing limitation of Internet Telephony calls in advance
to the consumers will be sufficient ?

40
3.61 Some of the stakeholders were of the view that emergency number
calling should be mandated for Internet Telephony service. On the other
hand, some of the stakeholders were of the view although it is possible
to provide the location related information to some extent, it should be
sufficient to inform the limitations of Internet Telephony services with
respect to emergency services. It is technically possible to ascertain the
location of the subscriber in GPS enabled handsets, if GPS is activated,
by the user. In case of user using Desktop PC or Laptop PC it is possible
to ascertain the IP address of the user. The address derived from the IP
address in an Internet access network may not provide the desired
granularity which is possible in fixed line networks or mobile networks.
Some of the stakeholders were of the view that access to emergency
services should not be allowed as users can spoof their location or
switch off location services in their devices.

3.62 The Authority is aware of the need and importance to facilitate access to
emergency services. However, imposition of restrictions and mandatory
obligations may kill the initiative to provide Internet Telephony before a
service can commercially pick up. In order to strike a balance, the
Authority is of the view that Internet Telephony service providers may be
encouraged to facilitate access to emergency number calls; however they
may not be mandated to provide such services at present.

3.63 In view of the above, the Authority recommends that the access
service providers providing Internet Telephony service may be
encouraged to facilitate access to emergency number calls using
location services; however they may not be mandated to provide
such services at present. The subscribers may be informed about
the limitations of providing access to emergency services to
Internet Telephony subscribers in unambiguous terms.

41
F. Quality of Service

3.64 Quality of speech in any communication service is an important

consideration. Subscribers are accustomed to the carrier grade voice
quality from PSTN/ PLMN services and expect similar quality from
Internet Telephony also irrespective of the technology used to provide
such services.

3.65 The quality of service has been a great challenge for Internet Telephony
in the past, but it has improved to a great extent in the recent years. In
many cases the quality of Internet Telephony is so good that its
discrimination from carrier grade service is not easily possible. The use
of advanced coding techniques and other innovative mechanism play
important role in further improving voice quality.

3.66 The following question was asked to solicit the views of the stakeholders
with respect to the need of QoS parameters for Internet Telephony:
“Question 14:
Is there a need to prescribe QoS parameters for Internet Telephony at present? If
yes, what parameter has to be prescribed? Please give your suggestions with
justifications.”

3.67 Some of the stakeholders were of the view that QoS parameters may be
mandated similar to TRAI regulations 2002 for VoIP based ILDO service.
They argued that since it is also a telephony service it should have QoS
parameters like other telephony services. On the other hand some of the
stakeholders are of the view that QoS parameters should not be
mandated as it cannot be ensured over Public Internet. They have also
opined that market forces will compel the service providers of Internet
Telephony services to compete on quality of service and price, among
other factors, which should ultimately ensure that the customers receive
the quality of service they demand at best price.

42
3.68 The Authority is of the view that QoS on Internet Telephony may be left
to market forces at present. Even low quality Internet Telephony offers
sufficient cost advantages over traditional voice services and customers
may be willing to make this price-quality trade-off. The service provider
must inform this aspect to the subscribers so that they can take an
informed decision. However, the service providers should ensure QoS as
per the extant regulations in the managed part of the network which is
not on the Public Internet. The Authority shall review the decision
regarding mandating QoS to Internet Telephony service providers at
appropriate time.

3.69 In view of the above the Authority recommends that:

i. QoS on Internet Telephony may be left to the market forces.
The service providers must inform QoS parameters supported
by them for Internet Telephony so that the subscribers can
take an informed decision.
ii. The Authority shall review the decision regarding mandating
QoS to Internet Telephony service providers at appropriate
time.

43
 CHAPTER IV

GLOBAL REGULATORY PRACTICES IN INTERNET TELEPHONY

AUSTRALIA

4.1 Australia’s telecommunications regulator, the Australian

Communications and Media Authority (ACMA), only requires telecom
licences to be held in relation to entities that own or operate certain
types of telecommunications infrastructure, known as ‘carriers’.

