nrforum bil 4 mixed use digit mnc codes 140407

Author Date Pages

Jan Yngvar Olsen 7 May 2014 1 (65)

Cybercom Group

Lindhagensgatan 126

P.O. Box 30154

SE-104 25 Stockholm

Sweden

Tel +46 8 578 646 00

www.cybercomgroup.com

[email protected]

Cybercom reference: SIN-035-14006-01

7 May 2014

Prepared by: Jan Yngvar Olsen

Email: [email protected]
mailto:[email protected]

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Table of contents

1 Executive Summary ........................................................................................... 4

1.1 Background............................................................................................................. 4

1.2 Analysis .................................................................................................................. 4

1.3 Recommendations .................................................................................................. 5 1.3.1 Mixed use of 2 and 3-digit MNCs under MCC 240 ............................................................................ 5 1.3.2 Shared use of MNCs under the Swedish geographic MCC 240 ........................................................ 5 1.3.3 ...................................................................................................... 6 1.3.4 General policies to further safeguard MNC resources ....................................................................... 6

2 Scope of study.................................................................................................... 7

3 Standardisation and evolution in the use of MNCs ......................................... 8

3.1 Structure of IMSI, MNC and MCC ........................................................................... 8

3.2 Key provisions of the standards and specifications ................................................. 9

3.3 Use of the identification plan ................................................................................... 9

3.4 Use of the identification plan for routing of signalling ............................................. 10

3.5 Current use of 2 versus 3 digit MNCs.................................................................... 10

3.6 Possible change from 2 to 3 digit MNCs ............................................................... 11

4 Background and overview of possible MNC changes .................................. 12

4.1 New service providers ........................................................................................... 12 4.1.1 Machine-to-machine (M2M) applications ......................................................................................... 12 4.1.2 Unbundling/decoupling of services .................................................................................................. 13 4.1.3 Coverage solutions to increase capacity and improve service quality ............................................. 13

4.2 MNC assignment criteria ....................................................................................... 14

4.3 How to meet demand for MNC resources ............................................................. 14 4.3.1 Introducing 3 digit MNCs ................................................................................................................. 15 4.3.2 Use of shared MNCs ....................................................................................................................... 16 4.3.3 MNCs under new MCCs .................................................................................................................. 16 4.3.4 Embedded SIM solution .................................................................................................................. 17

5 New services/applications and their MNC requirements .............................. 18

5.1 Utilities and security .............................................................................................. 19 5.1.1 Characteristics of market and service requirements ........................................................................ 19 5.1.2 Expected MNC requirements .......................................................................................................... 20

5.2 Automotive applications (eCall, etc) ...................................................................... 21 5.2.1 Characteristics of market and service requirements ........................................................................ 21 5.2.2 Expected MNC requirements .......................................................................................................... 24

5.3 Independent providers of unbundled services ....................................................... 26 5.3.1 SMS service providers .................................................................................................................... 26 5.3.2 Roaming service providers .............................................................................................................. 26 5.3.3 Mobile OTT Service providers ......................................................................................................... 26 5.3.4 Expected MNC requirements .......................................................................................................... 27

5.4 Providers of small cell coverage solutions ............................................................. 27 5.4.1 Public networks ............................................................................................................................... 27 5.4.2 Private networks .............................................................................................................................. 28 5.4.3 Expected MNC requirements .......................................................................................................... 28

5.5 Summary .............................................................................................................. 29 5.5.1 Transformed industry structure........................................................................................................ 29 5.5.2 MNC requirements .......................................................................................................................... 30

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6 Summary of discussions with Swedish market participants ....................... 31

6.1 Scope of the survey .............................................................................................. 31

6.2 Present use of assigned MNC resources .............................................................. 32

6.3 Need for MNC resources ...................................................................................... 32

6.4 ........................................................... 33

6.5 Impact on existing operations from mixed use of 2- and 3-digit MNCs under

................................................................................................................ 34 6.5.1 Core and access network systems and implementations ................................................................ 35 6.5.2 Billing and mediation systems ......................................................................................................... 35 6.5.3 Roaming agreements and related arrangements ............................................................................ 36 6.5.4 Interconnection arrangements ......................................................................................................... 36 6.5.5 Summary of potential impact on existing operations ....................................................................... 36

7 Analysis of mixed use of 2- and 3-digit MNCs ............................................... 38

7.1 Required changes to standards and specifications ............................................... 39

7.2 Impact on the different areas of operation ............................................................. 39 7.2.1 Core & access network systems, Mobile terminal behaviour .......................................................... 39 7.2.2 Billing and mediation systems ......................................................................................................... 43 7.2.3 Roaming arrangements and agreements ........................................................................................ 43 7.2.4 Interconnection arrangements ......................................................................................................... 45

7.3 Potential scenarios................................................................................................ 45

8 Analysis of the use of shared MNCs under geographic MCC ...................... 47

8.1 Shared MNCs as alternative to unique MNC ......................................................... 47 8.1.1 Shared MNC as identifier of networks and subscribers ................................................................... 48 8.1.2 Shared MNC in the Radio Access Network (RAN) .......................................................................... 49 8.1.3 International roaming ....................................................................................................................... 50

8.2 Implementation scenarios ..................................................................................... 51

9 International outlook ........................................................................................ 52

9.1 Netherlands .......................................................................................................... 52 9.1.1 Mixed use of 2 and 3-digit MNCs .................................................................................................... 53 9.1.2 Use of shared MNCs ....................................................................................................................... 53

9.2 Norway ................................................................................................................. 53

9.3 USA ...................................................................................................................... 54

9.4 India ...................................................................................................................... 54

10 Conclusions and recommendations ........................................................... 56

10.1 Reasons for change .............................................................................................. 56

10.2 Possible solutions and scenarios .......................................................................... 58

10.3 Recommendations ................................................................................................ 61 10.3.1 Mixed use of 2 and 3-digit MNCs under Swedish MCC 240 ....................................................... 61 10.3.2 Shared use of MNCs under the Swedish geographic MCC 240 ................................................. 62 10.3.3 ............................................................................................... 62 10.3.4 General policies to safeguard MNC resources ........................................................................... 62

11 References .................................................................................................... 64

12 List of abbreviations / acronyms ................................................................ 65

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1 Executive Summary The focus of this study is the expected shortage of MNC resources and possible solutions, in particular the possible mixed use of 2 and 3 digit MNCs under Sweden mobile country code (MCC) 240. The study has been carried out by Cybercom on behalf of the Swedish Post and Telecom Authority (PTS). The study is based on comprehensive consultations with a number of Swedish operators and other market participants. The results of these discussions form the basis for the further analysis presented in this report.

1.1 Background

A shortage of MNC numbering resources is expected over the coming years. New services and business models are assumed to result in continued fragmentation of the mobile services value chain resulting in a steadily growing number of service providers requiring appropriate MNC numbering resources. A review of the principles for assignment of MNCs, which so far has been reserved for use by public networks offering public telecommunication services, may also be required. There are both commercial and technical reasons for such changes. New users may include: large telematics customers, operators of private (non-public) networks, etc. A change in direction of less restrictive assignment policies will result in further shortage of MNC resources. The need for more MNC resources has been discussed for some time. The MNC may consist of 2 or 3 digits, and most countries, including all European countries, currently use 2 digit MNCs. 3 digit MNCs are used in North America and a few other countries. The possible introduction of 3 digit MNCs in Europe in order to obtain more addressing resources has been brought up from time to time, most recently in a report prepared by CEPT ECC1. Other solutions include use of shared MNCs and more extensive use of MNCs under shared

MCC 901 exists, and a new MCC 902 for international SMS service providers has been proposed by Sweden. Additional 90X MCCs may be considered.

