1. ATIS and Interoperability in the Americas
Dr. Asok Chatterjee
On Behalf of the Alliance for Telecommunications Industry Solutions (ATIS)
July 6, 2010

2. About ATIS
ATIS is the leading technical planning and standards development organization headquartered in North America.
ATIS is committed to the rapid development of global, market-driven standards to make possible tomorrow's communications ecosystem.
More than 600 industry professionals from approximately 250 companies actively formulate standards in ATIS’ Committees, Forums, and Incubators.
ATIS is the North American Organizational Partner for the 3rd Generation Partnership Project (3GPP), a member and major U.S. contributor to the International Telecommunication Union (ITU) Radio and Telecommunications’ Sectors, and a member of the Inter-American Telecommunication Commission (CITEL).

3. ATIS and Interoperability in the Americas
ATIS is pleased to be a part of the Regional ITU Consultation on Conformance Assessment and Interoperability and strongly supports the ITU’s objective of promoting interoperability and bridging the standardization gap as articulated in World Telecommunication Standardization Assembly 2008 (WTSA-08) Resolution 76.
ATIS seeks to support countries and regulators of the developing world.
In this regard, ATIS requests consideration of the step-by step approach to addressing interoperability as recommended in the CITEL Proposal to Plenipotentiary 2010 on Facilitating Interoperability.

4. Conformance Database Is Ineffective and Risky
A conformance database is not likely to improve interoperability.
Conformance is not necessarily related to interoperability. For example, whether a product conforms with product safety requirements does not impact its ability to interoperate with other devices.
Most products conform to many standards, not just ITU Recommendations. Hence, conformance with only ITU Recommendations will not ensure interoperability.
The majority of standards include many options. If a standard has two options, for example, products in conformance with Option A will not necessarily interoperate with products in conformance with Option B.

5. Conformance Database Is Ineffective and Risky (cont.)
The database could negatively impact countries and consumers.
Countries may be deprived of new, state-of-the art products and services if companies are inhibited from entering a market when its products are not listed in the database.
Time-to-market will likely be slowed by new conformance testing.
Marketplace confusion could result from false, misleading or otherwise erroneous database entries.
Consumers may face higher costs from additional conformance and/or interoperability testing and from reduced competition in the market. 5

6. CITEL Proposal to Plenipotentiary 2010
THEREFORE, ATIS supports the CITEL countries’ “step-by-step” approach.
The Telecommunication Standardization Bureau (TSB) Director, prior to the implementation of any conformance or interoperability database, should:
Identify the nature of the interoperability and conformity problems in the CITEL region;
Study the effects databases may have on sector members and stakeholders (e.g., other SDOs);
Proposed studies should also address relevance of the proposed searchable databases in “bridging the standardization gap” in the Americas Region;
Present the results of a robust consultative process with respect to the databases to future Council meetings;
Develop a detailed “business case” for the searchable database prior to its implementation; and
Address potential liability issues related to the use of the databases by the TSB Director before implementation.

7. In Summary
More work remains to be done in order to move toward a useful implementation of Resolution 76 that addresses the needs and priorities of member States, the structure of the ICT industry, and the expectations of end users around the world.
Any follow up action to Resolution 76 of WTSA-08 put forward by the TSB Director to Council and the Plenipotentiary Conference 2010 (PP-10) should be consistent with the CITEL Inter-American Proposal (IAP) to the Plenipotentiary Conference 2010.
A business plan that identifies costs and potential liabilities must be completed prior to launching of the proposed ITU-T database (see JCA-CIT).