4.2 Under the Telecommunications Act 1997, there are two types of persons
or organisations that can provide carriage services (telecommunications
services) to the public: carriers and carriage service providers (CSPs). 1

 Carriers are persons who own a telecommunications network unit

to supply carriage services to the public.

 CSPs use a telecommunications network unit to supply carriage

services to the public.

4.3 Carriage services include services for carrying communications, for

example telephone services, Internet access services and Voice over
Internet Protocol (VoIP) services. CSPs can include organisations that
resell time on a carrier network for phone calls, provide access to the
internet (Internet Service Providers) or provide telephone services over
the internet (VoIP service providers). CSPs are not required to obtain a
licence from ACMA to supply a carriage service to the public.

4.4 Australia does not expressly regulate points of interconnection; rather

these are usually determined as a matter of commercial negotiation
between telecommunications operators. However, various industry

http://www.acma.gov.au/Industry/Telco/Carriers-and-service-providers/Licensing/carriers-carriage-providers-
1

licensing-i-acma

44
 standards and codes apply to the technical requirements for points of
interconnection. Carriers and carriage service providers providing certain
“declared services” (such as standard telephone services provided over
the PSTN) have a regulatory obligation to make their telecommunications
networks available to persons wishing to establish a competing service
on negotiated terms (or baseline terms set by the regulator where
negotiations fail). Carriers also have powers to access the
telecommunications infrastructure of other carriers in order to establish
and maintain a competing service on negotiated or statutory terms.

4.5 A VoIP service is regulated where it constitutes a ‘standard telephone

service’ as defined under Australian telecommunications law. A two-way
VoIP service that enables customers to make calls to, and receive calls
from, users of the PSTN is likely to constitute a standard telephone
service and therefore be subject to regulation, on the basis that it is a
carriage service connecting with the PSTN, provided for the purpose of
voice telephony and connects end-users supplied with the same service. 2

4.6 The call termination charge for VoIP calls terminated onto a mobile or
fixed line network would be the same as calls made from traditional
services. In order for a call to be terminated onto a mobile network as a
mobile call, or a fixed network as a PSTN call; the call will need to be
delivered to the relevant carrier at its POI in the requisite form. This
means that the call will need to be converted from an internet call to a
standard call (with CCS#7 signaling, etc.) before it is routed to the POI of
the mobile or fixed carrier, unless separate arrangements are negotiated
with the mobile or fixed carrier. Assuming that the call is delivered at the
POI with the requisite characteristics, it would be accepted by the mobile
or fixed carrier for termination and the standard mobile terminating

2
http://www.acma.gov.au/Citizen/Phones/Landlines/Voice-over-internet-protocol/voip-legislation-codes-
standards-i-acma

45
 access (MTAS) charge or fixed terminating access (FTAS) charge would be
applied. The MTAS and FTAS charges in Australia are commercially
negotiated, but default charges set by the Australian Competition and
Consumer Commission (ACCC) are applied. If a call is not delivered to a
carrier at the POI in the requisite format at the POI, but is rather
delivered to the carrier as an internet call, then the call termination
arrangements will fall outside the scope of the regulated services. In such
circumstances, the charges will be determined as a matter of commercial
negotiation.

4.7 Historically, nomadic location independent communication services

(such as VoIP services) were assigned a dedicated special services
number commencing with the numbers 0550. However, in 2015, the
ACMA determined to phase out these numbers and cease making them
available for allocation. Now, carriage service providers who supply VoIP
services can apply for geographic numbers (also used for standard PSTN
services) to use in connection with VoIP services.3 Geographic numbers
are 10 digit numbers consisting of two components: (i) a 2 digit area code
corresponding to geographic regions and (ii) an 8 digit local number.

4.8 The obligations on VoIP service providers regarding emergency call

services are specified in the Telecommunications (Emergency Call
Service) Determination 2009 (the Determination). The determination
applies to two-way VoIP services and VoIP out-only services that are
capable of dialing into the Public Switched Telephone Network. Under the
Determination, carriers and carriage service providers (including those
providers of two-way VoIP services) must provide an indication of
possible location uncertainty of the customer.

http://www.acma.gov.au/Citizen/Phones/Landlines/Voice-over-internet-protocol/understanding-voip-numbers-
3

and-call-charges-i-acma

46
4.9 However, VoIP out-only service providers do not have such an obligation.
If they are unable to provide free of charge access to Triple Zero (000)
they must clearly inform customers that such access is not available and
obtain acknowledgement from the Customer that they understand the
limitations of the service.

