Position Papers

Connect Europe's position papers represent the views of its member companies on a wide range of technical, regulatory, and trade issues. These papers are directed at European Union decision-makers, national governments, and the general public.

Position papers are developed either internally by our working groups or, occasionally, in cooperation with third parties such as other industry associations at the European and national levels. This section also includes materials from our previous association, ETNO.

03 Sep, 2024

GSMA-ETNO response to public consultation on the Draft BEREC Report on M2M and permanent roaming (BoR (24) 96)

GSMA & ETNO welcome the possibility to comment on BEREC’s Draft report on M2M and permanent roaming based on BEREC’s call for input.

By Benedict William Gromann

03 Sep, 2024

GSMA-ETNO response to public consultation on the Draft BEREC Report on M2M and permanent roaming (BoR (24) 96)

The GSMA and ETNO welcome the possibility to comment on BEREC’s Draft report on M2M and permanent roaming based on BEREC’s call for input earlier this year. We first provide some general comments to the report followed by specific observations to the report findings including some suggestions for adjustments.

12 Aug, 2024

ETNO-GSMA contribution to BEREC Report on Cloud and Edge Computing Services

Brussels, 21 May 2024 – This week, the Council of the European Union hosts two important meetings gathering European ministers. Today, the Telecommunications Council discusses digital legislation adopted during the

01 Aug, 2024

ETNO-GSMA contribution on the draft BEREC Report on the IP interconnection ecosystem

Building on the previous stakeholder engagements, ETNO and the GSMA would like to provide some further views on the draft BEREC Report on the IP interconnection ecosystem.

25 Jul, 2024

ETNO-GSMA feedback on draft implementing act under the NIS2 Directive

ETNO and the GSMA welcome the opportunity to share their views on the draft implementing regulation regarding cybersecurity risk management and reporting obligations for various digital infrastructure and service providers. Our members, who represent the leading telecommunication network and service providers in Europe, are thoroughly preparing to comply with the NIS 2 Directive and have been actively engaging with decision-makers and regulators on the national implementation of the law.

23 May, 2024

ETNO-GSMA contribution to BEREC Report on Cloud and Edge Computing Services

Cloud and edge services are at the core of the transformation that our sector is undergoing: telecoms operators are turning their networks into platforms for innovation by embracing disaggregated and cloud native architectures, high automation (e.g. based on AI/ML), programmability, and the development of new network as a service (NaaS) applications.

29 Apr, 2024

ETNO Position Paper on 6G

The European Union has set ambitious Digital Decade targets for 2030, among them the objective to cover all populated areas with wireless high-speed networks of at least 5G performance. Societies increasingly rely on high-speed mobile and broadband connections. We expect Europe’s mobile data consumption per user to continue growing in the coming years with an annual growth rate of 25% . Mobile connectivity has a key role to play in attaining digital inclusion for all European citizens and businesses and enabling the twin digital and green transition.

23 Apr, 2024

ECTA, ETNO & GSMA Joint Statement on the European Parliament proposals to payment services regulation after the plenary vote

Today, the European Parliament voted on a report proposing amendments to the European Commission’s proposal for a revised Payment Services Regulation.
The European telecommunications industry recognises the importance of revising payment service rules to improve consumer protection in electronic payments . We are keen to work closely with the banking sector to fight against impersonation fraud.

14 Mar, 2024

ETNO-GSMA position on impersonation fraud in Payment Services Regulation

The GSMA and ETNO strongly encourage policymakers to reconsider their approach to increasing liability for electronic communications services (ECS) providers in cases of impersonation fraud.

20 Feb, 2024

ETNO position paper on EU guidelines on exclusionary abuses by dominant undertakings

With a view to the European Commission’s soon to be expected publication of the draft guidelines for the enforcement of Article 102 TFEU and the prohibition of exclusionary abuses by dominant undertakings, ETNO would like to provide some insights regarding its competitive experience on the telecoms market.

The following position is based on an internal legal assessment of the case law applied for the Guid

01 Feb, 2024

ETNO reflection paper on submarine communication cables

The European Union’s dependence on submarine communication cables has emerged as a significant concern for Europe’s security, resilience, and sovereignty, a vulnerability underscored by notable incidents involving the Nord Stream undersea gas pipeline in 2022 and undersea cables connecting Estonia and Finland in October 2023.

25 Jan, 2024

ETNO comments to the European Commission’s Draft Implementing Regulation laying down templates concerning the transparency reporting obligations of providers of intermediary services and of providers of online platforms under Regulation (EU) 2022/206

ETNO welcomes this opportunity to provide comments to the European Commission’s draft Implementing Regulation laying down templates concerning the transparency reporting obligations of providers of intermediary services and of providers of online platforms under the ‘Digital Services Act’ (DSA).

19 Jan, 2024

ETNO-GSMA comments on EDPB Guidelines 2/2023 on Technical Scope of Art. 5(3) of ePrivacy Directive

The protection of customer privacy and the confidentiality of their communications is at the core of the services offered by telecom operators. While these rules establish the foundation for delivering secure, trusted telecommunications services in Europe, they must also provide a degree of flexibility to enable European telcos to use data to improve customer experience, bring societal benefits, and, in general, keep pace with innovation and competition.

14 Dec, 2023

ETNO comments to the RSPG Draft Work Programme for 2024

The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Radio Spectrum Policy Group (RSPG) Draft Work Programme 2024.

22 Nov, 2023

ETNO and GSMA response to the consultation on the Commission’s Delegated Regulation amending Regulation (EU) 2015/758 of the European Parliament and of the Council as regards the standards relating to eCall

ETNO and GSMA represent the telecoms sector in Europe and worldwide. Our members are the companies responsible for deploying next generation connectivity, with the aim of meeting the European Commission’s digital decade connectivity targets, and in parallel, making important progress on the twin green-digital transformation.

19 Oct, 2023

ETNO-GSMA response to the European Commission consultation on eCall: Delegated Act on PSAPs

Draft Delegated Regulation amending Delegated Regulation (EU) No 305/2013 supplementing Directive 2010/40/EU of the European Parliament and of the Council with regard to the harmonised provision for an interoperable EU-wide eCall.

27 Sep, 2023

Joint Telecom Industry Statement on the Gigabit Infrastructure Act

Our Associations ECTA, ETNO, GIGAEurope and GSMA Europe represent the European telecommunications industry. Our industry plays a crucial part in connecting European citizens and businesses and facilitating the EU green and digital transition.

We welcome the European Commission’s proposal on the Gigabit Infrastructure Act (GIA) that aims at addressing the red tape and the challenge of slow, complex and costly deployment of Very High Capacity Networks (VHCN) across the European Union.

25 Aug, 2023

ETNO comments to the RSPG Draft Opinion on the development of 6G and possible implications for spectrum needs and guidance on the roll-out of future wireless broadband networks

The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Draft RSPG Opinion on the development of 6G and possible implications for spectrum needs and guidance on the roll-out of future wireless broadband networks.

In the first section, ETNO provides generic views to a selected set of topics relevant to the Draft Opinion, and in the second section, comments to the proposed recommendations are provided.

24 Aug, 2023

ETNO comments to the RSPG Draft Opinion on Strategy on the future use of the frequency band 470-694 MHz beyond 2030 in the EU

The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Radio Spectrum Policy Group (RSPG) Draft Opinion on the “Strategy on the future use of the frequency band 470-694 MHz beyond 2030 in the EU”.

In this document we provide first general remarks on the content of the Draft Opinion, then more specific comments related to existing flexibility, scenarios beyond 2030, and finally on the recommendations.

17 Jul, 2023

ETNO position paper: Substantiating Green Claims and Right to Repair

Telecom operators have taken decisive measures to increase sustainability of their operations and increase circularity in their business, bearing in mind the objective of increasing the useful life of devices.

17 Jul, 2023

ETNO statement on International Data Transfers

In the last years, new regulatory frameworks that guarantee user privacy in the digital environment have been adopted worldwide, from Africa, to South America and Asia.

The year 2018 marked a turning point in Data Protection with key developments:

17 Jul, 2023

GIGAEurope, ETNO & GSMA seek greater clarity on the media concentration screening mechanism in the European Media Freedom Act

Industry associations representing fixed and mobile connectivity providers in Europe, GIGAEurope, ETNO and GSMA, wholly support the objectives of the European Media Freedom Act (EMFA) to protect media independence and plurality, which are essential for functioning democracies and markets.

11 Jul, 2023

ETNO and GSMA input for the Call for Evidence on virtual worlds (metaverses): a head start towards the next technological transition

ETNO and GSMA welcome the opportunity to provide input to the European Commission’s Call for Evidence on virtual worlds and the technologies driving the transformation towards the next technological transition.

03 Jul, 2023

ETNO-GSMA position paper: European Spectrum Policy for the Digital Decade – options for the new Radio spectrum policy programme

Global events over the last three years have reminded us that advanced telecom networks are essential if Europe is to be successful in its pursuit of global leadership in the digital economy, remaining secure and resilient in the face of unpredictable global threats, and able to achieve its migration towards net-zero.

22 May, 2023

Joint Statement: Access to data by public bodies: a double-edge tool to use with caution and restraint

In times of crisis, companies stand ready to do their part and help public bodies by sharing data to tackle public emergencies, as evidenced during the Covid-19 pandemic. However, to function, mandatory data sharing between private companies and governments needs clear and transparent conditions for all parties involved.

17 May, 2023

ETNO position paper on the European Commission’s proposal “Gigabit Infrastructure Act”

ETNO attaches great importance to the current proper implementation of the Broadband Cost Reduction Directive (BCRD) and its successor, the Gigabit Infrastructure Act regulation, in order to help accelerate the deployment time of 5G and Gigabit broadband, as well as to help reduce the overall cost of deploying these networks.

11 Apr, 2023

EU Taxonomy and the European telecommunications sector

The European telecommunications sector is a major contributor to the fight against climate change. The sector is greening its own operations, and rolling out more energy-efficient, next generation networks, which play an important enabling role for smart solutions, thus reducing the environmental impact across other sectors of the economy and society.

05 Apr, 2023

ETNO contribution to the consultation on the Global Digital Compact

ETNO and its members have long played a key role in global digital leadership, engaging with organizations such as the Internet Governance Forum (IGF), the International Telecommunication Union, the Council of Europe, and the institutions of the European Union.

27 Mar, 2023

Joint GSMA – ETNO comments on the adoption of the European Parliament and Council of the EU mandate to negotiate on the Data Act

Thes comments have been released by ETNO and the GSMA
Brussels, 27 March 2023 - Europe’s telecommunication industry welcomes the Data Act and supports the objective of fostering data sharing and re-use across sectors and national borders in the single market.

20 Mar, 2023

ETNO-GSMA position paper on the Cyber Resilience Act

The Cyber Resilience Act (CRA) proposal comes at a time when European society, its citizens and businesses have been dealing with a crisis period marked by the COVID-19 pandemic and the war in Ukraine. The telecommunications sector has been capable of responding to these challenges and of demonstrating its robustness, by providing secure and reliable infrastructures and services that are essential for the functioning of the EU’s Digital Internal Market. However, telecommunication network operators are still faced with security gaps in their digital value chains that need addressing.

14 Mar, 2023

ETNO response on Key performance indicators for the Digital Decade policy programme 2030

ETNO welcomes the opportunity to provide its comments to the Draft European Commission Implementing Act on the Key performance indicators for the Digital Decade Policy Programme 2030 (DDPP). The telecom industry is engaged in fulfilling the 2025 Gigabit and 2030 Digital Compass objectives.

10 Jan, 2023

Edge Cloud and Strategic Capacity Building in the EU Policy Context on Cloud

The pressures of the pandemic have shown the importance of a reliable and secure digital infrastructure and the need to avoid dependencies in strategic supply chains. Next to communication networks, cloud services form a critical part of the infrastructure that enables the proper functioning of our economies and societies in an increasingly digitized world.

12 Dec, 2022

GSMA-ETNO input to BEREC’s opinion on the Commission Implementing Regulation on the Fair Use Policy and Sustainability of the Roaming Regulation

GSMA and ETNO welcome the opportunity to provide comments to BEREC’s opinion on the functioning of the Commission Implementing Regulation on the Fair Use Policy (FUP) and Sustainability of the Roaming Regulation.
The possibility to apply FUP is a fundamental feature of “roam-like-at-home” regime, which enables the operators to prevent losses caused by users using roaming services for purposes other than periodic travel.

12 Dec, 2022

GSMA - ETNO response to BEREC Call for input about the Review of the Intra-EU Communications Regulation

The GSMA and ETNO would like to use the opportunity to contribute to the future BEREC opinion analysing the measures on intra-EU communications.
In our contribution we reflect on the work done by BEREC collecting the inputs for three consecutive “Intra-EU communications BEREC Benchmark Reports”, and on our own experiences with the market development.

09 Dec, 2022

ETNO position paper on the European Media Freedom Act

ETNO strongly welcomes the initiative of the European Commission in adopting the proposal for a European Media Freedom Act (EMFA), as a free and open media is a fundamental part of our democracy. Furthermore, as the media and entertainment landscape continues to evolve, it is important that consumers’ possibility to choose from a wide range of media options is protected.

06 Dec, 2022

ETNO and EENA's letter to the European Commission on planned electricity network outages and impact on telecommunications network in Europe

ETNO and the European Emergency Number Association (EENA) call upon the European Commission to work together with Member States to ensure that in the event of planned electricity outages, telecommunications networks be placed on priority lists to ensure continuity of service and thus access to emergency communications.
Read the letter by ETNO Director General Lise Fuhr and EENA Executive Director Gary Machado to the European Commission below.

07 Nov, 2022

ETNO response to the public consultation on BEREC draft Work Programme 2023

ETNO welcomes the opportunity to provide input towards BEREC’s Work Programme 2023. We believe that BEREC should in general focus on the ongoing tasks as mandated by EU legislation, as defined in the EECC, the Open Internet Regulation, roaming and intra‐EU calls, for example. We support BEREC’s commitment establishing structured cooperation mechanisms with EU institutions and other competent authorities.

18 Oct, 2022

ETNO Position Paper on the European Commission’s proposal for a Regulation laying down rules to prevent and combat child sexual abuse

ETNO welcomes the initiative taken by the European Commission to prevent and combat child sexual abuse material online. ETNO members have been actively engaged in numerous initiatives to this end, including collaboration with law enforcement agencies, and the implementation of blocking lists.

30 Sep, 2022

ETNO response to the Scientific Committee on Health, Environmental and Emerging Risks (SCHEER) Preliminary Opinion on Radiofrequency

ETNO would like to welcome this opportunity to comment on the preliminary Opinion on the need of a revision of the annexes in the Council Recommendation 1999/519/EC and Directive 2013/35/EU, in view of the latest scientific evidence available with regard to radiofrequency.

16 Aug, 2022

ETNO response to RSPG Consultation on the Draft RSPG Opinion on ITU-R World Radiocommunication Conference 2023

ETNO appreciates the opportunity to provide comments to the consultation on the Draft RSPG Opinion on ITU-R World Radiocommunication Conference 2023 (WRC-23).

