RD334 - ETNO Reflection Document commenting on the draft BEREC Work Programme for 2011 agreed by the BEREC Board of Regulators

ETNO welcomes the new role of BEREC in working towards consistent and proportionate regulation in Europe under the revised EU regulatory framework for electronic communications.We encourage BEREC to prioritise its work in 2011 by taking into account the political goals of the “Digital Agenda for Europe” to achieve a high degree of high-speed broadband availability and take-up in the European Union.ETNO calls upon BEREC to address two urgent regulatory challenges regarding current and future broadband markets in its work programme (WP):

  • ETNO welcomes the new role of BEREC in working towards consistent and proportionate regulation in Europe under the revised EU regulatory framework for electronic communications.

  • We encourage BEREC to prioritise its work in 2011 by taking into account the political goals of the “Digital Agenda for Europe” to achieve a high degree of high-speed broadband availability and take-up in the European Union.

  • ETNO calls upon BEREC to address two urgent regulatory challenges regarding current and future broadband markets in its work programme (WP):
    - the need for a more symmetric approach to access regulation -- in particular, for next generation access networks (NGA);
    - the effects of platform competition -- in particular, the increasing importance of cable networks -- on market definitions and the imposition of remedies.

  • ETNO encourages BEREC to focus its harmonisation efforts. The issue of business services-specific regulation has been addressed by ERG and BEREC in 2009 and 2010 and appears adequately addressed by NRAs in their respective markets. BEREC should not expend further resources on this work item.
  • ETNO welcomes the continued work of BEREC on the issue of regulatory accounting and encourages BEREC to continue to promote economically sound solutions in a dialogue with all stakeholders and with the European Commission. An EU-level approach to access product costing, which would be disruptive to established and effective national practices, would severely undermine regulatory certainty for investors in the transition from current to next generation broadband and result in further delays in the roll-out of high-speed access networks in Europe.