think digital
ETNO
European Telecommunications Network Operators' Association

2010

| ETNO

RD321 - ETNO Reflection Document commenting on BEREC Work Programme 2010

ETNO has serious concerns that this first ever BEREC consultation is setting a precedent, allowing an unreasonable period for public consultation in contravention of Article 17 of the “BEREC Regulation”.

ETNO also has serious concerns about BEREC’s reliance on “reports” to develop preliminary positions – and in particular, about the fact that for such reports it is decided on a case-by-case basis whether to organise a public consultation and/or a public hearing.

In light of economic and market developments since the consultation on the ERG Work Programme 2010 in autumn 2009, among others increasing inter-platform competition in NGAs and the continuingly difficult NGA investment case, we do not believe that BEREC should simply adopt the 2010 IRG/ERG Work Programme as its own.  We call upon BEREC to reconsider the scope of its draft Work Programme and to consider devoting effort to other areas, such as "Symmetric access obligations" and "Impact of platform competition on market definition and remedies".

ETNO welcomes this opportunity to comment on the draft BEREC Work Programme 2010.

We, however, have serious concerns that this first ever BEREC consultation is setting a precedent for unreasonable period for public consultations in contravention of Article 17 of the Regulation establishing the Body of European Regulators for Electronic Communications (BEREC) and the Office  (the “BEREC Regulation”) which mandates a “reasonable period.”

ETNO also has serious concerns about BEREC’s reliance on “reports” to develop preliminary positions – and in particular, about the fact that for such reports it is decided on a case-by-case basis whether to organise a public consultation and/or a public hearing.

In light of economic and market developments since the consultation on the ERG Work Programme 2010 in autumn 2009, among others increasing inter-platform competition in the deployment of next-generation access networks (NGA) and the continuingly difficult NGA investment case, we do not believe that BEREC should simply adopt the 2010 IRG/ERG Work Programme as its own.  We call upon BEREC to reconsider the scope of its draft Work Programme and to consider devoting effort to other areas, such as:

  • Symmetric access obligations: a work stream on the implementation of Article 5(1) of the Access Directive  and the transposition and eventual implementation of amended Article 12 of the Framework Directive  for the imposition of symmetric access obligations to encourage co-location and sharing of network elements and associated facilities, assisting the deployment of NGA;
  • Impact of platform competition on market definition and remedies: a work stream on the definition of markets, such as ‘markets 4’ and ‘market 5,’  and the possible imposition of regulatory remedies in light of the impact of competing access platforms.
pdf

RD321 - ETNO Reflection Document commenting on BEREC Work Programme 2010

Download (134 KB)

Members & Observers - View companies map

  • A1 Telekom Austria Group
  • Albtelecom
  • Altice Portugal
  • BH Telecom
  • BT
  • CYTA (Cyprus Telecommunications Authority)
  • Deutsche Telekom AG
  • Eir
  • Elisa Communications Corporation
  • GO Plc (Malta)
  • Hrvatski Telekom
  • Koninklijke KPN
  • Magyar Telekom
  • Makedonski Telekom
  • Orange
  • Orange Polska
  • OTE
  • POST Group
  • Proximus
  • Síminn (Iceland Telecom Ltd.)
  • Slovak Telekom
  • Swisscom
  • TDC
  • TDF
  • Telecom Italia
  • Telefónica
  • TELEKOM ROMANIA COMMUNICATIONS S.A.
  • Telekom Slovenije
  • Telenor
  • Telia Company
  • Turk Telekom
  • Vivacom
  • AT&T
  • Cisco
  • Ericsson
  • Huawei
  • Nokia
  • Prysmian Group
  • Qualcomm Europe Inc.
  • Verizon

ETNO aisbl - Boulevard du Régent 43-44 - 1000 Brussels - Belgium

Phone: +32(0) 2 219 32 42 - info@etno.eu