(i) Letter from Hon Peter Caruana QC,
Chief Minister, Gibraltar, to Rt Hon Jack Straw MP, Secretary
of State, Foreign and Commonwealth Office, 16 January 2002
On 16 November 2001, the Spanish Government
published a Resolution laying down the arrangements under which
it purports to allocate an additional 70,000 telephone numbers
to Gibraltar (Resolution 21485 of 8 November 2001).
The Gibraltar Government has now had the opportunity
to examine the Resolution which has also been the subject of separate
technical and commercial evaluations by the telecommunications
operators in Gibraltar (including our US commercial partner, Verizon
Communications Inc.) and of a regulatory assessment by the Gibraltar
Regulatory Authority ("the Regulator").
I understand that the offer is commercially
unacceptable to the Gibraltar telephone companies. I also understand
it is unacceptable, for statutory and jurisdictional reasons to
the Regulator, whose statutory role is by-passed, together with
his ability to discharge his statutory obligations and duties
under the Directives and the Gibraltar legislation implementing
them. The offer is, for all of these, and additional, reasons
unacceptable to the Gibraltar Government and will not be implemented
The underlying reason for this is that the Resolution
vests full control over telephone numbers in Gibraltar in the
hands of Spanish interests. It comprehensively excludes any role
for any Gibraltar authority in the grant of numbers in Gibraltar.
Furthermore, the resolution is worse than the
current situation, itself unsatisfactory, in that, for the first
time ever, it requires Gibraltar's total integration within the
Spanish numbering plan thus altering the current position which
is that Gibraltar has its own numbering plan, to certain levels
of which Spain allows access for its network. The Spanish offer
makes it clear that Gibraltar has no numbering plan of its own,
but uses numbers allocated to it by Spain from Spain's numbering
plan. This is totally unacceptable.
As if all that were not bad enough, the offer
allows a Spanish entity, in this case Telefonica, to take over
from the Gibraltar Regulatory Authority the responsibility for
operating Gibraltar's numbering plan. It thereby allows Telefonica
to acquire a regulatory role in Gibraltar which it does not, and
cannot, have in Spain itself and certainly should not have in
I can only assume that this offer has been carefully
structured to constitute the first joint sovereignty/joint responsibility
item in your current negotiations with Spain.
Indeed, the Resolution not only vests control
over Gibraltar's numbering plan in an incumbent operator contrary
to EU requirements, but it does so in favour of the incumbent
operator in a separate (and dare I say, hostile) Member State
whose abusive behaviour, precisely in relation to numbering issues,
has led to the filing of the two complaints which are still pending
before the EC Commission. As if to prove this, and despite the
fact that the arrangements are not even operational yet, Telefonica
has already abused its control of the numbering plan to block
access via the new 8563 code to those levels in the numbering
plan used by our mobile operator, ie 54, 56, 57 and 58. They have
not blocked other levels starting with the digit "5"
not used by our mobile operators, eg "52" and "59".
Just as objectionably, Telefonica seeks to assign
the numbers (under its control to Gibraltar Nynex, Gibraltar's
incumbent monopoly service provider, thus further disabling our
compliance with the liberalisation legislation and the discharge
of their responsibilities thereunder by the Regulatory Authority
and the Licensing Authority.
The Resolution is therefore a highly prejudicial,
retrograde step which is unacceptable and unworkable on legal,
commercial, technical and regulatory grounds. It is also politically
unacceptable. In fact, it constitutes particularly clear evidence
of Spain's desire to limit and control the growth of the telecommunications
industry in Gibraltar, just as Sr Pique has publicly declared.
