This document puts forward the comments of the CEPT to the draft Memorandum of Understanding on free circulation of GMPCS terminals.
The CEPT welcomes the MoU. In order to have the MoU signed as soon as possible, there should not be major changes for the moment. Following minor modifications are however proposed:
a) The title should be modified to reflect the fact that the MoU is not the agreement for free circulation but the agreement to enter into discussions on free circulation. Therefore the title should be: "Memorandum of Understanding to prepare arrangements to facilitate the free circulation of Global Mobile Personal Communications by Satellite user terminals (GMPCS-MoU)".
b) The text should allow discussion on all issues relevant to free circulation, including the use of frequency bands. The first sentence in Article 2 of the MoU should be amended to be: "The Parties shall develop arrangements on the means by which licences should be granted based on general licences (e.g. class licences or blanket approvals) giving consideration to all relevant issues including the use of frequency bands."
c) Article 5 of the MoU should refer to annual review instead of periodic review. The annual review would facilitate reconsideration of the scope of the MoU at a later point in time.
d) Taking into account that the MoU is not a binding instrument, it would be appropriate to change the word shall to will throughout the text.
We note that some of the CEPT Member Administrations may forward
you their national comments to the draft MoU.