3. Proposal 1: Please give your reasons - cont.
6. NETWORK INTEGRITY: There is no difference to 'network integrity' between a
group of 'mobile station' subscribers initiating traffic in the same geographic location
(such as at football matches, rallies and other organised public events) to a GSM
Gateway initiating traffic from one geographic location.
7. NETWORK INTEGRITY: In consideration of proposal 1, point 5, we submit that
GSM Gateway traffic has the potential to be managed whereas a random group of
'mobile station' subscribers do not. MNO 'network planning' departments could liaise
with relevant GSM Gateway operators when working on the rollout of GSM
8. NETWORK INTEGRITY: GSM Gateway operators could supply 'spectrum
analysis' ofBTSs (Base Transfer Station) they intend to terminate traffic into to
assist 'network planning' departments with rollout.
9. NETWORK INTEGRITY: GSM Gateway devices can use external aerials which can
a. Omni directional
b. Directional (60 degree arc)
c. Parabolic -Line of sight
A combination of these can afford greater flexibility to which BTS is used for
termination to manage traffic capacity across BTSs with the most redundant capacity
avoiding those where congestion is prevalent.
10. CREDIT MANAGEMENT: The decision to accept a customer rests with each MNO.
Provided the 'network integrity' issues can be addressed -through working in
conjunction with MNO 'network planning' departments -there are still credit risk
issues. These can be addressed by developing GSM Gateway tariffs (with advance
payments for bundled minutes), forward payments and/or security deposits. All of
which are acceptable to the GSM Gateway operators who support this proposal.
11. NETWORK INTEGRITY / CREDIT MANAGEMENT: We submit that an SRO (Self
Regulatory Organisation) could adequately manage the rollout of GSM Gateways if
tasked to work in conjunction with GSM Gateway operators and MNOs in so far as
implementation and/or credit management issues are concerned.
12. PROPOSAL 1: Passing proposall would facilitate GSM Gateways to be used for
'private connection' to a 'public network'. This may only facilitate the use ofGSM
Gateways as an LCRoGSM (Least Cost Routing over GSM) model for parties with a
level of call traffic that justifies the expense of installation.
13. ISSUES WITH PROPOSAL 1: Proposal 1 would restrict the market benefit to larger
corporate companies only. The consumer would not enjoy the benefits of reduced
charges as the only way a SOHO, SME or private consumer could access GSM
Gateway technology would involve establishing a 'public connection' to a 'public
14. ADJUNCT: Proposal 1 would empower the MNOs to establish GSM Gateways to
arbitrage their own call traffic, terminate it onto their own network and price manage
their own rates without passing the benefit on to the consumer.
15. ASIDE GSM GATEWA Y: Road traffic cameras (not GA TSO or SPECS), remote
management alarm systems, courier location management systems, vending
machines, A TMs, and other remote located data transfer systems would all benefit
from acceptance to proposal 1. However, some may require proposal 2 in order to
effect multiple 'private connections' to a 'public network' resulting in the provision
of a 'telecommunication service' 'by way of business'.
END – Proposal 1
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