RD319 - ETNO RD on ERG draft report on the regulation of access products necessary to deliver business connectivity services
ETNO recalls the need for a transparent and balanced approach to interaction with stakeholders by the ERG and BEREC when developing regulatory guidance. ETNO agrees that NRAs should assess whether it is appropriate to define a separate market for services supplied to some or all business customers and to analyse the geographic scope of the market carefully, provided this approach is consistently followed at the level of wholesale and retail markets. We believe that a more granular analysis of the markets for services to businesses could create significant scope for deregulation.
ETNO recalls the need for a transparent and balanced approach to interaction with stakeholders by the ERG and BEREC when developing regulatory guidance. ETNO agrees that NRAs should assess whether it is appropriate to define a separate market for services supplied to some or all business customers and to analyse the geographic scope of the market carefully, provided this approach is consistently followed at the level of wholesale and retail markets. We believe that a more granular analysis of the markets for services to businesses could create significant scope for deregulation.
The draft report does not provide evidence of a lack of effective competition on business services markets across EU member states. As such, the report’s findings on market definition and remedies are inconclusive. Against this background there appears to be no justification to define a detailed list of “best practice” regulatory remedies in Annex 2 of the report. The Annex should not feature in the final report, unless a far more thorough analysis and justification is provided.
- ETNO welcomes the present consultation and recalls the need for a transparent and balanced approach to interaction with stakeholders by the European Regulators Group (ERG) and the Body of European Regulators for Electronic Communications (BEREC) when developing regulatory guidance for the internal market of the European Union.
- ETNO agrees that national regulatory authorities (NRAs) should assess whether it is appropriate to define a separate market for services supplied to some or all business customers and to analyse the geographic scope of the market carefully, provided this approach is consistently followed at the level of wholesale and retail markets. We believe that a more granular analysis of the markets for services to businesses could create significant scope for deregulation.
- The draft report does not provide evidence of a lack of effective competition on business services markets across EU member states. As such, the report’s findings on market definition and remedies are inconclusive. Against this background and notwithstanding the importance of a consistent approach to regulation in the internal market, there appears to be no justification to define a detailed list of “best practice” regulatory remedies in Annex 2 of the report. The Annex should not feature in the final report, unless a far more thorough analysis and justification is provided.