RD368 - ETNO contribution to the BEREC consultation on the Broadband Promotion Report

ETNO calls for the development of regulatory policies that take into account the high costs needed to develop high speed broadband both on the copper network (e.g. VDSL) and on fibre infrastructures.

Executive Summary

• Broadband promotion policies are an important tool to contribute to the achievement of the Digital Agenda. The targets of the Digital Agenda can be achieved if the right regulatory conditions are in place to allow the private sector to continue to invest in the deployment of networks. ETNO calls for the development of regulatory policies that take into account the high costs needed to develop high speed broadband both on the copper network (e.g. VDSL) and on fibre infrastructures.
• Access remedies should be proportionate to the actual demand and to the technology which seems most suitable to serve a given area with a reasonable return on investment. For this purpose, NRAs should analyse the concrete wholesale demand for a product and consider the impact of a potential measure not only on competition but also on investment in order to find a balanced solution.
• NRAs should implement the principle of geographic segmentation, in order to allow for varying regulatory obligations in both highly competitive and less competitive national markets. In addition, operators should be allowed the ability to apply regional pricing for NGA.
• ETNO supports the ambitious European goals regarding broadband coverage, speed and take-up, but considers universal service obligations to be an inappropriate tool for achieving these targets.
• National regulators should underline the need for local governments to fulfill their obligations concerning rights of use.  A virtuous administration of rights of use will help decrease barriers to achieving the ambitious broadband objectives for 2020.
• ETNO believes that demand side policies should at least go hand in hand with supply side policies in order to optimize the impact of broadband promotion policies. Some demand side policies appear to be relevant to improving the business case of network roll-out to encourage broadband availability, while other demand side policies are relevant to increasing user take-up, in cases where network availability exists.   
• Governments should work to close the gap between what citizens are currently willing to pay for broadband and what is necessary to provide high speed broadband to a large portion of the population. Direct subsidies to citizens and tax discounts could prove helpful.
• Increased support for e-services such as e-government, e-call, e-energy, e-learning and e-health would stimulate demand for high speed broadband services. Such support can be granted by several means, including State aid and a healthy regulatory environment.
• BB and NGA prices in Europe should evolve to become more in line with standards of other developed regions of the world, where fixed access revenues allow the business case of NGA to be profitable. 
• Strategies to promote broadband should acknowledge and allow for operators’ ability to provide advanced and managed services that may increase the customers’ perception of the real added value that a broadband connection can bring. This is specifically the case for fixed broadband.
• Public-private partnerships should be encouraged and promoted because of their likely success in combining the need to help private sector operators develop infrastructure with the need to improve consumer welfare through the access to and use of broadband services.