Position papers

• Position papers

  ETNO – GSMA joint response to the European Commission’s Digital Levy public consultation

  ETNO and the GSMA welcome the possibility to provide their comments below in response to the European Commission’s (‘EC’) Digital Levy public consultation.

  14 April, 2021 Read more
• Position papers

  ETNO responses to RSPG Consultations on draft opinions on RSPP, Spectrum sharing, and Additional spectrum needs

  As ETNO appreciates the opportunity to provide comments to the consultations on the RSPG draft opinions on RSPP, Spectrum sharing, and Additional spectrum needs and guidance on the fast rollout of future wireless broadband networks.

  30 March, 2021 Read more
• Position papers

  ETNO position paper on the Revised Directive on Security of Network and Information Systems (NIS2)

  Introduction

  ETNO welcomes the Cybersecurity Package proposed by the European Commission on 16^th December 2020, which is an important part of the EU's digital transformation and recovery efforts. The package consists of the EU Cybersecurity Strategy for the Digital Decade (Cybersecurity Strategy), a proposal for a Directive on the Resilience of Critical Entities, repealing the Critical Infrastructure Directive (EC) 2008/114, and notably, a proposal for a Directive on measures for a high common level of cybersecurity across the Union (‘NIS 2'), repealing Directive (EU) 2016/1148 (NIS).

  30 March, 2021 Read more
• Position papers

  Public Consultation on the Evaluation and Review of the Broadband Cost Reduction Directive

  Introduction

  The Broadband Cost Reduction Directive (2014/61/EU) aims to facilitate and incentivise the roll-out of high-speed electronic communications networks by lowering the costs of deployment with a set of harmonised measures. The measures focus on access to existing physical infrastructure, coordination of civil works, simplification of administrative procedures and requirements for in- building physical infrastructure for new buildings and major renovations. It also includes provisions to ensure transparency of relevant information through Single Information Points and dispute resolution mechanisms. 

  3 March, 2021 Read more
• Position papers

  Joint Statement on Strengthening sectoral social dialogue in the services industry: The all-important role of social partners in building a resilient Europe

  The origin of European social dialogue lies in the EU’s decision to address social and economic issues arising from the creation of an EU single market through discussions between representatives of employers and workers (Art. 154f). Social dialogue has been the cornerstone of the social dimension of the single market.

  28 January, 2021 Read more
• Position papers

  ETNO comments to Questionnaire of the Sub-group on Role of RSP to Help Combat Climate Change

  The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Questionnaire of the Sub-group on Role of RSP to Help Combat Climate Change.

  27 January, 2021 Read more
• Position papers

  ETNO Statement on the WACC Notice of the European Commission

  The European Commission issued a notice in November 2019[1] (the Notice) which outlines the methodology for the calculation of the Weighted Average Cost of Capital (WACC) of legacy assets and mandates BEREC to annually calculate the various individual input parameters. Although the Notice is non-binding, National Regulatory Authorities (NRA) within the EU might have little discretion to deviate from it as they would risk a serious doubts procedure under Art. 32 of the European Electronic Communications Code (EECC). Thus, the Notice and the BEREC calculations will directly affect national tariff decisions and, as an important benchmark for fibre returns, will also send strong signals for fibre investments. Therefore, the impact of the WACC notice on investment decisions cannot be underestimated.

  21 January, 2021 Read more
• Position papers

  ETNO comments to the draft delegated regulation on criteria defining environmentally sustainable activities

  The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the draft Delegated Regulation on a climate change mitigation and adaptation taxonomy.

  Investment towards environmentally sustainable projects and activities will be crucial to meet the EU’s climate and energy targets for 2030, and in general to advance on the content and the ambition of the European Commission’s strategy of the European Green Deal.

  15 December, 2020 Read more
• Position papers

  ETNO – GSMA joint response to the public consultation document by the OECD/G20 Inclusive Framework on BEPS on the Reports on Pillar One and Pillar Two Blueprints

  ETNO and the GSMA welcome the possibility to provide their comments below in response to the public consultation document by the OECD/G20 Inclusive Framework on BEPS on the Reports on Pillar One and Pillar Two Blueprints.

  15 December, 2020 Read more
• Position papers

  ETNO position paper on the New IP proposal

  Executive Summary

  In response to the proposal initially introduced in the ITU-T Telecommunication Standardization Advisory Group (TSAG), and further developed within SG11 and 13, whereby the ITU-T would take on a more consequential role in the development of IP protocols, this paper summarises the main reactions, and outlines the position of the European telecommunications sector on this important issue.

  5 November, 2020 Read more
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