Opinion

Country

Comments

Strongly Agree

Australia

ITR provisions most relevant for inclusion in treaty-level instruments such as the Constitution and Convention are those essential principles and undertakings that:
a) must be guaranteed by government-to-government agreement;

b) do not require regular review; and

c) do not duplicate points already contained in the Constitution and Convention.

ITR provisions that should be dropped to the level of Sector Recommendations are those undertakings that:

a) are decided by commercial negotiation, and

b) may require regular review.

On the basis of these principles, Australia considers the following provisions are treaty- level matters and should be integrated into the CS and CV.

Articles to be integrated into CS and CV

Article 1.2 definition of public

Article 1.3 concerning global interconnection and interoperability

Article 3.4 concerning quality of service

Article 4.1 concerning promotion of international services

Articles 1.6, 1.7b and 1.8 encouraging compliance with ITU-T Recommendations

Articles to be devolved to Sector Recommendations

Article 1.5 concerning bilateral negotiation of arrangements to apply between administrations*

Article 2.6 concerning the definition of ‘international route’

Article 3.3 concerning international routing negotiations

Article 4.3 concerning quality of service

Article 5.3 concerning priority communications

Article 6 concerning charging and accounting.

Appendices 1,2 and 3 concerning general accounting provisions, including for maritime and privilege telecommunications.

ITR Articles already covered by the Constitution or Convention

Preamble covered by the Preamble to the Constitution

Article 1.1a covered by Article 1 of the Constitution

Article 1.1b covered by Article 42 of the Constitution

Article 1.7a covered by preamble to the Constitution

Article 2.1 covered by Constitution Annex 1012

Article 2.2 covered by Constitution Annex 1011

Article 2.3 covered by Constitution Annex 1014

Article 2.4 covered by Constitution Annex 1006

Article 3.1 covered by Articles 38 and 1.2c of the Constitution

Article 3.2 covered by Article 1.1c of the Constitution

Article 4.2 covered by Articles1 and 38 of the Constitution

Article 5.1 covered by Articles 40 and 46 of the Constitution

Article 5.2 covered by Article 41 of the Constitution

Article 7 covered by Article 35 of the Constitution

Article 8 covered by Article 5.1 o and p of the Convention

Article 9 covered by Article 42 of the Constitution

ITR Articles covered in Recommendations

Article 2.7 covered by Recommendation D.000

Article 2.8 covered by Recommendation D.000

Article 2.9 covered by Recommendation D.000

Article 2.10 covered by Recommendation D.000

Obsolete ITRs Articles

Australia agrees with the Expert Group’s analysis that the following ITR Articles would become obsolete should the ITRs be integrated into the CS/CV and ITU-T Recommendations:

Article 1.4 concerning the legal status of the ITRs

Article 1.7c concerning implementation of the ITRs by Member States

Article 10 concerning ratification of the ITRs in 1988

Czech Republic

1,1.,1.7.a , Definitions 2.1.-2.4, 3.1 , 3.4 , 4.1 , 4.2 , 5.1 , 5.2 , 7, 8, 9

Denmark

Relevant provisions of articles 3-9.
To the greatest extent possible to be included in Recommendations or other existing instruments but not in the ITU Constitution and Convention which should deal only with ITU functioning etc and not to regulate international telecommunications.

Japan

Article 6 and Appendix 1 to Article 6: These provisions could be and should be covered by ITU-T Recommendations.
Article 5: These provisions are already covered by the Constitution.

Malaysia

Provisions most relevant are Article 4.3 and Article 5

Portugal

In our opinion, most of the ITRs relevant provisions are already reflected in other ITU instruments. Further expert analysis is required before a decision on which, if any, further ITRs provisions need to be integrated in other ITU instruments. (Treaty-level or other)

Portugal (CPR Marconi)

7 (mutual agreements between ROAs), 9 (right of Members to issue authorizations), 18 to 27 (relevant definitions), 30 (right to choose international routes with revision of the wording), 42 to 47 and 51 to 54 (charging and accounting with revision and updating of the wording)

Spain (HISPASAT)

(ITRs) are not already in the constitution or the convention

Sweden (TELIA)

Telia does not see a need for any of the ITR provisions to be transferred to the ITU CS/CV

United Kingdom

The following ITR provisions are no longer appropriate or relevant:

