TNAG-1779-FCO40-2539-Hong-Kong-international-telecommunications-1988 — Page 158

1.

2.

(i)

(ii)

CWHK interprets CCITT [1] recommendations D.1 and D.6 [2], which recommend restriction of the use of international leased lines for "third-party" traffic, in a strict way. Thus it is often difficult for value added service providers, other than CWHK or HKT, to provide access to international value added services economically.

The tariffs for international leased circuits are in any case high by the standards of many of Hong Kong's competitors (see section 2.5 below).

CCITT is the Comite' Consultatif International Telegraphique et Telephonique (International Telegraph and Telephone Consultative Committee).

CCITT Recommendations D.1 and D.6 provide telecommunications carriers with guidance as to the type of traffic which should be permitted to be transmitted on international leased circuits. In summary, D.1 recommends

that :

O traffic should relate only to the customer's business.

o the circuit, or portions of its capacity, should not be sub-leased.

the circuit should not be provided when "the customer's proposed activity would be regarded as an infringement of the functions of an Administration in providing telecommunications services to others".

if the circuit is to form part of a private network, the details of the network shall be furnished to the Administration, whose agreement to operation of the network in the way proposed is required.

o the type and method of interchange of traffic between a private

circuit and a switched public network must also be agreed with the Administration.

o Administrations may levy "special charges" for switched network access

if they wish.

In summary, D.6 recommends that :

o special conditions be applied where the customer is an "organization

formed to meet the specialized international communication needs of their members".

o private networks established under D.6 are subject to substitution by

switched services when Administrations can provide equivalent capabilities.

о

"volume-related" charges may be applied to international leased circuits for such organizations.

These recommendations leave "Administrations" (i.e. CWHK) a lot of leeway to be either liberal in allowing, for example, value-added services to run on such circuits, or not to do so. The evidence collected in Hong Kong suggests that CWHK leans towards a restrictive interpretation.

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