4.10 Australia imposes QoS parameters on VoIP service providers offering a

two-way service enabling customers to make and receive calls from users
of the Public Switched Telephone Network. Two-way PSTN VoIP services
are covered by these QoS because they are considered a “Standard
Telephone Service” as defined under applicable telecommunications
legislation.

4.11 Notably, however, a service provider may propose customers waive their
rights under the Customer Service Guarantee by completing a waiver in
writing or orally. A service provider may also choose not to supply a
customer with a service if the customer refuses to agree to a waiver.
Waiving the QoS guarantees or choosing not to provide the service is
legally permissible and, in fact, common practice for providers of two-way
PSTN VoIP service providers in Australia (with the effect that the
Customer Service Guarantee does not then apply)

CANADA

4.12 The federal telecommunications regulatory authority in Canada, which is

called the Canadian Radio-television and Telecommunications
Commission (CRTC), has established a light-handed regulatory approach
to telecom service providers (TSPs) that provide VoIP services.

4.13 The only obligations of VoIP providers under the CRTC’s rules are to4: (i)
register with the CRTC if they offer a voice communications service that

http://www.crtc.gc.ca/eng/archive/2005/dt2005-28.htm
4

47
 makes use of North American Numbering Plan (NANP) telephone
numbers to provide universal access to and/or from the PSTN; (ii) obtain
a Basic International Telecommunications Service (BITS) licence from the
CRTC if their VoIP services allow customers to make international
telephone calls; and (iii) comply with other, standard regulatory
obligations that apply to other registered TSPs, such as the obligation to
maintain customer information in confidence and to honour customer
requests to “port” their telephone numbers to other service providers.

4.14 Most of the VoIP services are not tied to a specific underlying network
and, therefore, they do not have a “network” to/from which other
networks need to interconnect. Instead, VoIP providers connect their
“cloud-based” services to the network of an underlying
telecommunications common carrier (usually a local exchange carrier or
“LEC”) that can provide access to and from the PSTN as well as other
network-based services. These arrangements are generally governed by
commercial negotiations between the VoIP provider and the
telecommunications common carrier.

4.15 In Canada, traffic is typically exchanged between telecommunications

common carriers on a “bill and keep” basis. This means that carriers do
not generally charge each other for traffic termination unless there is a
significant imbalance in the exchange of traffic between the carriers.

4.16 When the CRTC first established its regulatory framework for VoIP
services in 2005, it described two types of VoIP services, namely ‘access-
independent’ and ‘access-dependent’ VoIP services. Specifically, the
CRTC used the term ‘access-independent’ VoIP service to describe
services that do not require the VoIP provider to own or operate the
underlying network on which the service rides, nor do these services
require the underlying network operator to grant permission for end-
users to use the VoIP provider’ s ‘application’. By contrast, the CRTC

48
 used the term ‘access-dependent’ VoIP service to describe IP-based voice
services in which the access component and the service are necessarily
linked. Providers of ‘access-dependent’ VoIP services typically own and
operate a local access network and have simply converted the underlying
technology of that network from circuit-switched to packet-switched.
Despite these distinctions, the regulatory obligations that apply to TSPs
that provide these services are the same. In other words, all providers of
VoIP services, regardless of whether they provide ‘access-independent’ or
‘access-dependent’ VoIP services must (i) register with the CRTC, (i)
obtain a BITS licence if they offer international calling capabilities and
(iii) comply with the other, standard regulatory obligations that apply to
other registered TSPs in Canada.

4.17 The CRTC requires all providers of local telephone services, including
providers of local VoIP services, to provide access to 911 services.5
However, the CRTC recognizes that providers of certain types of VoIP
services - namely ‘nomadic’ VoIP services and ‘fixed non-native’ VoIP
services - may not be able to provide accurate location information to
public safety agencies. Until a technical solution is developed to address
this problem, the CRTC requires providers of both ‘nomadic’ and ‘fixed
non-native’ VoIP services to notify their customers (in marketing
materials, terms of service, customer contracts, etc.) that there may be
limitations associated with their access to 911 services. The CRTC also
requires these TSPs to ensure that their customers are able to update
their most likely physical address online.

