[Chapter-delegates] Input Request: ISOC Comments to WCIT

[Sally Wentworth]

Dear colleagues,
 
As you may be aware, the ITU has set up a system to accept public comments on the draft ITRs or other issues related to WCIT.  We have decided that the Internet Society should submit its views via this consultative process.  The good news is that we have much material to draw upon - found here: http://bit.ly/TvpSD7
 
Our intended comments are along the following lines:
 
-       to outline a positive way forward for the ITRs; 
-       to emphasize the things that have worked in the field of telecommunications; 
-       to make a case for why the Internet should not fall within the scope of the ITRs; and,
-       to highlight specific proposals where the Internet Society has strong positions.   
 
 
In terms of specific proposals, ISOC has already made its views clear on a few topics which we will probably reiterate in our contribution: 
-       Nature of ITU-T Recommendations in the treaty - ITU-T Recommendations should remain voluntary;
-       Concepts of competition and liberalization should be included in the treaty as key to the development of international telecommunications worldwide;
-       Inclusion of spam definition and provisions - concern with inclusion of content into the treaty;
-       Security - ISOC has already expressed concern with security-related provisions and has explicitly said that content, national defense and security, and cybercrime aspects should be excluded from the ITRs;
-       Interconnection Agreements - a new interconnection model via the ITRs runs the serious risk of fragmenting the Internet.  ITRs should not set out Interconnection criteria;
-       Naming, numbering and addressing - ISOC has opposed references to Internet resources such as IP addresses in the ITRs.
 
 
Some additional topics for consideration:
-       Scope of Application of the ITRs - use of the term "Recognized Operating Agency" versus use of term "Operating Agency" throughout the treaty text;
-       Changes to definitions of "telecommunication" and "international telecommunication";
-       mandating QoS and related network configuration and management issues in the ITRs; 
-       Traffic routing regulations related to IP traffic in the ITRs; 
-       ITR Regulations related to Internet naming, numbering or addressing. 
 
I would appreciate hearing your comments on the additional topics above or other aspects of the contribution by Friday, 26 October.  We will be submitting our comments to the ITU by the 03 November deadline (or earlier if possible). 
 
Kind Regards, 
Sally


Sally Wentworth
Internet Society 
+1 703 439 2146
wentworth at isoc.org
www.isoc.org

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