1.2 Analysis

Swedish operators and service providers did not expect any major problems with mixed use of 2 and 3-digit MNCs if introduced in the way proposed, i.e. 3-digit MNCs in the so far unused range 70 99, which would become the range 700 999. Any major impact on roaming arrangements and billing systems were not expected. Particular problems with core and access networks were not foreseen assuming mixed use of 2 and 3-digit MNCs was introduced in a harmonised manner supported by amended 3GPP specifications and updates to systems and networks available from equipment vendors. Mixed use of 2 and 3-digit MNCs is currently not supported by 3GPP specifications, and these specifications would therefore need to be changed. Any 3GPP compliant product can in principle not be assumed to support mixed use of 2 and 3-digit MNCs until specifications have been amended and products are updated and confirmed compliant with the new specifications.

1 ECC Report 212, Evolution in the Use of E 212 Mobile Network Codes.

http://www.erodocdb.dk/doks/doccategoryECC.aspx?doccatid=4

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A specific and widely discussed problem exists with regard to 3GPP specification TS 23.122. The issue related to home network matching and the implementation in mobile terminals is potentially difficult as it would impact the entire terminal population. However, this should mainly be a problem if a new 3-digit MNCs is used by an operator with radio network broadcasting the MNC. It may therefore be easier to assign 3-digit MNCs to operators without radio access networks (typically MVNOs). This could solve a significant part of the problem with shortage of MNCs, as most demand for MNC resources so far seems to come from operators without radio access networks. Finally, some experiences from other countries and regions (e.g. India) suggest that a transition to mixed use of 2 and 3-digit MNCs is manageable and that the issues with current 3GPP specifications should be possible to resolve with reasonable efforts.

1.3 Recommendations

The Swedish Post and Telecom Authority (PTS) as a National Regulatory Authority (NRA)

will have to make sure that shortage of MNC resources will not artificially constrain service

innovation and competition. It is therefore recommended that the following actions are taken:

1.3.1 Mixed use of 2 and 3-digit MNCs under MCC 240

The following approach is recommended:

Announce target date(s) for introduction (i.e. when to start assignments) of 3-digit

MNCs, possibly as a two-stage process. In the first stage, 3-digit MNCs could be

assigned to service providers without own radio network. In the second stage, all new

MNC assignments would be 3-digit MNCs.

The time schedule should permit reasonable time for:

o System updates and testing of key scenarios

o Further clarify details on variations of existing mixed use of 2 and 3-digit

MNCs in some other regions (e.g. India)

Delayed (or partially delayed) introduction of 3-digit MNCs must be accepted if the

tests reveal problems that demonstrate need for more time.

1.3.2 Shared use of MNCs under the Swedish geographic MCC 240

Shared use of MNCs (different service providers or networks would be identified by leading

proposed and planned to be implemented in the Netherlands is a suitable solution to

manage shared use of MNCs.

It is recommended that the NRA leave further development in this area to the market

participants. If Swedish market participants -providers

support this with appropriate MNC numbering resources.

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1.3.3

In a Swedish contribution to ITU, an MCC 902 has been proposed for use by international

SMS service providers. Further shared MCCs for specific types of service providers may be

considered, e.g. international MVNOs, Independent Roaming providers, etc. This may

generally be an effective way to create new MNC resources for operations, business models

and services, which naturally transcend national borders and not necessarily belong to a

specific country.

1.3.4 General policies to further safeguard MNC resources

Different types of MNC resources (geographic and non-geographic) suit different types of

services and applications. The NRA could therefore create policies for assignment of various

MNC resources (2 vs 3-digit codes under geographic MCC, MNCs under shared MCCs

Guidelines or recommendations

would need to be continually updated to reflect availability of various MNC resources and the

continuous evolution of services.

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2 Scope of study

This study, focusing on possible mixed use of 2 and 3 digit MNCs in Sweden, has

been carried out by Cybercom on behalf of the Swedish Post and Telecom Authority

(PTS).

The background for this study is an expected shortage of MNC numbering resources over

the coming years. New services and business models are assumed to result in continued

fragmentation of the mobile services value chain resulting in a steadily growing number of

service providers requiring appropriate numbering resources.

The study is based on comprehensive consultations with a number of Swedish operators

and other market participants. The results of the discussions form the basis for the further

analysis of the issues in this report.

The main focus of the study is the possible mixed use of 2 and 3 digit MNCs under existing

national MCC ). The possible introduction of 3-digit MNCs has been

analysed and the report provides conclusions and recommendations in this regard.

The study also considers alternatives and aspects of using the initial digits of the MSIN part

of IMSI to designate operators under shared MNCs

As background, the study provides an overview of:

Evolution in the harmonisation and standardisation of the MNC concept (ITU-T,

CEPT, GSMA, 3GPP)

Expected demand for MNC resources from various new services and applications

Experiences from some other countries where similar discussions or changes are (or

have been) taking place.

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3 Standardisation and evolution in the use of MNCs

The MNC is part of the IMSI as specified by ITU-T Rec. E.212. As a global addressing

plan, the IMSI is essential for mobile networks in order to facilitate authentication,

roaming, routing and billing, nationally and internationally.

MNC may consist of 2 or 3 digits. The length of the MNC is a national matter. This is

normally regulated by the National Regulatory Authority (NRA), which also is

responsible for assigning MNC resources to network operators and service providers.

Most countries, including all European countries, currently use 2 digit MNCs. 3 digit

MNCs are used in North America and a few other countries. The possible change to 3

digit MNCs in Europe has been brought up from time to time in order to obtain more

addressing space, most recently in a report prepared by CEPT ECC2.

Mobile Network Codes (MNCs) are parts of the International Mobile Subscriber Identity

(IMSI) as defined in ITU-T Rec. E.212. The IMSI and its components provide globally unique

identification of mobile networks and subscribers.

3.1 Structure of IMSI, MNC and MCC

The International Mobile Subscriber Identity (IMSI) consists of max 15 digits and permits

identification at three levels:

Country level: Mobile Country Code (MCC), 3 digits.

Network level: Mobile Network Code (MNC), 2 or 3 digits.

User level: Mobile Subscription Identification Number (MSIN), max 10 digits.

Figure 1: Structure and format of the IMSI

MCCs are assigned by the Director of the Telecommunications Standardization Bureau

(Director of TSB). MCCs in the

MNCs are 2 or 3 digits in length and, in accordance with E.212, are administered by the

respective national numbering plan administrator, usually the National Regulatory Authority

(NRA). MNCs under shared MCCs

2 http://www.erodocdb.dk/doks/doccategoryECC.aspx?doccatid=4

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3.2 Key provisions of the standards and specifications

ITU-T Rec. E.212 defines the structure of the IMSI, its components and usage as well as the

responsibility and principles for the awarding of numbering resources. 3GPP specifications

further refines the concept in the specifications for 3GPP compliant systems3. The following

provisions may be noted with regard to MNCs:

The MNC consists of 2 or 3 digits

(E.212, section 5.c)

INs are to be assigned by the MNC assignee to their subscribed users. A user

The 3GPP specification TS 23.003 further specifies that:

A mixture of 2 and 3 digit MNC codes within a single MCC area is not recommended

and is outside the scope of this specification 4

3.3 Use of the identification plan

The IMSI identification plan is a global addressing plan and was originally devised for use by

mobile networks operators (MNOs). The main functions of the IMSI, with its components

MCC and MNC, is shown in Figure 2 below.

Figure 2: Main functions of IMSI and its components for identification

These basic functions and architecture enable a mobile subscriber to be properly recognised

by home network as well as by visited networks when roaming, as:

3 Mobile technology based on GSM and evolved GSM specifications within the scope of IMT-2000,

i.e. UMTS, LTE, etc. 4 ITU-T Rec. E.212 specifies for shared

within geographic MCCsbut is made explicit by the 3GPP specification TS 23.003 applicable to MNCs under all MCCs, as quoted here.