UNITED KINGDOM

4.18 Under the UK’s general conditions for communications networks and
services, all communications service providers, including VoIP providers,

http://www.crtc.gc.ca/eng/archive/2005/dt2005-21.htm
5

49
 have the same general rights of interconnection.6 Specific technical
arrangements, including means of physical interconnection, are
determined by the network operators and Internet-originated or
terminated traffic is not treated differently.

4.19 In the UK, VOIP is treated as any other packet switched data, and VOIP
is not currently seen as a ‘relevant market’ in the UK that requires a
review to ensure that it is functioning correctly. Thus, it does not matter
if the VoIP app is provided as an extension to a regulated entity’s
preexisting PSTN voice service or by a company providing only the VoIP
capability all that matters is whether it is a ‘VOIP out’ or a ‘VOIP in and
out’ service.

4.20 Termination charges in the UK are not subject to regulatory controls,

except in the case of BT (with respect to fixed geographic call
termination) and call termination on mobile networks. Other
communications providers are only required to provide termination on
fair and reasonable terms and conditions, including charges.

4.21 There is no restriction in the UK on whether a VoIP service is nomadic or

non-nomadic. The potential portability of VoIP is recognized as a benefit
of VoIP over a fixed line PSTN line.7

4.22 A non-geographic numbering range (056), which is part of the UK

National Telephony Numbering Plan (NTNP), was made available by
Ofcom for nomadic VOIP services and geographic numbers are available
for all PATS including VOIP. While a special number range has been set

https://www.ofcom.org.uk/phones-telecoms-and-internet/information-for-industry/telecoms-competition-
6

regulation/general-authorisation-regime
https://www.ofcom.org.uk/__data/assets/pdf_file/0023/55571/voipstatement.pdf
7

50
 aside for VoIP services, VoIP service providers are permitted to use any
geographic telephone number in the UK number plan.8

4.23 In the UK, number portability is a right of any subscriber to a public

electronic communications service with a number from the NTNP.
Number portability is seen as a key facilitator of consumer choice and
effective competition.

4.24 As In 2007 Ofcom identified a high level of consumer confusion relating

to access to emergency services from a VOIP service and Ofcom requires
that a VoIP service provider is expected to provide accurate and reliable
CLI ‘to the extent technically feasible’ and at no charge to the emergency
organizations. This of course is not viable for those VoIP service providers
who do not use or assign an E.164 number (telephone number) as a user
identifier. If the VOIP service does not provide access to emergency call
numbers, this fact must be made clear at the time of signature of the
relevant agreement. If the service is to be used principally at a single,
fixed location, the service provider must require the customer to register
with it the address of the place where the service will be used, in order to
assist emergency services organisations. Customers must also be advised
of any limitations on location information. If access to emergency calls is
unreliable (particularly if access is cut off in the event of a power cut or
failure, or a failure in the broadband connection over which the service is
provided) this must be made clear to the customer, and acknowledged by
the customer at the point of signature.

https://www.ofcom.org.uk/about-ofcom/latest/media/media-releases/2004/ofcom-to-encourage-the-
8

development-of-new-voice-services

51
UNITED STATES

4.25 In the U.S., where regulation of VoIP services is generally limited to

“interconnected VoIP service” i.e. those that enable calls both to and from
the PSTN.9

4.26 The U.S. has no VoIP-specific interconnection rules. Each

“telecommunications carrier” is obligated to interconnect with other
“telecommunications carriers” under Section 251(a) of the
Communications Act of 1934, as amended, but because VoIP services
have not been classified as a telecommunications service, these
obligations do not apply to VoIP services. Moreover, VoIP services are
often untethered from any particular underlying network and, therefore,
generally have no “network” to/from which other networks need to
interconnect. Rather, the connection of a VoIP provider’s cloud to a PSTN
provider that is interconnected to the PSTN is managed through
commercial negotiations. The point at which the parties connect their
clouds and exchange traffic is not regulated. Notably, there has been no
need for such regulation as the VoIP-to-PSTN marketplace in the U.S. is
relatively vibrant, including network-based VoIP providers (e.g., cable
companies that have added VoIP to their line-up of services) and non-
network based providers (e.g., network untethered providers such as
Vonage).