ITR 7 Article 1.5, ITRs 22-25 Articles 2.7-2.8, ITR 28 Article 3.1, ITR 30 Article 3.3, ITR 33 Article 4.2, ITRs 41-54 Article 6 (all), ITRs 55-60 Articles 7-9, Appendices 1-3

The following should be placed in higher level instruments

ITR 29 Article 3.2, ITR 31 Article 3.4, ITR 32 Article 4.1, ITR 34 Article 4.3, ITRs 39-41 Article 5 (all)

UK (Inmarsat)

There is a general trend to apply general legislation regarding competition, consumer protection and data protection to telecommunications networks and services. This has as an effect that the scope of sector specific regulation (i.e. telecommunications law and licensing regimes) is being reduced and is integrated in legislation with a more general field of application. Taking into account this trend the review should aim to reduce sector specific regulation to a minimum and co-ordinate efforts with fora such as WTO in order to avoid duplicating or even conflicting rules to be applicable to the telecommunications sector, which would put this sector at a disadvantage compared to e.g. the IT world. In an environment that is converging rapidly the aim should be to subject substitutable services to identical rules.

In terms of the ITR’s  the proposal to replace or integrate various aspects into the CS or CV should not preclude a review and revision of the ITRs as they currently stand, to ensure they are meaningful in the current  market place.

Somewhat Agree

France (Telecom)

art. 6 (app 1) could be transferred to a non-restrictive D series recommendation

art. 56 and 57 (role in conflict arbitrage) could be deleted

Germany

Article 3.1, 3.2, 3.4, 4.1, 4.2 and 4.3 should be integrated in the Constitution. See remarks to Question 1 on separate sheet.

Kenya

All Articles except Article 6.
Article 6 could be integrated into some easily reviewable instruments such as the ITU Recommendations

Korea, South

Constitution Chapter VII Article 46, Convention Chapter V Article 36~38.

Norway (Telenor)

In the short term, this is probably the most realistic and best solution, even if we would have preferred a termination of the ITRs without compensatory measures.  We have noted that many of the provisions in the ITRs are already covered by similar provisions in the CS/CV.  As few as possible of the remaining provisions should be entered as new provisions in the CS/CV.  The ITRs were developed in a predominantly monopolistic environment, and many of the provisions are more or less irrelevant in today's competitive and commercial environment.

Sweden

The Agency  does not see a need for retaining the provisions in the ITR or  transfer them  to the ITU Constitution or Convention for the moment. Some parts of the ITR may be transferred to Recommendations if deemed necessary.

Further, the Agency is of the oinion that careful studies are necessary before developing any new provisions of transferring any existing provisions from the ITR to the ITU Constitution, Convention or other Treaty Instruments.

UK (Intug)

The issue is one of speed and flexibility of regulation as the e-communications market changes and evolves.  ITU needs to be "fleet of foot" in matching the needs of the market place in terms of technical standards and other regulatory measures.  It must be realized that the market place comprises user needs, both businesses and consumers, and the ICT industries.

Somewhat Disagree

Colombia (Telecom)

Mechanisms should be in place to help countries use the ITRs.
The regulations should be brought up to date to reflect the present international telecommunications market situation.

France

Clearly identified regulations should be maintained.

Iceland

Mali

Given the age of the present version of the ITRs and the advances made over the last 10 years, the regulations need to be brought up to date, and adapted if possible.  This must make the present ITU instruments sufficient.

Peru (INICTEL)

We think that the ITRs should exist.

Saudi Arabia (Telecom)

Article 6 + Appendix 1 : charging and accounting (in particular)

Since the process of international accounting and settlement has become much more commercial, article 6 + appendix 1 could be modified as necessary, but should be retained in the ITR (Final Acts, Melbourne, 1988). Certain other articles, as appropriate, may be modified and devolved into recommendations.

Syria

USA

(Kasstech)

　RASCOM (Regional Org)

International Telecommunication Regulations (ITRs) are generic frameworks and when crafted into a Constitution or Convention they become too binding to Member States or Sector Members in this developing telecommunication environment

Strongly Disagree

Albania

In their present form the existing ITRs are more practical and easier to be enforced.

Colombia

The ITRs are a specialized treaty and need to be studied, as they are different to the Constitution and the Convention, which treat separate issues.  Nor are the delegates at the plenipotentiary conferences necessarily in a position to treat these questions of telecommunication services.

Czech Republic (Telecom)

The existing type (form) of the document is considered as the most appropriate because it has a relevant power.

Ecuador

Those provisions transferred to recommendations would not hold the same degree of obligation. 
Aljlthough the advantage would be that one could select provisions and themes more susceptible to change in the environment and that could be revised.

Egypt

Because we strongly believe that the existing ITRs are very convenient and satisfactory for all the parts of communications

Finland

India

In the present form ITRs provide general principles for operation of international telecommunication services offered to the public as well as to the underlying international telecommunication transport means used to provide such services with a view to facilitating global interconnection and interoperability of telecommunication facilities and to promote the harmonious development and efficient operation of technical facilities, as well as the efficiency. Further, with no guiding mechanism for management and routing of traffic, and settlement of accounting rates amongst the countries, the developing countries may not able to recover their cost of carriage of traffic fully. Most of the developing countries are highly dependent upon international telephone traffic to finance their expansion plans. Without the ITR such countries may be deprived of their justified revenue establishing their network growth. As such it is considered that ITR should be continued.

Paraguay

Mexico

International level guidelines are required for international telecommunications with more force than recommendations.

The Regulations are separate and thus may be revised independently of the ITU Convention and Constitution in the constantly changing telecommunications environment.

Russian Federation

We suppose the efficiency of the regulation is declined due to scattering of various regulatory provisions over different documents.

Senegal

The ITR must remain an Annex of the Constitution and Convention and not an integrated party.

No Opinion　

Spain

An international treaty is necessary, such as the ITRs.

Switzerland

The ITRs in their present form are not up to date. Consequently, and in response to the question about modifying them, Switzerland supports this suggestion.  Such changes should take into account changes in the modern international telecoms market, the progressive liberalization of the sector and the progressive opening of national markets to competition.

Opinion

Country

Comments

Strongly Agree

Colombia

A conference should be organized.
Provisions for accounting rates.
To bring the ITRs up to date concerning convergence and multimedia services.

Colombia (Telecom)

All articles and appendix 1, 2 and 3
As soon as possible.

Czech Republic

Some ITRs provisions are necessary to be kept at the treaty-level status. If they are not incorporated in CS and CV the ITRs should be updated.

Ecuador

- Definitions (relations, themes)
- Accounting (new means of remuneration)
- Services and networks

Egypt (telecom)

We strongly believed that the existing ITRs should be modified according to modification of the international communication and the new invention and means of communications.

India

Continuation of ITR may not be construed as to freeze its provisions for all times. With emerging telecom scenario, the ITR may have to be modified especially to include payment for international internet traffic besides better cooperation of member states (Resolution PL/2), apportionment of accounting rates in favor of developing countries as 60:40 instead of 50:50 applicable currently (Resolution PL/3) and developing procedure for expeditions exchange of accounts and their settlement (Recommendation WG PLA/A). The WCIT may be held in 2002 after necessary preparation.

Ireland

Jordan (Telecom)

Generally most provisions, in particular international network & telecom services

Mali

All provisions affecting institutional reform and technological change
A CMTI should be held as soon as possible.

Mexico

The ITRs need to be completely revised for todays telecommunications environment, and the WCIT should be held as soon as possible.

Paraguay (ANTELCO)

Art. 4:  International telecommunications services should cover the latest generation of services.

Peru

Peru (INICTEL)

After 12 years, the ITRs should be brought up to date.

Russian Federation

Article 9 of the International Telecommunication Regulations should be revised in that part of the provisions concerning GMPCS, IMT-2000 and IP-telephony regulation. We think that the WCIT should take place after making another round of multilateral negotiations within the framework of the WTO and after conducting the ITU Plenipotentiary Conference-2002.

Senegal (SONATEL)

1. In general speaking, the ITRs should follow up the evolution of the telecommunication sector environment. An adaptation needs to be done.
International network;
International telecommunications services.
2. WCIT should be held around 2002

Spain (HISPASAT)

Must be studied in conjunction with 3A).  Perhaps a conference is unnecessary if the PP can make some changes.  A day of the PP could be given over to an ITRs conference.

Switzerland

If at the time of the modifications, compromises can not be reached, or if a yet another document is produced that still cannot be used in practical terms, then Switzerland is in favor of abolishing the regulations altogether.

Syria

All articles, 2004

RASCOM (Regional Org)

International Telecommunication Regulations on IP Telephony should be designed and established as voice over Internet (VoIP) and even Data over Internet (DoIP) is becoming a remarkable phenomenon and should be regulated in a win-win situation.

