Select Committee on Foreign Affairs Appendices to the Minutes of Evidence

Annex 11

(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 here.

  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 Gibraltar.

  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 Resolution.

  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 and conditions.

  To assist with this exercise, I enclose the following documents[61]:

    (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 of assessment;

    (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 matter.

  I look forward to hearing from you at your earliest convenience.

Peter Caruana

Chief Minister

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' information.

  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.

Peter Caruana

Chief Minister

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 2001


  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.").[62] 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 Decision:

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,[63] 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.[64] 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" numbers.

  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 Gibraltar.

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 "956" Numbers

  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 Available Capacity

  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 exhausted.

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

European Lawyers

28 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 below.


  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 Telefonica customers

  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.


  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 rate numbers).

  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 numbers

  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 above.

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 Regulator.

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 it.

7.  Roaming

  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.

Gibraltar Government

(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 services.

  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.

Gary Butler


20 December 2001

61   Ev 58-63 Back

62   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

63   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

64   Art. 13((1)(e). Ibid. Back

65   See Back

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