WCIT Statement

Pranesh Prakash pranesh at cis-india.org
Sun Nov 4 04:29:17 EST 2012


Dear Bill,
It is indeed unfortunate that you couldn't make it here today.

On Sunday 04 November 2012 01:22 PM, William Drake wrote:
> 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?

Perhaps this is covered by the below bullet point on "documentation"?

>> * 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;


>> 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.

The second clause being "where international regulations ... standards"?

>> * 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.

I am not happy with that phrasing either (and expressed it), but 
otherwise there was consensus.  I'm also unhappy that there is no noun 
after "above".


-- 
Pranesh Prakash
Policy Director
Centre for Internet and Society
T: +91 80 40926283 | W: http://cis-india.org
PGP ID: 0x1D5C5F07 | Twitter: @pranesh_prakash

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