Somewhat Agree

France

1. Detailed work to determine provision to be up-dated should be carried out. MW)
2. New provisions linked to the changes in the sector and the role of administrations could be introduced.
3. Hold a conference ASAP after the PP02, i.e. beginning 2004.
4. Evaluate the telecom sector between now and 2004 to follow point 1) and 2) above.

Kenya

All Provisions need to be updated.
The WCIT should be held as soon as possible.  In any case not later than 2003.

Saudi Arabia (Telecom)

Certain provisions could be modified and retained at treaty-level, for example those dealing with government-government agreement. There may also be need for ITRs for routes where one or both ends are non-competitive, and for developing countries in general.
The WCIT should be held after the next plenipotentiary.

Spain

Somewhat Disagree

Germany

We feel that the paradigm of telecommunication has changed. Details of operation are no longer a matter of governments but of commercially operating companies. Therefore, we feel that international treaties for this purpose are inappropriate.

Iceland (Telecom)

Swaziland

The ITRs are of mutual benefit to the administrations that operate international networks and as such should be adopted by the users raising them to treaty-level status.

UK (INTUG)

See comment in 3A.1.  I must apologies for my lack of understanding ITU procedures relating to treaty level status of ITRs.   However, it seems to me that this is a horrendously laborious procedure for modifying regulations.    Regulations must be able to keep up with technology and innovation.   The proposal does not seem to be timely especially having to convene a WCIT.

Strongly Disagree

Australia

Modifying the existing ITRs through a World Conference on International Telecommunications (WCIT) is unlikely to be either timely or effective, for a number of reasons:
the Constitutional requirement to hold such a Conference is itself a major problem, because it imposes very long time-frames and prevents any rapid adaptation to new technologies and commercial realities.·
For ITU agreements to be valid in the current global telecommunications environment, ITU documents must correctly identify the responsibilities of governments and the responsibilities of commercial entities.  Modifying the ITRs as they stand fails to address this issue because such modification would retain treaty-level status for matters that are clearly commercial.
Maintaining the ITRs as Administrative Regulations that can only be modified by a WCIT is inflexible and regressive in a constantly evolving telecommunications environment.

Denmark

We do not consider a detailed update of the regulations to be appropriate in the present and future global telecommunications environment, especially in the light of the WTO agreements.

Finland

France (Telecom)

only some provisions are to come from a treaty; the present study by the expert group should be continued

Japan

As is defined in Article 3 of the Convention, the WCIT shall be held upon decision by the Plenipotentiary Conference and it would take too much time. Therefore we think it is not desirable to keep the treaty-level status of all provisions of the ITRs.

Norway (Telenor)

It was very difficult to achieve a consensus in Melbourne on the present ITRs.  Considering the new competitive environment and the fact that many of the ITU Member States have signed the WTO Agreement on the Basic Telecommunications, we cannot see the need for new, revised ITRs, and we think it would be nearly impossible to reach a compromise that would be accepted by all Member States.  This option would required the convening of a WCIT which we think would be a waste of time and money.

Portugal

The ITRs were controversial from the beginning, Portugal being one of the countries that would prefer not to have them at all. Presently the concept of the ITRs is even more inconsistent with the telecommunications sector reality - a market increasingly private sector/commercially driven, along with decreasing Governments' direct involvement. Such a review/update of the ITRs would thus be not only inappropriate but also impossible to accomplish given the (even more) conflicting positions.

Sweden

The Agency does not see any need for retaining the ITR. See above.

Sweden (Telia)

Telia considers the ITR to be irrelevant within the scope of ITU

UK (Inmarsat)

The relevance of the ITR can easily be included in the revisions proposed in A above, which make this exercise valueless.

United Kingdom

USA (Kasstech)

Opinion

Country

Comments

Strongly Agree

Finland

Peru

Portugal

Although we would prefer to deal with the issue once and for all, adopting the option described in 3A and terminating the  ITRs, we think no consensus solution will be achievable in the near future (see comments in B1). Therefore, we would at this stage favor to defer a decision on this matter and concentrate on more pressing questions that ITU is facing. The current global liberalization trend may in the future bring closer the presently diverging positions and make it possible to come to consensus on this issue.

Russian Federation

Application of the accounting rate principles set by the acting Regulations makes it possible for Russia to compensate its high costs of network maintenance and of traffic completion stipulated by its geographical and economical characteristics.

