We thank the Secretariat of the ITU for making the opportunity to submit our views.

Nevertheless, the process of the revision of the International Telecommunication Regulations (ITRs) has not been sufficiently inclusive and transparent, despite some recent efforts to facilitate public participation. Fundamental to the framing of public policy must be the pursuit of the public interest and fundamental human rights, and we urge Member States to uphold and protect these values.

We as civil society organizations wish to engage with the World Conference on International Telecommunication (WCIT) process in this spirit. Member States, in most cases, have not held open, broad-based, public consultations in the lead up to the WCIT, nor have they indicated such a process for the WCIT itself.

In order to address this deficiency, and at a minimum, we would urge:

• All Member States and regional groups to make their proposals available to the public in sufficient time to allow for meaningful public participation;

• All delegates to support proposals to open sessions of the WCIT meeting to the public;

• The ITU Secretariat to increase transparency of the WCIT including live webcast with the video, audio, and text transcripts, as far as possible, to enable participation by all, including persons with disabilities;

• The ITU Secretariat, Member States, and regional groups to make as much documentation publicly available as possible on the ITU’s website, so that civil society can provide substantive input on proposals as they are made available;

• Member States to encourage and facilitate civil society participation in their national delegations;

• The ITU to create spaces during the WCIT for civil society to express their views, as was done during the WSIS process.

Given the uncertainty about the nature of final proposals that will be presented, we urge delegates that the following criteria be applied to any proposed revisions of the ITRs:

• That any proposed revisions are confined to the traditional scope of the ITRs, where international regulation is required around technical issues is limited to telecommunications networks and interoperability standards.

• There should be no revisions to the ITRs that involve regulation of the Internet Protocol and the layers above.

• There should be no revisions that could have a negative impact on affordable access to the Internet or the public’s rights to privacy and freedom of expression.

More generally we call upon the ITU to promote principles of net neutrality, open standards, affordable access and universal service, and effective competition.

Signed by:

Access (Global)

Association for Progressive Communications (APC) (Global)

Bangladesh NGOs Network for Radio and Communication (Bangladesh)

Bytes for All (Pakistan)

Centre for Internet and Society (India)

Center for Democracy & Technology (United States of America)

Centre for Community Informatics Research (Canada)

Collaboration on International ICT Policy for East and Southern Africa (CIPESA) (Eastern and Southern Africa)

Consumer Council of Fiji (Fiji)

Consumers International (Global)

Dynamic Coalition on Internet Rights and Principles (IRP) (Global)

Electronic Frontier Finland (Finland)

Imagining the Internet Center (United States of America)

Instituto Nupef (Brazil)

Internet Democracy Project (India)

Internet Research Project (Pakistan)

Fundação Getúlio Vargas (FGV) Rio de Janeiro Law School (Brazil)

Gobernanza de Inter​net​.co (Colombia)

Global Partners & Associates (United Kingdom)

ICT Watch Indonesia (Indonesia)

Instituto Brasileiro de Defesa do Consumidor (IDEC) / Brazilian Institute for Consumer Defense (Brazil)

InternetNZ (New Zealand)

IT for Change (India)

Media Education Center (Armenia)

ONG Derechos Digitales (Chile)

OpenMedia (Canada)

Public Knowledge (United States of America)

Thai Netizen Network (Thailand)

Ginger Paque (Venezuela)

Sonigitu Ekpe (Nigeria)

Wolfgang Kleinwächter (Denmark)