Section 15 in Intelligent Network Services in Multi Operator and Multi Network Scenario Regulations, 2006
15. Summary of the main comments of Stakeholders :-
(i)Network architecture wherein the SSP of originating access provider connects to the SCP of the interconnecting operator over CCS-7 link for authentication and other purposes has a number of technological pitfalls, integrating SSPs based on different technologies within existing SCPs is a difficult task.(ii)It would be very difficult and cost prohibitive for any Access Provider to not only procure SCP equipment to cater to its own customer base but also to size it for current and future customer base of all other Access Provider's in the absence of any knowledge of the business plans of the competitor.(iii)For services which rely only on signalling network, and do not rely at all on bearer network, this would require investment on small signalling platforms to be able to screen and account signalling messages and generate CDRs for inter-operator billing.(iv)Appropriate TEC GR does not define the capability set for SCPs supporting all protocols on one platform. In the absence of this and limitations of existing SCPs, implementation and that too uniform implementation across all operators is doubtful.(v)IN service is a value addition over Basic services. Such value added services have so far not been regulated by TRAI. Accordingly, IN services also need a similar treatment.(vi)All efforts should be made for Integrating SSP of all technologies with SCP of different technologies as SSP of one Service Provider interacting with SCP of different Service Providers at signalling interconnect level is the final solution for all kind of IN services. Protocol for IN services needs to standardized.(vii)There is an overlap in the domains of Access Providers and NLDOs and the service can be provided jointly by Access Provider and NLDO. These services will yield the best result if left for mutual arrangements to be made amongst the operators.(viii)Commercial arrangements and revenue share for IN services should be left for the mutual negotiation between the operators.(ix)IN regulations should be in conformity with the various court orders/license agreements/commercial requirements.(x)Security aspect will need to be kept in mind while finalising the IN Regulation.(xi)The issue of interconnect seeker and interconnect provider will need to be addressed.(xii)A list of allowed/not allowed services should be given to help in avoiding potential misinterpretation of the Regulation and subsequent litigations.(xiii)In order to avoid ambiguity and achieve the objective of providing free choice to all subscribers for IN services of all Intelligent Network Service Providers (INSPs), very clear billing, charging and revenue share guidelines for each type of IN service need to be specified.(xiv)The start up cost for IN services and also for continued investment for platform upgrades for deployment in a Multi Operator, Multi Service environment will have to be borne by INSPs.(xv)The issue who provides intelligent peripherals (like announcement) needs to be addressed.(xvi)How the location based IN services - when accessed by a subscriber of other access provider will be handled.(xvii)Issue of how the national and international roamers could use the IN services needs to be addressed.(xviii)There are chances of misuse, if 18xx call is handed over by the access provider to the INSP. Access provider will not able to know what service INSP is providing, once call is handed over to INSP.(xix)The interest of access provider should be protected.(xx)There are IN service providers (generally vendors) outside India who already have infrastructure and workable architecture for providing these services. These models should be studied and analysed in our context. Option of IN services provided by the third parties should also be explored.
