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.
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Position papers
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
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Position papers
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
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Position papers
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
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Position papers
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
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Position papers
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
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Position papers
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
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Position papers
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
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Position papers
Introduction – telcos and consumers
A 2019 study conducted for ETNO by Assembly[1] identified the telecoms sector as one which is characterised by evolving service, improved trust, and enhanced customer relationships. A result of strong competition between providers, innovation and considerable ongoing investments in networks and services, consumers derive considerable benefit from our services. As a sector defined by providing services to meet new demands and challenges, and one which develops and makes use of new technologies, we welcome the European Commission’s ambition in its forthcoming New Consumer Agenda: consumers must be at the heart of the Green and Digital Transitions in Europe, responding to the most important challenges of today with a holistic and coherent vision on the role of consumers.
6 October, 2020
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Position papers
Introduction
ETNO supports the European Commission’s global approach to cybersecurity reaffirmed in the “Shaping Europe’s Digital Future” communication and welcomes the upcoming revised European Cybersecurity Strategy, including a review of the Directive on security of network and information systems (NIS Directive).
5 October, 2020
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Position papers
Executive Summary
The telecommunications industry is a substantial enabler of the transition to the EU Green Deal. Telecommunication companies have invested and continue to invest heavily in the build-out and upgrade of energy efficient and high-speed network infrastructure, as well as in the growth of Digitalisation. They thus play a key role for achievement of the taxonomy’s first and so-far most-defined objective: “Climate change mitigation”.
30 September, 2020
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