CONSULTATION PAPER ISSUED BY

THE INFOCOMM MEDIA DEVELOPMENT AUTHORITY

ON

IMPLEMENTATION OF IP-BASED INTERCONNECTION IN SINGAPORE

1 MARCH 2021
INTRODUCTION

1. On 20 February 2019, the Infocomm Media Development Authority (“IMDA”)

issued a public consultation on the draft Code of Practice for Competition in the
Provision of Telecommunication and Media services (“Public Consultation”).
Subsequently, on 5 January 2021, IMDA issued an explanatory memorandum
on its decisions on the Public Consultation (“IMDA’s Decision”).

2. In the Public Consultation, IMDA holistically reviewed the regulations and

competition management for the Singapore info-communications media sector,
with the aim of developing a harmonised competition code for the
telecommunication and media markets. In addition, IMDA also reviewed
developments in the telecommunication market to ensure that its policy
frameworks continue to be relevant to the industry.

3. As IMDA noted in the Public Consultation, a significant development in the

Singapore telecommunication market has been the deployment and
widespread take-up of services on the Nationwide Broadband Network
(“NBN”). This development has contributed to the migration of services and
end-users from traditional copper and hybrid fibre-coaxial-based networks to
Internet Protocol (“IP”)-based networks - for example, the transition from Time
Division Multiplexing (“TDM”)-based voice services to IP-based voice services.
The growing take-up of Over-the-Top (“OTT”) voice and messaging services
that use IP-based networks has also further reduced reliance on and utilisation
of traditional voice and messaging services, and fuelled the demand for data-
centric services. In line with these developments, IMDA proposed in the Public
Consultation a number of changes to the interconnection regime, particularly
the following two proposals:

(a) To change the current interconnection charging regime for fixed-line call
termination between operators from “Calling Party Pays” (“CPP”) to “Bill-
and-Keep” (“BAK”), i.e. zero termination rate to the terminating operator;
and

(b) To replace the existing interconnection regime from Signalling System No.
7 (“SS7”) to IP-based signalling.

4. Following the close of the Public Consultation, IMDA carefully reviewed

respondents’ comments. In IMDA’s Decision, IMDA maintained its proposal to
change the interconnection charging regime for fixed-line voice termination
from CPP to BAK. IMDA noted that this change of the interconnection charging
regime for fixed-line call termination to BAK would be in line with the current
mobile interconnection charging regime, which is based on a zero mobile
termination rate. This would allow for a harmonised interconnection charging
framework for all domestic telephony services, which would be appropriate
given that all these services would eventually be provided over IP-based
networks. For the industry to effect the change to BAK, IMDA allowed a 3-year
glide path.

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5. In view of technology and market developments for fixed-line voice termination,
IMDA also proposed to review the case for IP-based interconnection in the
Public Consultation.

6. As highlighted in the Public Consultation, given the growing volume of IP-based

and Voice over LTE (“VoLTE”) calls, IMDA would consider interconnection at
the IP-level to be the new default going forward, replacing the existing SS7
signalling. From respondents’ submissions to the Public Consultation, IMDA
noted that respondents were broadly supportive of the proposal to migrate to
IP-based interconnection. One respondent agreed that IP-based
interconnection would allow efficient exchange of voice traffic, while another
respondent submitted that as traffic exchanges would be expected to converge
towards a multi-service IP-network, IP-based interconnection should be the
way forward for the industry.

7. IMDA agrees with the respondents and views that IP-based interconnection
may bring about higher operational efficiency for voice traffic and improved
voice call quality. In addition, IP-based interconnection may also result in cost
savings and reduced complexity for operators in the steady state. With the
eventual phasing out of technologies and equipment based on SS7 signalling,
and the progressive transition of end-users to IP-based services, IMDA shares
the respondent’s view that IP-based interconnection would be the way forward
for the industry. As a long-term policy consideration, migrating the
interconnection of all domestic networks in Singapore to IP-based ones would
also serve to increase the overall efficiency of voice communication in
Singapore.

8. On how IP-based interconnection should be implemented, one respondent

opined that it would involve complex technical issues that would have
commercial implications for the industry. Another respondent agreed that such
a migration towards IP-based interconnection would be a major exercise, as
significant amount of effort and resources, as well as implementation lead-time,
would be required to replace existing switches and/or interconnect
configurations, in addition to requiring co-ordinated efforts amongst all parties.

