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ETNO
European Telecommunications Network Operators' Association

Our Position Papers


ETNO's position papers present its member-companies' views on a wide range of technical, regulatory and trade issues to European Union decision-makers, national governments and the general public.

They are developed either internally by ETNO working groups or, occasionally, in co-operation with third parties such as other industry associations.

Click here for definitions of ETNO Position Papers and Expert Contributions.


Here are ETNO's latest position papers. Click on the date to find papers from previous years.


07
Feb

ETNO response on BEREC consultation BoR (13) 186 - by ETNO

PDF here

ETNO welcomes the review of BEREC’s common position on geographical aspects of market analysis.

ETNO believes that BEREC and NRAs should adopt a more proactive approach to reflecting the geographic differences within a national territory in their definition of relevant markets in order to effectively take into account the competitive dynamics of today’s telecommunications markets.

31
Jan

ETNO Reflection Document on “Draft ECC Report 213: Impact of Number Portability between Fixed and Mobile Services” - by ETNO

The Association of European Telecommunications Network Operators (ETNO)[1] welcomes the opportunity to comment on Draft ECC Report 213 “Impact of Number Portability between Fixed and Mobile Services”.

As a general remark, this Report seems to propose a revision of the European Regulatory Framework regarding Number Portability obligation, when that matter is not under the responsibility of ECC.

In fact the Universal Services Directive, in describing the implementation of the number portability provisions, clearly mentions that the number portability requirement “does not apply to the porting of numbers between networks providing services at a fixed location and mobile networks”.

In addition it is for ETNO premature to set milestones (for instance 2020) for “service portability”, when such a need is not predictable as emerging from the market and surely it cannot be considered a regulatory need for any concrete motivation.


[1] The European Telecommunications Network Operators' Association (ETNO) is representing 41 major companies, which provide electronic communications networks over fixed, mobile or personal communications systems in 35 countries. ETNO is Europe's leading trade association. More information about ETNO can be found at: www.etno.eu

31
Jan

ETNO Reflection Document on “Draft ECC Recommendation (14)03: Charging Principles for National and International Freephone Numbers” - by ETNO

The Association of European Telecommunications Network Operators (ETNO)[1] would like to thank the CEPT/ECC (Electronic Communications Committee) for the opportunity to comment on Draft ECC Recommendation (14)03 “Charging Principles for National and International Freephone Numbers”.

A freephone number is a number that is in principle reached free of charge for the calling party with the cost of the associated service covered by the called party. At national level, many CEPT countries have number ranges designated for this purpose.


[1] The European Telecommunications Network Operators' Association (ETNO) is representing 41 major companies, which provide electronic communications networks over fixed, mobile or personal communications systems in 35 countries. ETNO is Europe's leading trade association. More information about ETNO can be found at: www.etno.eu

03
Jan

ETNO Reflection Document on “Draft ECC Report 212: Evolution in the Use of E.212 Mobile Network Codes” - by ETNO

The Association of European Telecommunications Network Operators (ETNO)[1] would like to thank the CEPT/ECC (Electronic Communications Committee) for the opportunity to comment on Draft ECC Report 212 “Evolution in the Use of E.212 Mobile Network Codes”.

ETNO considers that the current E-212 numbering management process has been working in a fairly straightforward way and does not foresee the need for a major change in its functioning. Indeed, ETNO views the Draft ECC Report as a preliminary “reflection document” but also recognises that the issues addressed therein potentially have very relevant technical/operational/business implications not only in terms of future but also for current services. It is, therefore, of utmost importance to fully take all those into consideration before moving forward and taking any policy decision at this point.


[1] The European Telecommunications Network Operators' Association (ETNO) is representing 41 major companies, which provide electronic communications networks over fixed, mobile or personal communications systems in 35 countries. ETNO is Europe's leading trade association. More information about ETNO can be found at: www.etno.eu

28
Oct

ETNO Reflection Document on BEREC’s 2014 Work Program consultation - by ETNO

ETNO welcomes the present consultation on BEREC’s 2014 Work Programme. This contribution will also cover selected aspects of BEREC’s views on the draft TSM regulation proposal.[1]

The document BoR (13) 142 covers important areas of BEREC’s work for 2014 and takes firm positions on subjects which have not been previously discussed with the sector. While this is clearly not the sole responsibility of BEREC, a more in-depth analysis of the provisions of the draft regulation and discussions with stakeholders could have clarified some of the assumptions underlying BEREC’s position, for example that the provisions “conflict with the fundamental purposes of the current regulatory framework to promote competition” or “trigger market consolidation”. It is doubtful whether any of the provisions of the draft regulation could have such effect.