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IMSI (MCC+MNC+MSIN) uniquely identifies a subscriber and:

o It is stored on the SIM inserted in the mobile terminal

o It is used as the key to the user profile in the HLR

LAI (MCC+MNC) uniquely identifies the network and is broadcast on the Broadcast

Control Channel (BCCH) by the network

This structure is essential for mobile networks in order to facilitate authentication, roaming,

routing and billing, nationally and internationally.

Although originally devised for mobile networks, the IMSI identification plan has been taken

into use also in other types of networks including fixed networks and satellite networks. The

services. Finally, the unbundling of the mobile services value chain creates a number of new

players with need for identification resources.

3.4 Use of the identification plan for routing of signalling

Global Title addresses are used for routing signalling. There are three types of Global Titles

used in mobile networks, E.164 (MSISDN), E.212 and ITU-T Rec. E.214. E.214 defines the

Global Mobile Title (MGT) and how it is derived from the IMSI defined in E.212. The MCC

and MNC are translated to the MGT defined Country Code (CC) and Network Code (NC).

The MGT has a structure similar to addresses defined by ITU-T Rec. E.164, and enable

signalling over SS7 networks. Consequently, as there is a direct relationship between IMSI

and MGT, any changes to E.212 would in principle have a potential impact on E.214..

With the exception of North America, the MGT is used for routing signalling messages.

Because of North American standards and Number Plan, etc., the E.212 addresses are used

directly for routing signalling in North America (World Area 1).

3.5 Current use of 2 versus 3 digit MNCs

Most countries currently use only 2 digit MNCs. By various historic reasons, this includes the

original European GSM countries. Although an option in ITU-T Rec. E.212, the use of 3 digit

MNCs were first defined in 3GPP from R98 (early 1999).

MNCs of 3 digit length are used by the countries and territories in the North American

Numbering Plan and some other countries (in Central and South America and in India).

With the introduction of PCS1900 in North America, it was a regulatory mandate to allocate 3

digit MNCs. However, due to various technical constraints, a so-called 0 suffix rule was

adopted for a transition period. According to this rule, 3 digit MNCs were assigned with the

3rd

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accordingly, and North America is therefore the only region where mixed use of 2 and 3 digit

MNCs is explicitly defined by 3GPP specifications at present time.

3.6 Possible change from 2 to 3 digit MNCs

The possible change from 2 to 3 digit MNCs in Europe has been a subject of long

discussions. After an initiative taken by the CEPT European Committee for

Telecommunications Regulatory Affairs (ECTRA)5 in 2000, GSM Europe (now GSMA) made

an assessment of the possible mixed use of 2 and 3 digit MNCs under the same MCC. The

report6 delivered in July 2001 concluded that:

from a technical point of view, this introduction would cause serious problems to

the existing network operators, both those in the country where the 3 digits MNC is

introduced and in that of their roaming partners. Particularly, the impact on the

roaming agreement cannot be underestimated.

SM Europe is of the opinion that the introduction of 3-digit MNC would in either

case require a technical effort which is not proportionate to the foreseen shortage of

MNC that this introduction would solve.

The need for MNC resources was seen mainly in perspective of the requirements from

traditional full service MNOs with own radio access networks, and there were (and still are)

only a very limited number of such operators per country. GSM Europe mentioned in 2001

the upcoming introduction of UMTS, but concluded that existing GSM operators were

expected to reuse their existing MNCs for UMTS and that a maximum of 4 to 6 UMTS

operators were expected per country. Based on these requirements, no shortage of MNC

resources were expected.

The subsequent developments, in particular the unbundling of the mobile services value

chain, which have seen the emergence of Mobile Virtual Network Operators (MVNOs),

special services providers like SMS service providers, private networks (e.g. small cells), etc.

have changed the situation. Some NRAs are in the process of using up a very significant

part of their existing MNC numbering resources (e.g. Sweden with almost 40 MNCs

assigned, the Netherlands with almost 30 MNC assigned, etc.)

Following its March 2012 meeting, ITU-T Study Group 2 raised the issue of introducing 3

digit MNCs7 as member states experienced increasing demand for MNCs under their

respective MCCs as new services and business models emerge. CEPT ECC has also again

taken up the issue in its recent report 8.

5 Now CEPT Electronic Communications Committee (ECC).

6 http://www.gsma.com/gsmaeurope/wp-content/uploads/2012/03/gsmepositionmnc.pdf

7 ITU-T Liaison Statement COM2-LS129-E, Assignment of 3 digit MNCs and subsequent

communications. 8 http://www.erodocdb.dk/doks/doccategoryECC.aspx?doccatid=4
http://www.gsma.com/gsmaeurope/wp-content/uploads/2012/03/gsmepositionmnc.pdfhttp://www.erodocdb.dk/doks/doccategoryECC.aspx?doccatid=4

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4 Background and overview of possible MNC changes

New services and business models are expected to continue increasing the demand

for MNC resources.

A review of the principles for assignment of MNCs, which so far has been reserved for

use by public telecommunications operators, may also be required. New users may

include: large telematics customers, operators of private (non-public) networks, etc.

There are several ways to meet the demand for more MNC resources. Mixed use of 2

and 3 digit MNCs and more extensive use of shared MNC resources are in the focus of

this study, but other alternatives such as additional shared MCCs are also discussed.

4.1 New service providers

The need for more MNC numbering resources is driven by a number of new developments,

which create opportunities for new types of service providers. The key drivers are

summarised in Table 1 below:

Areas driving demand for MNCs Services providers

M2M Typically MVNO/MVNEs for: Utilities, automotive, security, healthcare, etc.

Unbundling/ decoupling of services Independent service providers: SMS Roaming VoIP

etc.

Coverage solutions to increase capacity and improve service quality

Operators of: In-house coverage Hotspot networks

etc. typically using unlicensed or shared spectrum

Table 1: Developments driving demand for MNC resources

4.1.1 Machine-to-machine (M2M) applications

New telematics applications (Machine-to-Machine applications, M2M) are among the most

important market developments driving the new requirements. The need for customised

service offerings and support adapted to new business models create opportunities for

specialised service providers. An increasing number of niche oriented service providers are

therefore entering this market, typically as specialised MVNOs.

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Specialised MVNOs targeting this market are t

with own core networks and issuing own SIM cards, providing maximum freedom to create

customised service offerings for their target segments.

Issuing own SIM cards also enable service providers to change access provider (host MNO)

more easily, thereby avoiding the so- - -

problem an M2M service provider would have changing host MNO if all SIM cards were to

be changed. The cost of changing the SIMs would in many cases make the change of MNO

economically unfeasible.)

Certain customers and applications may also require improved resiliency and coverage

through access to national roaming arrangements (e.g. power distributors, water utilities, car

manufacturers, etc.). This functionality is sometimes provided by using subscriptions from a

foreign MNO, but may also be provided by an MVNO connected to multiple host MNOs.

As a final aspect, telematics functions are often embedded in products at time of

manufacturing. Products are then distributed and sold in various countries and regions

requiring appropriate mobile subscription solutions for the telematics devices. Moreover,

products and devices may regularly cross borders as part of ordinary use and/or moved from

a country to another as part of change of ownership (all scenarios would be typical for cars,

etc.). Solutions addressing the SIM provisioning as well as the various roaming issues are

therefore required.

These market developments in combination with strong growth of the telematics market are

expected result in increasing demand for MNC numbering resources.

4.1.2 Unbundling/decoupling of services

Unbundling (or decoupling) of services are seen in various areas. Services previously seen

as just integrated parts of the mobile operator service offerings are increasingly being

offered as separate services by independent service providers. Examples of such services

are:

SMS service providers (SMS-SPs)

Alternative Roaming Providers (ARPs)

(OTT) services e.g. Voice over IP (VoIP) service providers, typically

-the- of data connections (e.g. Skype, Viber, etc.)