9. In IMDA’s Decision, IMDA agreed with the respondents that a separate in-depth
consultation would be appropriate to review and address the industry’s
technical, operational, and commercial concerns in implementing IP-based
interconnection as the default in Singapore.

10. In this regard, IMDA hereby issues this consultation, inviting views and
comments on IMDA’s proposals and preliminary views on the implementation
of IP-based interconnection in Singapore.

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IMPLEMENTATION PROPOSALS

11. IMDA’s proposals are set out in the following sections:

(a) Scope and technical requirements;

(b) Singapore Telecommunications Limited’s (“Singtel”) Reference
Interconnection Offer (“RIO”) for IP-based interconnection;
(c) Impact to number portability;
(d) Network security and Quality of Service; and
(e) Migration approach.

Scope and Technical Requirements

12. At the outset, IMDA would like to define the regulatory scope for the
implementation of IP-based interconnection. IMDA recognises that under the
current environment/landscape, a full end-to-end deployment of IP-based
signalling protocol in the operator’s network may not be feasible in the
immediate to near term, especially in view of legacy network elements, and
some international voice traffic terminating and/or transiting the operator’s
network which may still require SS7 signalling to establish the calls. Given the
above context, IMDA proposes, at this time, to require only the establishment
of IP-based signalling protocol at domestic Points-of-Interconnection (“POIs”)
across all operators’ networks that are interconnected to provision voice
services.

13. Based on the above defined scope, IMDA is of the preliminary view that all
operators should follow a standardised set of technical requirements to
implement IP-based interconnection at domestic POIs. IMDA notes that a lack
of standardisation in technical requirements when implementing IP-based
interconnection may give rise to various issues, including call quality problems;
impeding the development of higher call quality; and possible higher costs for
IP-based interconnection (to support multiple configurations such as
transcoding between voice codec standards, etc.). With a standardised set of
technical requirements deployed by all operators for IP-based interconnection,
issues relating to the inter-operability of systems and hardware, which will have
an adverse impact on the provision of voice services, may be avoided. IMDA
believes that standardising the technical requirements for IP-based
interconnection will lower the overall migration risk, and minimise any service
disruption to end-users. Similar views have also been shared by overseas
regulators, such as UK’s Ofcom, which has conducted a public consultation on
this matter1. Nonetheless, IMDA understands that such standardisation may
have an impact on operators who have deployed certain IP-based technical
configurations in their networks and would prefer minimal changes, if any.

1 Ofcom launched the consultation ‘Future of interconnection and call termination’ on 11 April 2019.
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Question 1:
IMDA invites views and comments on whether operators should follow a standardised
set of technical requirements to implement IP-based interconnection at domestic POIs
across all operators’ networks that are interconnected to provision voice services.

14. Based on the consultation responses, IMDA will determine an appropriate and
relevant mode of IP-based interconnection for Singapore. IMDA would like to
further propose that operators adopt the Session Initiation Protocol (“SIP”)
based on IETF2 and 3GPP3 specifications at the POIs (the “Proposed SIP”).

15. IMDA understands that the Proposed SIP, which is defined by IETF standards,
also fulfils the specifications of 3GPP. As it is based on the use of the IP
Multimedia Subsystem (“IMS”) defined by 3GPP, the Proposed SIP is deemed
appropriate for operator’s networks that use an IMS. Further, the Proposed SIP
is suitable for the growing proportion of VoLTE calls over mobile networks,
which are based on SIP and IMS specified by 3GPP.

16. Notwithstanding IMDA’s proposal for the Proposed SIP to pave the way for all
domestic telephony services to be eventually provided over IP-based networks,
IMDA notes that there are other SIP standards which are commonly deployed
in other jurisdictions and can also be considered for Singapore. For example,
based on the case studies4 by BEREC (“BEREC’s Case Studies”) on IP-based
interconnection deployed in the European Union (“EU”), the fixed network
operators analysed by BEREC had mostly deployed SIP (IETF and 3GPP), with
some deploying SIP (IETF) or SIP-I5 (ITU-T). All the mobile network operators
in BEREC’s Case Studies had deployed SIP-I (ITU-T).