In addition, if given effect, the Resolution
would place Telefonica in a position where it will determine whether
community obligations in Gibraltar are complied with. A Spanish
company will thereby decide whether or not the UK Government will
be exposed to infraction proceedings, with the potential for financial
liability, which may be initiated by private operators whose commercial
interests may well be prejudiced by the restrictive terms of the
I cannot understand how and why you and Peter
have so warmly welcomed this offer. Notwithstanding it being prematurely
lauded as a gesture of Spanish good faith, I hope that the unacceptability
of the Spanish offer will be as clear to HMG as it is to us, once
you and your officials gain a proper understanding of its terms
To assist with this exercise, I enclose the
(1) A memorandum dated 26 November 2001 by
O'Connor & Co, Gibraltar Nynex's Brussels lawyers, assessing
the meaning and effect of the Spanish offer;
(2) The Gibraltar Government's own memorandum
(3) Letter dated 20 December 2001 addressed
to me by Verizon Inc Vice President.
I understand that the local telephone operators
are now reviewing the options in the complaints with a view to
early commencement of litigation.
For all of these reasons the "new"
numbers will not be used in Gibraltar, since the terms upon which
they are available constitute a humiliating and calculated sell
out of every aspect of Gibraltar's rights and interests in this
I look forward to hearing from you at your earliest
16 January 2002
(ii) Letter from Hon Peter Caruana QC,
Chief Minister, Gibraltar, to Rt Hon Jack Straw MP, Secretary
of State, Foreign and Commonwealth Office, 18 March 2002
Thank you for your letter dated 26 February
2002 on the subject of telephones.
At the time that you wrote that letter you may
not have been made aware of the (further) Spanish Government decision
made on 14 February 2002. I enclose a copy for your officials'
That decision alters the historical status of
the original 30,000 numbers by now (retrospectively as from 17
November 2001) assigning them to Telefonica, the Spanish operator
and licensee. The statement in your letter under reply, that the
talks in Madrid on 11 February helped to clarify the details of
the allocation of the original 30,000 numbers, has to be seen
in the context of this decision, ie the unilateral Spanish recategorisation
of the original 30,000 numbers to put them on the same unacceptable
basis as the new 70,000 numbers.
You say that Sr Pique is convinced that the
Spanish offer is consistent with Spanish and corresponding EU
legislation. We disagree. In any case, your letter is silent on
our other fundamental objections, especially the usurpation by
Spain of our licensing, regulatory and jurisdictional competences.
One of the elements of the Spanish decision
is that the existing 30,000 numbers that currently access Gibraltar
via "9567" will not be available to us after December
2002. This seems designed to pressurise us into accepting the
new arrangements on the current unacceptable terms or risk complete
disconnection from Spain. Since we shall not be willing to accept
either of those options, we are looking at alternative arrangements.
I shall be happy for Gibraltar officials to
take part in talks with UK and Spanish officials provided that
it is clear that such talks are not part of the Brussels process.
18 March 2002
(iii) Memorandum from Mr Steven E. Brummel
O'Connor and Company, European Lawyers, to Mr Charles S. Fortunato,
Managing Director, Gibraltar Nynex Communications Ltd. 28 November
The purpose of this memorandum is to provide
a preliminary review and analysis of a recent Spanish Governmental
decision on telephone numbers allocated to Gibraltar network termination
points ("Decision") published in the 16 November 2001
edition of the Spanish Government's official gazette ("B.O.E.").
The Decision embodies the Spanish offer for resolving the numbering
shortage raised in the GNC Numbering Complaint. It expands with
immediate effect the number space allotted to Gibraltar from the
current 30,000 numbers to 100,000 numbers. The Spanish Government
published its offer four days before the scheduled 20 November
discussions between the British and Spanish Governments.
At this point it is unclear whether the offer
is final or still subject to negotiation or, if it is final, whether
it addressed Gibraltar's temporary or permanent needs. The joint
press communiqué issued at the end of the 20 November bilateral
discussions stated that the British Government "welcomed
the Spanish decision" to triple numbers to 100,000 while
noting that "both Ministers agreed on the need for experts
to continue discussions to resolve the other telecommunications
issues." It is clear that the roaming issue is left to further
discussions among experts. It is, however, unclear whether, under
the terms of reference, these experts may review the size of terms
for the current 100,000 number offer or seek to establish a procedure
by which additional numbers can in future be made available to
Gibraltar (eg via Spanish 350 recognition or the allotment of
additional number blocks from the Spanish Numbering Plan).