USA

(Worldcom)

The international telecommunications market has experienced increased liberalization and competition during the period of the 1988 ITRs. Notwithstanding some concerns that the existing ITRs, in whole or in part, are outdated and do not conform to the current international telecommunications market, the trend toward market liberalization and growth remains strong. Because th market is still evolving, and efforts to modify the existing ITRs would not be a constructive use of valuable ITU staff, Member State and Sector Member resources.

Somewhat Agree

Czech Republic (telecom)

We don't have the impression that the existence of the ITRs has in any way hampered the development of our business.

Denmark

Our position is as stated under A and A1 above that the existing ITRs should be replaced in some way, i.e. that they should cease to exist. However, any review or modification of the ITRs in the present situation of on-going telecommunications reform in many countries seems somewhat unrealistic.

Egypt (Telecom)

The decisions of reviewing and modifying should not be deferred completely but it will be a kind of complementary decisions

Ireland

International telecommunications is in a stage of rapid change and evolution of present and forward looking long term discussions made now are likely to be found unsatisfactory in the future.

Peru (INICTEL)

The delay on the would depend on the ITU agenda.

UK (INTUG)

This would depend on the direct effect to global regulations and emerging e-communications policies including IP network, numbering and addressing planning, continued development of emerging telecommunications infrastructures in developing countries.    We need to consider the effect of modifying existing ITRs balanced against not doing so and bearing in mind that nothing has been changed in the last 12 years.   What has been the adverse effect if any, from non-modification?   What would be the benefit from going through a review?

Somewhat Disagree

Albania

Any decision to review the existing ITRs shouldn’t be deferred because ITRs should keep abreast with the rapid evolution of telecoms market and sector reform going on.

France

See B1

France (Telecom)

Putting off any decision prolongs the present highly criticized situation (pp 98) which is incompatible with current telecom environment.

Germany

There is a general feeling that the ITRs do longer meet the requirements of today's telecommunication environment. We hold the opinion that this situation should be rectified by a decision to abrogate the regulations preferably by a Plenipotentiary Conference

Iceland (Telecom)

Japan

To facilitate modification in accordance with the current telecommunication environment, some provisions of the existing ITRs should be developed to ITU-T Recommendations. But as there is no consensus on whether new areas should be addressed in an inter-governmental regulatory agreement, it is better to defer the decision rather than to strengthen the regulations.

Jordan (Telecom)

ITU should lead fast changing field.

Kenya

The existing ITRs clearly do not conform with the current telecommunications environment.  Deferring a decision to review can only encourage members to ignore the provision therein.

Saudi Arabia (Telecom)

Deciding on the need to revise the ITR would be preferable at the earliest (appropriate) opportunity, because of rapid development in telecommunications, especially the WTO agreements.

Senegal (SONATEL)

According to the new environment of telecommunication sector a lot of provisions of the ITR must be bring up to date. Example : Privilege telecommunication

Spain

Swaziland

The ITRs are now more than 10 years and they should be updated to be in line with the new environment.

Strongly Disagree

RASCOM (Regional Org)

Australia

Australia strongly supports the timely revision of ITU basic instruments to restore the validity of the ITU agreements with regard to international telecommunications traffic.  Further delay would undermine the credibility of the ITRs and ultimately the status of the ITU as the accepted forum of global consensus on international telecommunication regulatory issues.

Colombia

changes experienced in the telecom sector in relation to the date when the ITRs treaty was signed are increasing, to the point where they are no longer relevant.

Colombia (Telecom)

The present ITRs is not in accord with the present global telecommunications market.

Czech Republic

The telecommunication market has changed substantially towards liberalization and Member States have lost most of their direct control over ROAs international commercial activities (due to international multilateral treaties, national regulatory regime, etc.

Ecuador

It is convenient not to delete the decision because in various aspects this regulation has been overtaken by the events and there are problems.

India

On the same grounds as mentioned in B1 above

Malaysia

The ITR is outdated and is no longer relevant. Many of the ITR provisions have been overtaken by events.

Mali

Mexico

It is time for the ITRs to be revised given that the market has changed but that they have not been revised for 13 years.

Norway (Telenor)

Some key provisions o f the ITRs are considered irrelevant or in conflict with widespread practices.  Therefore, we think that the ITRs should be terminated as a separate legal instrument.

