ICGSF (00) 26
27 March 00

From:	R. Ebadi, Ali [ali_ebadi@utsb.astro.com.my]
Sent:	27 March 2000 03:05
To:	keithwhittingham@compuserve.com
Subject:	FW: Comments to ICGSF22 and ICGSF 23

> Dear Mr. Whittingham,
> 
> Reference is made to the proposals in documents ICGSF22 and ICGSF 23.
> 
> As informed in the Malaysian Administration document (Doc 13), we object
> to any discussion on the issue of Financial Due Diligence. This subject
> was heavily debated during the Plenipotentiary 1998 Conference and
> objected by majority of the participating administrations.
> 
> In view of the decision at PP98, we firmly believe that the any issue with
> regards to Financial Due Diligence should not be discussed until a clear
> indication on the effectiveness of Resolution 49 is made known.
> 
> While we understand that the full impact of Resolution 49 would not be
> known until the year 2003 or maybe earlier for some networks, it would be
> inapropriate to conclude that it is deficient at this time.
> 
> Also during PP98, the concept of Cost-Recovery was adopted and agreed,
> while Council99 implemented the procedures to this concept. We fully
> support the concept of introducing processing charges for satellite
> filings but view Financial Due Diligence differently due to the following
> reasons:
> 
> i) Financial Due Diligence would a major constraint on developing
> countries' ability to secure orbital slots or frequency bands due to
> financial limitations.
>  
> ii) Developing countries may not want to commit themselves financially due
> to uncertainties in the outcome of the coordination process.
> 
> iii) Countries with substantial financial resources would be able to
> secure multiple orbital slots and frequency bands, leading to them
> dominating the space industry.
> 
> iv) Financial Due Diligence would have a major impact on the advancement
> in technology since most administrations would shy away from securing
> orbital slot and spectrum. Thus, would result in a rapid downturn in the
> requirement for technology improvement.
> 
> In conclusion, we object to any further discussions on the issue of
> Financial Due Diligence at this point of time. We believe that Financial
> Due Diligence should be addressed at the next Plenipotentiary meeting
> after the Director has provided its finding on Resolution 49 at WRC-2000.
> 
> We would also like to add that the ICGSF group was set up to address the
> issue of improving satellite coordination and notification process. It is
> our opinion that Financial Due Diligence would not play a major factor on
> this matter.
> 
> We should instead concentrate on simplification of the notice forms for
> coordination and notification. Achieving this task would not only improve
> the coordination and notification process but reduce the current backlog
> problem.
> 
> Regards,
> 
> 
> Ali R Ebadi