These independent service providers may generally require MNC resources for interconnect

and traffic termination. Some service implementations may also require MNCs to facilitate

billing and authentication.

4.1.3 Coverage solutions to increase capacity and improve service quality

Small cell implementations ( pico / nano / femto cell solutions) typically for in-house or

coverage, is a third area expected to require MNC resources, in particular if

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provided by independent service providers. Development of small cell networks is generally

driven by the need for improved quality of in-house coverage, increased capacity for data

services in hotspots, etc.

Small cell networks may offer public services or they may be private (closed) networks.

Numbering resources for private networks need to be regulated and harmonised with public

networks when same technologies and frequency ranges are used, and to avoid creation of

technical barriers to future interconnection of the networks.

4.2 MNC assignment criteria

MNC numbering resources enable market participants to operate core networks with own

HLR and to issue own SIM cards with own operator profiles, thereby increasing their

technical and commercial independence of a mobile network operator (MNO) used for radio

access.

Switching of an entire subscriber base from one MNO radio access provider to another can

be done without change of SIM cards. An MVNO with own core may also in principle

connect to more than one MNO, thereby obtaining better network coverage and resiliency.

Operators of private small cell coverage solutions may also need MNC resources for

technical and operational reasons (ref. 4.1.3 above). In case of private networks, this may

require a change of general eligibility criteria for assignment of MNCs as defined by E.212.

MNCs are at present only allowed to be assigned to, and used by, public networks offering

public telecommunication services (ref. 3.2 above). Assignment of MNCs to entities other

than public telecommunication operators would need further consideration.

4.3 How to meet demand for MNC resources

There are various ways to expand the available MNC numbering resources and to utilise

existing MNC resources more efficiently, for example:

Expand numbering resources through the use of 3 digit MNCs

More efficient use MNC resources through use of shared MNCs, in particular HLR

Proxy Provider (HPP) solutions

Use of new MNCs assigned under new MCCs either under national/geographic

MCCs and/or international shared MCCs (e.g. the existing MCC 901 and possibly

under new MCCs 90X

ver-the- SIM provisioning (ref. the GSMA proposed standard for

initially load and change operator

credentials remotely, for example change of home operator without change of

physical SIM. This technology does not create more MNC resources directly, but it

- d require MNC

resources.

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4.3.1 Introducing 3 digit MNCs

Unlike some previous proposals for a general transition to 3 digit MNCs, the solution

proposed by the recent CEPT report assumes, at least for an unspecified transitional period,

a partial transition to use of 2- and 3-digit MNCs under the same MCCs.

Partial transition means that 2-digit MNCs already assigned can be maintained as 2 digit

MNCs. Operators and service providers not able to switch to 3-digit MNCs can therefore

continue to use their existing 2-digit MNCs.

New 3-digit MNCs would be assigned only using combinations of the first two digits that are

different from already assigned 2- -

For example:

-digit MNC in Sweden,

therefore not be available as new MNCs.

available as new 3-digit MNCs.

The plan in Sweden is to use the current MNC range 70 99 as 3-digit MNCs 700 999.

The resulting change of the Swedish MNC numbering plan is shown in Figure 3 below:

Figure 3: Proposed evolution of Swedish MNC numbering plan

Specifically, this plan means:

for use by the operator or service provid

It should also be noted that for technical reasons, it is recommended that for those 2

le for the assignee

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This is the specific plan for 3-d discussed in

more detail in subsequent sections of this report.

4.3.2 Use of shared MNCs

Use of shared MNCs is a way to extend existing MNC resources. For some applications, for

example private small cell networks, not even the introduction of 3 digit MNCs would create

enough MNC resources to satisfy the expected potential demand.

Shared MNCs may then be a feasible solution and the leading digits of the MSIN can be

used to identify different networks. Various alternatives for use of shared MNC are discussed

in more detail in subsequent sections of this report.

4.3.3 MNCs under new MCCs

MNC numbering resources may also be expanded through introduction of additional MCCs.

Two alternatives are possible:

Assigning new geographic MCCs to countries.

o The general rule is that additional MCCs may be assigned by the Director of

TSB when 80% of existing address space has been used, provided that the

national numbering plan administrator can demonstrate efficient use of

existing numbering resources.

o Another option having been discussed is to assign additional geographic

MCC to countries currently using 2 digit MNCs. The new MCCs would then be

dedicated for assignment of 3 digit MNCs. This would be an alternative to

mixed use 2 and 3 digit MNCs under same MCC and would also have various

advantages and disadvantages. Consideration of additional geographic

MCCs is outside the scope of this study, and is not further discussed here9.

Assigning new shared (non-geographic) MCCs in the s

o Shared MCCs would create additional MNC resources and be suitable for

which has been proposed for SMS service providers in a recent Swedish

contribution to the ITU10.

o MNCs under new MCCs may be assigned as 3-digit codes in order to

preserve addressing resources.

9 Additional geographic MCCs were discussed in the GSM Europe assessment from 2001:

http://www.gsma.com/gsmaeurope/wp-content/uploads/2012/03/gsmepositionmnc.pdf 10

COM 2-C4-E ITU-T SG2 MNCs under new MCC for International mobile messaging services
http://www.gsma.com/gsmaeurope/wp-content/uploads/2012/03/gsmepositionmnc.pdf

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4.3.4 Embedded SIM solution

The possibility to initially load and -the-

interfaces, i.e. effective change of home operator without change of physical SIM. Remote

-

raised in connection with telematics implementations, should be resolved.

The GSMA has announced its specification enabling r the air provisioning

and management of Embedded SIMs in machine-to-machine (M2M) devices. According to

this specification, a non-removable SIM is embedded into the M2M device at the point of

manufacture and can later be remotely provisioned with the subscription profile of the

operator providing the connectivity11. First deployments of the GSMA-compliant Embedded

SIM solution are expected to roll out in 2014.

Various solutions have previously been proposed for over the air SIM provisioning and

change of home operator. Except when otherwise explicitly stated, this report assumes use

of solutions based on the above mentioned GSMA specification for this type of functionality.

11

http://www.gsma.com/connectedliving/embedded-sim/
http://www.gsma.com/connectedliving/embedded-sim/

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5 New services/applications and their MNC requirements

Machine-to-machine (M2M) applications, new unbundled/decoupled services in the

mobile value chain and increased use of small cell coverage solutions to improve

capacity and service quality are the main forces driving demand for new MNC

resources. Within the M2M sector, utilities and automotive are the most important

sectors.

Utilities and small cell operations are expected to be main drivers of demand for

MNCs under country specific geographic MCCs.

Automotive applications as well as the various unbundled/decoupled services are

most often international by nature (in terms of product distribution, usage, etc.) and

may be best served by MNCs under shared MCCs that are not country specific.

As briefly discussed in the previous section, we expect that the emergence of a number of

new mobile services and business models will increase the demand for MNCs. This section

provides a more detailed review of some typical applications and business models and the

possible requirements and demand for MNCs, which might be expected as a result of the

developments in these areas.

As discussed in 4.1 above, the main forces driving demand for new MNC resources are:

Machine-to-machine (M2M) applications

New unbundled services and independent service providers

Small cell coverage solutions to increase capacity and improve service quality

The largest M2M segments are the utilities, security and the automotive & transport

segments. The utilities segment, driven primarily by smart metering solutions, is the largest

and fastest growing M2M segment. It is expected that this segment will represent around two

thirds of worldwide M2M device connections by around 202012. The security sector is

expected to represent around one quarter of the M2M market and the automotive & transport

sector another quarter of the worldwide M2M connectivity market by 2020. Regulatory

requirements for installation of eCall facilities in new car models from 2015 are expected to

have an important impact on the development of automotive M2M market in coming years.