We provide below an explanation of the salient
provisions of the Decision, then an analysis of its implications
followed by [deleted].
The Decision sets down certain terms for the
move from 30,000 to 100,000 numbers for Gibraltar's use. We outline
the main points below:
Number Blocks Opened and Retired
The Decision (Section Primero) designates a
new block of 100,000 numbers in the Spanish Numbering Plan for
allotment to Gibraltar under the "856" code, available
immediately, and retires the existing block of 30,000 numbers
under "956" effective 31 December 2002 for redistribution
to Cadiz Province locations (Section Tercero).
Award Procedures for New Numbers
New numbers are awarded to operators satisfying
the following criteria (Section Segundo):
Have their own means for direct delivery
of telephone traffic to Gibraltar; and
Hold a Spanish license for public
fixed telephone service.
Obligation to Use "856" for Gibraltar
and Subassignment Possibility
Operators obtaining these "856"number
blocks are obligated to use them for connections to fixed network
termination points located in Gibraltar (Section Segundo). The
text adds that this obligation can be implemented by means of
subassignment if necessary without stating clearly to whom the
subassignment could be made. No procedures or criteria are set
down for the subassignment of number blocks.
Registration of Existing "956" Numbers
The Comision del Mercado de las Telecommunications
("CMT") will register on the official "Registro
de Assignaciones y Reservas de Recursos Publicos de Numeracion"
the existing "956" number blocks used for Gibraltar
network termination points in the name of Spanish licensed operators
(Section Tercero second paragraph). This registration is valid
until 31 December 2002. It is unclear whether such registration
requires an application from a Spanish licensed operator and which
criteria are applied to identify eligible or appropriate recipients
of "956" number block assignments.
Universal Accessibility and Domestic Call Status
Termination points in Gibraltar using "856"
numbers and, until 31 December 2002, "956" numbers must
be accessible from all public telephone networks in Spain (Section
Cuarto). Calls to such termination points are also to be treated
as domestic calls (Section Quinto).
In our view, the Spanish Government has chosen
to offer additional numbers to Gibraltar in a manner which binds
Gibraltar more closely to its administrative authority and makes
GNC and other Gibraltar operators dependent on rival Spanish telecom
operators. Moreover, the offer takes the form of a decision that
has already taken effect and appears to create a default position
that penalises Gibraltar if the bilateral talks on numbering issue
come to a deadlock. That is, absent bilateral agreement to resolve
the number shortage problem in another manner, the Decision takes
effect and Gibraltar must choose to abide by it and obtain new
"856" numbers under it or risk losing its current "956"
number space in the Spanish Numbering Plan on 31 December 2002.
We identify below major consequences of the
Absolute Deadline to Accept Spanish Offer
As stated above, Gibraltar must act soon on
the offer or risk losing its existing numbers at the end of December
2002. As of 31 December that year, the "956" numbers
revert to Cadiz Province and can be reassigned to operators for
network termination points in Cadiz Province.
The Decision has set down in a binding fashion
the target deadline mentioned by both Britain and Spain for their
comprehensive settlement of Gibraltar issues.
Applicants for New "856" Numbers Must
be Spanish Licensees
The Decision establishes an award procedure
that may, in practice, serve to exclude Gibraltar operators from
direct application for and assignment of "856" numbers.
One criterion is that the applicant holds a Spanish public fixed
telephone service license. While it may be possible for a Gibraltar
operator to apply for and obtain such Spanish license, we regard
it as unlikely that a Gibraltar entity would follow this course
of action. To do so would subject it to the rules and obligations
of the Spanish telecommunications framework and the monitoring/enforcement
authority of the Spanish regulator. [Deleted]
The other criterion requires an operator to
hold transmission infrastructure that allows direct delivery of
telephone traffic to Gibraltar. This criterion does not state
explicitly that the infrastructure has to be located in Spain.