01 Aug, 2022

ETNO response to EC call for evidence on EU position for WRC-23

ETNO appreciates the opportunity to provide comments to the European Commission Call for Evidence on the World Radiocommunication Conference 2023 EU position.

25 Jul, 2022

Response to public consultation on the Commission’s Call for Evidence for the initiative “State aid – Exemptions for small amounts of aid (de minimis aid)”

ETNO welcomes the initiative of the Commission and the possibility to provide preliminary comments in response to the Call for Evidence.
Beyond the fact that the Regulation in force is going to expire at the end of 2023, a review is needed in order to take into account the experience registered since its adoption, the review applied to other State aid relevant laws (i.e. GBER thresholds) and the new market context.

19 Jul, 2022

Joint ETNO and GSMA position on the EC proposal for a Data Act

ETNO and the GSMA, who represent the telecoms sector in Europe and worldwide, welcome the Data Act proposal of the European Commission.

We support the objective of fostering data sharing and re-use across sectors and national borders in the single market that underlies the proposed Data Act. However, as the European Commission states in the proposal, that should not be detrimental to innovation, competition and incentives to invest in ways of generating value through data.

27 Jun, 2022

ETNO-GSMA response to the public consultation on the draft BEREC Guidelines on the application of Article 3 of Regulation (EU) 2022/612 of 6 April 2022 on roaming on public communications networks within the Union (Wholesale Roaming Guidelines)

Introduction
ETNO and the GSMA, who represent the telecoms sector in Europe, welcome the opportunity to comment on BEREC’s Draft Wholesale Roaming Guidelines. ETNO and the GSMA hope the following detailed comments can serve as a constructive contribution to BEREC’s deliberations on its draft Guidelines.
Wholesale roaming provisions

21 Jun, 2022

ETNO response to the public consultation on the Informal Guidance Notice for businesses – anti-competitive agreements and abuse of a dominant market position

ETNO welcomes the update of the Commission Notice on informal guidance and appreciates the intent of the revision.

30 May, 2022

Empowering Consumers in the Green Transition

ETNO welcomes the opportunity to comment on the European Commission’s proposal for a Directive on empowering the consumer in the green transition through better protection against unfair practices and better information.

25 May, 2022

ETNO’s response to the EC public consultation on cybersecurity of digital products and ancillary services – Cyber Resilience Act

ETNO welcomes the opportunity to provide complementary views to its response to the European Commission’s (EC) public consultation on the cybersecurity of digital products and ancillary services.

11 May, 2022

ETNO Statement on the European Chips Act

ETNO welcomes the European Commission’s proposal establishing a framework of measures for strengthening Europe's semiconductor ecosystem (Chips Act). A robust legal framework will respond to the need for a sustainable and resilient semiconductor supply chain across different geographies and ensure the EU’s place in the global supply chain.

15 Apr, 2022

ETNO’s submission to the public consultation on BEREC early call for input on BEREC Work Programme 2023

ETNO welcomes the opportunity to provide early inputs towards BEREC’s Work Programme 2023. We believe that BEREC should in general focus on the ongoing tasks as mandated by EU legislation, as defined in the EECC, the Open Internet Regulation, roaming and intra‐EU calls, for example. We support BEREC’s commitment to establish structured cooperation mechanisms with EU institutions and other competent authorities.

14 Apr, 2022

ETNO-GSMA-GIGAEurope response to the public consultation on the draft BEREC Guidelines on the Implementation of the Open Internet Regulation

ETNO, the GSMA and GIGAEurope, who represent the telecoms sector in Europe, welcome the opportunity to comment on BEREC’s Draft Guidelines on the Implementation of the Open Internet Regulation. It is a crucial milestone to implement and enforce Regulation 2015/2120 on the Open Internet, especially in light of the European Court of Justice (ECJ) rulings concerning the interpretation of the specific Articles of the Regulation.

05 Apr, 2022

ETNO response to the EC public consultation on sustainable consumption of goods – promoting the right to repair and reuse

General considerations
ETNO represents the main telecommunications network operators in Europe. In addition to the provision of access to communications services for consumers, our members provide mobile handsets to allow consumers to avail of the communications services to which they are subscribed.
ETNO welcomes the opportunity to send complementary views to its response to the EC public consultation on sustainable consumption of goods – promoting the right to repair and reuse.

17 Mar, 2022

ETNO-GSMA Statement Why filling the gap in supply chain management is a cybersecurity necessity

Following the current decision to not directly capture all relevant actors of the ICT sector with the Directive on measures for high common level of cybersecurity across the Union (NIS2 Directive), ETNO and the GSMA would like to re-emphasise how important it is for the resilience of European critical infrastructure to leave no gaps in the supply chain risk management.

17 Mar, 2022

ETNO response to EDPB Guidelines 01/2022 on data subject rights - Right of access

ETNO welcomes the opportunity to comment on the draft Guidelines 01/2022. We highly value article 8 of the EU Charter of Fundamental Rights. The right of access for data subjects has been implemented by the members we represent since Directive 95/46/EC came into force. The members have looked closely at Article 15 GDPR and the corresponding considerations 63 and 64 when the GDPR came into force to determine whether any changes were necessary. The right of access has been actively exercised by data subjects without major problems or complaints for many years.

28 Jan, 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.

28 Jan, 2022

ETNO response to the draft BEREC Report on “a consistent approach to migration and copper switch-off”

ETNO welcomes the possibility to comment on the draft BEREC report on a consistent approach to migration and copper switch-off.

06 Jan, 2022

ETNO response to the RSPG Consultation on the draft Work Programme for 2022 and beyond

The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the RSPG draft Work Programme for 2022 and beyond.

17 Dec, 2021

ETNO’s feedback on the EC Decision establishing the 2030 Policy Programme ‘Path to the Digital Decade’

ETNO welcomes the opportunity to provide its comments on the European Commission’s (EC) Decision establishing the 2030 Policy Programme “Path to the Digital Decade”. The telecom industry is engaged to fulfil the 2025 Gigabit and 2030 Digital Compass objectives. The European Union’s digital targets are key to achieve a successful digital transformation. Thus, the governance system of the EC establishing the ‘Path to the Digital Decade’ and its enhanced monitoring system will be of major importance for achieving these targets. Please find below some considerations from ETNO.

13 Dec, 2021

ETNO Position Paper on Open RAN

As 5G is continues to be rolled out in Europe, and its advantages realised, we present an overview of one of the innovations which can help facilitate this transition. This paper explains what Open RAN is and assesses its expected impact on innovation, roll-out, competition, security and efficiency. We provide an overview of the state-of-play of Open RAN and suggest some ways in which EU public policy can contribute.
What is Open RAN?

19 Nov, 2021

ETNO response to the feedback period on the EU energy efficiency directive (EED)

The European Telecommunication Network Operators' Association (ETNO) welcomes the European Commission opportunity to provide feedback to the revised EU energy efficiency directive (EED).
As stated in our response to the EC public consultation earlier this year, we believe efficient use of energy is key to achieve the Green Deal objectives. The original objectives of the Directive are still highly relevant, and in general they have helped to increase awareness and knowledge related to energy, which is often still seen a plain commodity.

19 Nov, 2021

ETNO views on RED revision on Universal Charger

We welcome the initiative by the European Commission to achieve important objectives on consumer choice, reducing cost for the consumer, and reducing waste and environmental impact.

09 Nov, 2021

ETNO comments on the draft BEREC Report on the regulatory treatment for fixed and mobile backhaul

ETNO welcomes the opportunity to comment on the draft BEREC “Report on the regulatory treatment for fixed and mobile backhaul” (“the report”) to express its views and conclusions. ETNO would like to share the following analysis on the report. In general terms, ETNO considers that at present, the current regulatory framework (EECC, BCRD) has the necessary instruments and obligations on the different relevant markets included in the EC 2020 recommendation, to be able to address any competition issues that may arise in the future.

09 Nov, 2021

ETNO’s submission to the BEREC public consultation on the draft BEREC Work Programme 2022

ETNO welcomes the opportunity to provide comments on the draft BEREC’s Work Programme 2022. We believe that BEREC should in general focus on the ongoing tasks as mandated by EU legislation, as defined in the EECC, the Open Internet Regulation, roaming and intra‐EU calls, for example. We support BEREC’s commitment to establish structured cooperation mechanisms with EU institutions and other competent authorities.

Concerning the strategic priorities and work items for 2022, ETNO will hereby provide some comments and suggestions.

05 Nov, 2021

ETNO-GSMA position paper on European Commission proposal for an Artificial Intelligence Act

ETNO and the GSMA welcome the initiative of the European Commission to propose a Regulation on Artificial Intelligence, and notably the central role of the risk-based approach, which keeps citizens at the centre and is based on a robust ethical framework. Nevertheless, the risk-based approach requires more precision in order to achieve the intended results. It is encouraging to see that the legal focus is put on the use of AI and its impacts to society, rather than the technology itself.

12 Oct, 2021

ETNO POSITION PAPER on the Consumer Credit Directive

ETNO welcomes the European Commission’s initiative in proposing a Consumer Credit Directive, repealing and updating the current Directive (2008), and bringing consumer protection law with regard to credit agreements up to date, as part of the New Deal for Consumers.

What credit agreements do our members offer?

07 Oct, 2021

ETNO response to the European Commission public consultation on the revision of the Horizontal Block Exemption Regulations and Guidelines

The response to this consultation is available here.
Additional views on network sharing are available here.

24 Sep, 2021

Cyber Security Rating – a rising challenge for EU industries

The financial crash that occurred in the United States in 1837 prompted the need for risk assessment for investors. The power of financial rating agencies in influencing investors has grown in importance over the past decades, due to a number of significant events (the collapse of Enron in the US; the US Subprime mortgage crisis; the late 2000 financial crisis; and the Greek national debt crisis). Following increased complaints and impact of such agencies, this has led to the creation in Europe of the European Securities and Markets Authorities (ESMA).

24 Sep, 2021

ETNO response to the Call for feedback by the Platform on Sustainable Finance on the draft report on preliminary recommendations for technical screening criteria for the EU taxonomy

The European Telecommunication Network Operators' Association (ETNO) welcomes the ongoing work by the Platform on sustainable finance and its relevant role in providing advice on the further development of the EU taxonomy. We thus appreciate the opportunity to provide feedback on the draft report on preliminary recommendations for technical screening criteria.

03 Sep, 2021

ETNO comments to the Public Consultation on the Data Act

ETNO welcomes the opportunity to comment on the measures being explored by the European Commission in preparing the Data Act. This document complements our response to the public consultation questionnaire with regards to the two specific sections on business-to-government data sharing for the public interest and on business-to-business data sharing, building on our recent feedback to the Commission’s Inception Impact Assessment (IIA) on the Data Act.

03 Sep, 2021

ETNO comments to the Draft RSPG Opinion on the role of radio spectrum policy to help combat climate change

The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Draft RSPG Opinion on the role of radio spectrum policy to help combat climate change.

We also positively acknowledge that many of our comments provided in the response to the RSPG Questionnaire[1] were taken into account in the RSPG report on the role of radio spectrum policy to help combat climate change, published in June 2021[2].

31 Aug, 2021

ETNO response to the Public Consultation on the Preliminary Report on the Sector Inquiry into Consumer Internet Of Things

ETNO welcomes the European Commission’s (EC) aim to get a comprehensive understanding of the consumer Internet of Things (IoT) sector, and to assess whether competition in this sector may be restricted or distorted within the internal market.

17 Aug, 2021

ETNO response to the Commission’s public consultation on ‘’Designing mobile phones and tablets to be sustainable – ecodesign’’

ETNO welcomes the European Commission’s (EC) initiative to look into two new initiatives aimed to make mobile phones and tablets more energy efficient and to improve their material efficiency.
European telecommunication companies have high ambitions to include sustainability and circular economy measures as essential core elements into their business.

26 Jul, 2021

ETNO response to BEREC Report on COVID-19 crisis – lessons learned regarding communications networks and services for a resilient society

ETNO welcomes the initiative of BEREC to undergo a stock-take of the lessons learned regarding communications networks and services for a resilient society, including the response of the NRAs.The global COVID-19 crisis once more shed light on the importance of strong and reliable connectivity among societal and business communities. The COVID-19 crisis showed that telecom networks witnessed an increase in internet traffic, as entire societies moved to remote working, but ISPs have coped extremely well with the increase in internet traffic and they avoided networks congestions.

14 Jul, 2021

ETNO Statement on the BEREC WACC-Parameters Report 2021

On June 15, 2021, BEREC published its second Report on WACC parameter calculations according to the European Commission’s WACC Notice of 6th November 2019 (‘WACC Report 2021’).
ETNO had taken a critical stance on the Commissions WACC Notice and the first BEREC Report in January 2021 and provided suggestions for rectifications to achieve the goal of a more harmonized WACC which would indeed provide the opportunity for a fair and simplified WACC setting throughout Europe.

25 Jun, 2021

ETNO comments on the Inception Impact Assessment on the Data Act

ETNO welcomes the possibility to provide its comments below in response to the public consultation on the Inception Impact Assessment on the future Data Act.

04 Jun, 2021

ETNO’s position on the draft delegated regulation on the obligation for certain companies to publish non-financial information

ETNO (European Telecommunications Network Operators' Association) represents Europe’s telecommunications network operators and is the principal policy group for European e-communications network operators. ETNO’s primary purpose is to promote a positive policy environment allowing the EU telecommunications sector to deliver best quality services to consumers and businesses.

10 May, 2021

ETNO policy position on Data Governance Act

With the ever-growing number of data generated today, the EU needs the right governance model to unleash the potential of the data economy that could benefit to the society, citizens and companies. A key pillar of the EU Data Strategy (February 2020) welcomed by ETNO, the proposed Data Governance Act aims at boosting data sharing across sectors and member states while increasing citizens’ and companies’ trust and control over their data.

06 May, 2021

A TELECOMS INDUSTRY VIEW ON THE DIGITAL MARKETS ACT JOINT POSITION PAPER BY ETNO AND GSMA

ETNO and GSMA welcome the Commission’s initiative to create a harmonised ex-ante instrument targeted at the providers of core platforms services designated as gatekeepers via the Digital Markets Act (DMA). Current legislative instruments are not sufficient to ensure contestable and fair markets in the digital economy. This would also support the DMA’s objective to strengthen the internal market by setting out harmonised rules across the EU.

05 May, 2021

ETNO POSITION PAPER on the EC proposal on the review of roaming regulation

The main objective pursued by the EC when reviewing current Roaming regulation is to assess whether the retail roaming market within the EU (RLAH) is working properly and whether since 2014 the market has experienced any material changes that are not properly reflected or tackled through current framework and accordingly the need for an update of such framework.

27 Apr, 2021

Digital Services Act Joint Position by the GSMA and ETNO

Since the adoption of the eCommerce Directive (eCD) in 2000, the use of digital services has increased considerably. Last year, almost 85 percent of all individuals in the EU-28, aged between 16 and 74 years, were using the internet regularly1. At the same time, the variety of online services has also grown exponentially, and new business and value creation models have emerged. In particular, the importance of online platforms that allow the wide dissemination of user-uploaded content to society has drastically increased.