Paraguay

Spain (HISPASAT)

This theme should be studied without delay, especially to take decision 3A.

Sweden

The Agency does not see any need for retaining the ITR.

Syria

UK (Inmarsat)

United Kingdom

USA (Kasstech)

No Opinion

Sweden (Telia)

Telia considers that the ITRs should be abrogated in the smoothest possible way, perhaps by the Plenipotentiary Conference in Marrakech 2002

Opinion

country

Comments

Strongly Agree

Rascom (regional org)

IP Telephony, Data on Mobile Telephony

Australia

Australia believes that there is a need for general principles at government to government level concerning new and converging technologies that are not currently covered by current treaty level instruments.

Colombia

(e.g. Convergence and multimedia)
to introduce
-IP technology
- broadband
- Internet
- IMT-2000
especially multimedia services.

Colombia (Telecom)

With globalization, new services, convergence and traffic bypass, operators need to establish new procedures for interconnection and payment.

Ecuador

- convergence of technology
- Competences
- new types of agreements between operators
- new types of revenue system

Kenya

The Global obligation  for universal access towards the realization of the Global Information Infrastructure (GII).
Dispute resolution mechanism including those, arising from unilateral decision by particular members on bilateral and multilateral issues

Mali

This offers a chance for new players in the market to take part in the international debate on competition regulation and innovation policy.

Mexico

Routing mechanisms and accounting principles associated with interconnection of international and IP traffic.

Peru

Peru (INICTEL)

The effects of electromagnetic compatibility and to standardize its impact.

Saudi Arabia (STC)

International telecommunication legal norms, coordination by governments of regulatory policy goal ; new services, for example, Internet, Audio text, Home Call Direct (HCD), aeronautical mobile service.

Senegal (SONATEL)

Charging and accounting

Spain (HISPASAT)

Liberalization of telecoms but linked to the answer in 3A.

Syria

call back
refiling
etc

USA (Kasstech)

In the era of wireless, there should be strong regulatory talks for total integration and compatibility, especially in the U.S.

Somewhat Agree

Czech Republic

There are potential candidates as e.g.: e-commerce, SG and higher generation of mobile communications and other components of global telecommunications infrastructure.

France

see B1

Ireland

Jordan (JTC)

International mobile telecommunications, international satellite service, such as Teledesic

Russian Federation

Spain

UK (Inmarsat)

The whole question of trying to graft what was originally a national system and set-up i.e. the internet onto an international environment requires close review to ensure that the integrity of the international telecommunications network is maintained.

UK (INTUG)

Faster regulatory agreement on liberalizing factors and related issues i.e. number portability, new service offerings [one numbering, pan-regional free phone services etc], interconnection agreements - mandatory at the standards interconnection level and commercial agreements left to the interconnecting parties with "local regulators" taking the role of arbitrators.  Using the EU as an example, Local Loop Unbundling has been made mandatory across 15 member states and will open up local infrastructure to new operators.  This has been achieved in a timely manner because of the existence of one regulatory body.

Belgium (Siemens Atea)

Formal regulation shall be reduced as much as possible to those areas, where liberalization is done and effective competition is in place.

Somewhat Disagree

Czech Republic ( TELECOM)

The global marketplace is covered by the WTO agreement on Basic Telecommunications.

Germany

As we are of the opinion that telecommunication should be dealt with by commercial enterprises we think it is inappropriate to conclude treaty level agreements for the regulation of operational details. We support the idea that the regulatory topics as stipulated in WTSA Resolution 40 should be dealt with on a basis of Recommendation rather than on treaty level.

Iceland (Telecom)

Japan

At this stage we cannot support the option that new areas should be addressed by an inter-governmental regulatory agreement, as regulatory-agreement in general can be harmful for development of new areas. And we believe there is not a consensus among  the ITU members on this matter yet.

Strongly Disagree

Egypt (Telecom)

We strongly believe that the ITRs are very respectable and carried out from all the members and achieve the benefits for all and there are no need to be governmental regulatory agreement it is now more stronger

Finland

France (Telecom)

Treaties are incompatible with the commercial environment of telecommunications, new sectors are having commercial success without regulation.

Malaysia

Each jurisdiction is at a different stage of development and may have different priorities and policies towards achieving  varying objectives. An inter-governmental regulatory agreement with treaty-level status would hamper the development of self regulation in general, particularly with nations increasingly moving towards deregulation.