4.27 The U.S. does not impose any geographic restrictions on the provision or
use of VoIP services. Telephone numbers in the U.S. are allocated to VoIP
services in one of two ways: (i) they are sub-allocated through a
commercial relationship between the VoIP provider and a telephone
service provider (typically a “Competitive Local Exchange Carrier” or
CLEC) which has obtained its telephone numbers directly from the U.S.
number administrator; or (ii) the VoIP provider obtains the numbers

https://www.gpo.gov/fdsys/pkg/CFR-2015-title47-vol1/pdf/CFR-2015-title47-vol1-sec9-3.pdf
9

52
 directly from the numbering administrator because the VoIP provider
has, itself, obtained a CLEC certificate or has otherwise been granted
FCC authority to directly obtain the numbers. In no case are VoIP
providers precluded from obtaining and using any particular type of
number – i.e., there are no geographic vs. non-geographic number
restrictions in the U.S. and, there are no restrictions on a VoIP provider’s
assignment of phone numbers to its users.

4.28 Number portability is a regulatory mandate for VoIP providers that are
subject to the FCC’s rules – that is, “interconnected VoIP” providers that
enable calls both to and from the PSTN. Portability is critical to ensuring
a robustly competitive market.

4.29 In the U.S., VoIP providers do not have an obligation to – nor is there
currently a technical methodology to enable it – provide the real-time
location of a nomadic VoIP user who has dialed the emergency services
number, 911. Rather, the FCC has required that the interconnected VoIP
providers, i.e., only those that provide a service that enables calls both to
and from the PSTN, to collect a “registered location” from each customer.
That registered location is then used for purposes of routing the call to
the appropriate emergency call center. It is well recognized in the U.S.
that the user may not be at that location when he/she calls 911.
Therefore, the FCC has also required that interconnected VoIP providers
provide their customers a disclaimer that informs them of the limitations
of its VoIP 911 calling capabilities.

4.30 The U.S. imposes no federal QoS obligations on any type of VoIP service,
including interconnected VoIP which is subject to other regulatory
obligations.

53
 CHAPTER V

SUMMARY OF RECOMMENDATIONS

5.1 The Authority recommends that:

(i) As per Authority’s understanding of present Access service
licences, Internet Telephony service is un-tethered from the
underlying access Network. In other words, Internet
Telephony Service can be provided by Access service provider
to its subscriber who may be using Internet of other Access
service providers. DoT should issue a clarification to the
effect. If DoT has a different understanding, the Authority
recommends that the DoT may issue amendment to Access
service licences so that Internet Telephony service is un-
tethered from the underlying access Network.
(ii) The UL (VNO) licensee with access service authorisation
should also be allowed to provide un-tethered Internet
Telephony in the designated service area.
(iii) Internet Telephony calls originated by International out
roamers from international locations should be handed over
at the International gateway of licensed ILDOs and
International termination charges should be paid to the
terminating access service provider. In case the Access
provider is not able to ensure that Internet Telephony call
originated outside of the country is coming through ILDO
gateway, International out-roaming to Internet Telephony
subscribers of the access provider should not be allowed.
(Para 3.34)
5.2 The Authority recommends that :
(i) The mobile numbering series should be used for providing
Internet Telephony by a service provider. TSPs should be

54
 allowed to allocate same number to the subscriber both for
Cellular Mobile service and Internet Telephony service.
(ii) The SDCA linked numbering series may also be used for
providing Internet Telephony by a service provider. However,
in this case, mobility should be limited to consumer premises.
(iii) The clause 2.5 in UL (access service) related to translation of
E.164 number to IP address may modified as below:

Present Clause Amended Clause

“IP Address assigned to a “IP Address assigned to a
subscriber for Internet Telephony subscriber for Internet Telephony
shall conform to IP addressing shall conform to IP addressing
Scheme of Internet Assigned Scheme of Internet Assigned Numbers
Numbers Authority (IANA) only. Authority (IANA) only.
Translation of E.164 number /
private number to IP address and
vice versa by the licensee for this
purpose shall be as per
directions/instructions issued by
the Licensor.”

