Informal Group


Geneva, 14 February 1997

Comments of the Ministry of Posts, Telegraph and Telephone (Iran)
on the Memorandum of Understanding

In respect to the draft Memorandum of Understanding to facilitate the free circulation of Global Mobile Personal Communications by Satellite user terminals (GMPCS-MoU), I would like to bring to your attention the following:

To issue permission to carry a terminal into a visited country may require:

a) the operating frequencies of the terminals be coordinated by the visited country beforehand;

b) these terminals should not be used to provide any other services beyond the testing requirements as outlined.

As far as technical conditions for placing terminals on the market, although we are in agreement that the standards should be based on the relevant ITU Recommendations, we had to familiarize ourselves further with the issues outlined in the said draft MoU. Our comments regarding this part of arrangements will be formalized in due time.

Meanwhile our proposals in response to Circular-letter Ro/No DM No. 81-SPU/DM/Jb of 1 November 1996 are attached herewith.

1 In reference to Principle 1, countries that their telecommunication services are not yet privatized could not globalize these services. Furthermore, the prevailing Rules will not permit them to comply with the "international obligations" in this relation. An appropriate approach should be to let the parties concerned formalize a bilateral agreement (MoU) to benefit from GMPCS in a manner practical and possible.

2 In reference to Principle 2, developing countries should not confide to the internationally established corporation to handle their telecommunication services. Since it appears that there is no guarantee that a new version of monopoly will not be called in without any effective means of control on their operations. In a word, the required financial and technical resources may permit any developing country to benefit from the services of only one GMPCS operator without competition. May ITU be able to provide such an assurance.

3 In reference to Principle 3, it should be internationally recognized by the Members of ITU and GMPCS operators that the services of any country or any region shall not be blocked or cut off under any political, financial excuses or pressures. ITU as usual should concern itself to safeguard the rights of its Members.

4 Provisions should be made to let the developing countries to have easy and permanent access to the technical specifications, type of services, arrangements and references of GMPCS operators.

5 The coordination of certain regional countries to work with a specific gateway terminal of GMPCS may not only be an easy task but may also become a challenge for those concerned. Therefore ITU should intervene and coordinate the matter. This should be provisioned in MoUs.

6 In our inferring, the letter and spirit of subparagraph 2 of "is of the view" (page 4 of revised report by the Chairman) recognizes some sort of rights for GMPCS operators and providers, and at the same time imposes certain obligations on the Member countries of ITU. This may be in contradiction with the "voluntary principles" referred to in aforesaid report. Therefore, it should be put in a right track.

7 In reference to Principle 9, interconnectivity could not be coordinated and could not be applied unless the technical specifications of GMPCS systems are coordinated as approved by ITU Study Groups, ITU-T. Technical specifications could as well be coordinated by GMPCS operators and country operators.

8 Some clarification and explanation in respect to tariffs should be provisioned.

9 We propose the Article 1 to read as follows:

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.

10 The measurement and providing traffic parameters of each country should be within specific procedure, therefore we propose that in Article 6 third line the wording: "the best available" be deleted.