NRO contribution to the WCIT Public Consultation ­­P rocess

Chronological Thread 
  • From: John Curran <jcurran@xxx>
  • To: "wcit-public@xxx" <wcit-public@xxx>
  • Subject: NRO contribution to the WCIT Public Consultation ­­P rocess
  • Date: Thu, 1 Nov 2012 12:33:51 +0000
  • Accept-language: en-US

On behalf of the 5 Regional Internet Registries (AFRINIC, APNIC, ARIN,
RIPE NCC), please find the attached submission to the WCIT Public
Consultation ­­Process


John Curran
Chair, Number Resource Organization (NRO)

=== Plain text format

3 November 2012

International Telecommunication Union
Place des Nations
CH-1211 Geneva 20

Re: NRO contribution to the WCIT Public Consultation ­­Process

The Number Resource Organization (the NRO, comprising the five Regional
Internet Registries) appreciates the opportunity to contribute some views in
preparation for the World Conference on International Telecommunications
(WCIT) that will discuss the long-established International Telecommunication
Regulations (ITRs).

The ITRs were originally intended to guide the provision of international
switched telephone services and, within its scope and strength, have promoted
the growth of international connectivity. We support the continuance of the
ITRs as they were intended.

The NRO has followed with interest, the discussions about proposed changes to
ITRs. Under the current ITU procedures, our organizations do not have full
access to the discussions nor a formal say in the negotiations. However, as
we have been acquainted with some of the proposals to revise the existing
ITRs, we note that if some of these are accepted into the regulations, they
may adversely affect how telecommunications networks are managed and how they
may develop into the future. These are important matters affecting the public
interest, for which participation of relevant stakeholders could be sought in
the decision-making process.

We have noted proposals to include new provisions into the ITRs as means to
address some concerns by ITU Member States in the fields of: a)
interconnection costs; b) security; c) spam; and, d) issues relating to
Internet resources.

While we share many of the concerns expressed by the ITU Member States, we do
not believe that new provisions in the ITRs can effectively help to solve
these matters, and instead, may carry unintended consequences. The ITRs will
remain unchanged for many years after WCIT, while most of the issues of
concern will change as technologies will evolve.

Our concerns can be summarised more particularly, as follows:

a) Proposals to include in the ITRs provisions to change
interconnection models could impose undue limitations to service providers.
The expansion of the Internet could not have occurred if not through peering
agreements and the establishment of Internet exchange points (IXPs). These
agreements are voluntary, sometimes with no written contracts, and frequently
involve no financial transactions. Introducing an intergovernmental,
treaty-based, global regulatory scheme to codify or lock-in particular
business models may hinder instead of encourage innovation and further growth
in international connectivity.

b) There are proposals from a number of ITU Member States to amend the
ITRs to include references to security, touching the realms of content,
national defence, and cybercrime. In the quest to guarantee more secure
networks, cooperation with different stakeholders is essential. The
application of legal or policy principles related with security into the ITRs
may impose obligations to ITU Member States that limit, instead of foster,
this needed collaboration. c) With regard to the inclusion of spam in
the provisions of the ITRs, we note that spam is complex issue of network
usage or content for which no simple solution exists. Our concern is that the
suggested ITR provisions are likely to have little effect and will certainly
become quickly out-dated as technology evolves.

d) Proposed revisions to the ITRs involving aspects of naming,
numbering, and addressing, are prone to have unintended consequences if
accepted by ITU members. It appears these provisions transcend the realm of
switched telephony for which the ITRs were formulated and may negatively
impact existing Internet operations and management. Resource management for
Internet naming, numbering, and addressing have well-established,
multistakeholder governance structures and policy development processes. Some
proposals could have unintended consequences and impact these successful
structures, or even create obligations for ITU Member States to outlaw
firewalls, filters and proxies, which are common practice in the Internet

We commend the ITU Council for creating a space such as this one for
participation in the WCIT process. We do hope that ITU Member States find
value in collaborating with other stakeholders who may be affected by the
outcomes of WCIT. Shared expertise and exchange of information are important
in order to find viable solutions, to avoid unintended consequences, and for
the protection of the public interest. We do share a strong commitment to the
growth of international connectivity and we trust for an inclusive
environment where we can work together to achieve these goals.

[1] More of this subject is explained in the article: “Number misuse,
telecommunications regulations, and WCIT”. Available here: