WCIT Statement

[William Drake]

Hi

Congrats on the nice statement.  Since I alas can't be there today and am not a signatory organization and you understandably want to avoid further tweaks if possible, the below comments are probably just FWIW:

On Nov 4, 2012, at 12:20 PM, Pranesh Prakash wrote:

> In order to address this deficiency, and as a minimum, we would urge:
> * All member states and regional groups to make their proposals available to the public in sufficient time to allow for meaningful public participation;

Did you not want to specifically state that because most have not seen the actual proposals, CS will be commenting further and ask that the ITU continue to post these on its website beyond this weekend's deadline?

> * All delegates to support proposals to open sessions of the WCIT meeting to the public;
> * The ITU Secretariat to increase transparency of the WCIT including live webcast with the video, audio, and text transcripts, as far as possible, to enable participation by all, including persons with disabilities;
> * The ITU Secretariat, member-states, and regional groups to make as much documentation publicly available as possible on the ITU's website, so that civil society can provide substantive input on proposals as they are made available;
> * Member-states to encourage and facilitate civil society participation their national delegations;
> * The ITU to create spaces during the WCIT for civil society to express their views, as was done during the WSIS process.
> 
> Given the uncertainty about the nature of final proposals that will be presented, we urge delegates that the following criteria be applied to any proposed revisions of the ITRs.
> 
> * That any proposed revisions are confined to the traditional core mandate of the ITU and scope of the ITRs, where international regulation is required around technical issue limited to basic telecommunications networks and interoperability standards.

A few concerns here.

*There is no such thing as a basic telecommunications network (unless you mean a telegraph or telex net).  There are basic telecommunications services, but that's different.

*It is not true that either the ITU or the ITRs are limited to basic telecommunications.  Most of the debates at the 1988 conference were precisely about how to treat non-basic telecom (i.e. "enhanced" in the US, "value-added" elsewhere), and hence about Articles 1.7 (the "any entity" authorization battle) and 9 (special arrangements).  Indeed, the ITU Secretariat contends that "all Internet traffic moves under Article 9."  

*There is effectively no real international regulation of telecom networks in the ITRs anymore, that was the point of WATTC-88; it moved to the GATS.

If it were me I'd just delete the second clause, but whatever.

> * There should be no revisions to the ITRs that involve regulation of the Internet Protocol and above.

I'm not quite sure what it means to regulate a protocol, but if others are, great.

Cheers,

Bill


> * There should be no revisions that could have a negative impact on affordable access to the Internet or the public's rights to privacy and freedom of expression.
> 
> More positively we call upon the ITU to promote principles of net neutrality, open standards, affordable access and universal service, and effective competition.
> 
> Signed by:
> 
> ====
> 
> -- 
> Pranesh Prakash
> Policy Director
> Centre for Internet and Society
> T: +91 80 40926283 | W: http://cis-india.org
> PGP ID: 0x1D5C5F07 | Twitter: @pranesh_prakash
> <bestbits_wcit_statement.txt>