Question 2:
IMDA invites views and comments on whether the Proposed SIP, based on IETF and
3GPP specifications, is appropriate and suitable to be implemented at the POIs.

Singtel’s RIO for IP-based Interconnection

17. Depending on the eventual agreed migration plans by industry, IMDA notes that
each operator could have differing readiness levels for implementing the
Proposed SIP at all the POIs established with the other domestic operators. In
such a scenario, IMDA believes that a transition period may be inevitable,
whereby operators may have to support and cater for both SS7 and the
Proposed SIP signalling at the POIs (“Transition Period”).

2 IETF: Internet Engineering Task Force

3 3GPP: 3rd Generation Partnership Project
4 ‘Case studies on IP-based interconnection for voice services in the European Union’ issued by BEREC

on November 2015.
5 SIP-I (ITU-T): SIP which is defined by IETF, but used in a specific way defined by ITU-T. SIP-I is a

hybrid signalling protocol where TDM-based signalling protocol (ISUP) is transported within the IP-
based signalling protocol (SIP).
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18. Considering the possibility of a Transition Period, and that interconnection with
Singtel (being the Dominant Licensee regulated under its RIO for TDM-based
interconnection) is currently offered based on SS7, IMDA is of the view that it
may be necessary to firm up the specific details of the interconnection
arrangement under an IP-based interconnection environment before
commencing the migration. IMDA considers that providing clarity to the industry
on the specific details of any IP-based interconnection arrangement with Singtel
will facilitate the migration planning and preparation of industry players who are
currently directly interconnected with Singtel via Singtel’s RIO. This will also
serve as a reference for other IP-based interconnection arrangements between
Non-Dominant Licensees which are commercially negotiated. With both sets
(TDM-based and IP-based) of interconnection arrangements ready/in place,
IMDA believes the Transition Period will be smoother and more manageable
for the industry.

19. In this regard, following the conclusion of this consultation, IMDA intends to
require Singtel to propose the offerings of the RIO services related to IP-based
interconnection for IMDA to consult the industry on. Once the RIO offerings to
support IP-based interconnection are finalised and approved by IMDA, IMDA
will engage the industry further on implementation and migration plans.

20. Primarily, IMDA will require Singtel to propose an RIO offering that will
eventually replace the current RIO Schedule 1 – Physical and Virtual (Distant)
Interconnection. The proposed offer should contain a similar level of technical
details, requirements and specifications (including transmission, signalling,
routing, interconnect testing, etc.) to enable operators to establish IP-based
interconnection with Singtel’s network. At this juncture, IMDA believes that IP-
based interconnection should also be on reciprocal terms and conditions, as
per the current interconnection regimes, and that all parties should bear their
own cost of establishing interconnection.

21. In order to ensure the public’s uninterrupted access to emergency call services,
IMDA will also require Singtel to propose a similar service to be offered under
IP-based interconnection, if the implementation of IP-based interconnection
affects Singtel’s provision of emergency call services under Schedule 4A of the
RIO.

Question 3:
IMDA invites views and comments on the proposed approach to finalise the offerings
of the RIO services related to IP-based interconnection, before commencing the
migration to IP-based interconnection.

Impact to Number Portability

22. In the Public Consultation, some of the respondents submitted that a shift to IP-
based interconnection might have an impact on the existing Fixed Number
Portability (“FNP”) arrangements, and that therefore would be a need to study
the implications.

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23. IMDA understands that the FNP service is currently implemented using an
Intelligent Network (“IN”) solution based on the Query-on-Release (“QoR”)
method. In order to support the QoR method, the network is required to
implement a signalling option to indicate to the originating network that the
dialled number has been ported out. Each network has its own database as the
solution requires the originating network operator to query its database for the
routing number to route the call to the port-in operator. Given that the current
signalling option used to support the QoR method is based on SS7, IMDA
believes that the migration to IP-based interconnection will require changes to
the technical solutions currently implemented for the FNP service.

24. In this regard, IMDA would like to propose the following options for FNP
operators’ consideration:

(a) The FNP operators can review whether there is a similar “Release”
message with a specific cause value under SIP signalling, or a similar
signalling function under SIP signalling, which all FNP operators can agree
to use as an indication to the originating network that the dialled number
has been ported out; or

(b) To adopt an All-Call-Query (“ACQ”) method, given that all FNP operators
have their own database.