[1] (BoR (13) 142) “BEREC views on the proposal for a regulation laying down measures to complete the European single market for electronic communications and to achieve a Connected Continent”

30
Aug

ETNO Reflection Document on the EC Proposal for a Directive on Network and Information Security (NIS Directive) - by ETNO

ETNO supports the European Commission’s global approach to cyber-security and welcomes the proposed NIS Directive which recognizes the importance of security throughout the entire value chain.

As eCommunication providers are already submitted to such obligations under the telecoms regulatory framework, we welcome their explicit exemption from the scope of the draft NIS Directive. However, we would welcome further clarification on the relationship between the various existing risk management and incident reporting frameworks (telecoms package, draft Regulation on e-identification). Indeed, the “exempted” market operators may also provide bundled services falling in scope of this proposed Directive. This calls for further legal certainty as to which measures apply to different services and more importantly to avoid unnecessary cumulative or inconsistent and burdensome obligations. Indeed, market providers should not be subject to different flavours of requirements depending on the service they provide.

The European Commission [EC] should ensure that eventual further revisions of Framework Art. 13 remain consistent with the NIS Directive.

ETNO believes that cross-sector regulation should replace sector-specific frameworks.  In the long term, a cross-sector approach based on reasonable notification processes would benefit both business and customers and would avoid the need to keep aligned the obligations stemming from different Directives.

The NIS Directive’s end-to-end approach should be more explicit in establishing that non-EU based “market operators” are covered. Due to the global nature of the Internet, this is a key aspect with respect to customers’ security and having a level playing field to allow all businesses to compete on an equal footing in the EU.

ETNO welcomes the launch of the NIS platform as a way to consult all stakeholders of the global ICT value chain and exchange best practices. We welcome the DG Connect representative’s statement that this Platform intends to guarantee a balanced cooperation between the public and private sector. ETNO would like to propose a NIS platform working group dedicated to the international enforcement of NIS obligations.

07
May

ETNO comments on the Draft RSPG Opinion on Strategic Challenges facing Europe in addressing the Growing Spectrum Demand for Wireless Broadband - by ETNO

PDF Here

ETNO welcomes the opportunity to comment the draft RSPG opinion on Wireless Broadband as we believe that frequencies for WBB need forward looking strategy in Europe.

As general guiding principles ETNO believes that the identified frequency bands for WBB should be globally harmonised and national deviations should be minimised.

As the economy of scale is another import aspect to be considered, the industry should commit itself to ensure a complete ecosystem.

ETNO believes that licensed and un-licensed spectrum should be considered complementary and not as substitutes. In the short and mid-term, the Public cellular mobile networks primarily need further exclusive licensed spectrum access in order to offer reliable communication services with a high quality of service nationwide. In the long term ETNO agrees that the identification of further spectrum to destine to unlicensed uses, such as WiFi, will be needed also. However, any consideration of allocation of unlicensed spectrum should take into careful consideration the overall balance of spectrum’s alternative uses within WBB allocations.

Concerning the UHF band, ETNO believes that it is very important to define a channel plan for the 700 MHz band compatible with APT plan and so to be able to harmonise it with possible extensions downwards.

The development of a long-term strategic policy on the future convergence shall, however, not delay the preparatory work regarding the allocation of the 700 MHz band for the mobile service at the WRC-15. ETNO believes that, in the long-term, terrestrial spectrum in the lower frequencies band should be predominantly destined to WBB applications.

12
Nov

ETNO Reflection Document on “Draft ECC Recommendation 12(04): Numbering for VoIP Services” - by ETNO

The Association of European Telecommunications Network Operators (ETNO)[1] would like to thank the CEPT/ECC (Electronic Communications Committee) for the opportunity to comment on Draft ECC Recommendation 12(04) “Numbering for VoIP Services”.


[1] The European Telecommunications Network Operators' Association (ETNO) is representing 38 major companies, which provide electronic communications networks over fixed, mobile or personal communications systems in 35 countries. ETNO is Europe's leading trade association. More information about ETNO can be found at: www.etno.eu


30
Oct

ETNO Reflection Document: ECC WG NaN Green Paper - Long Term Evolution in Numbering, Naming and Addressing 2012-2022 - by ETNO

The Association of European Telecommunications Network Operators (ETNO)[1] would like to thank the CEPT/ECC (Electronic Communications Committee) WG NaN (Working Group Numbering and Networks) for the opportunity to comment on the Draft Final of Green Paper on “Long Term Evolution in Numbering, Naming and Addressing: 2012 – 2022”.

ETNO appreciates the difficulty of the task undertaken by the WG NaN to outline potential evolutions of a complex and multi-dimensional area ten years ahead in an environment as diverse as the 48 CEPT countries. In response, this paper merely intends to provide comments on the Green Paper for further discussions and related workshops; it does not have the ambition of setting out ETNO’s perspective on that same evolution.  

On a general note, ETNO also observes that the introduction of the paper emphasises a potential trend for E.164 numbers to be used chiefly as ‘names’ within ten years. Whilst ETNO understands (and endorses) the growing importance of IP-based technologies (and addresses) and social media addressing schemes, we would note that as far as numbering plan evolutions are concerned, most current evolutions under study on national or international numbering plans for the next five years are related to the use of phone numbers as “addresses”, which may be seen as being in contradiction with this long term vision.

That vision seems also to argue for a gradual disappearance of “service numbers” like short numbers. This is not consistent with the current approach of harmonisation.


[1] The European Telecommunications Network Operators' Association (ETNO) is representing 41 major companies, which provide electronic communications networks over fixed, mobile or personal communications systems in 35 countries. ETNO is Europe's leading trade association. More information about ETNO can be found at: www.etno.eu


02
Feb

RD344 - ETNO Response to the Public Consultation on the Review of the Functioning of Regulation (EC) No 544/2009 (the "Roaming Regulation") - by ETNO


If measured against the initial rationale of the roaming regulation, current regulation has reached its prime objective to protect consumers. Future regulation should carefully balance this objective with other policy goals, based on an assessment of costs and benefits. The roaming target in the Digital Agenda for Europe of lowering the difference between national and roaming charges to close to zero by 2015, should be seen as one potential means to achieve the policy goals regarding roaming, not as a policy objective in itself. Such an approach risks creating major distortions of competition and further increases regulatory costs. Legislative proposals should be subject to a thorough impact assessment.

EU policy to roaming should be consistent with the principles of the EU electronic communications framework, in particular with the principles of necessity and proportionality. Some of the regulatory options considered could lead to a competition regime which is not aligned with the existing regulatory framework. Some approaches would put at risk other goals of the Digital Agenda such as universal access to broadband networks for EU citizens.

As documented by the BEREC report on roaming regulation, wholesale data roaming charges are subject to competitive pressures. Growing data volumes and pressure from established alternatives to mobile roaming for accessing data communication from abroad will moreover accelerate the trend towards attractive data roaming retail offers, justifying a light-touch approach to the growing data roaming market.


30
Nov

RD333 - ETNO Reflection Document on the future of electronic commerce in the internal market and the implementation of the e-Commerce Directive - by ETNO

ETNO welcomes this consultation on the future of electronic commerce in the internal market and the implementation of the Directive on Electronic Commerce. The current EU legal framework on e-commerce - in particular the provisions related to intermediaries’ liability - strike the right balance amongst the interests of the different stakeholders. The framework respectd fundamental principles and rights, in particular freedom of speech, freedom of access to the internet and the right of privacy.

However, some stakeholders, in particular right-holders, are arguing for an increased liability for electronic communications operators concerning the content of communications transported over their networks. Any modification in this direction of the current liability regime for intermediaries as provided for by the e-Commerce Directive would be contrary to the basic principles of freedom of speech and privacy and go against the principle of proportionality and non-discrimination amongst actors of the value chain.