14 Apr, 2021

ETNO – GSMA joint response to the European Commission’s Digital Levy public consultation

ETNO and the GSMA welcome the possibility to provide their comments below in response to the European Commission’s (‘EC’) Digital Levy public consultation.

We agree that the European Union (‘EU’) needs a modern, stable regulatory and tax framework to appropriately address the developments and challenges of the digital economy. We therefore consider it appropriate for the digital economy to be taxed in a fair and transparent way with profits taxed where value is created.

30 Mar, 2021

ETNO responses to RSPG Consultations on draft opinions on RSPP, Spectrum sharing, and Additional spectrum needs

As ETNO appreciates the opportunity to provide comments to the consultations on the RSPG draft opinions on RSPP, Spectrum sharing, and Additional spectrum needs and guidance on the fast rollout of future wireless broadband networks.

The Draft RSPG Opinion on a Radio Spectrum Policy Programme (RSPP)

30 Mar, 2021

ETNO position paper on the Revised Directive on Security of Network and Information Systems (NIS2)

Introduction

03 Mar, 2021

Public Consultation on the Evaluation and Review of the Broadband Cost Reduction Directive

Introduction

28 Jan, 2021

Joint Statement on Strengthening sectoral social dialogue in the services industry: The all-important role of social partners in building a resilient Europe

The origin of European social dialogue lies in the EU’s decision to address social and economic issues arising from the creation of an EU single market through discussions between representatives of employers and workers (Art. 154f). Social dialogue has been the cornerstone of the social dimension of the single market.

27 Jan, 2021

ETNO comments to Questionnaire of the Sub-group on Role of RSP to Help Combat Climate Change

The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Questionnaire of the Sub-group on Role of RSP to Help Combat Climate Change.

Q1. How can the wireless technologies contribute to the efforts to reduce the climate impact of your sector?

21 Jan, 2021

ETNO Statement on the WACC Notice of the European Commission

The European Commission issued a notice in November 2019[1] (the Notice) which outlines the methodology for the calculation of the Weighted Average Cost of Capital (WACC) of legacy assets and mandates BEREC to annually calculate the various individual input parameters. Although the Notice is non-binding, National Regulatory Authorities (NRA) within the EU might have little discretion to deviate from it as they would risk a serious doubts procedure under Art. 32 of the European Electronic Communications Code (EECC).

15 Dec, 2020

ETNO comments to the draft delegated regulation on criteria defining environmentally sustainable activities

The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the draft Delegated Regulation on a climate change mitigation and adaptation taxonomy.
Investment towards environmentally sustainable projects and activities will be crucial to meet the EU’s climate and energy targets for 2030, and in general to advance on the content and the ambition of the European Commission’s strategy of the European Green Deal.

15 Dec, 2020

ETNO – GSMA joint response to the public consultation document by the OECD/G20 Inclusive Framework on BEPS on the Reports on Pillar One and Pillar Two Blueprints

ETNO and the GSMA welcome the possibility to provide their comments below in response to the public consultation document by the OECD/G20 Inclusive Framework on BEPS on the Reports on Pillar One and Pillar Two Blueprints.

05 Nov, 2020

ETNO position paper on the New IP proposal

Executive Summary
In response to the proposal initially introduced in the ITU-T Telecommunication Standardization Advisory Group (TSAG), and further developed within SG11 and 13, whereby the ITU-T would take on a more consequential role in the development of IP protocols, this paper summarises the main reactions, and outlines the position of the European telecommunications sector on this important issue.

ETNO does not support the New IP (renamed ‘future vertical communication networks’) proposal, on the grounds that:

06 Oct, 2020

ETNO-GSMA position paper on the New Consumer Agenda

Introduction – telcos and consumers

05 Oct, 2020

ETNO Position Paper on the Review of the NIS Directive

Introduction
ETNO supports the European Commission’s global approach to cybersecurity reaffirmed in the “Shaping Europe’s Digital Future” communication and welcomes the upcoming revised European Cybersecurity Strategy, including a review of the Directive on security of network and information systems (NIS Directive).

30 Sep, 2020

ETNO Position Paper on the European Commission's Renewed EU Sustainable Finance Strategy and Green Bond Standard

Executive Summary
The telecommunications industry is a substantial enabler of the transition to the EU Green Deal. Telecommunication companies have invested and continue to invest heavily in the build-out and upgrade of energy efficient and high-speed network infrastructure, as well as in the growth of Digitalisation. They thus play a key role for achievement of the taxonomy’s first and so-far most-defined objective: “Climate change mitigation”.

16 Sep, 2020

ETNO Policy Note: Licensing Mobile Spectrum

Given the ongoing preparatory work by the European Commission and the RSPG on a new multiannual radio spectrum policy programme and the wider European socio‐economic recovery context, ETNO would like to provide its views and suggestions on the common efforts to accelerate the development of digital communications. This brief policy note should be considered as an initial contribution towards the future policy framework on licensing mobile spectrum.
Read the ETNO Policy Paper by clicking the link below.

16 Sep, 2020

ETNO EP letter on internet shutdowns

ETNO welcomed the European Parliament’s actions to raise the issue of internet shutdowns, more specifically in Belarus. This is a crucial issue for European telecom companies, who are hit hard whenever a government decides to mandate internet shutdowns. As we work on stepping up efforts to discourage such shutdowns, we provide here some important facts on the 2020 shutdowns in Belarus.
Read more here.

09 Sep, 2020

ETNO - GSMA Position Paper on a New Competition Tool

ETNO and GSMA associations, which represent the vast majority of telecom operators in the European Union, welcome the opportunity to provide input to DG Competition on the possibility to introduce a New Competition Tool (NCT). In summary, GSMA & ETNO European mobile and fixed telecom operator’s position on the matter and response to the Commission’s Inception Impact Assessment and questionnaire is as follows:

07 Sep, 2020

A Telecoms Industry View on the Digital Services Act: Joint Position Paper by ETNO and GSMA

In this digital age, the future of our democracies, societies and economies depends on digital ecosystems that are open, fair, competitive, and respectful of the rule of law.
The adoption of digital technology brings the promise of addressing some of the biggest challenges of our times: climate change, inclusion, socio-economic growth – just to name a few. However, progress will only happen if digital industries are able to advance a purpose that goes beyond just delivering for narrow categories such as “users” or “consumers”. Digital technology needs to serve citizens.

28 Aug, 2020

ETNO Position Paper on the European Commission proposals for WTO disciplines and procedures relating to e-Commerce, and for the Review of the WTO Reference Paper on Telecommunications Services

ETNO is following with great interest the developments at the WTO to define rules for Electronic Commerce and to update the Reference Paper on Telecommunications Services, as well as to negotiate and update specific commitments related to the digital economy.

24 Jun, 2020

ETNO unveils European telecoms contribution to EU Green Deal debate

ETNO has today published its contribution to one of the key policy initiatives of President von der Leyen’s European Commission: the EU Green Deal. The key message of ETNO’s Policy Paper is that high-quality telecom networks and services are not only the basis for digitalising Europe, but also a key catalyst for reaching ambitious climate targets.

15 Jun, 2020

European Commission's White Paper on Artificial Intelligence - A European approach to excellence and trust (ETNO position paper)

ETNO welcomes the publication of the European Commission’s White Paper on “Artificial Intelligence – A European approach to excellence and trust” (the “White Paper”), a key pillar of the Commission’s digital strategy for the next five years.

02 Jun, 2020

ETNO policy position on the European strategy for data

Executive Summary
This paper outlines ETNO’s views on the European Data Strategy, released by the Commission on 19 February 2020. The document focuses on the Strategy’s approach to data access and sharing in the business-to-business (B2B) and business-to-government (B2G) contexts, also including B2B competition issues linked to exclusive data access. Furthermore, we elaborate on investment in data infrastructures, with emphasis on a European cloud ecosystem.

28 May, 2020

Building a digitally-enabled recovery

Executive Summary
This paper offers unique insights on the impact of the coronavirus crisis on Europe’s top tech business: the telecom sector[1]. As we collectively work to re-design Europe’s vision and strategic plans for the coming years, ETNO puts forward facts, figures, analysis and ideas on how to reboot the EU socio-economic engine by leveraging telecom networks and digital services.

09 Apr, 2020

Public questionnaire for the 2019 Evaluation of the Research & Development and Specialisation Block Exemption Regulations

ETNO position paper

Horizontal Guidelines (“HGL”) - general

The Horizontal Guidelines (“HGL”) provide valuable guidance with regards to self-assessment of horizontal co-operation agreements. However, in order to remain effective for the telecommunications sector, it is necessary to update them to cover new market situations related to digitalisation, increase investments and to encourage technical developments and innovation.

In particular:

01 Apr, 2020

ETNO – GSMA joint response to the OECD Update Statement

ETNO and the GSMA provide their comments below in response to the ‘Statement by the OECD/G20 Inclusive Framework on BEPS on the Two-Pillar Approach to Address the Tax Challenges Arising from the Digitalisation of the Economy’.

01 Apr, 2020

Key comments to the EC proposal of Implementing Regulation for SAWAPs

Joint response by GSMA, ETNO, Small Cell Forum, DIGITALEUROPE and GSA
1 April 2020

27 Jan, 2020

Telecommunications and Cable Industry Note on the Draft e-Privacy Regulation

ETNO, the GSMA and Cable Europe, as the voice of Europe’s leading telecom and cable operators, have been heavily invested in the debate surrounding the draft e-Privacy Regulation, since its publication in January 2017.

18 Dec, 2019

ETNO position on DNS over https (DoH)

Executive summary
The Domain Name System (DNS) is a critical element of the Internet infrastructure. DNS resolvers in particular play an essential role for operators and Internet Service Providers in providing access to the web for their customers. These resolvers are intermediaries that see the vast majority of DNS traffic sent today from and to their end-users to access the Internet, from web content to cloud infrastructures.

05 Dec, 2019

ETNO-GSMA Tax Policy Committee Position

Implementation within Member States of provisions of Council Directive 2006/112/EC (“the EU VAT Directive”) concerning VAT adjustments on unpaid invoices, and specific impact on the telecommunications sector.

ETNO-GSMA Tax Policy Committee Position
The ETNO-GSMA Tax Policy Committee (hereinafter The Committee) has taken the opportunity to consider the correct implementation of Article 90 of the EU VAT Directive within various EU Member States, and would like to articulate the following position.

09 Jul, 2019

GSMA ETNO Position paper on the proposal for a regulation on preventing the dissemination of terrorist content online

Executive summary
• We invite co-legislators to support the amended wording in the Parliament’s text on Article 2 and Recital 10, clarifying that hosting services which satisfy at least one of the following criteria should be outside of the scope of the regulation:

31 May, 2019

ETNO Comments on EDPB draft Guidelines on Article 6(1)(b) GDPR

Introduction
On 9th April, the European Data Protection Board (EDPB) released its draft Guidelines on the processing of personal data under the contractual necessity legal basis (Article 6(1)(b) GDPR) in the context of the provision of online services to data subjects. EDPB has invited interested stakeholders to comment on the draft Guidelines until 24th May 2019. ETNO welcomes the opportunity to submit comments to the EDPB on this important topic, but regrets the static interpretation given by EDPB on the “contractual necessity” legal ground.

20 Feb, 2019

Telecom operators’ priorities for Horizon Europe

Last June, the European Parliament and the European Council endorsed a decision regarding the next Horizon Europe framework programme, which brings an overview of its structure.

18 Feb, 2019

ETNO position paper on a revision of WTO rules in the field of telecommunications and other digital services / e-commerce

The digital transformation is fundamentally changing societies and economies, including international trade. Digital trade creates tremendous opportunities for inclusive economic growth and societal advancement. At the same time, digitally enabled trade in goods and services has given rise to new regulatory challenges. Therefore, we are convinced that the digital economy should be an important element of bilateral and multilateral trade policy. Already in July 2016, ETNO called for an update of trade policy to reflect new realities of the digital economy.1

01 Feb, 2019

ETNO Response to the Stakeholders' Consultation on Draft AI Ethics Guidelines

ETNO responded today to the stakeholder consultation on the draft AI Ethics Guidelines for Trustworthy Artificial Intelligence, prepared by the European Commission’s AI High-Level Expert Group.

ETNO supports the guidelines’ vision to create a culture of “Trustworthy AI made in Europe” that is human-centric and strengthens user trust in AI systems. The establishment of a European approach to AI around ethics has the potential to become a competitive advantage for “Made in Europe” AI solutions.

23 Jan, 2019

ETNO response to the Public Consultations on BEREC Report on Access to physical infrastructure in the context of market analyses

ETNO welcomes the opportunity offered to comment the draft BEREC report on Access to physical infrastructure in the context of market analysis. We welcome the comprehensive overview BEREC offers of the way various NRA’s treat physical infrastructure in the context of their respective national markets. However, we do have questions regarding the chapter reflecting on ways to deal with a hypothetical separate market for physical access. We elaborate on the reasons for that below.

23 Jan, 2019

Joint ETNO / GSMA response to the BEREC public consultation on the Draft BEREC Report on Terminating Contracts and Switching Provider

Do you have any comments or observations regarding the processes set out in Section 2 above, related to the switching of provider for different categories of ECS and the safeguards that are provided to consumers?

18 Jan, 2019

Joint GSMA-ETNO response to the BEREC public consultation on the BEREC Common Position on Mobile Infrastructure Sharing

Introductory Remarks on the Impact of 5G

18 Jan, 2019

ETNO response to the BEREC public consultation on the BEREC Public Consultation on Internet of Things Indicators

General issues

1.1. Do you consider that the European Commission’s definition of the IoT is sufficiently appropriate to collect relevant statistical information on the IoT? If not, how should the definition be changed?

11 Jan, 2019

Legal memo with respect to Law Enforcement Access to Data across Borders - Legal Challenges for Digital Service Providers and Citizen Rights

Executive summary
This legal memo investigates the challenges for private sector service providers of complying with recent initiatives that facilitate cross border law enforcement access to data across borders, with a particular emphasis on potential impacts on the European electronic communications and ICT industries.

Specifically, it examines two recent legislative initiatives in greater detail:

28 Nov, 2018

GSMA/ETNO position paper on the European Commission’s Proposal for a Regulation on preventing the dissemination of terrorist content online COM(2018) 640 final

I. Executive summaryOver the last years, the European Commission has proposed measures to further increase the fight against illegal content online. The latest proposal of September 2018 aims to prevent the dissemination of terrorist content online. GSMA and ETNO fully endorse the objective of the European Commission to effectively tackle the dissemination of terrorist content online.

21 Nov, 2018

ETNO responses to BEREC public consultations on data economy, work programme 2019, and contractual simplification

ETNO contributed to BEREC’s ongoing work on the data economy and to the definition of BEREC’s Work Programme for 2019. In a joint response with the GSMA, ETNO also responded to the public consultation on the draft BEREC Report on contractual simplification.The responses submitted to the BEREC Public Consultations are available in PDF below:

03 Oct, 2018

ETNO response to the call for contributions "Shaping Competition Policy in the Era of Digitalization"

ETNO welcomes the opportunity to respond to the Commission’s call for contributions on the implications of digitisation for competition policy. ETNO believes that – while competition rules are in principle flexible enough – digital markets require a critical review of the underlying assumptions and tools.