IMDA seeks FNP operators’ comments on the feasibility of the proposed

options to change the technical implementation of the FNP service, following
the migration to IP-based interconnection. IMDA also welcomes FNP operators’
suggestions on other feasible solutions.

25. As for Mobile Number Portability (“MNP”), IMDA understands that the technical
implementation of the current MNP service is not related to SS7 signalling.
Thus, IMDA believes that the implementation of IP-based interconnection will
not have an impact on MNP service.

Question 4:
IMDA invites views and comments on the feasibility of IMDA’s proposals to revise the
technical implementation of FNP service in an IP-based interconnection environment.

Network Security and Quality of Service

26. In the Public Consultation, one of the respondents submitted that SS7 was an
established technology which was reliable and secure, with high Quality of
Service (“QoS”). The respondent opined that in comparison, there could be
security and QoS issues if operators were to migrate to IP-based
interconnection. A lower QoS standard would be a concern for operators,
especially those with regulatory obligations to meet IMDA’s QoS requirements.

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27. On network security, IMDA has taken reference from BEREC’s Case Studies
and notes that almost all of the EU operators analysed by BEREC had
interconnected their networks using direct physical interconnection links
(mostly 1 Gigabit Ethernet), and not the public Internet. BEREC noted that such
arrangements would already provide substantial protection against threats from
the Internet. Further, BEREC found that almost all of the EU operators studied
had implemented the recommended security measures for IP-based networks,
such as the use of a Session Border Controller (“SBC”), external Border
Gateway Protocol (“eBGP”) authentication, topology hiding, and firewall, etc. to
protect their networks.

28. IMDA emphasises the importance of operators securing their IP-based

networks to address cyber security risks and vulnerabilities. IMDA believes that
a baseline set of network security requirements that are aligned with industry
best practices should be adopted. These baseline requirements will be in
addition to other security measures and protection that operators should
undertake to protect their own IP-based networks, and/or avoid technical harm
to the telecommunication network and/or system of another operator. Such
baseline requirements can include the following:

a) Monitor and analyse signalling messages to detect malicious traffic6;

b) Adopt signalling firewalling to filter malicious traffic;
c) Harden interconnect infrastructure such as Signalling Transfer Points
(“STP”) and Diameter Signalling Controllers (“DSC”); and
d) Perform external network security assessments and penetration tests
periodically, if domestic exchange points are used.

29. On how a network should be connected to another network under an IP-based

interconnection environment, IMDA will continue to leave it to the industry to
discuss the appropriate and mutually agreed arrangements in good faith, be it
via direct physical transmission links (ethernet or otherwise) or via domestic
exchange points, if operators choose not to take up the RIO for interconnection
purposes. IMDA notes that BEREC’s observation of the EU operators’
deployments reflects the trend that the number of POIs is usually reduced with
the migration to Next Generation Network (“NGN”) and all-IP networks. Thus,
with fewer POIs and the corresponding decrease in the overall number of
transmission links deployed by operators to interconnect the IP-based networks
(as compared to the current overall number of E1 transmission links deployed),
IP-based interconnections may result in cost savings and reduced complexity
for operators in the steady state.

30. Further, IMDA would like to highlight that at any point in time (whether during
the Transition Period or otherwise), IMDA will require each operator to prevent
or minimise any adverse impact on the voice services it is providing to end-
users (including any emergency call services).

6 Malicious traffic includes those used to perform unauthorised interception, service disruption, data
theft, etc.
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Question 5:
IMDA invites views and comments on IMDA’s preliminary views on network security
and QoS under an IP-based interconnection environment.

Migration Approach

31. Broadly, the following is IMDA’s preliminary proposals on the migration

approach:

(a) If industry can agree on and co-ordinate a common cut-over time to deploy
the Proposed SIP at the POIs, then a co-ordinated single migration
approach may be more efficient overall; or

(b) If there is differing readiness of the operators to deploy the Proposed SIP
at the POIs, then a phased approach with a Transition Period may have
to be adopted for industry to migrate in phases.

Further, to avoid/minimise migration issues, IMDA considers that it may be

prudent for industry to conduct a co-ordinated industry-wide trial migration on
testing platforms first before actual migration, while IMDA will remain involved
in facilitating the exercise.

