*AFAG REPLIES TO HON HARUNA IDDRISU*

The attention of the Alliance for Accountable Governance(AFAG) has been drawn to the newspaper Publication of the Ghanaian Times edition of Friday May 21, 2010 in which the Hon. Minister of Communication distorted and deliberately misrepresented AFAG’s position on the Installation of the *Intelligence Signal Management System (ISMS*) by the *Global Voice Group(GVG) S.A.*

AFAG regrets that, in paragraph 2 of the Minister’s statement, he stated that, “had AFAG availed itself of the widely advertised opportunity to seek responses to its concerns, it would have at least, been spared the blatant mis-representation and factual inaccuracies delivered by the media”.

We wish to inform the Hon Minister just in case he never cross checked, AFAG was present at the Association of Ghana Industries (AGI) sponsored Consumer Forum at the International Conference Centre which the Ministry of Communication couldn’t have found a more appropriate day solely to address the concerns of Ghanaians on Telecommunication services, than for the AGI’s event of Monday 17-20 May.

Be it as it may, we can state authoritatively that the issues of GVG to install the ISMS and the increase in international calls cost from 12UScents to 19 UScents to be effective 1st June, 2010 was not a subject for discussions on that day.

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*AFAG’s CONCERNS:*

In direct response to the issues raised by the Hon. Minister. We wish to point out that:

i. It is disappointing for the Hon Minister to state in his submission that “the establishment of the floor termination rate at 19 cents in Ghana will have no effect on the end user in Ghana as it is to be borne by international carriers”

It is our position that:

· increasing international call cost from average 8-12 cents and fixing it at 19 cents with a punitive action against Service Operators who charge below or above in a liberalised market is unacceptable

· Ghanaians living abroad will suffer high international call charges in reaching loved ones in Ghana

· The cost of doing business in Ghana will also go up

We find it therefore very strange that the Hon Minster holds the erroneous view that, the cost as a result of the imposition of the 6 US cents tax will not be passed on to the end user.

The question is who is the end user?

Though the Minister in his assertion may remain heartless to the Ghanaian living abroad, what remains of the Ghanaian who travels on a short visit abroad and will want to call home? It may be a young child, student, working or non working parent or grandparent.

The Minister also stated*” by the exercise of the prerogative in ITU Resolution D.156 on Network Externality, regulators are to ensure sustainability of Network and to exercise the right to apply a premium on all international calls to develop and strengthen their ICT infrastructure*”

The Minister refers to the ITU Recommendation 156 on network externalities, but does not appear to have understood its intentions.

Recommendation 156 is explicitly concerned with increasing availability of telecommunication services for marginal users in developing countries. Recommendation 156 speaks of a small, non-cost element to be added to the cost-based elements that make up a settlement collected by the service operators to fast track ICT infrastructure development.

Because the 6c share of the 19c is being paid to NCA, rather than collected by the network operators as envisaged by Recommendation D.156, there is no indication how it will be used to further the availability of Telecom services.

Hon Minster, AFAG is very much aware of already the existence of the Ghana Fund for Electronic Communication (GIFEC), formerly called GIFTEL. This Funds we are aware is made up 1% of after tax profit contribution by all the operators annually. It is meant to make telecom infrastructure available at mainly deprived areas i.e. rural areas, to develop ICT centres and Human Resource development.

The question is; what has happened to the average contribution of USD 15 million made from the GIFEC fund annually?

Thus, in-spite of the already existing provision the argument is flawed if it remains that the USD 6c is been added to the industry average of USD 12 cents for international calls in order to facilitate ICT infrastructural development.

In furtherance to the above, we wish to remind the Minister that the recommendation D.156 states that the externality premium should be negotiated on commercial bilateral basis by the concerned operators and in section 4 and 9 of the explanation document prepared by the International Telecommunication Union (ITU) of which the Hon Minister is the Vice President, study group 3, clearly states that; ‘the externality premium shall not be payable to Government’. Hence what business has the NCA to do with over USD 50 million annually you claim would accrue to the state?

ii. On the Minister’s *assertion that our statement purported to portray that attempts by the company to work in the country during the tenure of the previous administration was halted because it was dangerous*, we are asking the Hon Minister and the good Public to check on our whole statement on the internet i.e. www.peacefmonline.com or www.myjoyonline.com or on our www.facebook.com page for our full statement.

AFAG never made such a statement. Rather, we reiterated that there was a Political conspiracy between High profiled persons of both the previous and the current Government to impose the operation of GVG on Ghanaians.

If indeed, it was the previous regime who engaged GVG to operate in Ghana, then, it is AFAG’s position that, the decision was absolutely inimical, hence we call on the current Government to bring the change.

iii. On the Minister’s position i.e. ”to allay the fears of AFAG that the facility has the tendency of monitoring and tracking all international call and viewing all text messages, the Group should be assured that the Signalling Transfer Point(STP), an out-of-band signalling system which will be connected via F-links, uses only ITU SS7 signalling protocol. Therefore this structure lacks the capacity to tap into the content of incoming or outgoing electronic communication traffic”

AFAG finds this position absolutely erroneous and calculated to do mischief.

Indeed AFAG did not mention Signal Transmission Point (STP).We stated categorically that, we have an issue with the installation of the INTELLIGENT SIGNAL MANAGEMENT SYSTEM (ISMS) which can monitor and tap the content of phone conversations and text messages.

We are aware that ISMS and STP are not same. For a fact, F-Links (i.e. Fully Associated Links) are not used in networks with STPs. Indeed F-links connect two signal endpoints i.e. Service Switching Point (SSP) and Service Control Points (SCPs)

AFAG is however very surprised the Minister is not aware the ITU SS7 signalling protocol can be monitored and tapped into by non intrusive devices (e.g. Dialogic MSP 1010 Multisystem Platform). This may account for why he underestimates the advanced operational capabilities of the ISMS which the law frowns on.

We therefore on this note, would want to remind the Hon Minister of some functions of ISMS. Among other things it has these functions;

· Optimal routing

· Location based services

· Traffic engineering and net work traffic

· Fraud detection

· Network billing and Call Detail or Data Recording (CDR) generation checks-{this* is a telecommunication operator’s tool for arbitrating interconnections. This can be used to crosscheck content of voice calls or text messages* *and identification of calling and called parties*}

Mr. Minister the CDR function of ISMS will be in the control of GVG/NCA from June 1st on all international calls. The question AFAG expect the Hon Minister to answer is; ‘Is the CDR function exiting from the service operators to NCA?

In the event where AFAG is not clear on this issue, in the interest of the Public we shall want to seek redress in the Court of Law. God Bless Ghana. *SIGNED: *

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1. Nana Ayew Afriyie 0244780359

2. Arnold Boateng 0244294754

3. James Kwabena Bomfeh 0244535472

4. Sammy Awuku 0244252052

5. Kojo Quainoo 0244852464