It may or may not be implied. If infrastructure must be located
in Spain, then a Gibraltar operator could not qualify for numbers,
even if it had received a Spanish public fixed telephony license.
We presume that the infrastructure does not have to be located
in Spain. Nonetheless, this is an ambiguous point that the Spanish
Government should clarify.
Gibraltar Operators Eligible for "856"
Subassignments from Spanish Rivals
Gibraltar operators who cannot qualify for direct
assignment of "856" numbers appear to have the option
of obtaining them via subassignment from Spanish operators who
do qualify and have received allocations. The Decision effects
this in an oblique manner. Section Segundo states that any recipient
of "856" numbers must use them for connecting to Gibraltar
network termination points, if necessary, by means of subassignment.
What does this mean in practice?
A Gibraltar operator asks a Spanish licensee
to apply for "856" number blocks and for subassignment
of them. Subassignment is not a purely commercial matter between
operators. The Spanish regulator, the CMT, must be notified in
advance and probably has powers to modify or block the subassignment.
Specifically, under other Spanish rules,
the Spanish licensee in its application must state that the numbers
are intended for subassignment. Further, the Spanish licensee
must put the numbers to use within twelve months of receipt or
risk forfeiting them.
In other words, the Gibraltar operator can only ask a Spanish
licensee for numbers it will use within the next twelve months.
It cannot keep numbers in reserve because, if it does, it may
lose them. From a procedural standpoint, this process is time-consuming
and awkward as it forces a Gibraltar operator to route its growing
number capacity needs through a third party operator. We also
believe that the Spanish regulator will exercise vigilance to
detect when subassigned numbers are not used within the 12 month
deadline and return them to the pool of unassigned "856"
The necessary exchange of information on numbering
needs between a Gibraltar operator and a Spanish licensee also
may raise EC competition problems. For instance, the Spanish operator
would be kept appraised on a continuous basis of the business
expansion plans of a rival operator just across the border in
No Role for Government of Gibraltar
The entire number award process excludes any
role for any unit of the Government of Gibraltar ("GOG").
The Gibraltar Regulation Authority ("GRA") does not
have any role in administering the assignment of "856"
numbers. Thus, it cannot plan or manage capacity. Neither does
it hold a monitoring or enforcement function.
Apparent Registration Requirement for Existing
Provisions in Section Tercero of the Decision
appear to require the CMT to register the existing "956"
number blocks in the name of Spanish licensed operators. As the
"956" numbers revert to Cadiz province in twelve months,
there does not seem to be an objective reason for this requirement.
Nonetheless, one could imagine subjective reasons. For instance,
this provision does not leave the initiative for allocating existing
"956" numbers to Spanish licensed operators. CMT takes
the initiative and perhaps sets the pattern for the assignment
of the new "856" number blocks.
Lack of Automatic Follow-Up Procedure To Enlarge
If one accepts the Spanish offer as is (and
we are not saying one should), the offer still fails to address
the need for number capacity beyond 100,000. It lacks any mechanism
to identify and award number resources once the 100,000 pool is
exhausted. Gibraltar and its operators are thrown back to the
current position of vainly petitioning over a period of 10 years
for additional allocations of number supplies. We believe that
the "856" arrangement should contain procedures for
the award of numbers supplies once the 100,000 pool is almost
Pressure to Abandon Complaint
The "856" number allocation procedure
generates implicit pressure on GNC to abandon its DG-COMP competition
complaint. Let us explain. Requests for "856" numbers
are funnelled through a Spanish licensed operator and the Spanish
regulator. The CMT retains the ultimate power to refuse the assignment
or subassignment of "856" numbers. It can also act to
take back assigned numbers. Given such CMT powers, it seems possible
that Gibraltar operators may be denied additional numbers on a
subassignment basis so long as GNC maintains the Numbering Complaint
and perhaps even if Gibtel maintains its roaming complaint.