32. IMDA is of the view that the assessment of whether a co-ordinated single
approach or a phased approach is more appropriate can only be carried out at
a later stage when there is more clarity on the various aspects of the
implementation of IP-based interconnection, specifically the technical details.
As such, IMDA will consult and engage the industry on migration plans after
completing (a) this consultation and (b) the proposed RIO consultation to
finalise the RIO offerings for IP-based interconnection.

33. The broad outline of IMDA’s proposed steps to implement IP-based

interconnection in Singapore is appended as Annex 1.

Question 6:
IMDA invites views and comments on IMDA’s preliminary views on the broad migration
approach.

CONCLUSION

34. While this consultation broadly outlines IMDA’s proposals and preliminary
views on implementing IP-based interconnection in Singapore, IMDA
recognises that a migration of this scale will involve many considerations for
each operator to plan, implement and operationalise the change to IP-based
interconnection. Sufficient time needs to be catered for each individual
operator’s preparation and procurement of necessary hardware and/or
systems, and careful planning and co-ordination amongst all operators is critical
to a successful migration. In this regard, IMDA will work closely with the industry

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 to address the issues for the proposed implementation of IP-based
interconnection.

35. Following the close of this consultation, IMDA will give careful consideration to
all views and comments received, in implementing IMDA’s decision on the
matter. In this regard, IMDA may issue a direction and/or make the relevant
changes to the specific regulatory instruments as may be necessary, to effect
the same.

INVITATION TO COMMENT

36. IMDA invites interested parties to submit written comments to this consultation
on the proposed implementation of IP-based interconnection in Singapore.

37. All respondents are requested to keep their comments clear and succinct. All
views and comments should be submitted in soft copy (in both Adobe PDF and
Microsoft Word format) via email to Consultation@imda.gov.sg with the email
header “Consultation on IP interconnection”.

38. All submissions should reach IMDA by 12 noon, 26 April 2021. All views and
comments should be addressed to:

Ms Aileen Chia
Director-General (Telecoms and Post)
Deputy Chief Executive (Connectivity Development & Regulation)
Infocomm Media Development Authority
10 Pasir Panjang Road
#03-01 Mapletree Business City
Singapore 117438

39. In its submission, the respondent should include the following:

(a) Respondent’s statement of interest in the consultation;

(b) Summary of the respondent’s submission; and

(c) Specific comments to IMDA’s consultation questions which are as

follows:

Question 1:
IMDA invites views and comments on whether operators should follow a
standardised set of technical requirements to implement IP-based
interconnection at the domestic Points-of-Interconnection across all
operators’ networks that are interconnected to provision voice services.

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 Question 2:
IMDA invites views and comments on whether the Proposed SIP, based
on IETF and 3GPP specifications, is appropriate and suitable to be
implemented at the Points-of-Interconnection.

Question 3:
IMDA invites views and comments on the proposed approach to finalise
the offerings of the RIO services related to IP-based interconnection,
before commencing the migration to IP-based interconnection.

Question 4:
IMDA invites views and comments on the feasibility of IMDA’s proposals
to revise the technical implementation of Fixed Number Portability
service in an IP-based interconnection environment.

Question 5:
IMDA invites views and comments on IMDA’s preliminary views on
network security and Quality of Service under an IP-based
interconnection environment.

Question 6:
IMDA invites views and comments on IMDA’s preliminary views on the
broad migration approach.

40. IMDA reserves the right to make public all or parts of any written submission
made in response to this consultation, and to disclose the identity of the
respondent. Any part of the submission which the respondent considers to be
commercially sensitive must be clearly marked and placed as a separate annex
to the comments raised. IMDA will take this into consideration when disclosing
the information submitted.

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Annex 1

Broad outline of IMDA’s proposed steps on implementation of IP-based

interconnection in Singapore

Consultation on IMDA's broad proposals for implementing IP-based

interconnection

Issuance of IMDA's decision to the Consultation

Consultation on RIO offerings for IP-based interconnection

Finalisation of the RIO offerings

Finalisation of the Fixed Number Portability service under an IP-based

interconnection environment

IMDA's decision on transition to IP-based interconnection in Singapore

Consultation on migration process

Operators' preparation for migration

Industry-wide trial migration

Commencement of actual migration

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