12

World wide number of connections. Sources: Analysys Mason and Machina Research. Web site published research abstracts and publicly distributed papers as listed below. Analysys Mason: 2.1 bn by 2020 http://www.analysysmason.com/About-Us/News/Insight/M2M_forecast_Jan2011/ Machina Research: 2.6 bn by 2022 http://www.telecomengine.com/sites/default/files/temp/CEBIT_M2M_WhitePaper_2012_01_11.pdf
http://www.analysysmason.com/About-Us/News/Insight/M2M_forecast_Jan2011/http://www.telecomengine.com/sites/default/files/temp/CEBIT_M2M_WhitePaper_2012_01_11.pdf

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We have therefore chosen the following sectors for further discussion in this section:

Utilities and security sector

Automotive sector (Automotive discussed here as a specific part of the automotive &

transport segment. Transport segment would also include e.g. fleet management,

etc.)

Independent providers of unbundled services

Providers of small cell coverage solutions

The focus of the discussion here is the type of MNC resources (or other solution), which

would be most appropriate for the various sectors and types of applications.

5.1 Utilities and security

Smart metering (e.g. for electricity) and security alarms are the main application in this area.

Other applications include solutions for water utilities, etc. Estimates (see above) indicate

that the utilities and security sectors together account for more than three of four M2M

devices currently installed worldwide and forecasts indicate that these sectors will continue

to dominate the market in coming years. Most M2M service providers consulted as part of

this study provided services to these sectors.

5.1.1 Characteristics of market and service requirements

The utilities sector, in particular, is characterised by very large customers in number of

connections. The market is served by several MVNO/MVNEs specialising in services

targeted at this segment. A main concern is the so- -

Consequently, MVNO/MVNEs, and ultimately also large customers themselves, would prefer

own MNCs in order to issue SIM cards with own operator profiles not tied to any particular

mobile network operator (MNO).

The sectors are well suited for service providers setting up specialised MVNO operations

:

Own core network provides maximum flexibility for creation of services tailored to the

specific customer requirements

As international mobility is not a particular concern due to the very nature of these

services and installations (equipment normally installed in a fixed location), roaming

arrangements will normally be a minor concern. (The problem of establishing a

network of roaming agreements could otherwise have been the main obstacle for

smaller niche oriented MVNO in these sectors.)

On the other hand, national roaming might be necessary in order to meet network

quality/coverage requirements as well as for network redundancy. National roaming

is currently provided by MNOs in form of subscriptions (SIM) with a foreign (affiliated)

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Page 20 of 65

MNO13, but may also be provided by an MVNO having agreements with multiple

MNOs.

-the-

-

large numbers of subscriptions as typical for the utilities sector.

Network redundancy through national roaming arrangements may be provided by a fully

independent MVNO (with own core) with multi-MNO interconnections14. As a service from an

independent MVNO, this would appear as the feasible long term response to these customer

requirements.15

The combined flexibilities obtained through own SIM profiles (physical SIM cards or profiles

-the- -MNO

interconnects for national roaming are illustrated in Figure 4 below.

Figure 4: Embedded SIM only vs. MVNO with national roaming + Embedded SIM

5.1.2 Expected MNC requirements

MVNOs (typically with own core networks) serving these sectors should be expected to

require more MNC resources as these market sectors develop, usually under country

13

Most Swedish MNOs in our survey provide national roaming functionality by use of SIMs issued by foreign associated companies (i.e. operators within same sphere of ownership).. 14

Implementation of a fully functional multi-MNO MVNO model would generally require a fully access agnostic evolved core. 15

An alternative solution provided by MNOs is based on SIMs issued by foreign operators in order to obtain national roaming. Typically SIMs issued by a foreign operator under special commercial agreements to control international roaming costs.

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specific geographic MCCs. As the largest M2M sectors, significant demand for MNC

resources may come from these sectors.

If assignment criteria would permit, large customers may also request right to use MNCs in

- - be resolved by use

of embedded SIM with OTA provisioning of operator profiles.

5.2 Automotive applications (eCall, etc)

Over the next few years, a number of new mobile services are being expected for the

connection of cars. Various connectivity options might be considered depending on the types

of services, applications and implementations.

5.2.1 Characteristics of market and service requirements

Telematics services for the automotive sector include a wide range of services16, for

example:

Emergency services (e.g. the standardised Pan European eCall)

Remote diagnostic services

Stolen vehicle tracking services

Navigation support

Infotainment

etc.

The various alternatives for In-Vehicle systems (IVS) include embedded solutions where

both connectivity and intelligence is built into the vehicle as well as various other options

where connectivity, and in some cases also the intelligence, remains in a separate mobile

terminal.

The main IVS options are shown in Table 2 below:

Components Embedded Tethered Integrated

Communication module Built-in Built-in Brought-in

SIM Built-in Brought-in Brought-in

Intelligence Built-in Built-in Built-in

Table 2: In-Vehicle System (IVS) connectivity options 16,17

16

An overview of such ser, GSMA Connected Car Forum, February 2013. http://www.gsma.com/connectedliving/wp-

content/uploads/2013/02/GSMA_mAutomotive_TechnologyRoadmap_v2.pdf 17

Source GSMA: http://www.gsma.com/connectedliving/wp-content/uploads/2012/03/embedded_sim_imv1v091213vFinal.pdf
http://www.gsma.com/connectedliving/wp-content/uploads/2013/02/GSMA_mAutomotive_TechnologyRoadmap_v2.pdfhttp://www.gsma.com/connectedliving/wp-content/uploads/2013/02/GSMA_mAutomotive_TechnologyRoadmap_v2.pdfhttp://www.gsma.com/connectedliving/wp-content/uploads/2012/03/embedded_sim_imv1v091213vFinal.pdfhttp://www.gsma.com/connectedliving/wp-content/uploads/2012/03/embedded_sim_imv1v091213vFinal.pdf

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For the discussion in this document, we will focus on the requirements of embedded IVS

solutions, which will have typical telematics requirements with regard to subscription issues,

SIM provisioning, etc.18

manufacturer, in most cases the user of the vehicle might not even be aware of the

embedded IVS, and MNO can be assumed contracted by the vehicle manufacturer19. For

, where connectivity module (mobile terminal) and/or

- the situation would be different. The

user should in that case be expected to be fully aware of the communication device, its

subscription, roaming aspects and other cost related issues as for a usual mobile

subscription. The basic subscription requirements should therefore in principle not differ

fundamentally from those of an ordinary mobile phone and its subscription.

Focusing on the embedded telematics services, the automotive applications raise some of

the most complex issues with regard to subscription management:

Devices installed in moving vehicles will experience variable network coverage

conditions and still require the highest reliability of connectivity service (sometimes

for emergency services, etc.)

Vehicles will move regularly across borders (international roaming)

Vehicles typically change owners during product lifetime

Vehicles may be sold/exported and change home country (i.e. country of registration

and country of most frequent use)

There would be a question whether ordinary users/owners of vehicles can be

generally expected to be aware of embedded communication devices and

subscription arrangements in a way similar to the owner of a mobile phone.

Of particular importance in Europe will be the EU requirement that all new models of

passenger cars and light duty vehicles sold and distributed in Europe from October 2015

should be equipped for the in-vehicle pan-European emergency service (eCall). Private

emergency call services already established and provided by various car manufacturers are

expected to continue to exist in parallel with eCall. The operating requirements between 20

Furthermore, car manufacturers may provide a range of value added services in addition to

emergency call service (e.g. Breakdown services (bCall), remote diagnostics, stolen vehicle

tracking, etc.)

