RD372 - Position Paper - ETNO response on the Draft BEREC report on Co-investment and SMP in NGA networks BoR (11) 69

ETNO welcomes the present consultation on a draft report on co-investment  and significant market power. We encourage BEREC to in particular reflect the following elements in its final report.

Executive Summary

ETNO welcomes the present consultation on a draft report on co-investment  and significant market power. We encourage BEREC to in particular reflect the following elements in its final report:

Co-investment and co-financing of different types can play a positive role in the deployment of next generation access networks in Europe, provided it is market-driven and in the economic interests of all partners involved.

The regulatory approach to co-investment should be technology neutral and in particular not impede, or favour, specific types of network architectures or high-speed access technologies.

Next to the co-investment models discussed in the draft report, important benefits for investment can occur under risk-sharing models that reduce the risk of a roll-out by a single operator in a certain area, for example if partners agree on upfront payments or long-term agreements to rent a fixed number of lines over a longer period of time, reflected in the price of access.

Geographic differentiation of regulation will be important when considering regulation of fibre-based networks that are jointly deployed by several co-investors as well as when considering the regulation of single-company deployment in specific geographical areas, e.g. by municipal or other alternative fibre operators, cable operators, etc.