Archived—Global U Network Inc.

October 30, 1998

Via Courier and e-mail
Mr. Ronald Amero
Director, Space and International Regulatory Activity,
Radio Communication and Broadcasting Regulatory Branch,
Industry Canada,
300 Slater Street, Ottawa, Ontario, K1A 0C8

Re: Canada Gazette Notice Reference No. DGTP-014-98, October 10th, 1998 and
Proposed Regulatory Initiative - Radio communication Regulations, October 10th, 1998

Dear Sir:

Global U Network Inc. welcomes Industry Canada's commitment for improving market access to facilitate the availability of mobile and fixed satellite services for Canadians. We welcome the achievements reached by Canada's commitment in the World Trade Organization (WTO) agreement on basic telecommunications services. We believe that free circulation of mobile earth stations to be the most important part of globalization of satellite telecommunications. However, we understand that this free circulation is going to pose difficulties for some countries, especially those that need to bridge the policy and regulatory gap.

We recognize that some countries may have apprehensions about bridging this gap due to security concerns raised by the potential of a global communications, licenses for service operation, for equipment use, and for use of the radio-frequency spectrum, as well as of interconnection, customer billing and revenue sharing are just a few of the important issues. The legal complexity of negotiating individual licenses with each country of operation cannot be underestimated, which is why partnerships with local operators and service providers are so important.

Almost all countries currently require individual terminals to be individually licensed for use. We believe this, and not the restricted foreign ownership for Canadian service providers, is the main obstacle for international market access in satellite communications.

Canadian ownership of service providers has benefits for Canadians, which are as follows: 

  • The Canadian government has more control over quality of services provided.
  • The Canadian government has more control over revenue of satellite carrier companies from Canadian sources.
  • Canadian companies will benefit from services provided directly and will have revenues from foreign services.

In future, technology will enable the satellite communication system to provide multimedia and other high-speed services directly to customers. The only way the Canadian government can have control on revenue of the carrier companies from Canadian sources is through Canadian-owned companies or citizens who receive benefit from those revenues. Some of these services are already available (remote Wide Area Network (WAN) services for national and multinational companies and complete Internet service through satellite for local IP's.)

To ease access to foreign markets, the Canadian government should try to encourage other countries to adopt general or blanket licenses that would cover a whole class of mobile terminals to be used internationally. Consumers could then buy or rent a terminal, get it licensed in Canada, and pay bills for its use from one central point of contact in Canada.

We encourage policy-makers and regulators to apply the following policies to Mobile and fixed satellite services. Based on General Agreement on Trade in Services (GATS), and Policy Framework for the Provision of Mobile Satellite Services Via regional and Global Satellite Systems in Canadian Market (RP-007, Rev. 1, February 1998), and keep the Policy Framework unchanged.

The applicant (service provider) must be a Canadian-owned and controlled corporation incorporated or continued under the laws of Canada or a province. The Canadian-owned and controlled corporation, if it were a Canadian carrier, would be eligible to operate as a communications common carrier under the provisions of the Telecommunications Act and the regulations made thereunder;
The mobile satellite system used by Canadian licensee may be owned and controlled up to a level of 100% by Foreign Service provider.

We believe the proposed amendments for "mobile satellite service" and "fixed satellite service" do not allow the Canadian satellite service providers sufficient access to the United States, Europe and other important markets (because other countries are not willing to do the same), but it will rather enable foreign carriers to bypass the Canadian service providers.

Yours Sincerely,
Global U Network Inc.

Abdi Roudafshan
President

CC: Mrs. Chantal Beaumier; Chief, Space Services-Authorization

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