03 Aug, 2018

ETNO-GSMA Response to European Commission proposed Directives on Digital Taxation

European Commission (‘EC’) proposals for Council Directives on the common system of a digital services tax (‘DST’) on revenues resulting from the provision of certain digital services, and laying down rules relating to the corporate taxation of a significant digital presence.

23 Jul, 2018

ETNO Response to the BEREC Public Consultation for the Draft Common Position on Monitoring Mobile Coverage

COMMENTS ON THE DRAFT COMMON POSITIONS [BoR (18) 132]1. Objectives and key principles- We fully support the objective to enable consumers’ informed choice between different network providers’ tariffs, based on reliable information on network performance.- ETNO believes that monitoring Quality of Service (QoS) can be a positive and fruitful exercise both for European citizens and for European market players operating along the broadband value chain.

26 Jun, 2018

ETNO response to the European Commission Public Consultation on measures to further improve the effectiveness of the fight against illegal content online

ETNO welcomes this opportunity to comment on the public consultation “on measures to further improve the effectiveness of the fight against illegal content online” launched by the European Commission, which follows in the footsteps of the Commission Communication of September 2017 and the Recommendation of March 2018. Our Association recognises the need to work towards an online environment respecting – to the fullest possible extent – the applicable legal requirements and, with this aim, to further address availability and proliferation of illegal content online.

20 Jun, 2018

ETNO – GSMA Position Paper on P2B Regulation

ETNO and GSMA position in relation to the proposal for a Regulation on promoting fairness and transparency for business users of online intermediation services20 June 2018 - ETNO and the GSMA welcome the European Commission’s targeted approach aimed at tackling a number of identified issues with regard to the contractual relationships between online platforms and their business customers.

29 May, 2018

ETNO and GSMA joint position paper on Article 13 of the proposed Directive on Copyright in the Digital Single Market

Introduction
The core aim of Article 13 of the proposed Directive on Copyright in the Digital Single Market is to consider the legal relationship between content rights-holders and a new class of information society service provider termed a ‘online content sharing service provider’ (“OCSSP”) that stores and gives public access to copyright works such as music/audiovisual content.

28 May, 2018

ETNO and GSMA joint position paper on the proposal for a Directive on Representative Actions for the Protection of the Collective Interests of the Consumers

Executive SummaryETNO and the GSMA welcome the objective to improve law enforcement and strengthening consumer protection across the EU, irrespective of the location of size of an undertaking. This also requires Member States to provide sufficient resources, which is unfortunately not addressed in this proposal. Rules should be fully harmonised, providing Member States some flexibility to specify EU level provisions.

28 May, 2018

ETNO and GSMA joint position paper on the proposal for a Directive on Better Enforcement and Modernisation of EU consumer Protection Rules

Executive SummaryETNO and the GSMA welcome the objectives of the proposals on “A New Deal for Consumers”, which aim at updating consumer protection standards and improving enforcement. To effectively reach these, objectives several crucial adjustments are required, addressing only clearly identified problems in a targeted way and based on the principle of proportionality. More efforts should be focused on enforcing existing rules, rather than creating new ones which might be rendered ineffective.

26 Apr, 2018

ETNO - GSMA Position Paper on The Proposed European ePrivacy Regulation

Use cases for enabling privacy-protective innovative products and services, April 2018

10 Apr, 2018

Communication on Engagement to the UN Global Compact and its ten Principles in the areas of Human Rights, Labour, Environment and Anti-Corruption

Find the full communciation here.
The European Telecommunications Network Operators’ Association (hereinafter ETNO) with this document submits its second Communication on Engagement with the UN Global Compact.
(...)

04 Apr, 2018

ETNO Reflection Document on the European Commission’s proposal for text on Data Flows in Trade Agreements

ETNO members support the inclusion into Trade Agreements of provisions to ensure the flow of data across international borders as well as to prevent forced data localisation. In June 2017 we published a Reflection Document[1] on this matter, highlighting the three objectives that shall be pursued by such provisions:

21 Feb, 2018

2nd Joint Declaration by Industry and RTOs: Boosting Europe’s Future Competitiveness as Key Priority for FP9

We, the undersigned associations representing key European industrial research and innovation stakeholders, call on the European Commission, the European Parliament and the Council of the European Union to develop the next EU Research & Innovation Framework Programme (FP9) with an appropriate design and budget, at the level of the ambitions of the Renewed EU Industrial Policy Strategy.

20 Feb, 2018

GSMA-ETNO position paper on the proposed Copyright Directive in the Digital Single Market

On 14 September 2016, the European Commission presented its reform proposals on copyright and related rights which form a central pillar of the Commission’s Digital Single Market (DSM) policy.

20 Feb, 2018

GSMA-ETNO position paper on the proposed Sat Cab Regulation

On 14 September 2016, the European Commission presented its reform proposals on copyright and related rights which form a central pillar of the Commission’s Digital Single Market (DSM) policy.

23 Jan, 2018

ETNO comments on the Article 29 Working Party Guidelines on Consent under Regulation 2016/679 (WP259)

On 28 November 2017, the Article 29 Working Party (WP29) adopted a set of Guidelines on Consent under Regulation 2016/67 and invited interested stakeholders to present comments. ETNO welcomes this opportunity to comment on WP29’s guidelines and would like to stress the importance of clear rules on free and informed consent in order to ensure trust of individuals and data subjects.

23 Jan, 2018

ETNO comments on the Article 29 Working Party Guidelines on Transparency under Regulation 2016/679 (WP260)

On 28 November 2017, the Article 29 Working Party (WP29) adopted a set of Guidelines on Transparency under Regulation 2016/67 and invited interested stakeholders to present comments.

16 Jan, 2018

Joint Statement of the European Telecom Social Partners on Reconciling Innovation and Privacy Protection to the Benefit of the European Data Economy

Brussels, January 2018 - The value of the European data economy could reach up to 740 billion euros, or 4% of the European Union’s total GDP, by 2020. Smart solutions such as big data analytics, the Internet of Things, and connected driving thus have the potential to trigger a fourth industrial revolution.

09 Jan, 2018

ETNO-GSMA Joint Position Paper on Article 13 of the proposed Directive on Copyright in the Digital Single Market

January 2018 - The Commission’s objective in Article 13 (the so-called ‘value gap’ provision) is to improve copyright protection through the promotion of the level playing field between content rights-holders and certain types of online music/audio-visual sharing service providers. As such, Article 13 is intended to represent a highly focussed sector-specific approach to address a specific situation in which a ‘value gap’ is perceived.

20 Dec, 2017

ETNO-GSMA Tax Policy Committee Response to European Commission Public Consultation on fair taxation of the digital economy

The ETNO-GSMA Tax Policy Committee (hereinafter The Committee) appreciates the opportunity to provide its input on the consultation on fair taxation of the digital economy and would like to provide the following comments, complementary to the answers submitted through the on-line form questionnaire.

30 Nov, 2017

ETNOs Views on the Proposed Regulation on a Framework for the Free Flow of Non-Personal Data in the European Union

Full text available here
November 2017

28 Nov, 2017

ETNO comments on the Working Party 29 draft guidelines on data breach notification and profiling

ETNO provided the Article 29 Data Protection Working Party (WP29) with its comments on the WP29’s draft guidelines on personal data breach notification as well as on automated individual decision-making and profiling under the General Data Protection Regulation (GDPR).

08 Nov, 2017

GSMA-ETNO response to BEREC Consultation on Monitoring Mobile Coverage

ETNO and the GSMA, who represent the telecoms sector in Europe, welcome the opportunity to comment on BEREC’s Preliminary Report on Monitoring Mobile Coverage. We hope the following detailed comments can serve as a constructive contribution to BEREC’s deliberations on this preliminary report.

27 Oct, 2017

ETNO response to the European Commission public consultation on improving cross-border access to electronic evidence in criminal matters

Full text available hereOctober 2017

26 Jun, 2017

ETNO RD 441 on Data Flows in Trade Agreements

PDF available here.

Brussels, June 2017

15 Jun, 2017

Joint position of the European Telecom Social Partners on the EECC

PDF available here.

20 Mar, 2017

ETNO’s views on the Proposal for an ePrivacy Regulation

PDF available here.

16 Feb, 2017

170131 ETNO Data Portability Memo

ETNO shared with the Article 29 Working Party the a legal memo noting that while the Guidelines provide many useful additions and clarifications, they also contain some suggestions that are particularly problematic for the industry, users and third parties.

PDF available here.

16 Feb, 2017

170131 ETNO Data Portability Memo

25 Jan, 2017

ETNO Position Paper on the European Electronic Communications Code

PDF available at this link.

18 Jan, 2017

ETNO response to the consultation of the European Commission on “Evaluation of procedural and jurisdictional aspects of EU merger control”

Link to ETNO response to the consultation available here.

10 Jan, 2017

ETNO on European Data Economy

Read ETNO's full position here.

January 2017

ETNO on the European Data Economy

14 Dec, 2016

RD437 - ETNO Position Paper for the Trilogue Negotiations on the UHF Band Decision

Read ETNO's full position here.

In the context of the trilogue negotiations on the “Proposal for a Decision of the European Parliament and of the Council on the use of the 470-790 MHz frequency band in the Union”, ETNO, the association representing Europe’s leading providers of electronic communications and services, would like to make the following remarks.

13 Sep, 2016

ETNO and GSMA note on the implementation of the Roaming Fair-Use Policy

Full, signed letter here.

01 Sep, 2016

Public consultation for the Fitness Check of EU consumer and marketing law - Complementary Policy Paper of ETNO and GSMA

Link to full Policy Paper

Link to Response

28 Jul, 2016

RD435 - ETNO comments on draft ECC Report 255

Comments on draft ECC report 255 “the use of assisted-global navigation satellite system (A-GNSS) capabilities to improve caller location information for emergency calls originating on mobile devices”
Download the full response here.
(...)

28 Jul, 2016

RD436 - ETNO Response to the RSPG consultation on “spectrum related aspects for next-generation wireless systems (5G)”

PDF hereETNO welcomes the RSPG opinion on the strategic roadmap towards 5G for Europe. The establishment of a strategic roadmap towards 5G should go beyond 2020, and should not only aim at facilitating the launch of 5G on a large scale by 2020, but also at enabling European industrial and societal transformation and economic growth from 2020 onwards.

19 Jul, 2016

Joint Etno-Gsma response to the BEREC Open Internet Guidelines Consultation

Read the full position paper here.

14 Jul, 2016

RD434 - ETNO NOTE ON TRADE NEGOTIATIONS

PDF here
ETNO members have actively supported trade negotiations in general and with particular emphasis in the cases of TTIP and TiSA. Our association has contributed to the public consultations on these and other negotiations, providing meaningful input and helping decision-makers in shaping EU’s trade policy for Digital-related sectors.

06 Jul, 2016

Draft regulation on the cross-border portability of online content services

PDF here

01 Jul, 2016

RD431 - ETNO Contribution to the BEREC Draft Report on “Challenges and Drivers of NGA Rollout and Infrastructure Competition” – BoR (16) 96

Full document here
Introduction
ETNO has read with interest the BEREC Draft Report on “Challenges and Drivers of NGA Rollout and Infrastructure Competition”. We welcome the opportunity to provide our comments to the document.

01 Jul, 2016

RD432 - ETNO response to the public consultation on the draft BEREC common position on Layer 2 Wholesale Access Products - BoR (16) 95

Full document here
ETNO welcomes the opportunity to contribute to BEREC’s public consultation on the common position on Layer 2 wholesale access products (L2 WAP).

20 Jun, 2016

RD430 - ETNO position paper on Privacy Shield

Towards the swift adoption of a future-proof and sustainable textPDF here

15 Jun, 2016

ETNO response to the Termination Rates Recommendation

Read the full response here

31 May, 2016

RD429 - ETNO Position on Draft Directives on certain aspects concerning contract for the online and other distance sales of goods and of digital content

Read ETNO's full position here.

08 May, 2016

RD428 - ETNO on GDPR implementation

PDF hereETNO would like to express its views on how to ensure a proper implementation of the GDPR in view of new digital business models and technologies such as IoT, Big Data, 5G and Connected Cars. In light of these enormous technological developments, input from the industry and from experts will be crucial during the implementation phase.

03 May, 2016

RD427 - ETNO position on the proposal for an EU decision on the 470-790 MHz band

Download the PDF here.ETNO welcomes the European Commission's proposal for a Decision of the Parliament and the Council on the use of the whole 470-790 MHz frequency band in the Union.

29 Apr, 2016

RD426 - ETNO response to the European Commission public consultation on the evaluation and modernisation of the legal framework for the enforcement of IPRs: intermediaries

Full document here

06 Apr, 2016

ETNO-GSMA Position Paper on the BEREC Guidelines for the implementation of the Open Internet provisions of the TSM Regulation (2015/2120)

Read full Position Paper here

Introduction

In addition to the GSMA and ETNO papers delivered to BEREC last December, we would like to share Internet access service providers’ (ISPs) views on the implementation of the open Internet provisions of the Telecoms Single Market (TSM) Regulation and we ask BEREC to consider the following elaborations when drafting guidelines for National Regulatory Authorities (NRAs).

23 Mar, 2016

RD424 - ePRIVACY DIRECTIVE: FORTHCOMING REVIEW

Read full Reflection document hereIntroductionEurope must create an environment that encourages data driven innovation in Europe, therefore, now that the General Data Protection Regulation (GDPR) has been agreed, it is time for an urgent review of ePrivacy Directive with the aim to:

21 Mar, 2016

RD423 - Review of the horizontal Consumer Protection Legislation

PDF here

29 Feb, 2016

ETNO response to the EC consultation concerning empowering the national competition authorities to be more effective enforcers

PDF here

17 Feb, 2016

ETNO response to the Public consultation on the review of national wholesale roaming markets, fair use policy and the sustainability mechanism referred to in the Roaming Regulation 531/2012 as amended by Regulation 2015/2120

Read the full questionnaire here(...)Question 36: What are the risks associated with permanent roaming for a mobile operator, if any? Please explain your response and provide examples:

27 Jan, 2016

Communication on Engagement to the UN Global Compact and its ten Principles in the areas of Human Rights, Labour, Environment and Anti-Corruption

Find the full communciation here.
This is the first Communication on Enagement with the UN Global Compact that the European Telecommunications Network Operators’ Association releases since it joined the Global Compact in 2004. This document provides a brief overview of ETNO’s sustainability commitments and achievements.

22 Jan, 2016

RD420 - Comments on Draft ECC Recommendation (16)01 “3rd Party Access to Number Portability Data (NP Data)”

Please find the full response here.