ETNO acknowledges the limited takeoff of e-commerce and believes that the causes for this situation can be found in various factors, such as the lack of harmonised consumer protection rules, the insufficient availability of instruments for electronic payments, the lack of multi-territorial licenses for online content, insufficient consumer trust and knowledge, etc. Therefore, ETNO believes that the Commission should focus on the development of harmonised rules in the aforementioned fields and organise information campaigns addressed to users. The revision of the e-commerce directive, in particular the provisions related to intermediaries liability, is not the right instrument to remove the barriers to e-commerce and to encourage innovation and market development.

30
Nov

RD334 - ETNO Reflection Document commenting on the draft BEREC Work Programme for 2011 agreed by the BEREC Board of Regulators - by ETNO

  • ETNO welcomes the new role of BEREC in working towards consistent and proportionate regulation in Europe under the revised EU regulatory framework for electronic communications.

  • We encourage BEREC to prioritise its work in 2011 by taking into account the political goals of the “Digital Agenda for Europe” to achieve a high degree of high-speed broadband availability and take-up in the European Union.

  • ETNO calls upon BEREC to address two urgent regulatory challenges regarding current and future broadband markets in its work programme (WP):
    - the need for a more symmetric approach to access regulation -- in particular, for next generation access networks (NGA);
    - the effects of platform competition -- in particular, the increasing importance of cable networks -- on market definitions and the imposition of remedies.

  • ETNO encourages BEREC to focus its harmonisation efforts. The issue of business services-specific regulation has been addressed by ERG and BEREC in 2009 and 2010 and appears adequately addressed by NRAs in their respective markets. BEREC should not expend further resources on this work item.
  • ETNO welcomes the continued work of BEREC on the issue of regulatory accounting and encourages BEREC to continue to promote economically sound solutions in a dialogue with all stakeholders and with the European Commission. An EU-level approach to access product costing, which would be disruptive to established and effective national practices, would severely undermine regulatory certainty for investors in the transition from current to next generation broadband and result in further delays in the roll-out of high-speed access networks in Europe.
30
Nov

RD335 - RPOL BEREC FS guidance - by ETNO

As ETNO argued[1] during the 2007-2009 ‘Telecoms Review,’ the proposed introduction of functional separation into the Framework was not based on any cost-benefit analysis or regulatory impact assessment.  Instead, it was politically motivated, linked to NRAs reliance on mandatory unbundling and the concept of the ‘ladder of investment’ in their implementation of the Framework. 

Existing access remedies under the Framework can be imposed to ensure non-discrimination by imposing rules on an operator deemed to have significant market power (SMP).  In the context of the Telecoms Review, NRAs – supported by the European Commissioner for Information Society and Media at the time -- claimed that these remedies “might not be enough”[2] to prevent discriminatory behaviour from a vertically integrated operator. “ERG (the European Regulators Group) believes functional separation can be a supplementary remedy in markets where non-discrimination has been shown to be ineffective in dealing with problems of equivalence in wholesale markets.” they concluded on foot of a high-level, non-quantitative analysis.

Now, as then, ETNO also argues that insufficient attention has been given to the theoretical and empirical case against functional separation. 



[1] See ETNO RD265, “ETNO Reflection Document on a functional separation remedy in telecoms,” June 2007.

[2] See ERG (07)44, “ERG Opinion on Functional Separation,” October 2007.


30
Nov

RD336 - ETNO Reflection Document commenting on draft BEREC Report on relevant market definition for business services - by ETNO



[1] Commission guidelines on market analysis and the assessment of significant market power under the Community regulatory framework for electronic communications networks and services (2002/C 165/03),


30
Sep

RD329 - ETNO response to the Commission consultation on the Open Internet and Net Neutrality - by ETNO

For ETNO the economic context of the open internet debate includes:

  • The European ICT sector requires major investment in next generation fixed and mobile high-speed networks in the coming years. The European Commission’s Digital Agenda sets ambitious targets for the availability of high-speed broadband by 2020.
  • Commissioner Kroes has repeatedly stressed the need for a regulatory framework which promotes private investment in next generation networks characterised by both high speed and high quality. Investment in these smart broadband networks in Europe crucially depends upon network operators’ freedom to innovate and develop new business models in the market in line with EU competition and consumer protection rules.
  • Starting from strong market positions in other areas of the internet, internet-based content and service providers increasingly operate in electronic communications services (ECS) markets. Openness and quality of internet-based services in many cases depend on both network operators’ and internet players’ behaviour.
  • Any analysis of internet openness therefore has to take into view the internet economy as a whole, not just isolated parts of it. Otherwise, EU policy risks aggravating distortions of competition caused by the application of different regulatory regimes to electronic communications network operators on the one hand and internet content and application providers on the other. This is particularly the case in the field of ex-ante market regulation, consumer protection and data protection.
31
Jul

RD307 - ETNO Reflection Document in response to the Commission Recommendation on regulated access to Next Generation Access Networks (NGA) - by ETNO

Next generation access (NGA) networks are a key prerequisite for Europe’s future competitiveness and the participation of its citizens in the global information society. ETNO welcomes the Commission’s ambition to provide a policy framework for NGA deployment with the present Recommendation on access to NGA and the forthcoming guidelines on state aid for broadband networks. The Commission guidance should promote private investment in NGA networks through a consistent approach in both documents. 

ETNO supports the objectives of the draft Recommendation to foster investment and innovation in new and enhanced infrastructure while preserving strong market competition. We welcome the Commission’s recognition of the increased risks incurred by undertakings investing in NGA networks.

ETNO is concerned that the Recommendation, if adopted in its present form, will not achieve the stated objectives of innovation, competition and, in particular, investment in next generation access networks. The draft foresees extensive access and price control obligations imposed on operators of new NGA network as the standard regulatory solution, and largely transposes the current regulation of copper networks to the NGA environment. This approach is not in line with the conclusions of the spring European Council and the preliminary agreement by the European Parliament and Council on the legislative review proposals aimed at adapting the current regulation to yet-to-be-built NGA networks in order to encourage investment in these networks.

28
Nov

RD295 - ETNO Reflection Document in response to the Commission Recommendation on regulated access to Next Generation Access Networks (NGA) - by ETNO

ETNO is very concerned that the draft Recommendation does not yet provide the required response to the increased risks involved in NGA investment and therefore will not facilitate those investments in Europe. ETNO supports the stated goals of the Commission to promote investment and competition in NGA and to foster sustainable infrastructure-based competition. The Association welcomes the more targeted ‘graduated approach’ to regulation which takes account of different competitive conditions in different regions in particular with regard to infrastructure competition. ETNO finds the Recommendation should remain neutral as regards the technology used for the roll-out of fibre networks to premises and the aspect of legal certainty should be re-enforced in the Recommendation.

The Reflection Document highlights in detail the draft Recommendation elements where significant changes are required, which includes the issues of regulatory response to investment risk (introducing the concept of risk sharing), gradation of remedies and geographic segmentation, the need to address symmetric sharing obligations, pricing principles for existing assets, the approach to new markets, and the choice of technology and network architecture.

Annexed to the Reflection Document is an elaborate economic analysis of “Competition dynamics in broadband networks and the competitive impact of NGANs”.

Members & Observers - View companies map

  • Albtelecom
  • Proximus
  • Eir
  • Elisa Communications Corporation
  • GO Plc (Malta)
  • Hrvatski Telekom
  • Koninklijke KPN
  • Lattelecom
  • Magyar Telekom
  • Makedonski Telekom
  • Orange
  • OTE
  • Portugal Telecom
  • Síminn (Iceland Telecom Ltd.)
  • Slovak Telekom
  • Swisscom
  • TDC
  • TDF
  • Telecom Italia
  • Telefónica
  • Telekom Austria
  • Telekom Slovenije
  • Orange Polska
  • Telenor
  • Telia Company
  • Turk Telekom
  • Vivacom
  • Deutsche Telekom AG
  • CYTA (Cyprus Telecommunications Authority)
  • BT
  • BH Telecom
  • TELEKOM ROMANIA COMMUNICATIONS S.A.
  • POST Group

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