Spanish Offer Confirms Grounds of Complaint
It is important to note that the Spanish offer
as set out in the Decision, particularly in the procedures established
for number allocation, constitute clear, new evidence of Spain's
efforts to limit the growth of Gibraltar telecom operators and
service providers. It reconfirms the basis of the GNC numbering
complaint against anti-competitive abuse. [Deleted]
[Remainder of Memorandum Deleted]
O'Connor and Company
28 November 2001
GIBRALTAR GOVERNMENT COMMENTS ON SPANISH
OF 8 NOVEMBER 2001
1. The underlying deficiency in Spanish
Resolution 21485 of 8 November 2001 is that it requires Gibraltar's
total integration within the Spanish numbering plan. The manner
in which this is done, and the consequences which flow therefrom,
are summarised in Part 1 below. The Resolution is also deficient
in a number of other respects. These are summarised in Part II
PART I. GIBRALTAR'S
2. Under current arrangement, Gibraltar
operates 30,000 numbers from within the Spanish numbering plan
for the province of Cadiz (under code 9567). These 30,000 numbers
are omitted from Spain's numbering plan, are recognised by Spain
as being Gibraltar's and are under the Gibraltar Regulator's control.
3. The Resolution does considerably worse
than that. Whereas it claims to allocate the new code (8563) to
Gibraltar, it assigns the numbering space thereunder to an operator
which must hold a public fixed telephone service licence in Spain
(the assignment has already been made in favour of Telefonica)
who would then sub-assign numbers to fixed network termination
points situated in Gibraltar. This is an important regression
from the current situation, itself unsatisfactory, as it requires
Gibraltar's total integration within the Spanish numbering plan
and the numbers for subassignment to Gibraltar operators to be
controlled and administered by an operator which must be licensed
in Spain and thereby subject to the Spanish regulatory framework
and ultimately the Spanish Regulator.
4. The implications and consequences of
the foregoing may be summarised as follows:
1. Telefonica becomes Gibraltar's Regulator
for Numbering Purposes
5. The Gibraltar Regulator is stripped of
one of the most essential functions of any telecoms regulator,
namely, the control and assignment of numbers to operators. Since
the 8563 range of numbers has already been assigned to Telefonica,
it is this company that would perform this role in Gibraltar.
Telefonica thereby acquires a regulatory role in Gibraltar which
it does not, and cannot, have in Spain itself. Indeed, one of
the fundamental objectives of the EU's liberalisation programme,
and an essential element of any truly liberalised market, is to
divorce the regulatory and commercial functions of incumbent operators.
Accordingly, EU law requires that numbering plans be controlled
by regulatory authorities in order to ensure independence from
the incumbent operator. The Resolution achieves precisely the
opposite. It vests on an incumbent operator, to boot, the dominant
operator in a separate Member State whose abusive behaviour with
respect precisely to numbering issues has led to the filing of
the two Gibraltar complaints before the EC Commission, with responsibility
for controlling Gibraltar's numbering plan.
2. Telefonica will decide whether or not the
UK Government complies with its EU obligations
6. Under EU law, the United Kingdom, as
the Member State responsible for Gibraltar, has an ultimate obligation
to ensure that adequate numbers are available for all telecommunications
services in Gibraltar. Under EU law, the Gibraltar Regulator has
an obligation to ensure that numbers are allocated in an objective,
non-discriminatory and transparent manner in Gibraltar.
7. The Resolution cannot remove these obligations.
Yet compliance with these obligations depends on Telefonica. Are
we to assume that the UK Government is content for a Spanish company
to decide whether or not the UK complies with its obligations
under EU law? Are we to assume that the UK Government accepts
that a Spanish company will decide whether or not the UK Government
will be exposed to infraction proceedings, with the potential
for financial liability, which may be initiated by private operators?