18

It should be noted that there are also several other issues which need to be addressed with regard to embedded solutions. Of particular concern might be service availability over lifetime of a vehicle, e.g. GSM services currently available may be switched off in some countries or regions over a

19

For eCall, MNO is assumed contracted by vehicle manufacturer, ref. HeERO presentation to CEPT ECC, Numbering & Networks Working Group, 22 January 2014, page 13 20

Intelligent transport systems - eCall - Operating requirements for Third Party Support http://www.cen.eu/cen/products/en/pages/default.aspx
http://www.cen.eu/cen/products/en/pages/default.aspx

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The introduction of eCall will certainly lead to a strong increase in the number of In-Vehicle

systems deployed. This is also likely to lead to a strong growth in private value added

services, as combined devices for eCall and private services (emergency and value added

services) should be expected. The value added services may enable the car manufacturer to

recover some of the cost of providing mandatory eCall units for all new car models

(estimated to 60-100 euro per unit21).

A typical Dual SIM In-Vehicle System is illustrated in Figure 5 below:

Figure 5: Dual function / Dual SIM In-Vehicle System

The subscription issues (choice of operator, SIM provisioning) will be fundamentally different

for eCall versus private services.

Pan European eCall ( eCall ) will use standard 112 emergency call service (TS12) +

in-band modem for data transfer22, and will therefore be functioning on a pan-

European basis without any local subscription or roaming arrangements.

Private emergency (Third Party Support, TPS) and value added services use

ordinary mobile voice/data services, and therefore require subscription arrangements

with national as well as international roaming.

However, the difference in requirements means that a subscription meeting the requirements

of private value added services also will meet requirements for eCall. It would therefore be

appropriate to focus on the subscription requirements of the private value added services.

These services will need national and international roaming arrangements which are

technically and commercially feasible.

In principle, either the owner/user of the vehicle or the car manufacturer may have the

contractual relationship with the mobile communications provider (MNO or MVNO). For

eCall, the plan is that the car manufacturer will be responsible for contracting with the mobile

communications provider23. For eCall, it is also assumed that subscription will be dependent

on country where contract is taken out. This may be a feasible soltion for eCall, as roaming

21

Indicative figure from industry sources. 22

Data is transferred using in-band modem over the 112 voice channel 23

Ref. HeERO presentation to CEPT ECC NaN meeting 22 January, 2014, page 13.

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For the other telematics services, however,

this may not be the best solution as international roaming would be required. The solutions

in this area will be up to the industry (market participants) to decide.

Based on our interviews market participants, we expect the main subscription requirements

to be:

National roaming may be required in order to avoid coverage problems with a

single operator

International roaming would be required in order to support vehicles moving

temporarily or permanently across borders. Unlike emergency services, private

value added services, as for example remote diagnostics, will often involve more

significant data volumes on regular basis. International roaming on commercially

feasible terms is therefore important.

The possibility to move vehicles with subscriptions (individual subscribers or

blocks of subscribers) from one home network operator to another, without

change of SIM cards, would be generally required.

Various implementations are possible in order to meet the different requirements, but the

ideal solution meeting all requirements may be difficult to find.


The remote -the- management and provisioning of operator profiles on SIM modules

will play a key role in automotive telematics applications. The Embedded SIM specification

as developed by GSMA (see section 4.3.4 above) has been selected for eCall24, and can

therefore be assumed to be de facto standard in this sector. First deployments of the GSMA-

compliant Embedded SIM solution are expected to roll out in 2014, in time for the mandatory

deployment of eCall from 2015.

Irrespective of the possibility to manage operator profiles remotely, there would be various

alternatives for choosing the home operator of subscriptions in order to meet the different

requirements listed above. These are shown in Table 3 below:

24

Ref: http://www.gsma.com/connectedliving/wp-content/uploads/2012/03/embedded_sim_imv1v091213vFinal.pdf
http://www.gsma.com/connectedliving/wp-content/uploads/2012/03/embedded_sim_imv1v091213vFinal.pdfhttp://www.gsma.com/connectedliving/wp-content/uploads/2012/03/embedded_sim_imv1v091213vFinal.pdf

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Subscription options for

automotive M2M

MNC

(assumed

requirements or

preferences)

National roaming International

roaming

Change of home

network

(1) Use MNO in country

other than

home country

(typically one of a few

contracted MNOs in

the region)

MNOs MNC

(foreign)

Yes, as

international

roaming

Yes Embedded SIM /

Remote provisioning

(2) Use an MNO in

home country

MNOs MNC (in

user

country)

Questionable Yes, but may require

negotiations with

each country/MNO

to get acceptable

roaming cost

levels25

Embedded SIM /

Remote provisioning

(3) Use a national

(specialist)

MVNO/MVNE

MVNOs or car

MNC (in

home country)

Yes, assuming

MVNO/MVNE has

agreements with

multiple MNOs

Possible, but

MVNO/MVNE will

need to establish

network of roaming

agreements

Embedded SIM /

Remote provisioning

(4) Use of international

(specialist)

MVNO/MVNE

or

Independent roaming

provider

MVNOs or car

MNC under

shared MCC

(90X)

Yes, assuming

MVNO/MVNE has

agreements with

multiple MNOs

Possible, but

MVNO/MVNE will

need to establish

network of roaming

agreements25

Embedded SIM /

Remote provisioning

Table 3: Subscription options for embedded automotive devices

1. In order to get national roaming, a typical solution at present is to use a SIM from a

country other than the country where the vehicle is expected to be (mostly) used.

This is shown as case (1) in the table above. The fact that the device will be a

permanent international roamer in the country of most frequent use is an important

cost issue, but continuous deregulation of the market should be expected to continue

reducing roaming charges within Europe. The solution may therefore be increasingly

feasible in Europe.

2. Case (2) might be a less interesting alternative for the general telematics SIM

because of national roaming problems. However, it may work for the eCall SIM, as

eCall does not require roaming.

3. Case (3) is the only case among the above which would result in increased demand

for MNCs under national MCCs, but the case might appear less attractive as the

significant efforts required to establish all necessary international roaming

agreements might be uneconomical for an MVNO/MVE with only national focus.

4. Case (4) could be a solution in co-operation with a regional (e.g. pan-European)

MVNO/MVNE with extensive network of roaming agreements in the region. The

25

Within EU, roaming cost should be expected to fall significantly as various regulatory measures such as unbundling of roaming services will result in increased competition and reduced prices. EU roaming regulation now requires all for

. Direct regulatory interventions, such as price caps for certain services, are already used and should be expected more whenever deregulation is not effective.

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Page 26 of 65

MNC(s) could be registered under an international shared MCC . A new MCC

the best solution, as our consultation with

market participants shows that MVNOs and service providers have problems

obtaining acceptable interconnection agreement for operations using the existing

C26. If assignments criteria under such MCC would allow, car manufacturers

may prefer their own MNCs, alternatively establish their own special purpose

MVNOs, which could request unique MNCs.

Consequently, automotive applications are expected to use either existing geographic

National MNOs

might be used for the eCall SIM, as roaming is not required. This sector is therefore

not expected to require more MNC resources under the country specific geographic

MCCs.

5.3 Independent providers of unbundled services

Technical and regulatory evolutions are increasingly opening up new opportunities for

services like SMS, Roaming, and voice/video to be offered by independent service

providers.

5.3.1 SMS service providers

SMS service providers typically provide services for sending and receiving SMSs from/to

connected devices, various solutions for enterprise to individual user communication over

SMS, premium SMS (payment) services, etc. Services can be used for information

distribution, alerts, various forms of two-way communications (e.g. voting, gaming, etc.),

integration with various applications on PC or smartphones, etc.

5.3.2 Roaming service providers

Under new EU regulations from 201227, d

from domestic services should be possible from 1 July 2014. Under same regulations,

requests for wholesale

interesting new opportunities for Independent Roaming providers, and many new providers

might enter this market over the coming months and year.

5.3.3 Mobile OTT Service providers

Multiple OTT Services providers typically offer voice, chat and video services over IP data

connections, accessible through apps on device (e.g. Skype, Viber).