22 Jan, 2016

RD421 - Comments on Draft ECC Report 248 “Evolution in CLI usage – decoupling of rights of use of numbers from service provision”

Please find the full response here.
1. General Comments
ETNO welcomes the opportunity to comment on the Draft ECC Report 248 ‘‘Evolution in CLI usage --- decoupling of rights of use of numbers from service provision’’.As a general comment, in ETNO's view this Report has some basic drawbacks that should be overcome:

30 Dec, 2015

ETNO response to the consultation on the regulatory environment for platforms, online intermediaries, data and cloud computing and the collaborative economy

Please find the full response here.Extracts from ConsultationBackground and objectives

30 Dec, 2015

ETNO response to the European Commission public consultation on “The needs for Internet speed and quality beyond 2020”

Read the full response hereETNO welcomes the opportunity to respond to the “Public consultation on the needs for Internet speed and quality beyond 2020”, launched by the European Commission in the context of the Digital Single Market Strategy.

17 Dec, 2015

ETNO-GSMA Tax Policy Committee contribution to EU consultation on Modernising VAT for cross border e-commerce

Please find the full questionnaire here.
(...)

07 Dec, 2015

ETNO response to the public consultation on the evaluation and the review of the regulatory framework for electronic communications networks and services

Please find the full response here.(...)

16 Nov, 2015

ETNO response to the Public Consultation on the Review of the EU Satellite and Cable Directive

Please find the full questionnaire here.(...)

09 Nov, 2015

RD419 - ETNO Contribution to the Public Consultation on the draft BEREC Report on enabling the Internet of Things BoR (15) 141

Read the full reflection document here.

03 Nov, 2015

RD418 - ETNO Response to the Public Consultation on the draft BEREC Report on OTT services BoR (15) 142

Read the full reflection document here.IntroductionETNO welcomes the opportunity to contribute to the BEREC draft report on OTT services that timely addresses the issue of the level playing field between substitute communication services in the European digital single market.

30 Oct, 2015

RD417 - ETNO Response to BEREC Consultation on the 2016 Draft Work Programme (BoR (15) 140)

Download the full Reflection Document here.
Introduction
ETNO welcomes the opportunity to provide its views on the BEREC draft Work Programme for 2016 (BoR (15) 140).

27 Oct, 2015

CP88 - ETNO Common Position on the World Radiocommunication Conference (WRC-15)

Download the full Common Position Paper here.

01 Oct, 2015

ETNO response to the consultation on Directive 2010/13/EU on audiovisual media services (AVMSD)

A media framework for the 21st centuryExtract from QuestionnairePlease find the full questionnaire here.

03 Sep, 2015

Joint GSMA-ETNO response to the questionnaire on contract rules for online purchases of digital content and tangible goods

31 Jul, 2015

RD 415 - ETNO comments on the Draft BEREC Report on Oligopoly Analysis and Regulation – BoR (15) 74

Download the full Reflection Document here.
Introduction
ETNO welcomes the opportunity to respond to the consultation on the draft BEREC Report on Oligopoly Analysis and Regulation (the “draft report”).

30 Jun, 2015

RD 414 - ETNO Comments on Draft ECC Report 238 “3rd Party Access to Number Portability Data (NP Data)”

Download the full Reflection Document here.

General Comments

ETNO welcomes the opportunity to comment on the Draft ECC Report 238 “3rd Party Access to Number Portability Data (NP Data)”.

30 Apr, 2015

RD413 - ETNO response to the “Public consultation on the Lamy Report: the future use of the UHF TV broadcasting band”

Download the full Reflection Document here.

20 Feb, 2015

Open Letter on OECD Discussion Draft on International VAT/GST Guidelines for Business-To-Consumer (B2C) Supplies

To: Piet Battiau, head of consumption taxes at the OECD's Centre for Tax Policy and AdministrationDear Mr Battiau,

16 Feb, 2015

ETNO Response to the NETmundial Initiative Consultation for the development of the Terms of Reference of the NETmundial Initiative

30 Jan, 2015

ETNO Response to BEREC Consultation on Oligopoly Analysis and Regulation - BoR (14) 172

Download the full Reflection Document here.

19 Jan, 2015

Comments on Draft ECC Recommendation 15(02): “Guidelines for Major Changes to National Numbering and Dialling Plans concerning E.164 Numbers”

Download the full Reflection Document here.

12 Jan, 2015

ETNO comments on the Draft RSPG Opinion on Common Policy Objectives for WRC-15

Download the full Reflection Document here.Executive SummaryETNO welcomes the opportunity to comment on the draft RSPG opinion on Common Policy Objectives for WRC-15 and to provide its point of view on some ofthe topics proposed.In particular ETNO is of the opinion that:

12 Jan, 2015

ETNO comments on the Draft RSPG Opinion on a long-term strategy on the future use of the UHF band (470-790 MHz) in the European Union

Download the full Reflection Document here.Executive SummaryETNO welcomes the opportunity to comment on the draft RSPG opinion on a long-term strategy on the future use of the UHF band (470-790 MHz) in the European Union.

31 Oct, 2014

ETNO response to the ICANN public comment request on the board working group report on nominating committee

27 Oct, 2014

ETNO Reflection Document on the draft BEREC Strategy 2015-2017 and Work Programme 2015

27 Oct, 2014

ETNO Reflection Document on BEREC draft guidance on the regulatory accounting approach to the economic replicability test

Download the full Reflection Document here.

23 Sep, 2014

ETNO RESPONSE TO ECC Report 225

Executive Summary

05 Sep, 2014

ETNO Response to Australian Online Copyright Infringement Consultation

ETNO, the leading trade association in Brussels for European telecom operators, welcomes the opportunity to respond to the Attorney-General's Department consultation on the Online Copyright Infringement paper.

31 Jul, 2014

ETNO views on the EU Commission’s Forthcoming White Paper on the Review of EU Copyright Rules

ETNO, the leading trade association in Brussels for telecom operators, takes particular interest in the follow-up of the European Commission’s public consultation on the review of the EU copyright rules and welcomes the Commission’s initiative to put forward proposals for revision through a White Paper.In undertaking this exercise, ETNO believes that it is of the utmost importance that the European Commission adopts a forward looking and ambitious approach to copyright reform considering that:

23 Jul, 2014

ETNO views on M2M

This ETNO position was drafted following a request from the BEREC M2M Project Team, further to a meeting held with ETNO in June 2014. The topic of M2M spans several ETNO WGs (NANI, DI and SPEC) and as such, an informal expert group was formed within ETNO to address the topic, with input from the 3 WGs.

15 Jul, 2014

ETNO Comments regarding the FCC NOTICE OF PROPOSED RULEMAKING

“Protecting and Promoting the Open Internet” from European Telecommunications Network Operators’ AssociationETNO appreciates this opportunity to restate its support of the open Internet and its commitment to the success of the Internet as an open platform where users have access to any lawful content, application or service of their choice.

30 Apr, 2014

ETNO response on BEREC report on Monitoring Quality of Internet Access Services in the context of Net Neutrality

Download the full Reflection Document here.

14 Apr, 2014

ETNO response to the OECD’s Public Discussion Draft on the Tax Challenges of the Digital Economy

An invitation for comments on the OECD public discussion draft on BEPS Action 1 (Address the Tax Challenges of the Digital Economy) was published on the OECD Website on 24 March 2014, with a deadline of 14 April 2014.

28 Feb, 2014

ETNO response to the Public Consultation on the review of the EU copyright rules

ETNO, the leading trade association in Brussels for telecoms operators, welcomes the current public consultation on the review of the EU copyright rules and thanks the EU Commission for the opportunity to provide views.

07 Feb, 2014

ETNO response on BEREC consultation BoR (13) 186

PDF hereETNO welcomes the review of BEREC’s common position on geographical aspects of market analysis.ETNO believes that BEREC and NRAs should adopt a more proactive approach to reflecting the geographic differences within a national territory in their definition of relevant markets in order to effectively take into account the competitive dynamics of today’s telecommunications markets.

31 Jan, 2014

ETNO Reflection Document on “Draft ECC Recommendation (14)03: Charging Principles for National and International Freephone Numbers”

The Association of European Telecommunications Network Operators (ETNO)[1] would like to thank the CEPT/ECC (Electronic Communications Committee) for the opportunity to comment on Draft ECC Recommendation (14)03 “Charging Principles for National and International Freephone Numbers”.

31 Jan, 2014

ETNO Reflection Document on “Draft ECC Report 213: Impact of Number Portability between Fixed and Mobile Services”

The Association of European Telecommunications Network Operators (ETNO)[1] welcomes the opportunity to comment on Draft ECC Report 213 “Impact of Number Portability between Fixed and Mobile Services”.As a general remark, this Report seems to propose a revision of the European Regulatory Framework regarding Number Portability obligation, when that matter is not under the responsibility of ECC.

31 Jan, 2014

ETNO Reflection Document on EU-Ecuador Trade Relations

In June 2012, the EU signed an ambitious and comprehensive Trade Agreement with Colombia and Peru. These negotiations were part of a broader effort to enhance economic ties with the CAN (Andean Community of Nations); however, given certain disagreements within the CAN in late 2008, Ecuador and Bolivia decided not to continue the negotiations.

03 Jan, 2014

ETNO Reflection Document on “Draft ECC Report 212: Evolution in the Use of E.212 Mobile Network Codes”

The Association of European Telecommunications Network Operators (ETNO)[1] would like to thank the CEPT/ECC (Electronic Communications Committee) for the opportunity to comment on Draft ECC Report 212 “Evolution in the Use of E.212 Mobile Network Codes”.

19 Nov, 2013

ETNO Position on Completing the Telecoms Single Market and Response to the ITRE Stakeholders Consultation

The European Telecommunication Networks Operators association publishes today its position on completing the telecoms single market.See below for ETNO's response.PDF here

18 Nov, 2013

ETNO responds to European Commission's consultation on Internet Governance

ETNO welcomes the opportunity to respond to the European Commission’s consultation on Internet Governance, entitled Europe and the Internet in a global context – What future, what challenges ahead?We include below our responses to the questions posed within the online consultation document.

28 Oct, 2013

ETNO Reflection Document on BEREC’s 2014 Work Program consultation

ETNO welcomes the present consultation on BEREC’s 2014 Work Programme. This contribution will also cover selected aspects of BEREC’s views on the draft TSM regulation proposal.[1]

25 Sep, 2013

ETNO Response to European Commission Green Paper: Preparing for a Fully Converged Audiovisual World: Growth, Creation and Values

ETNO welcomes the European Commission’s Green Paper ‘Preparing for a Fully Converged Audiovisual World: Growth, Creation and Values’ as a timely initiative aimed at better understanding the current developments in the audio-visual sector and the likely trends.

19 Sep, 2013

ETNO Contribution to European Commission Consultation on the Draft “General Block Exemption Regulation” (GBER II)

ETNO welcomes the opportunity to comment on the draft “General Block Exemption Regulation” (GBER II) and recognises the importance of setting appropriate rules in this regard.

30 Aug, 2013

ETNO Reflection Document on the EC Proposal for a Directive on Network and Information Security (NIS Directive)

ETNO supports the European Commission’s global approach to cyber-security and welcomes the proposed NIS Directive which recognizes the importance of security throughout the entire value chain.

30 Aug, 2013

ETNO Reflection Document on the Trade In Services Agreement

Download the full Reflection Document here.

26 Aug, 2013

ETNO Reply to the Draft RSPG Opinion on Licensed Shared Access

ETNO believes that exclusive licensing is the appropriate regulatory approach for efficient use of spectrum by public cellular mobile networks.ETNO considers that the LSA concept is a good instrument to improve the efficiency of spectrum use in underutilised bands.

30 Jun, 2013

Position Paper on the Transatlantic Trade and Investment Partnership

Download the full Reflection Document here.

07 May, 2013

ETNO comments on the Draft RSPG Opinion on Strategic Challenges facing Europe in addressing the Growing Spectrum Demand for Wireless Broadband

PDF HereETNO welcomes the opportunity to comment the draft RSPG opinion on Wireless Broadband as we believe that frequencies for WBB need forward looking strategy in Europe.

12 Apr, 2013

JOINT REPLY TO THE COMMISSION’S CONSULTATION ON THE CIVIL ENFORCEMENT OF INTELLECTUAL PROPERTY RIGHTS

Our pan-European organisations, Cable Europe, ECTA, ETNO and EuroISPA, represent the European electronic communications industry that is comprised of both national and pan-European fixed and mobile telecoms operators, Internet Services Providers (ISPs) and cable companies. The European electronic communications industry plays a crucial part in connecting European citizens and businesses to information, news, entertainment and cultural content.

29 Mar, 2013

Civil enforcement of intellectual property rights: public consultation on the efficiency of proceedings and accessibility of measures - ETNO considerations

ETNO is the European association representing approximately 40 member companies in the telecommunications market across 35 European countries. Besides being network and Internet access providers, many ETNO members also offer hosting services. In addition to this, many members are also content providers and are active in the promotion and provision of legal content services. As such, ETNO is very much interested in this debate.

15 Feb, 2013

Consultation of e-Business Stakeholders for the WSIS+10 Review

The C7 e-Business action line covers the following items:a) Governments, international organizations and the private sector, are encouraged to promote the benefits of international trade and the use of e-business, and promote the use of e-business models in developing countries and countries with economies in transition.b) Through the adoption of an enabling environment, and based on widely available Internet access, governments should seek to stimulate private sector investment, foster new applications, content development and public/private partnerships.

08 Jan, 2013

RD392 - CMA ETNO response to Relevant markets review consultation

Electronic communications markets are undergoing profound changes. The revision of the Commission Recommendation on Relevant Markets (the Recommendation) presents a unique opportunity to adapt ex-ante regulation to the needs of electronic communications markets in the EU in the coming 6 – 8 years.

16 Nov, 2012

ETNO Reflection Document on “Article 28(2) Universal Service Directive: a harmonised BEREC cooperation process - Consultation paper”

The Association of European Telecommunications Network Operators (ETNO) would like to thank BEREC for the opportunity to participate in the Consultation on “Article 28(2) Universal Service Directive: A harmonised BEREC cooperation process”.The proposed BEREC cooperation mainly with the NRAs process has been thoroughly analyzed, and, since it mainly relates to regulatory and legal issues inside NRA legal roles and powers, additional suggestions are possibly outside the operators’ scope.Executive Summary

12 Nov, 2012

ETNO Reflection Document on “Draft ECC Recommendation 12(04): Numbering for VoIP Services”

31 Oct, 2012

Response to DG Trade’s Public Consultation on regulatory issues for a possible future EU-US trade agreement

There is a wide consensus that Information and Communication Technologies (ICTs) are a key driver of economic growth on account of their multiplier effect across all sectors of the economy, providing the foundation for global competitiveness and job creation in manufacturing, agriculture and services.

30 Oct, 2012

ETNO Reflection Document: ECC WG NaN Green Paper - Long Term Evolution in Numbering, Naming and Addressing 2012-2022

The Association of European Telecommunications Network Operators (ETNO)[1] would like to thank the CEPT/ECC (Electronic Communications Committee) WG NaN (Working Group Numbering and Networks) for the opportunity to comment on the Draft Final of Green Paper on “Long Term Evolution in Numbering, Naming and Addressing: 2012 – 2022”.

