28 January, 2022

Joint ETNO / GSMA response to BEREC Consultation on Net Neutrality Regulatory Assessment Methodology

ETNO and the GSMA, who represent the telecoms sector in Europe, welcome the opportunity to comment on BEREC’s Draft Net Neutrality Regulatory Assessment Methodology. The methodology will provide important guidance on how to monitor Quality of Service (QoS) for access to the internet, which is a crucial milestone to implement and enforce Regulation 2015/2120 on the Open Internet.

We believe that customers deserve meaningful consumer information, trust in internet access services and the full confidence that service providers operate under legal certainty. We believe that it is essential to ensure that the implementation of Regulation 2015/2120 results in greater clarity for consumers and that it does not create unfair or undue burden on our sectors, at a time in which we are focussed on increasing our investment and quality of networks.

GSMA/ETNO welcome BEREC’s commitment that quality of service measurement parameters and methodologies must be based on already existing consolidated technical and scientific foundations. The selection of parameters that are considered relevant and representative from the end user perspective to measure Internet access service (IAS) quality is already set in the relevant ETSI standards as defined by the STQ Technical Committee. Equally we welcome BEREC’s finding that different measurement tools serve different objectives. Monitoring customers’ experience about the IAS or applications is very different compared to the monitoring of contractual compliance of IAS providers. These differences must be translated into the methodology or rather different methodologies advanced in the methodology. 

BEREC should acknowledge that a range of NRAs have already implemented monitoring systems, also due to legal obligations based on Art. 4 of the Open Internet Regulation. Where these established systems already deliver sufficient results, NRAs should refrain from readjustments that burden industry and may confuse customers who have got used to the established tool.

ETNO/GSMA would also refer BEREC to our earlier response to consultation issued 5 July 2017( BoR PC03 (17) 08, the views expressed in that response should also be read as part of this response.

© ETNO 2022
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