26

providers, MVNOs and service providers report problems obtaining local interconnection agreements for operations using MNCs under this MCC. 27

http://ec.europa.eu/information_society/activities/roaming/docs/roaming_recast11.pdf
http://ec.europa.eu/information_society/activities/roaming/docs/roaming_recast11.pdf

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Page 27 of 65


All services might require MNCs for interconnection and billing purposes, and as all these

services are in principle international in nature, assignment of MNCs under international or

o be the most natural solution. SMS, Roaming and VoIP

service providers are therefore not expected to result in increased demand for MNCs under

geographic MCCs.

As for automotive applications, a

solution. However, our consultation with market participants shows that MVNOs and service

providers have problems obtaining acceptable interconnection agreement for operations

. This problem would need to be resolved for any

MCC. It seems that some type of regulatory intervention, if possible, might be necessary.

5.4 Providers of small cell coverage solutions

Development of public small cell networks is driven by the need for improved quality of in-

house coverage, increased capacity for data services in hotspots, etc. Private networks

using spectrum and technology compatible with public mobile networks will also need to be

taken into account in this area.

The typical cases are shown in Figure 6 below:

Figure 6: Public small cell and private networks

5.4.1 Public networks

There is an increasing interest in small cell implementations for in-house and other

coverage:

MNOs or independent service providers may build in-

(pico/nano cells) to improve coverage and capacity. Reasons might be: high traffic

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load from large number of users (e.g. in shopping malls, offices), need for increased

data capacity in such locations (high concentration of

communication intensive devices as tablets, etc.), problems with macro network radio

coverage in various building structures (e.g. high rise buildings).

Independent service providers may also enter this market implementing networks

based on shared or unlicensed spectrum. Unlicensed spectrum in the 1800 MHz

band (previously used for DECT) is currently subject to particular interest.

Another area which eventually will need to be considered in Sweden is the 3.4 3.8 GHz

band. The spectrum is of potential longer term interest for provision of higher data capacity

local/regional basis, it will need to be considered in this category.

5.4.2 Private networks

Private networks would also need MNC resources as 3GPP technologies of same type as

used in public mobile networks are deployed. LTE might be expected to increasingly replace

WiMAX for many private network deployments. These networks will require MNC resources

for technical implementation, but MNC should be also assigned so that future

interconnection and roaming between various networks (public and private) would be

possible without fundamental changes of numbering.


Independent service providers offering public network services using small cell solutions

would require unique MNC resources.

MNOs may be assumed normally to use their existing MNC resources for small cell

solutions. However, it is conceivable that in some cases, additional MNCs might be

requested. An example could be for in-

also be open for roaming subscriber from other operators. Use of unique MNCs could be a

As deployment of these types of networks and coverage solutions gather pace, an

increasing demand should be expected for MNC resources for this purpose. MNCs

under country specific geographic MCCs would be the natural solution in most cases.

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5.5 Summary

The various services and business concepts discussed in this section shows that the mobile

telecommunications industry is moving towards a more fragmented structure.

The fragmentation of the industry, resulting in more specialised players in both service

provision and radio access, potentially opens for more service innovation, new business

models and investments. These are desirable developments for market and consumers, and

it is important to avoid artificial technical constraints in form of limited MNC resources and

restrictive assignment criteria.

5.5.1 Transformed industry structure

Service requirements and innovation are resulting in a proliferation of specialised service

providers. Specialized service providers access customers over common radio access

infrastructures: MNOs RAN, shared RANs, and specialized (supplementary) access

providers. Figure 7 shows and overview of the various players.

Figure 7: Fragmentation of the mobile telecommunications industry

The radio access network is no longer seen as the main differentiator in the competition. The

increasing interest in shared access infrastructure among traditional MNOs confirms this

trend.

In addition to the MNO operated RANs, we may see an increasing number of independent

providers of specialized access for in-

may use various combinations of licensed, unlicensed and shared spectrum. 3GPP

technology, in particular LTE, is likely to be the technology of choice, but WiFi may also play

The increasing number of players, both in specialized service provision and radio access,

results in a growing demand for MNC resources.

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5.5.2 MNC requirements

Assumed preferences / requirements for various types of subscriber arrangements and the

resulting demand for MNC numbering resources are summarised in Table 4 below.

MNCs under geographic MCCs MNCs under international

shared

Other alternatives

Utilities and security Preferred as roaming normally not

required / significant demand

might be expected

HPP28

,

IMSI range with MNO

Automotive IMSI range with local MNO may

be an alternative for eCall only

(but not for general telematics

with roaming requirements)

Preferred for internationally

distributed products

IMSI range with foreign MNO

Independent providers

of unbundled services

SMS

Roaming

VoIP

Alternative if interconnect

Possible for services which are

local or country specific by nature

Preferred for services which

by their nature would

naturally transcend borders

Providers of small cell

coverage solutions

Public

networks

Preferred assuming requirements

for inbound roaming only /

Significant demand might be

expected

Private

networks

Shared MNC with own IMSI

range.

The use need to be co-ordinated

by NRA

Table 4: Summary of MNC requirements and expected demand per service area

The overview shows that most demand for geographic MNC numbering resources may be

expected to come from the utilities and security sectors and from small cell coverage

deployments.

The automotive sector may be expected to request MNC resources under shared (

type non-country specific MCCs) if such MNC resources are made available. The alternative

is to continue use of subscriptions with (remotely located) foreign MNOs to enable a

combination of national and international roaming. For the eCall SIM, a subscription with a

local MNO may be a feasible alternative as roaming is not required for eCall (as it is based

general telematics SIM would probably be preferred for logistical reasons. This may be an

opportunity for new service providers.

Unbundled services of interest for independent providers are mostly services that by nature

transcend national borders. Consequently, if appropriate MNC resources can be made

available under shared non-geographical e to

be preferred as the most efficient use of total MNC resources available.

28

HLR Proxy solution, ref. section 8.

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6 Summary of discussions with Swedish market

participants

Comprehensive consultations with a number of Swedish operators and other market

participants were an integral part of the analysis.

Potential problems with mobile terminal behaviour (related to 3GPP specification TS

23.122) were the main problems seen in connection with introduction of 3-digit MNCs

that would co-exist with 2-digit MNCs under same MCC. Except for this problem,

market participant only expected minor problems assuming mixed use of 2 and 3-digit

MNCs was introduced in the way proposed.

offering services which naturally transcend national borders. However, participants in

the survey made little use of such codes because of problems to obtain interconnect

agreements on local terms, resulting in increased demand for geographic MNCs in

each of the countries they operate. From a general perspective, this can be seen as

less efficient use of numbering resources.

The study included a comprehensive survey among Swedish operators and other market

participants. The survey was based on interviews and meetings, and the participants were

also invited to provide written comments to the proposed changes.

6.1 Scope of the survey

Operators and market participants consulted as part of the study fall in the following

categories:

Infrastructure based mobile operators with own frequency spectrum (MNOs)

Shared infrastructure providers

MVNOs (Mobile Virtual Network Operators)

MVNOs/MVNEs for M2M (Intermediate Specialised Service Providers for M2M)

Operators of private small cell networks (typically for in-house coverage)

SMS Service providers (SMS-SP)

Telematics solutions/equipment developers/vendors

Mobile network equipment vendors

The participants in the survey were primarily invited to discuss and comment on the possible

introduction of mixed use of 2- and 3- cribed in

section 4.3.1 above. The discussions were focused on the following aspects:

Present use of currently assigned MNC resources

Need for MNC numbering resources. Possible advantages and disadvantages of

introducing 3 digit MNCs in perspective of existing and new services and solutions

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HLR Proxy provider ( HPP

MCC codes were discussed with some market participants as considered

appropriate in perspective of their current service portfolios and configurations

Impact on existing operations of mixed use of 2- and 3-

current MCC 240, with regard to:

o Core and access network systems and implementations

o Billing and mediation systems

o Roaming agreements and related arrangements

o Interconnection arrangements

The results of the discussions are summarised in the following sections.