3. Gibraltar operators are compelled to become
8. In practice, all Gibraltar operators
will be required to obtain numbers from Telefonica or any other
operator licensed in Spain. It is clear, particularly in view
of the comments which both Telefonica and the Spanish Government
have made in the context of the complaints before the EC Commission,
that these Gibraltar operators will be, or will be perceived to
be, potential competitors of Telefonica. In these circumstances,
the requirement on Gibraltar operators to have to ask Telefonica
(a potential competitor) for numbers flouts numerous competition
rules. The Resolution reinforces Telefonica's status as an unavoidable
trading partner for all Gibraltar operators. It strengthens its
dominant position. Gibraltar operators would be required to disclose
in advance sensitive business developments to potential commercial
rivals in Spain. This is both unacceptable and unworkable and
will inevitably give rise to EC competition problems.
9. Furthermore, since Telefonica is required
to sub-assign numbers to fixed network termination points in Gibraltar,
it can only sub-assign the numbers to operators in Gibraltar with
whom it connects at a network termination point.
PART II. FURTHER
10. In addition to the foregoing, the Resolution
is unacceptable and unworkable for the following further reasons.
1. Fixed/Mobile Networks
11. The Resolution explicitly states that
Telefonica can only sub-assign numbers to "fixed network
termination points situated in Gibraltar". This excludes
the possibility for a mobile operator to directly interconnect
with mobile or fixed networks in Spain rather than having to interconnect
via the incumbent operator. This is contrary to EU law.
2. Interconnection between networks
12. There appears to be an indication in
the fourth recital to the Resolution that the interconnect regime
that would apply to the relationship between the Spanish licensee
and the sub-assignee of numbers in Gibraltar would be the regime
applicable for calls within Spain. If so, this is unworkable as
the interconnect charge applicable in Gibraltar is double that
of what it is in Spain.
3. 70,000 additional numbers are not on offer
13. The 8563 code contains a numbering space
of 100,000 numbers, 10,000 numbers being available at each of
the ten sub-levels (0-9) under the 8563 code (ie 8563-0 has 10,000
numbers and so on).
14. Of the 100,000 numbers available under
the 8563 code, 30,000 will correspond to those already in use
under the 9567 code (under sub-levels 4, 5 and 7). The additional
70,000 numbers are available under the remaining sub levels under
the 8563 code (ie 10,000 numbers per sub level 0, 1, 2, 3, 6,
8 and 9). For technical reasons, certain of these sub levels cannot
be assigned to customers. For instance level 1 is, by convention,
reserved by operators for network services such as emergency numbers
and operator enquiries. Equally, level 0 is reserved for numbers
which cannot be accessed from overseas (eg free phone and premium
15. Consequently, what is on offer is no
more than 50,000 additional numbers. In this context, it must
be noted that in a liberalised market (effective in Gibraltar
as from 19 July 2001) the demand for numbers in Gibraltar will
be greater than ever before (both from existing operators and
new entrants). Already today, an operator which will shortly be
licensed has expressed an interest for 10,000 numbers. Accordingly,
an additional 50,000 numbers may well prove to be insufficient
in the not too distant future. It is impossible to run a credible
telecommunications industry when the essential raw material in
the industry is rationed in this manner.