Similar clause in other access licences (BSO, CMTS, and UASL)

should also be amended.

(iv) The access service licensee should use private ENUM in its
network for Telephone number mapping from E.164 to
SIP/H.323 addresses and vice-versa.
(v) In case of provision of Internet Telephony by VNO with access
service authorisation, the numbering resource allocation
should be done by the parent NSO. (Para 3.48)
5.3 The Authority recommends that:
i. The licensees should comply with all the interception and
monitoring related requirements as specified in the licence as
amended from time to time for providing Internet Telephony.
ii. The Public IP address used for originating/terminating
Internet Telephony calls should be made a mandatory part of

55
 CDR in case of Internet Telephony. The location details in
form of latitude and longitude should also be provided
wherever it is feasible.
iii. CLI Restriction (CLIR) facility should not be provided for
Internet Telephony Subscribers. (Para 3.51)
5.4 The Authority recommends that the access service providers
providing Internet Telephony service may be encouraged to facilitate
access to emergency number calls using location services; however
they may not be mandated to provide such services at present. The
subscribers may be informed about the limitations of providing access
to emergency services to Internet Telephony subscribers in
unambiguous terms. (Para 3.63)
5.5 The Authority recommends that:
i. QoS on Internet Telephony may be left to the market forces.
The service providers must inform QoS parameters supported
by them for Internet Telephony so that the subscribers can
take an informed decision.
ii. The Authority shall review the decision regarding mandating
QoS to Internet Telephony service providers at appropriate
time. (Para 3.69)

56
 List of Acronyms
S.No. Acronym Description
1 ACCC Australian Competition and Consumer Commission
2 ACMA Australian Communications and Media Authority
3 ARPA Advanced Research Projects Agency
4 BITS Basic International Telecommunications Service
5 BSO Basic Service Operators
6 CLEC Competitive Local Exchange Carrier
7 CLI Caller Line Identification
8 CMSO Cellular Mobile Service Operators
9 CMTS Cellular Mobile Telephone Services
10 CPE Customer Premises Equipment
11 CSP Carriage Service Providers
12 ENUM E.164 Number to URI Mapping
13 FBG Financial Bank Guarantee
14 FCC Federal Communications Commission
15 FMT Fixed Mobile Telephony
16 FTAS Fixed Terminating Access
17 FQDN Fully Qualified Domain Name
18 GMPCS Global Mobile Personal Communication by Satellite
19 GSM Global System for Mobile
20 IANA Internet Assigned Numbers Authority
21 IETF Internet Engineering Task Force
22 ILDO International Long Distance Operator
23 IMS IP Multimedia Subsystem
24 IP Internet Protocol
25 IPTV Internet Protocol Television
26 ISP Internet Service Provider
27 ITSP Internet Telephony Service Provider
28 ITU International Telecommunication Union
29 LEC Local Exchange Carrier
30 LFMT Limited Fixed Mobile Telephony

57
31 MTAS Mobile Terminating Access
32 NANP North American Numbering Plan
33 NGN Next Generation Network
34 NLD National Long Distance
35 NSO Network Services Operator
36 NTNP National Telephone Numbering Plan
37 NTP New Telecom Policy
38 NVP Network Voice Protocol
39 PATS Publicly Available Telephone Services
40 PBG Performance Bank Guarantee
41 PCM Pulse Code Modulation
42 PLMN Public Land Mobile Network
43 POI Point of Interconnection
44 PSTN Public Switched Telephone Network
45 QoS Quality of Service
46 SDCA Short Distance Charging Area
47 SIP Session Initiation Protocol
48 TCP Transmission Control Protocol
49 TDM Time Division Multiplexing
50 TSP Telecom Service Provider
51 UASL Unified Access Service Licence
52 UASP Unified Access Service Provider
53 UK United Kingdom
54 UL Unified Licence
55 US United States
56 VoIP Voice over Internet Protocol
57 VNO Virtual Network Operator

58
 Annexure-I

59
60
 Annexure-II

61
62
63
64