Informal Group


Geneva, 14 February 1997

Comments of Pakistan Telecommunication Company Ltd (PakTelecom)
on the Memorandum of Understanding


1 Pakistan being a developing country, has not yet able to provide basic telephony in all parts of the country and also could not lay terrestrial links widely in Pakistan having different terrains specially in Northern areas.

2 GMPCS services could make good contribution in providing quick and better communication services all over the country. Following comments are presented keeping in country benefits:

- Pakistan (PTCL) will welcome and happily cooperate with the GMPCS operators and service providers for the early introduction of GMPCS keeping in view the ITU standards and Radio Regulations to achieve full benefits of service.

- Pakistan Telecommunication Authority (PTA) is already working for the preparation of national policy and regulations to adopt GMPCS technology and service. Country law will be observed while making regulation in this regard.

- Frequency Allocation Board of Pakistan being responsible for allocation of frequencies shall consider desired allotment of frequencies within WARC decisions.

- Special seminars be arranged by ITU, APT and GMPCS operators in Pakistan and in regional countries to enable better understanding of different norms in GMPCS field.

- ITU and WTPF to indicate level of cooperation and assistance in taking measures to introduce GMPCS technologies in the developing countries.

- Regulatory authority should be free to auction or negotiate licence fee, tariffs and accounting rates with GMPCS operators and service providers keeping its own policy interest.

- Service obligation on low cost for under-served areas for GMPCS operators and service providers shall be worked out by regulatory authority specially in developing countries - could be a small percentage of total business.

- Policy to give a good competitive platform for the GMPCS operators considering all issues like regulatory, sovereignty security and technology including standardization, cross-border communication, monitoring, data protection, licensing, environmental, country franchising, interconnectivity, gateway station authorization and pricing, etc. is under preparation.

- ITU standards may be formed for user terminals type approval and may list laboratories for standardization, compatibility and designing roaming laws and circulated.

- All GMPCS operators should ensure minimum charges and cost for services suitable to developing countries and similarly tariff rates be designed at reasonable cost.

- Regulatory authority will negotiate and decide proper interconnectivity to allow GMPCS systems in the country.

- Pakistan will try its best to contribute to ITU activities for GMPCS implementations. Cooperation and assistance from ITU in terms of technology and financing of activities for GMPCS regulation should be extended.

- GMPCS operators shall arrange to make access and to check traffic data and statistics at any required time.

- GMPCS operators shall conform to country numbering plan for their customers registered in different countries.

GMPCS-MoU to facilitate free circulation

ITU draft
Pakistan comments
Convinced of the need to reach regional, and preferably global, arrangements on issues related to the three levels of free circulation of user terminals defined as follows: ITU standards awaited. Country standards not made. Other country views be provided.
- permission to carry a terminal into a visited country but not to use it; Once standards are made negative list for custom/check of such user terminals shall be provided.
- permission to carry a terminal into a visited country and to use it without the need for obtaining authorization in the visited country; and Once standards are made class licensing policy shall be made for standards/approved terminals. Use will be allowed for authorized GMPCS equipment and relevant roaming, revenue and accounting country agreements.
- technical conditions for placing terminals on the market; Technical conditions to be decided after standards are approved.
that such arrangements would necessarily include the conditions pursuant to which Administrations would grant mutual recognition of type approval of terminals, mutual recognition of terminal licensing, recognize the marking of terminals, and permit terminals to be placed on the market; and that such arrangements could form the basis of national regulations on these matters, or be implemented by reference; ITU may guide on conditions, recognition details and requirements both for GMPCS operators and inter-administration. Technology, type approval, terminal licensing and marketing needs more details on standards, sharing, accounting, charging and tariffing matters.
the Parties to this Memorandum of Understanding hereby agree to cooperate, according to their respective roles and competencies and taking into account the voluntary principles for GMPCS adopted by WTPF-96 on the following issues:

ITU draft
Pakistan comments
Article 1 Type Approval of Terminals

The Parties shall develop arrangements on the essential requirements necessary for the type approval of terminals, and the means by which such approvals shall be mutually recognized. That the type approval standards should be based on the relevant ITU Recommendations, and should be impartial with respect to all GMPCS technologies, and without reference to performance or quality of service standards.

Custom procedures and marketing details are to be worked out. ITU may help/guide and provide existing custom procedures adopted in developed and less developed countries. We need to know why it should be without reference of quality of service and minimum standards.
Article 2 Licensing of Terminals

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). That such arrangements shall be drawn up and include the means by which these general licences shall be mutually recognized.

ITU to specify standards and help developing countries devise means to develop standards.
Article 3 Marking of terminals

The Parties shall develop arrangements on the marking of terminals which will permit their recognition and the implementation of the arrangements on mutual recognition of type approval and licensing.

Various GMPCS operators will have different standards and dual/triple mode terminals. Marketing policy shall be possible once standards are known and approved.
Article 4 Customs Arrangements

The Parties shall develop recommendations to their competent authorities proposing exemption of approved terminals from customs restrictions when visiting or transiting countries.

Tariff regimes are different. We need to know expectations of GMPCS operators about rate of custom. Government needs standards from ITU, costs of terminals and WTO policy. Lot of homework and coordination. Reference to Government will be possible when enough information is available.

ITU draft
Pakistan comments
Article 5 Review

The Parties shall periodically review the results and consequences of their cooperation under this Memorandum of Understanding. When appropriate the Parties will consider the need for improvements in their cooperation and make suitable proposals for modifying and updating the arrangements, and the scope of this GMPCS­MoU.

Review shall be needed once policies and standards as above are made.
Article 6 Access to Traffic Data

The Parties shall develop arrangements for GMPCS operators to provide, on a confidential basis, within a reasonable period of time to any duly authorized national authority which so requests, the best available traffic data concerning traffic originating in or routed to its national territory, and to assist it with any measures intended to identify unauthorized traffic flows therein.

We need to know the following:

a) Obligations of GMPCS operators on cross­border data and monitoring tools.

b) Country administration role on cross­border issues.

c) Third country role on cross-border data.

d) If GMPCS operators, service providers and gateway operators shall also provide statistics on country demand.

e) Identification/marking of customers/user terminals to be provided by GMPCS operators on demand.