6.2 Present use of assigned MNC resources

MNOs and shared infrastructure operators use assigned MNC resources for their networks

in the conventional manner.

Other service providers use assigned MNC resources mostly for services not requiring

international roaming. These are mainly M2M services where the assigned MNC numbers

enable service providers to set up specialised MVNOs. These MVNOs are typically so-called

them more flexibility in choice of network operator and more possibilities for customisation of

the services.

For general voice and data services requiring international roaming, service providers

established international roaming networks. The effort required to establish

own network of roaming agreements is generally regarded as commercially unfeasible for

service providers which normally are niche oriented with a more limited number of users.

The

this type of services, and MNCs are not required.

alongside M2M services.

The assigned MNCs are typically used for the M2M operations only.

6.3 Need for MNC resources

All operators and other market participants in the study had currently assigned MNC

resources. All assigned MNC resources were in actual use or were planned to be taken in

use for specific planned services in the near future.

Service providers typically use their MNCs for the M2M oriented MVNO operations, so

growing demand for MNCs should be expected as the M2M market is growing with new

specialised service providers likely to enter the market.

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The automotive sector (including eCall and other telematics applications appear to have the

most complex and urgent problems with existing arrangements. Current services typically

include private emergency/breakdown services, remote diagnostics, etc. These services use

ordinary mobile data connections29. The main issues of concern are therefore:

Access to national roaming in order to ensure network coverage in all locations

where a vehicle might be moving.

Access to international roaming on economically feasible terms, as vehicles regularly

cross borders

Communication devices (In-Vehicle System, IVS) not requiring physical access for

modifications (e.g. SIM changes) after time of manufacture. As the cost of changing

or refitting the communication device for a vehicle in the field (i.e. already sold and

distributed) is very high30 -the-

strong requirement in this sector.

The embedded SIM design (ref. 4.3.4 above) removes the need for physical installation or

change of SIM card in connection with initial provisioning and subsequent changes.

However, it does not by itself resolve the roaming issues for services requiring ordinary

mobile data connections31. In order to resolve the national roaming issue, a typical solution

is mostly used. This might, however, have undesirable cost implications32.

It will be up to the market participants (mobile operators, service providers and car

manufacturers) to find suitable solutions. Depending on solutions, various entities may

require new MNCs, ranging from specialised MVNOs targeting the sector to car

manufacturers themselves (see previous discussion under section 5 above).

6.4 Use of shared country codes ( MCC

Some of the market participants in the study had been awarded MNCs under the shared

country code MCC 901, or they were (or had been) considering applying for such code.

The typical service providers, who could potentially use MNC resources under a shared

international code, operate services which naturally transcend borders and meet the general

requirement in ITU-

demonstrate that its international network infrastructure will contain connecting physical

29

Ordinary mobile data connection might be assumed as to be the usual connectivity option. The

30 Typically in the range of euro 400, according to various indications from industry sources.

31

services, which can be expected to reside in the same IVS, are likely to require ordinary mobile data connections in most cases. 32

Some MNOs provide subscriptions (SIMs) for M2M use from a foreign associated MNO in order to resolve the national roaming issue. For M2M applications with limited mobility, as for example in the utilities sector, this may be a suitable solution. In the automotive sector, however, with vehicles frequently crossing borders, the cost implications might be more difficult to manage.

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nodes in two or more countries. In the case of satellite terminals, serving mobile terminals in

However, the MNCs under MCC 901 are currently considered less useful, as it is understood

that local MNOs generally demand international interconnection rates for interconnect with

operations under MCC 901, as if it was a different country. This is incompatible with the

business models of these service providers, who are therefore forced to apply for MNCs

under geographic MCCs. This may be regarded as less efficient use of numbering

resources.

A new suggested

ITU33, was described in discussions with service providers who could potentially use it. It

was seen as interesting, provided that interconnection could be agreed on feasible terms.

It appears therefore that in order for MNC resources under any new shared MCCs ( ) to

be useful, they must be seen that would be seen as

local in all countries and markets where they are used. This

might have technical34, commercial and regulatory implications. Regulatory intervention may

6.5 Impact on existing operations from mixed use of 2- and 3-digit

Potential impact on existing operations was raised in discussions with all market participants,

but was mainly a topic discussed with MNOs.

The alternative considered for mixed use of 2- and 3-digit MNCs is as described in section

4.3.1 above. This plan assumes that current 2-digit MNCs would remain unchanged and 3-

digit MNCs will be introduced in a separate range of the number plan, currently 70 99,

which would be replaced by 700 999. This way, 3-digit MNCs would be assigned in a

separate range not overlapping with 2-digit codes. Existing 2-digit MNCs will therefore

continue to unambiguously identify the operators and service providers to which they are

already assigned, and operators and service providers not able to switch to 3-digit MNCs

can therefore continue to use their existing 2-digit MNCs.

33

COM 2-C4-E ITU-T SG2 for E.212 MNCs under new MCC for International mobile messaging services. 34

As 3GPP specifications generally assume an MCC code to represent a country, there may be some issues which need to be addressed in this regard. These issues would generally be the same as those that arise when multiple geographic MCCs are used by the same country. As this is already a situation in several countries, it is assumed to be a fully manageable issue.

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6.5.1 Core and access network systems and implementations

In accordance with current specifications (ref. 3.2 above), systems and networks

components based on current 3GPP specification will in principle not support mixed use of

2- and 3-digit codes. In the event of changes, operators assume that required updates will

be available from equipment vendors in accordance with the evolution of specifications.

Operators expect some additional work with system updates and other administrative work if

3-digit MNCs were introduced. This includes both one-time work in connection with the

introduction of 3-digit MNCs as well as more continuous maintenance work due to increased

complexity.

One specific obstacle brought up in the discussions was the consequences of the

specification in The problem

concerns the interactions between the network and mobile terminals, as the radio network

broadcasts the so-called Location Area Identity (LAI), which includes MCC and MNC. The

problem is complex as it concerns both network and the entire mobile terminal population35.

The problem is further discussed in the analysis section (section 7 below).

With the exception of the issues related to TS 23.122 above, operators did not envisage any

fundamental problems with mixed use of 2 and 3-digit MNCs, but generally emphasised the

need for more detailed studies in order to analyse the exact consequences of possible

changes.

6.5.2 Billing and mediation systems

Only minor impact is expected on billing and mediation systems:

For incoming roaming user, billing systems already supports both 2 and 3-digit

MNCs, although the case where a user comes from a country with a mix of 2 and 3-

digit MNCs under same MCC might need to be tested.

Some billing systems may only support 2-digit MNCs for domestic users. Other

MNCs would be classified as roaming. This may be an issue if it is the billing system

of an MNO hosting an MVNO with a 3-digit MNC. However, it would be a commercial

decision for such an MNO when and if to accept hosting an MVNO with a 3-digit

MNC. The MNO would be free to delay hosting of such MVNOs until it can support

the solution technically.

35

The issue is the same as brought up by 3GPP TSG CT WG1 Reply LS on assignment of 3 digit MNC -COM2 LS129 E (March 2012).

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6.5.3 Roaming agreements and related arrangements

Minor impact is expected on roaming agreements and involved systems, as the

implementations already support interaction with operators with both 2 and 3-digit MNCs.

However, in particular the MNOs (as well as some other service providers) emphasise two

critical assumptions:

Existing 2-digit MNCs already assigned will not be changed, and no overlapping 3-

-digit MNCs with

Mixed use of 2 and 3-digit MNCs will be introduced in an internationally harmonised

and co-ordinated manner that will permit general specifications and network systems/

products to be upgraded in accordance with normal procedures.

6.5.4 Interconnection arrangements

Possible impact on interconnection arrangements was brought up in the discussions with

operators, but no potential impact could be identified.

6.5.5 Summary of potential impact on existing operations

The potential impact on

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