29 Oct, 2012

ETNO Reflection Document on BEREC 2013 WP

ETNO’s 40 telecoms members are making long-term investments in the broadband networks of the future in order to help boost competitiveness, foster development of the Internal Market and benefit EU consumers and businesses. Europe’s electronic communications industry is a key enabler of smart and sustainable growth and it is important to ensure that the appropriate regulatory environment is in place in order to ensure continued investment during difficult economic times.

19 Oct, 2012

ETNO response to BEREC draft CP on best practice in remedies on markets 4, 5 and 6; BoR (12) 104, BoR (12) 88, BoR 12 (83)

ETNO takes the opportunity to comment on the present draft BEREC Common Positions on best practice remedies on markets 4, 5 and 6.

16 Oct, 2012

ETNO response to the Commission Public Consultation on specific aspects of transparency, traffic management and switching in an open Internet

ETNO welcomes the present consultation. ETNO members provide access to the Internet over more than 300 millions broadband connections (fixed and mobile) in the 27 EU Member States and beyond, making ETNO companies a guarantor of an open, accessible and sustainable Internet ecosystem.

15 Oct, 2012

ETNO Expert Contribution on the European Commission Consultation “Improving Network and Information Security (NIS) in the EU”

With a view to the forthcoming EU Strategy on Cyber-security, expected by end 2012, the Commission has launched this public consultation on “Improving Network and Information Security (NIS) in the EU” in order to gather input from interested stakeholders.

27 Sep, 2012

ETNOC01 - DSM - Notice and Action Consultation Sep 2012

"A clean and open Internet: Public consultation on procedures for notifying and acting on illegal content hosted by online intermediaries"This is the ETNO full and official response to the Commission's consultation on Notice & Action.Read more

27 Sep, 2012

ETNOC02 - ETI - ETNO Contribution DG trade cons

ETNO Response to DG Trade’s Public consultation on the future of EU-US trade and economic relationsThis position paper is ETNO’s contribution to DG Trade’s Public Consultation on the future of EU-US trade and economic relations. It stresses some aspects of the ETNO contribution to the EU-US High level Working Group on Jobs and Growth consultation (April 2012).Read more

04 Sep, 2012

RD384 - ETNO Response to [Draft] EU Guidelines for the Application of State Aid Rules in Relation to the Rapid Deployment of Broadband Networks

ETNO supports the Commission’s recently announced new policy / regulatory approach for the broadband investment environment and believes that the revision of the State aid Guidelines for broadband networks should take due account of these new objectives.ETNO agrees with the European Commission’s cornerstone principle that public funding should remain complementary and should not substitute the investments of market players.State aid measures should not try to determine technology choices but rather should remain technology neutral and support the market’s choice of th

13 Jun, 2012

RD379 - WTO Review of the Information Technology Agreement

The ITA needs a revision and ETNO supports such evolution. ETNO members welcome an ITA expansion. ETNO’s position is to recommend the start of negotiations promptly, with a view to rapid conclusion and implementation.

05 Jun, 2012

RD378 - ETNO Response to Mediation Process Concerning Private Copying and Reprography Levies

ETNO welcomes the opportunity to contribute to the debate launched on how to tackle the existence of disparate levy systems throughout Europe and the need to adapt the functioning and scope of the levies in the today’s fast evolving digital environment.Any modification in the regulatory framework should be aimed at fostering, and not hampering, the development of innovative services and facilitating their use by the users.Executive Summary:

05 Jun, 2012

RD377 - ECC WG NaN Green Paper - Long Term Evolution in Numbering, Naming and Addressing 2012-2022

ETNO would like to thank the CEPT/ECC (Electronic Communications Committee) WG NaN (Working Group Numbering and Networks) for the opportunity to comment on the Green Paper on “Long Term Evolution in Numbering, Naming and Addressing: 2012 – 2022”.ETNO very much welcomes the statement that “efficient and effective regulations in the area of numbering, naming and addressing are only possible after a detailed and well informed dialogue with all the involved stakeholders…”Executive summary:

01 May, 2012

RD376 - ETNO Comments on the EC Proposal for a General Data Protection Regulation (GDPR)

ETNO welcomes the European Commission’s commitment to maintaining Europe’s high standards in the protection of personal data while at the same time ensuring better harmonization throughout the EU and achievement of a fully internal market.The latter objective can only be reached via a Regulation and therefore ETNO fully supports the choice of this legal instrument.Executive Summary:

01 Apr, 2012

RD375 -ETNO Contribution to Public Consultation on EU – US High Level Working Group on Jobs and Growth

At the EU-US Summit meeting of 28th November 2011, leaders directed the Transatlantic Economic Council to establish a High-Level Working Group on Jobs and Growth, led by the US Trade Representative and EU Trade Commissioner. This Working Group is tasked to identify policies and measures to increase EU-US trade and investment to support mutually beneficial job creation, economic growth, and international competitiveness.Executive Summary:

01 Apr, 2012

RD374 - Modernizing the scope of the telecommunications chapter on EU trade agreements: addressing the convergence between telecommunication services and the transmission of audiovisual services

This position paper highlights the rationale behind adapting the current scope of the chapters on telecommunications services relating to the trade agreements that the EU Commission is negotiating with third countries.This position paper highlights the rationale behind adapting the current scope of the chapters on telecommunications services relating to the trade agreements that the EU Commission is negotiating with third countries.

09 Mar, 2012

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 SummaryETNO 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:

01 Mar, 2012

RD 373 - ETNO Response to the Draft BEREC High Level Principles on Issues of Non-Discrimination

ETNO welcomes the consultation launched by BEREC on the high level principles associated with non-discrimination. This is a matter of great impact and importance to ETNO members and ETNO hereby submits answers to the questions that are of concern to the association.

13 Feb, 2012

RD371 - Position Paper - ETNO answer to BEREC Report on Impact of Fixed-Mobile Substitution in Market Definition

ETNO shares BEREC’s analysis that the degree of fixed-mobile substitution varies considerably between member states. Overall, fixed-mobile substitution effects are becoming more relevant and, where present, should lead to a reconsideration of current obligations imposed on fixed network operators.Executive Summary

09 Feb, 2012

RD370 - ETNO Reflection Document - Comments on Draft ECC Report 178 “Open and Closed Dialling Plans”

ETNO would like to thank the Electronic Communications Committee (ECC) for the opportunity to comment on the Draft ECC Report 178 “Open and Closed Dialling Plans” and considers that the report offers a very valuable and useful viewpoint on the issue of closed/open dialling plans.Executive Summary

09 Feb, 2012

RD369 - ETNO Reflection Document - Comments on ECC Recommendation (12)02 “Number Portability – Best Practices”

ETNO would like to thank the Electronic Communications Committee (ECC) for the opportunity to comment on the proposed recommendations on Number Portability Best Practices.Executive Summary

23 Jan, 2012

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

16 Jan, 2012

RD367 - ETNO Reflection Document on BEREC draft Medium Term Strategy Outlook

ETNO welcomes BEREC’s initiative to provide a mid-term strategic outlook on its priorities. It reflects BEREC’s increasingly important role in ensuring a consistent and proportionate regulatory regime in the EU.Executive Summary

06 Jan, 2012

RD366- ETNO Reflection Document - ETI ETNO comments FCC on Foreign ownership

On October 21st, the Federal Communications Commission published in the US Federal Register a Notice of Proposed Rulemaking (NPRM) in which it seeks comments by December 5th 2011 (with possible extension) on the procedures it has applied over many years when scrutinising foreign investments in wireless spectrum licences.

09 Nov, 2011

RD365 - ETNO Reflection Document - ETNO Response to the EU Consultation on Costing

ETNO welcomes and shares the concern of the Commission over the deployment of next generation access networks in Europe. ETNO members are contributing more than two thirds of NGA investments in Europe. Over the past year our companies have engaged in a constructive dialogue with the European Commission on how to improve conditions for high-speed broadband roll-out in Europe.Executive Summary

08 Nov, 2011

RD364 - ETNO Reflection Document - ETNO answer to EU-consultation on Non Discrimination

ETNO welcomes the consultation launched by the European Commission on non-discrimination. This is a matter of great impact and importance to its members. ETNO hereby submits answers to the questions that are of joint concern to the association.Executive Summary

07 Nov, 2011

RD363 - ETNO Reflection Document - on new Business to Consumers 2015 place-of-supply VAT rules for telecommunications services

The new B2C 2015 place of supply rules for telecommunications services will have a big impact on telcos’ businesses, will result in huge costs and may create an unworkable situation and/or irresolvable problems in relation to a non-domestic customer base and the small amount of revenue from individuals resident in another Member State (much less than 1 %).Summary

04 Nov, 2011

CP085 - ETNO Common Position on WRC-12

The WRCs (World Radiocommunications Conferences) of the ITU-R and their decisions are of great importance for the mobile industry. Among the WRC-12 Agenda Items, the most important from the operators’ point of view are:Executive Summary:The WRCs (World Radiocommunications Conferences) of the ITU-R and their decisions are of great importance for the mobile industry.Among the WRC-12 Agenda Items, the most important from the operators’ point of view are:

03 Nov, 2011

RD362 - ETNO Reflection Document - Reponse to the European Commission’s Green Paper on the Online Distribution of Audiovisual Works in the European Union

ETNO believes that the Commission’s Green Paper on Audiovisual Works provides an important basis for the necessary debate on the policy options needed in order to develop a sound framework within which European industry and European consumers can benefit from the digital single market and to improve Europe’s competitive position.Executive Summary:

02 Nov, 2011

RD361 - ETNO Reflection Document on BEREC 2012 WP

BEREC’s work in 2012 should primarily focus on creating a regulatory framework that incentivises private investment in high-speed wireline and wireless networks. ETNO welcomes BEREC’s intention to carry out work on regulatory accounting, Next Generation Access networks and the implementation of the EU framework provisions on net neutrality in 2012. ETNO thinks that market definition and the impact of reduced mobile termination rates on the mobile sector for its 2012 WP should also be considered.Executive Summary:

01 Nov, 2011

RD360 - ETNO Reflection Document - Response to the BEREC Consultation on Draft Guidelines for Transparency and Net Neutrality

ETNO members are committed to providing transparent and meaningful information to end-users on their services of choice and as required by the existing telecoms regulatory framework. Network management is an indispensable means to control network congestion. ETNO believes that BEREC has correctly identified the key areas relevant for the implementation of transparencyExecutive Summary:

05 Sep, 2011

RD359 - ETNO Reflection Document - Response to BEREC call for contributions on cross border accessibility of numbers

ETNO welcomes the opportunity to respond to this questionnaire about crossborder issues under Article 28 of the Universal Service Directive (USD). According to ETNO, there are no problems evident in the EU Member, States ETNO reiterates the difficulties and disadvantages of provisioning access to all national non-geographic service numbers between EU Member States. ETNO has serious concerns regarding, in particular, national non-geographic service numbers access provisioning at the international level.Executive Summary:

01 Sep, 2011

RD358 - ETNO Reflection Document - Response to the public consultation on the ePrivacy Directive: circumstances, procedures and formats for personal data breach notifications

Data breach notification systems must remain valuable for end-users and excessive notifications, without due cause, must be avoided. “Undue delay” in notification to individuals should be the shortest period possible but it may not be appropriate to define a specific timeframe in legislation. Standardized notification forms may be useful when notifying authorities. However, flexibility around communicating with subscribers/individuals should be allowed.Executive Summary:

08 Aug, 2011

RD357 - ETNO Reflection document - Response to next Phases of the UNGIS Open Consultations on the Overall Review of the Implementation of the WSIS Outcomes (WSIS+10)

ETNO supports the proposal made during the United Nations Group on Information Society (UNGIS) meeting to devote the next WSIS Action Lines Forum to the WSIS Review.Executive Summary:

05 Aug, 2011

RD356 - ETNO Reflection Document replying to the public consultation on Cloud Computing

ETNO belives there is no need for specific regulatory or legislative action on cloud computing. In particular, there should be no new consumer rights introduced. General rules of data protection and consumer protection should be applied to all actors. The main barriers include divergent implementation of the Data Protection and Data Retention Directives. Interoperability, standardisation and data portability are key issues.

Executive Summary:

04 Aug, 2011

RD355 - ETNO Reflection Document - Reply to the public consultation on the Revision of the Community Guidelines for the application of State aid rules in relation to rapid deployment of broadband networks.

The Commission’s Broadband Guidelines provide a solid framework to assess the use of public funding for broadband network development. In this position paper, ETNO believes that in order for the EU2020 Strategy and the Digital Agenda targets to be fully reached, further funds should be made available for the rollout of NGA networks. In addition, next generation mobile networks should no longer be excluded from the NGA definition in the State aid broadband Guidelines.Executive Summary:

03 Aug, 2011

RD354 - ETNO Reflection Document – Response to Draft ECC Decision ECC/DEC(11)EE on “Reserving the National Number Range 111 for Long Term European Harmonisation Purposes”

In this position paper, ETNO wishes to explain the drawbacks about reserving the National Number Range 111 for Long Term European Harmonisation Purposes.Executive SummaryETNO welcomes the opportunity to respond to the Draft ECC Decision ECC/DEC(11)EE on “Reserving the National Number Range 111 for Long Term European Harmonisation Purposes”.In this position paper, ETNO wishes to explain the drawbacks about reserving the National Number Range 111 for Long Term European Harmonisation Purposes.

02 Aug, 2011

RD353 - ETNO Response to the Draft ECC Decision ECC/DEC(11)FF on the “Withdrawal of ECTRA/DEC(96)01 regarding ETNS, ECTRA/DEC(96)48 regarding ETNS, ECC/DEC(04)07 on ETNS Conventions”

ETNO welcomes the opportunity to respond to the Draft ECC Decision ECC/DEC(11)FF on the withdrawal of ECTRA and ECC decisions re ETNS. In this position paper, ETNO explains its point of view about the closure of the ETNS.Executive Summary:

01 Aug, 2011

RD352 - ETNO Reflection Document - Draft ECC Recommendation (11)07 on “Usage and Reservation of National Short Numbers Beginning with 11X”

In this position paper on Draft ECC Recommendation (11)07 on “Usage and Reservation of National Short Numbers beginning with 11X”, ETNO explains the drawbacks about usage and reservation of the national short numbers beginning with 11X.Executive Summary

01 Jun, 2011

RD351 - Response to the National Telecommunications and Information Administration of the US Department of Commerce on the Internet Assigned Numbers Authority (IANA) Functions

ETNO believes that management of the Internet Assigned Numbers Authority (IANA) functions should transition from a Government oversight contractual responsibility to that of the Internet Corporation for Assigned Names and Numbers (ICANN). ETNO is deeply concerned that the IANA functions could be used as a means to verify or revisit decisions made on new generic top level domain (gTLD) delegations. Such delegation decisions should be made according to the process set out in the new gTLD Applicant Guidebook.Executive Summary:

02 May, 2011

RD350 - ETNO Reflection Document on the EU Green Paper on the future of VAT

VAT should be charged by the supplier irrespectively wherever the customer in the internal market belongs. Input VAT should be recovered in the country of the customer, as in ordinary tax returns. VAT revenue to be distributed among Member States should be based on macroeconomic data.