4. No procedure for the allocation of future
16. The Resolution is silent on the allocation
of further numbers once the amount of numbers envisaged by the
Resolution is exhausted. I refer to the comment at Paragraph 15
5. The threat of the withdrawal of numbers
17. It is clear from Article 2 of the Resolution
that sub-assignment from the Spanish licensee to the Gibraltar
operator will have to conform with the requirements of Spanish
law, notably Royal Decree 225/1998 of 16 February 1998. Under
the said Decree, the Spanish Regulator must oversee the sub-assignment
of numbers and may ask for the withdrawal of sub-assigned numbers
which have not been used within twelve months of receipt. This
does not allow us to establish secure market conditions in Gibraltar
conducive to business development particularly since the power
to withdraw number lies with the Spanish and not the Gibraltar
6. The Least Cost Routing Problem persists
18. HMG officials have constantly been appraised
of the highly detrimental effects on Gibraltar of the Least Cost
Routing Problem. This problem arises as a result of the fact that
Gibraltar numbers can be accessed from abroad via either Gibraltar's
350 code or Spain's 34 code. It gravely affects the quality of
telephony services in Gibraltar (notably through the large number
of lost calls) and, as a result of the current arrangements between
our operator GNC and Telefonica (set out in a Sender Keeps All
Agreement) it allows Telefonica to unjustifiably enrich itself
with revenue which is due to Gibraltar. The Resolution does nothing
to solve the Least Cost Routing Problem. Indeed, it perpetuates
19. The Resolution does nothing to solve
the roaming problem.
8. The imposition of a deadline
20. In view of all the foregoing, the imposition
of a deadline of 31 December 2002, by which time Gibraltar either
accepts the 8563 "offer" or risks losing its existing
9567 numbers, can only be interpreted as an attempt to exert pressure
and to force Gibraltar's hand into accepting a new arrangement
under which the future of Gibraltar's telecommunications industry
will be totally controlled by Spanish interests.
(v) Letter from Mr Gary Butler, Vice President,
Europe and Asia, Verizon Communications, to Hon Peter Caruana
QC, Chief Minister, Gibraltar, 20 December 2001
On behalf of Verizon Communications, which is
invested in Gibraltar NYNEX (GNC) and GibTel, I wish to extend
our congratulations and appreciation for the tremendous efforts
extended by you and your government to resolve long-standing telecommunications
disputes between Gibraltar and the Government of Spain. We believe
that your efforts are essential to ensuring that the citizens
of Gibraltar are afforded a full range of high quality telecommunications
Despite the progress that has been realised,
however, we remain very concerned about the Spanish government's
allocation of 100,000 telephone numbers to Telefonica for administration
in Gibraltar, as well as the long-standing issue of international
mobile roaming to Spain. Through this action, Spain has effectively
positioned its own incumbent carrier as the overseer of a crucial
aspect of Gibraltar's telecommunications operations, a situation
that Verizon, GNC and Gibtel view as untenable and extends Telefonica's
market power beyond the borders of Spain to Gibraltar.
We believe that it will be extremely important
for the Government of Gibraltar to actively oppose Spain's action
on the telephone numbering issue, and we respectfully encourage
you to block the implementation of Telefonica's control of Gibraltar's
numbering scheme. Verizon fully intends to lend its voice and
action to this issue by working with senior government officials
such as yourself, as well as in the United Kingdom, Spain and
the European Union, to ensure that measures are taken to prevent
GNC from being placed at a competitive disadvantage.
I would be honoured to speak with you about
this matter and hope you will not hesitate to call upon me as
you continue your efforts to create a fair competitive telecommunications
environment in Gibraltar.
20 December 2001
61 Ev 58-63 Back
Resolution de 8 novembre de 2001. de la Secretaria de Estado
de Telecomunicacioines y para la Sociedad de la Information (del
Ministro de Ciencia y Tecnologia) por la que se adjudican recoursos
publicos de numeracion a la colonia britanica de Gibraltar, BOE
num 275, 16 noviembre 2001, pp. 42100-42101. Back
Art. 13 (1)(b) of Numbering Regulation approved by Real Decreto
225/1998 de 16 de febrero, por ei que se aprueba el Reglamento
de procedirgineto de asignacion y reserva de recursos publicos
de numeracion por la Cornision del Mercado de las Telecomunicaciones,
B.O.E. NUM. 48. 25 Febr. 1998. Back
Art. 13((1)(e). Ibid. Back
See www.boe.es/boe/dias/2001-11-16/pdfs/A42100-42101.pdf Back