TRAI should not be setting stringent Quality of Service (QoS) norms since it is “irrelevant in the Indian scenario”, Cellular Operators Association of India (COAI), a telecom lobbying group said in a response (pdf) to a recent consultation paper on QoS norms for telecom networks. To support this argument, COAI said that “market forces and consumer empowerment” would lead telcos to maintain “acceptable QoS in order to retain and grow their market share.”

QoS parameters are minimum service delivery levels set by TRAI, which it monitors to ensure that customers get a particular experience desired by the regulator. Examples of QoS parameters include call drop rates, network availability, response time to customer for assistance, etc. More here.

The COAI added that hyper-competitiveness in the telecom sector, impending entry of Virtual Network Operators, freedom of consumers to move between networks via Mobile Number Portability (MNP) makes it “irrelevant” for defining stringent QoS norms in the country. Interestingly, it also makes a reference to VoIP calling apps stating that TRAI has only sought comments from telcos regarding QoS “whereas no QoS parameters have been set so far for OTT voice communication services (VoIP)”.

“Since over the last few years, the OTT voice services are being used extensively, any rule applied on cellular network should be equally applicable to the OTT services as well for a level playing field and in the spirit of ‘Same service, same Rules’,” COAI added.

Telecom operators oppose penalties for not meeting quality of service norms

The regulator proposed fining operators who do not maintain their networks within levels set by it. Telecom lobby body Association of Unified Telecom Services Providers of India (AUSPI) and COAI had submitted almost the same comment opposing such a move. Both associations said that operators lose market share as well as subscribers in case they do not meet “good QoS”. This is the biggest financial disincentive in a market which is highly competitive, they added.

COAI said that penalties or fines has never contributed “in either increasing investments or improve quality of service because it cannot”. “Operators have been making extensive investments continuously in their Networks and therefore it is submitted that Financial Disincentive has no nexus with the objective of increasing investments or quality of service. Further, we believe that it is a misguided approach,” it added.

Telecom operators oppose granular monitoring of network parameters

TRAI’s suggested that current QoS parameters could be concentrated down till a sub-service level, district level or Base Transceiver Station (BTS) level. However, COAI stressed that performance of a (telecom) network can be judged only at a Licensed Service Area (LSA) level or circle level and not any other lower level due to:

-Natural and man-made barriers hindering setting up of towers and other telecom infrastructure,

-Interference in networks due to high density of buildings, vehicular traffic, hilly terrain, weather, etc

-Absence of mandatory Right of Way permissions to lay down telecom infrastructure, stringent laws regarding ElectroMagnetic Field (EMF) levels being emitted from towers.

“..it would be unreasonable and arbitrary to mandate QoS parameters without taking into consideration the submissions made by TSPs (telcos) regarding external factors, beyond their control,” COAI said in its submission.

Telecom operators oppose monitoring of user call data records

The regulator also considered calculating Call Drop Rates by analyzing subscriber’s Call Data Records (CDRs). However COAI and AUSPI, telcos including Idea, Vodafone, RCOM, Aircel have opposed this. They argued that CDRs can be used for billing purposes only and not for the function of determining Call Drop Rates.

COAI said that call durations vary from customer-to-customer with subscribers spending seconds to hours on different calls. “Metrics such as call duration may also depend on customer behavior…such as conserving talk time in case of low balance which may result into a shorter call duration than usual,” it added.

TRAI suggested CDRs for determining call drop rates since it found that more than 30% of calls were less than 30 seconds of duration. To this, Aircel pointed out in its response that “this data point itself emphasizes that there is huge tendency among mobile subscribers to make voice calls of small duration (less than 30 sec).”

P.s.: We noticed that the submissions from COAI, AUSPI were almost exactly the same. Why have two associations then?