Executive Summary:

01 May, 2011

RD349 - ETNO Reflection Document commenting on the Roadmap for moving to a competitive low carbon economy in 2050

ETNO welcomes the Commission roadmap towards a low carbon economy but calls on EU policy makers to ensure that the role of the ICT and broadband networks and services in achieving better energy efficiency is fully reflected. Sector-specific roadmaps and national low carbon plans should include concrete incentives for other sectors of the economy to embrace low-carbon solutions.

04 Mar, 2011

RD348 - ETNO Reflection Document - Response to the National Telecommunications and Information Administration of the US Department of Commerce on the Internet Assigned Numbers Authority (IANA)

This is the ETNO response to the NTIA consultation on IANA functions. In ETNO’s view, the responsibilities of the IANA functions should remain as a whole within ICANN and not fall under any direct government oversight. We urge ICANN to work towards fully implementing the Affirmation of Commitments and its resulting recommendations for improvement and in our cover letter we ask the US government to act as a catalyst in this direction.Executive Summary:

03 Mar, 2011

RD347 - ETNO Reflection Document on the Application of Directive 2004/48/EC on the Enforcement of Intellectual Property Rights

Directive 2004/48/EC regarding the enforcement of intellectual property rights (hereinafter “IPRED”) played and continues to play a crucial role in providing Europe’s right holders with a high level of intellectual property right protection. The IPRED is based upon principles that remain valid today and that should be maintained.

02 Mar, 2011

RD346 - ETNO Reflection Document - Comments on draft ECC Recommendation (11)02 "Calling Line Identification and Originating Identification"

ETNO welcomes the opportunity to comment on the draft ECC Recommendation (11)02 "Calling Line Identification and Originating Identification”.ETNO agrees with most of the recommendations and only wants to offer suggestions to clarify some of them.Executive Summary:

01 Mar, 2011

RD345 - ETNO Reflection Document - Comments on draft ECC Recommendations (11)03 "Numbering and addressing for Machine-to-Machine Communication"

ETNO welcomes the opportunity to comment on the draft ECC recommendation (11)03 "Numbering and Addressing for Machine-To-Machine (M2M) Communications.ETNO agrees that national numbering policies for M2M communication are required to support the potential demand for specific M2M applications, and as a consequence, considers that no harmonised approach is needed in Europe.Executive Summary:

02 Feb, 2011

RD344 - ETNO Response to the Public Consultation on the Review of the Functioning of Regulation (EC) No 544/2009 (the "Roaming Regulation")

01 Feb, 2011

RD343 - ETNO Reflection Document - Response to the European Commission questionnaire on the future harmonisation of numbering resources for the provision of business services

For more than ten years, ETNO has expressed its absolute reservations regarding the European Telephony Numbering Space (ETNS) concept. ETNO believes that it is now time to recognise that this concept was basically flawed, because there is no viable commercial demand. Pursuing the same remit as proposed in this renewed approach would only lead to unnecessary costs. Instead, all European business customers can use ITU-T administrated global numbers, already well known by end users.Executive Summary:

03 Jan, 2011

RD342 - ETNO Reflection Document on the EC Public Consultation on the Communication on a comprehensive approach on personal data protection in the European Union

ETNO welcomes that the Communication stresses and reaffirms the twofold objective of the Directive 95/46/EC: protection of fundamental rights and freedoms of natural persons, and free flow of personal data between Member States. An eventual revision of the Directive should seek the right balance between both objectives. A revision that would only focus on protecting the fundamental right to data protection would forget the second pillar of the Directive.

02 Jan, 2011

RD341 - ETNO Reflection Document in reply to the public consultation on the Draft RSPG opinion on Common Policy Objectives for WRC-12

In general ETNO supports the views expressed in the draft RSPG opinion. The WRCs of the ITU-R and their decisions are of great importance for the mobile industry. Among the WRC-12 Agenda Items, the most important from the operators’ point of view are Agenda Items 1.17, Agenda Item 1.2 and Agenda item 1.19.Executive Summary:

01 Jan, 2011

RD340 - ETNO Reflection Document to BEREC Consultation on Cross-border Issues under Article 28 of Universal Service Directive

ETNO has concerns regarding non-geographic numbers access provisioning at international level, as there are existing unresolved issues. The Association explains the disadvantages of provisioning access to all non-geographic numbers in Member States and presents its views on the consultation questions.Executive Summary:

30 Dec, 2010

RD338 - IGV ETNO ATRT recommendations

ETNO welcomes the opportunity to contribute to the consultation on the draft proposed recommendations of the Review Team of Accountability and Transparency of ICANN.ETNO supports most of the draft recommendations and highly anticipates that the final recommendations will be implemented in a timely manner.

12 Dec, 2010

RD339 - ETI Triple-play services in MERCOSUR

FTA negotiations, including the ongoing talks with MERCOSUR, use the “Reference Paper” annexed to the “WTO Telecommunications Agreement” as a basis. This covers important “standard” aspects of telecommunications and ETNO acknowledges that they are already well covered in the current texts. Crucial aspects which go beyond the “Reference Paper” aim at stimulating and protecting investments in this sector: elimination of foreign equity limits on telecom and audiovisual services; assuring the principle of National Treatment; and suppressing unduly restrictive market access conditions.

30 Nov, 2010

RD337 - ETNO Reflection Document on the BEREC consultation “Electronic communications services: ensuring equivalence in access and choice for disabled end-users”

30 Nov, 2010

RD336 - ETNO Reflection Document commenting on draft BEREC Report on relevant market definition for business services

ETNO welcomes this public consultation by the Body of European Regulators for Electronic Communications (BEREC) on its draft report on relevant market definition for business services, BoR (10) 46.ETNO concurs with many of the principles identified in the report and encourages BEREC and national regulatory authorities (NRAs) to continue to refer to the SMP-guidelines of the European Commission[1] when delineating separate or common markets for busines

30 Nov, 2010

RD335 - RPOL BEREC FS guidance

As ETNO argued[1] during the 2007-2009 ‘Telecoms Review,’ the proposed introduction of functional separation into the Framework was not based on any cost-benefit analysis or regulatory impact assessment. Instead, it was politically motivated, linked to NRAs reliance on mandatory unbundling and the concept of the ‘ladder of investment’ in their implementation of the Framework.

30 Nov, 2010

EC106 - ETNO Expert Contribution on the ECO Questionnaire related to the Revision of ECC Report 003

The document is ETNO's reply to the ECO Questionnaire on the potential revision of ECCReport 003.ETNO welcomes the opportunity to express its views on the future of the Fixed Service in Europe.The attached replies are offering comments on the questions asked by ECO in relation to the potnetial revision of the ECC Report 003 on the use of Fixed Service in Europe.

30 Nov, 2010

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):

30 Nov, 2010

RD333 - ETNO Reflection Document on the future of electronic commerce in the internal market and the implementation of the e-Commerce Directive

ETNO welcomes this consultation on the future of electronic commerce in the internal market and the implementation of the Directive on Electronic Commerce. The current EU legal framework on e-commerce - in particular the provisions related to intermediaries’ liability - strike the right balance amongst the interests of the different stakeholders. The framework respectd fundamental principles and rights, in particular freedom of speech, freedom of access to the internet and the right of privacy.

31 Oct, 2010

EC105 - ETNO Expert Contribution – Cost accounting for key access products in the transition to NGA

ETNO made this proactive submission to the Directorate-General for Information Society & Media to raise the issue of pricing of key wholesale access product on copper-based broadband networks and its impact on investment in next generation access networks (NGA).

31 Oct, 2010

RD332 - ETNO Reflection document - Comments on the Draft ECC Report 155 on “Number Portability Procedures”

Number portability is a fundamental element to consolidate competition on the market. ETNO urges Member States to take a very cautious approach when transposing the Directives into national legislation.Too far-reaching requirements which could be unrealistic for operators and unreliable for customers should be avoided. The practical implementation and the duration of service interruption are critical issues.Consumers should not be faced with loss of service beyond one day or preferably less.

31 Oct, 2010

RD331 - ETNO Reflection document - Comments on the Draft ECC Report 154 on the Evolution of geographic numbers

ETNO finds the scarcity of numbers is not a reason for removing requirements for geographic information.A specific need for nation-wide location number portability for geographic numbers should be assessed in the market before considering it as a reason to support location independent numbers evolution.Nation-wide location number portability is a one way move which induces significant costs due to technical and business impacts.

31 Oct, 2010

RD330 - ETNO Reflection document - Comments on the Draft ECC Report 153 on Numbering and Addressing in Machine-to- Machine (M2M) communications

ETNO agrees that national numbering policies for M2M communication are required to support the potential demand for M2M applications and endorses the conclusion of the report that no harmonised approach is needed in Europe, regarding the solutions to address the impact and needs on numbering and addressing of M2M services.

30 Sep, 2010

RD329 - ETNO response to the Commission consultation on the Open Internet and Net Neutrality

For ETNO the economic context of the open internet debate includes:

27 Aug, 2010

RD328 - ETNO Reflection Document commenting on the Draft ECC Report 152

ETNO strongly believes that any revision of the regulatory framework and in particular of the ERC Decision (00)07, that will constrain the radio relay network development in the 18 GHz band, should eventually be taken into account only after the completion of the ECC Report 003 revision and after detailed investigations on the compatibility issues.

30 Jul, 2010

RD327 - ETNO Reflection Document on the future direction of EU trade policy

This Reflection Document lists ETNO’s replies to the 20 questions in the European Commission DG TRADE public consultation on a future trade policy (close 28 July 2010). The Association’s comments were submitted via the EC’s dedicated web tool.

30 Jul, 2010

RD326 - ETNO Reflection Document - Input to the Review Team on Accountability and Transparency of ICANN

The document is ETNO’s reply to the "Questions to the Community on Accountability and Transparency within ICANN" consultation.

30 Jul, 2010

RD325 - ETNO Response to BEREC consultation on procedures for public consultations held by BEREC

The January 2010 Rules of Procedure (RoPs) of the Board of Regulators (BoR) should be considered provisional until the completion of this consultation. If the RoPs are considered final, as implied in the consultation document, this consultation is rendered meaningless.

28 May, 2010

RD324 - ETNO Reflection Document on universal service principles in e-communications

ETNO calls upon the Commission to conduct a thorough, systematic review of the universal service regime on par with the review of the directives of the regulatory framework for electronic communications networks and services completed in 2009. Please read-on to see ETNO's detailed comments.

30 Apr, 2010

RD323 - ETNO Reflection Document commenting on the RSPG opinion on the Radio Spectrum Policy Programme

ETNO welcomes the establishment of multi-annual radio spectrum policy programmes whereby a long term vision that extends to at least 2020 is necessary. The Association agrees with the general directions defined in the RSPG opinion on the radio spectrum policy programme.ETNO supports the harmonisation of spectrum usage and appreciates flexibility of usage by moving towards technology neutrality which however requires a very careful approach on a band by band basis.

30 Apr, 2010

RD322 - ETNO Reflection Document on the first Radio Spectrum Policy Programme

ETNO agrees that spectrum issues are of strategic importance and strongly supports coordination of spectrum management policies and common initiatives at European Union-level. The RSPP should address all types of radio spectrum usage within EU jurisdiction and provide incentives in order that the goal of spectrum optimisation applies to everyone -- and not only to electronic communications networks (ECN) and network services (ECNS).

31 Mar, 2010

RD321 - ETNO Reflection Document commenting on BEREC Work Programme 2010

ETNO has serious concerns that this first ever BEREC consultation is setting a precedent, allowing an unreasonable period for public consultation in contravention of Article 17 of the “BEREC Regulation”.ETNO also has serious concerns about BEREC’s reliance on “reports” to develop preliminary positions – and in particular, about the fact that for such reports it is decided on a case-by-case basis whether to organise a public consultation and/or a public hearing.

26 Feb, 2010

RD320 - ETNO Reflection Document in response to the discussion draft: “Affirmation Reviews – Requirements and Implementation processes” presented by ICANN

ETNO largely supports the discussion draft "Affirmation Reviews” presented by ICANN.ETNO is concerned that the proposed size of the Review Teams is far too small and these must be enlarged. Given the key role Review Teams play and bearing in mind the various major stakeholders of ICANN, a proper representation, diversity and balance must be found within each Review Team. ETNO proposes that additional members participate in the Review Teams and that GNSO is represented in all Review Teams by at least one member.

26 Feb, 2010

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.

29 Jan, 2010

RD318 - Reflection Document on the Radio Spectrum Policy Group 2010 Work Programme

ETNO expects that 2010 will be challenging, focusing on the implementation of the new provisions on management and spectrum use as defined in the recently approved Telecom package. The RSPG 2010 Work Programme should provide guidelines whereby it is important to seek continuity while improving the work developed in the past. It would be useful to continue monitoring and supporting wireless broadband developments, which should be included specifically in the 2010 Work Programme.

29 Jan, 2010

RD317 - ETNO Reflection Document on Taking stock of the Sharm El Sheikh meeting and preparing for the IGF 2010 Meeting

ETNO and its members are fully committed to the IGF process. This document contributes to the discussions on Taking Stock of the Sharm El Sheikh IGF meeting, as well as to the preparation of the 5th IGF meeting in Lithuania, ahead of the open consultation in Geneva (9 February 2010).

29 Jan, 2010

RD316 - ETNO Reflection Document on a possible revision of the 18 GHz band regulatory framework in Europe

The 18 GHz band is heavily used by the fixed service in Europe, providing operators with a unique opportunity to implement very high capacity links with long hop length. The ERC Decision (00)07 defines the rules for the use of the band, which was the result of a long debate. ETNO therefore opposes any reopening of the discussion on the band and in particular any revision of the ERC Decision (00)07 that will constrain the radio relay network development.

29 Jan, 2010

RD315 - ETNO Reflection Document in reply to the EC “Creative Content Online” consultation

ETNO supports the approach taken by the DG Infso and Markt “Reflection Document on Creative Content in a European Digital Single Market: Challenges for the future” namely;

31 Dec, 2009

RD314 - ETNO Reflection Document on draft RSPG report on Cognitive Technologies

Studies performed so far have demonstrated that Cognitive Radio Technologies (CRT), although look promising for certain applications, do need further developments before being put in place. ETNO therefore believes that the introduction of CRT should only happen when the detection of primary users has been demonstrated to be efficient, and their application should focus on “under-used” frequency bands.

31 Dec, 2009

RD313 - ETNO Reflection Document on the EC Public Consultation on the Framework Data Protection Directive

ETNO welcomes the EC public consultation on the legal framework for data protection. The current EU legal framework introduced a high level of protection. However, in the light of the speed of technological change, some adjustments may be necessary to maintain the same level of protection of individuals’ fundamental rights while, at the same time, improving legal certainty and flexibility for EU companies

31 Dec, 2009

EC104 - ETNO Expert Contribution on the on-going ACTA negotiations

The EU and other countries such as the US are negotiating the Anti-Counterfeiting Trade Agreement (ACTA) dealing with the trade of counterfeit goods and copyright infringement. Leaks from the process point to disproportionate and wide-ranging measures. ETNO wishes to raise concern over the lack of transparency in the process. We are concerned such a sensitive issue is not discussed with all the relevant stakeholders instead of being negotiated behind closed doors.

