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interconnection and determining appropriate tariffs. Interconnection has, though, been accomplished reasonably smoothly in the UK and US. There should, therefore, be no insurmountable difficulties for Hong Kong.
A Second International Telecommunications Carrier
HK Telecom :
Irrevocable Rights of Use (IRUS) in submarine cables (the main alternative to satellite transmission of international telecommunications traffic) could not be obtained quickly by a competitor.
Administration's Response : The experience of competing international carriers has shown that difficulties may be encountered in obtaining IRUS and the authorities of the countries concerned have in some cases been obliged to assist their competitive carriers to obtain access to such transmission facilities. If a competing international carrier in Hong Kong had the participation of an established international telecommunications operator (e.g. British Telecom), such difficulties should not arise.
HK Telecom : BAH does not give due recognition to the costs involved in the provision of back up facilities required by an international carrier.
Administration's Response: According to BAH, account is taken of the need to provide some degree of equipment back up in the calculation of the competing carrier's costs. However, as the competitor would be carrying substantially less traffic than CWHK (even by 2007) provision for a full back up international gateway is not required.
Accordingly, it has quite rightly not been provided for in
the cost calculations.
Economic Services Branch
Government Secretariat
16 June 1988
335Y
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