Norway

We think that the  WTO Agreement on the Basic Telecommunications is the appropriate instrument for regulating the global telecommunications market.  ITU regulations should be kept to a minimum.

Portugal

Exactly the opposite - see comments in B1.

Sweden

The Agency does not see any need for new issues to be in a treaty level agreement within the framework of ITU.

Sweden (Telia AB)

Telia considers that there is no need for inter-governmental regulatory agreements regarding telecommunications (Except radio communications) within the scope of ITU.

United Kingdom

Country

Additional Comments

Columbia (Telecom)

Must change and improve the system quickly.

Czech Republic

There are only a few issues in the international telecommunications to be addressed at the level of intergovernmental treaty. These issues should be identified by an experts group in co-operation with ITU general Secretary and submitted for consideration to PP-02 to decide if it is possible to incorporate them into CS or CV- or if it is necessary to update and maintain ITRs. No decision in this respect is the worst possibility that should be avoided. (At any expense).

France (Telecom)

Transparency of the process and more sector member representation; the group of experts (CC99) had few private sector members
abandon provision that are incompatible with commercial practices in liberalized markets.
Avoid slowing down of the revision of the ITRs process, e.g. by putting off decisions until PP2006.

Germany

Different Articles in the ITRs commit the Member States which are Party to the Regulations to ensure that operating agencies cooperate in the establishment, operation and maintenance of international networks. In our opinion, these commitments address the individual Member States and are more binding than the respective wording in the Constitution.
The provisions in Article 6 could lead to a cartel like behavior of operators insisting on the accounting rate regime and as such be counterproductive to efforts for efficiency gains and fostering of competition.

India

In the new telecommunication environments technology, facilities, operators, services, service providers, customer needs and operational practices are changing rapidly. Due to this fast changing scenario in telecommunications, many countries have started to adopt progressive labialisation policies as a means of economic growth and development. The reforms in the International Telecommunication Regulations should take into accounts these factors for offering services to the public in an efficient and cost effective manner.

Jordan (Telecom)

WCIT may be best preceded by at least one preparatory meeting CPM.

Kenya

There is need to recognize the fact that improvement of telecommunications in any part of the Globe contributes positively in terms of increasing the value of global telecommunication to the rest of the world.
The need to establish a universal service programme to assist developing countries, in particular, to improve the state of their networks.  This could be done through building, into international accounting rates, explicit subsidies for network development in developing countries.

Portugal

Dealing with this issue at this stage will be like opening Pandora's Box. It will only serve to waste ITU's and Administrations' scarce resources without any foreseeable positive result.

Portugal (CPR Marconi)

Opting for solution 3 A, some of the provisions should be updated according to the WTO obligations and the liberalization world environment, putting an emphasis on the liberty of contract and not closing the eyes on new forms of traffic delivery.

Russian Federation

We think it is reasonable to include the regulatory provisions on GMPCS, IMT-2000 and IP-telephony when revising the Regulations.

Syria

Eliminate all text duplicated between ITR and the Constitution and Convention

UK

The UK Government believes that the International Telecommunications Regulations (ITRs) are now irrelevant in modern liberalized telecommunications markets which represent the majority share of international traffic. Furthermore, the ITRs 'require' the use of accounting rates which are widely recognized as being excessive in relation to cost leading to consumers paying too much for international calls.

UK (Immarsat)

The fact that the ITRs have been left to gather dust for over 12 years is an indictment of the regard in which they are held by many Member States.
Careful consideration needs to be given to either paralleling the manner in which the Radio Regulations are reviewed and updated within a  2-3 year timeframe or consider the possibility of integrating the ITR’s and RR’s.
With a fast evolving international telecommunications environment the ITU has to be more proactive in this area to avoid stifling competition and potential growth.

UK (INTUG)

I do not have sufficient knowledge of the process to comment from a position of strength.   My experience of discussing, gaining agreement and implementing international regulatory recommendations has been disappointing.   Timeframes and procedures are lengthy, time consuming for delegates and not appropriate in the fast moving e-communications arena.  Any new process must ensure that reform takes into account the environment in which we trade and purchase, communicate and seek new applications for e-communications.   The current structures and procedures are unacceptable and outdated.

USA

The following constitutes the response of the United States of America to the Questionnaire on the Reform of the International Telecommunication Regulations (ITRs) distributed by the International Telecommunication Union General Secretariat on 20 December 2000.  Rather than providing answers to each of the several questions, the United States submits this statement.  In the United States' view, there is no need to proceed with a revision of the ITRs at this time.  Indeed, to proceed with a revision could be undesirable for a number of reasons.

Need for Revision.  The telecommunications sector and sectors dependent on telecommunications have grown and prospered during the period since 1988 when the current ITRs were negotiated.  The changes in the number of global telecommunications facilities, services and providers have been dramatic and positive.  The economic structure and the regulatory regimes have also changed, and are still changing, in many countries.  There is an overall trend internationally toward liberalization, competition, and privatization which the United States views as a positive development.  However, perceptions of the value of these changes in economic and regulatory structures differ from country to country.  The 1988 ITRs have not suppressed or slowed growth and change.  Indeed, improvements in economic and regulatory developments in individual countries have proceeded rapidly.  It is, therefore, difficult to see any pressing need for revision of the ITRs.

Dynamism of the Telecommunications Sector and Regulatory Regimes.  The very dynamism of economic and regulatory developments makes it unwise to renegotiate the ITRs.  Clearly, it would be very difficult to agree upon a single harmonized international approach, as national regulatory regimes are themselves changing.  Governments are adapting to the Telecommunications Annex to the General Agreement on Trade in Services (GATS), and the commitments on Basic Telecommunications that went into effect in 1998.  Governments are also making changes in their approach to market structures independent of the adoption of these trade obligations.  It is not appropriate to renegotiate the ITRs in the face of these ongoing changes and differences, and the prospects for further change in national systems as the trade laws develop and their coverage is expanded.

Suggestions for Expansion of Scope.  There have been some suggestions that the scope of treaty-level mandates be expanded.  This would be inconsistent with developments in the telecommunications sector, where commercial companies and commercial agreements are assuming an ever larger role in a growing number of countries.  To the extent that there are suggestions to expand the regulatory regime to cover new services, any such change would be contrary to the lessons of experience, which show a trend of decreasing government regulation.  Indeed, there has been very significant growth and innovation in areas that have never been subject to traditional regulation, or where governments have chosen not to impose regulation.  Therefore, any negotiation on revising ITRs that is predicated upon suggestions for the expansion of regulation are likely to fail.  The United States is mindful of the fact that different countries have different views about the scope of government regulation generally, about telecommunications regulation in particular, and about market structure.

            The changes in economic and regulatory development have been comfortably accommodated within the parameters of the Melbourne ITRs.  This demonstrates that the current ITRs are suitable to the dynamic telecommunications environment.  Without some compelling reason to seek revisions now, in light of the continuing changes expected in markets and regulatory regimes, United States is of the view that the ITRs should remain intact, at least for the time being.  The United States will review carefully the responses by Member States and Sector Members to this Questionnaire.  We will also review carefully any proposals made by Member States to Council 2001 on this subject, as invited by Council 2000, and we may at that time supplement these views.

RASCOM (regional org)

International Telecommunication Regulations (ITRs) should be generic and aimed at compromising vested interests of the big and small players in the telecommunication industry. The small players (National telecommunication Operators (NTOs) or Public Telecommunications Operators (PTOs) , especially in the African Continents should not be allowed to perish in the so-called privatization as do you call it foreignisation of the national telecommunication entities ? They have a Socio-economic, political and cultural roles to play beyond mere economics!

Country

Comments

Albania

Regulation of public telecomm operators performance recently licensed

Regulation of radio & telecoms liberalized market

No assessment of outcomes made so far

Colombia

concerning a dispute between a long distance operator and a mobile operator.

Egypt (Telecom )

We always carry out and invite the others for do the same towards the ITRs

France

Operator licenses bind  operators to the ITRs.

Japan

In accordance with the provisions of Appendix 2 to Article 6, Ministry of Public Management, Home Affairs, Posts and Telecommunications made an ordinance, designates entities and notifies the Secretary-General of ITU.

Korea, South

Over the year, the international service was provided by monopoly in Korea. Some rules relating accounting regime were stipulated as a part of national law. But these rules were abolished as the international services became fully liberalized.

Russian Federation

In Russia the international agreements in the telecommunication field are concluded in accordance with the International Telecommunication Regulations.

Spain

(Comment added to question 1A) To establish norms, with international treaty level, will guarantee present and future international telecom services, without prejudice to the international political or economic regimes.