31 Dec, 2009

RD312 - Reflection Document on Bill & Keep for IP interconnection charging

These are ETNO comments on the ERG draft “Common Position on Next Generation Networks Future Charging Mechanisms / Long Term Termination Issues,” ERG(09) 34.

31 Dec, 2009

RD311 - ETNO Reflection Document with Comments - In the Matter of Broadband Study Conducted by the Berkman Center for Internet and Society – NBP Public Notice #13

ETNO believes that a robust empirical approach is required, if independent research and analysis are to be used for policy advice. In our non-exhaustive review of the qualitative country case studies in the draft report, “Next Generation Connectivity: A Review of Broadband Internet Transitions and Policy from Around the World” (the “Berkman study”), ETNO has found numerous factual errors, inaccuracies and inconsistencies.

30 Nov, 2009

RD310 - ETNO Reflection Document on the ERG Draft 2010 Work Programme

ETNO understands that the 2010 ERG Work Programme is of transitional nature in view of the establishment of the successor Body of European Regulators for Electronic Communications (BEREC) in 2010. ETNO believes that BEREC should consult with stakeholders on its work programme as soon as possible after its establishment. A key success factor for BEREC will be its transparency. Furthermore ETNO calls for a direct stakeholder involvement in the development of regulatory guidance under the new framework.

30 Oct, 2009

RD309 - ETNO Reflection Document in reply to the public consultation on post-i2010 - Priorities for new strategy for European information society (2010-2015)

The ICT sector, in particular broadband, is key to EU economic development, efficiency growth, recovery from the crisis and will contribute to a sustainable low carbon economy. Next-generation broadband networks will have positive benefits for consumers, businesses and society. Investments in such technologies should be a top priority in the Commission’s digital agenda for the years to come. The consultation rightly places NGA investments at the top of the priorities.

30 Sep, 2009

CP084 - ETNO Common Position on the ECC draft Decision on “Reserving the National SMS Numbering Range Beginning with '116' for Harmonised SMS Numbers for Harmonised Services of Social Value”

ETNO welcomes the possibility to contribute to the EEC consultation and remains committed to ensuring the best useable outcome for the vulnerable groups who are the intended beneficiaries of these services. ETNO is however not convinced that the use of SMS to access 116xxx social service numbers represents any additional value to the potential users nor does it meet any demand - being mindful of the complexity of using SMS for these services.

31 Jul, 2009

RD308 - ETNO contribution to the ECC consultation “Increasing trust in Calling Line Identification and Originating Identification”

ETNO is supportive of the goal of the ECC with regard to Calling Line Identification (CLI) and Originating Identity (OI), but believes that there are still several issues that need to be resolved.

31 Jul, 2009

RD307 - ETNO Reflection Document in response to the Commission Recommendation on regulated access to Next Generation Access Networks (NGA)

Next generation access (NGA) networks are a key prerequisite for Europe’s future competitiveness and the participation of its citizens in the global information society. ETNO welcomes the Commission’s ambition to provide a policy framework for NGA deployment with the present Recommendation on access to NGA and the forthcoming guidelines on state aid for broadband networks. The Commission guidance should promote private investment in NGA networks through a consistent approach in both documents.

31 Jul, 2009

RD306 - ETNO response to the RSPG public consultation related to the draft Opinion on the coordination of EU spectrum interest: Preparation of ITU World Radio Communication Conference of 2011

ETNO agrees with the necessity to identify as early as possible the main agenda items of ITU World Radio Communication Conference 2011. In particular, among the WRC-11 Agenda Items, the most important from the operators’ point of view are:•it is important that the mobile allocation of the sub-band 790-862 MHz is not changed for Europe.•a more flexible international regulatory approach is possible as long as it does not conflict with the objective of world-wide harmonisation and interference free operation of public mobile radio services

30 Jun, 2009

RD305 - ETNO Reflection Document on the Online Commerce Roundtable Conclusions consultation

The overall licensing system in Europe is much more complex than the US as copyrighted content including music are directed to the country of residence. Against this background ETNO supports the promotion of competition between collecting societies on the market for rights management. Furthermore, regulation for multi-territory licensing should be harmonised for all types of content, not only for music. In general, it is essential that licensing solutions are adapted to the online environment.

30 Jun, 2009

RD304 - ETNO Reflection Document on the draft “Community Guidelines for the application of State aid rules to rapid deployment of broadband networks”

30 Jun, 2009

RD303 - ETNO Reflection Document in response to the National Telecommunications and Information Administration of the US Department of Commerce Inquiry , on the Assessment of the Transition of the Technical Coordination and Management of the Internet

ETNO renews its support for the transition of ICANN towards a fully independent and fully privatised organisation, accountable to all stakeholders. Such a move demands that ICANN becomes fully accountable to its multistakeholder community, by completing the required implementation plan by the expiration of the JPA at the end of September 2009. If this cannot be achieved by that date, ICANN must, as a minimum, commit to achieving that and also ensuring that the new accountability mechanism is reflected within its bylaws, within a period of one year from that date.

29 May, 2009

RD302 - ETNO Reflection Document in response to the "Implementation Plan for Improving Institutional Confidence" presented by the ICANN President’s Strategy Committee

ETNO renews its support for the transition of ICANN towards an independent organisation which enjoys improved institutional confidence. ETNO requests that detailed information about the implementation of the recommendations be published as soon as possible.

29 May, 2009

RD301 - ETNO Reflection Document on the draft Programme, Format and Schedule for the 2009 IGF meeting

This document presents the views of ETNO and contributes to the discussions on the draft Programme, Format and Schedule for the 2009 IGF meeting in Sharm El Sheikh, Egypt, ahead of the 2nd open consultation in Geneva (13 May 2009).

30 Apr, 2009

RD300 - ETNO Reflection Document with strong support for FDD as the sole channelling arrangement in 790 – 862 MHz

This Reflection Document is ETNO’s input for the ECC/PT1 meeting in Stockholm on 27-29 April 2009. Its main message is included in the title.

31 Mar, 2009

EC102 - ETNO Expert Contribution commenting on Draft Recommendation e.cpnd

The paper was presented by BT and France Telecom, on behalf of ETNO, at the Study Group 2 meeting in March 2009

27 Feb, 2009

EC101 - Expert Contribution on issues relating to numbering resources used for Services of Social Importance

ETNO thinks the current reservation mechanism is appropriate to support the development of consumer awareness of 116 for Services of Social Importance. As for other related emerging services such as ETTIN, ETNO believes that existing global numbering resources, that minimise the impact upon current national numbering schemes and that meet the requirements of the applicant, are more appropriate.

27 Feb, 2009

EC100 - Expert Contribution on the Principles for the use of the last IPv4 /8 address space in the RIPE NCC Region

ETNO, using its previously agreed principles with regard to IPv4 address exhaustion, proposes a set of principles to be considered when developing a RIPE policy on the use of the last IPv4 /8 address space.

27 Feb, 2009

RD299 - ETNO Reflection Document on Taking stock of the Hyderabad meeting and the way forward, as well as on the Review of the IGF

ETNO and its members are fully committed to the IGF process and participate in both the preparatory open consultations and the IGF meetings. This document contributes to the discussions on Taking Stock of the Hyderabad meeting and the way forward, as well as to the discussions on the review of the IGF.

30 Jan, 2009

RD298 - ETNO Reflection Document on the “Questionnaire for the Call for Input in the fundamental review of Commission Decision 2005/050/EC on automotive Short-Range Radar”

ETNO believes that the SRR is already well regulated in Europe. ETNO opposes changing the regulation in place once more and considers that the cut-off date (2013) is to be respected. Furthermore the 24 GHz solution has to remain the only interim solution up to the cut-off date, and after that date SRR will have to be deployed in the 79 GHz band only.

30 Jan, 2009

EC099 - ETNO Expert Contribution in reply to the Public consultation “Towards a Strengthened Network and Information Security Policy in Europe”

This is ETNO’s input to the European Commission on the future objectives of a strong and coordinated Network and Information Security Policy.Internet Network and Information Security challenges require a strong, coordinated European response without unnecessary regulatory burdens on e-communications service and network providers. To this end the EU should foster enhanced cooperation at the international level with other entities. A “culture of security” should be promoted among all ICT users.

31 Dec, 2008

RD297 - ETNO Reflection Document on the Customs classification of Mobile Phones

Mobile phones are covered by the Information Technology Agreement (ITA), but other Information and Communication Technology (ICT) products such as Global Positioning System (GPS) receivers are not. The Nomenclature Committee (NC) of the European Union is evaluating whether sophisticated mobile phones should be reclassified and made subject to customs duties in line with products such as GPS-units, TVs and video cameras In this paper ETNO stresses that the move to reclassify multifunctional mobile telephones should not lead to higher customs tariffs.

28 Nov, 2008

RD296 - ETNO Reflection Document in reply to the EC consultation on “Future networks and the Internet” – early challenges regarding the Internet of things

More than before, the fast deployment of NGNs must be a priority for the EU when considering policy issues or support actions for the future of the Internet. Discussed in the paper are security aspects, the protection of personal data, identity management, and naming as critical parts of any RFID application architecture. Obligatory measures should remain proportionate and avoid implying unnecessary burdens that could prevent innovation and deployment of new technologies.

28 Nov, 2008

RD295 - ETNO Reflection Document in response to the Commission Recommendation on regulated access to Next Generation Access Networks (NGA)

ETNO is very concerned that the draft Recommendation does not yet provide the required response to the increased risks involved in NGA investment and therefore will not facilitate those investments in Europe. ETNO supports the stated goals of the Commission to promote investment and competition in NGA and to foster sustainable infrastructure-based competition. The Association welcomes the more targeted ‘graduated approach’ to regulation which takes account of different competitive conditions in different regions in particular with regard to infrastructure competition.

28 Nov, 2008

RD294 - ETNO Reflection Document on the draft ERG 2009 Work Programme

ETNO looks forward to a continued interaction with ERG in 2009. We are confident that ERG will adhere to high standards of quality and transparency in its work, including adequate deadlines for stakeholder consultations. In 2008 ERG has proven it can play an important role in finding reasonable and facts-based solutions to regulatory challenges. We encourage ERG to continue to act as a counterbalance in case of initiatives which may harm the sector rather than contribute to its sustainable long-term development.

31 Oct, 2008

RD293 - ETNO Reflection Document in response to the 2nd round of consultation “Improving Institutional Confidence” launched by ICANN

ETNO reiterates its strong support to the multi-stakeholder model ICANN is built. The Association supports the general direction proposed by the Presidents Strategy Committee in order for ICANN to transition to a fully independent organisation. Nevertheless, most of the ETNO comments from the first round of consultation remain valid.ETNO welcomes the opportunity to respond to the second round of the ICANN consultation “Improving Institutional Confidence”.

31 Oct, 2008

EC098 - ETNO Expert Contribution on IP Addressing in a Post IPv4 World Reallocation of resources

ETNO has considered the new version of the RIPE 2007-08 Policy Proposal Enabling Methods for Reallocation of IPv4 Resources, submitted for discussion in the RIPE Address Policy Working Group mailing list. ETNO believes this revised version that provides for additional criteria to demonstrate the need for an LIR to receive IPv4 addresses trough transfer, is significantly improved. Therefore ETNO will support this Policy Proposal. Still there are outstanding considerations regarding the extent and effect of this proposal that should be addressed by the community.

30 Sep, 2008

RD292 - ETNO Reflection Document on EC consultation on the draft Recommendation on “The Regulatory Treatment of Fixed and Mobile Termination Rates in the EU”

Over the last decade, considerable work has been invested by operators and regulators to develop and implement TR regulation. This has led to a set of accepted regulatory practices and costing principles on which business is based and which should not be disrupted.ETNO is concerned with all the provisions in the draft concerning common and joint costs, particularly mobile licence and coverage costs, and considers that the corresponding paragraphs should be suppressed from the final version of the Recommendation.

29 Aug, 2008

RD291 - ETNO Reflection Document on the Practical Application of the New B2B Place of Supply Rules applicable from 2010

ECOFIN adopted a VAT Package of proposals on 12th February 2008 which will bring in some changes in the way VAT is accounted for in Member States, principally with effect from 1st January 2010.

29 Aug, 2008

RD290 - ETNO Reflection Document in response to ECC/ CEPT consultation on Fixed-Mobile Convergence with Survey of Numbering Related Issues

ETNO has considered the arguments being raised in the ECC/ CEPT consultation on Fixed-Mobile Convergence with Survey of Numbering Related Issues and has substantial concerns on certain issues presented in this report. These relate to the characteristics of the FMC services suggested in the report, regulatory issues relevant to Interconnection and in particular voice termination and the interpretation of the concept of technological neutrality under the EU framework, as well as conclusions on CLI presentation, emergency call handling and number portability.

29 Aug, 2008

RD289 - ETNO Reflection Document on the Programme, Agenda and Format of the Hyderabad Meeting, ahead of the 3rd open consultation

ETNO has been working for many years on a range of policy issues associated with the information society, including Internet governance and the World Summit on Information Society process. Many ETNO member companies attended the Athens and the Rio IGF meetings and participated in the preparatory open consultations. This document describes how telecommunications network operators view organizational (programme, agenda and format) as well as content issues for the preparation of the Forum’s third meeting in Hyderabad, India.

31 Jul, 2008

RD288 - ETNO comments on the ERG draft common position on geographic aspects of market analysis

ETNO welcomes the ERG consultation and the recognition of the fact that geographic aspects of market analysis have increased over the last years.Geographic segmentation should take into consideration the final goal of regulation to guarantee competition in retail markets. A too strong focus on competition in wholesale markets would ignore the competitive pressure exerted on consumer markets by the presence of cable operators for instance.

31 Jul, 2008

RD287 - ETNO Reflection Document in response to the consultation “Improving Institutional Confidence” launched by ICANN

ETNO supports the general direction proposed by the Presidents Strategy Committee. However, the document raises a number of serious concerns that need to be addressed prior to the expiry of the current JPA. ETNO suggests a way forward in a number of areas that should assist with that task.ETNO welcomes the opportunity to comment as part of the ICANN consultation “Improving Institutional Confidence”.

31 Jul, 2008

RD286 - ETNO Reflection Document in response to ERG consultation on Regulatory Principles of IP-IC/NGN Core

The Reflection Document is a reply to the ERG consultation on IP Interconnect (ERG (08) 26 rev1). ETNO is of the opinion that:• A strict separation of transport and service layer would not allow the required end-to-end quality of service.• Managed NGNs are a prerequisite for the fully secure networks of the future.• The number and location of different PoIs will emerge as networks are rolled out. Ex-ante definition could lead to an artificial and more costly network structure then needed.

30 Jun, 2008

RD285 - ETNO Reflection Document on the Digital Dividend in Europe

ETNO supports the harmonisation of part of the 470-862 MHz band for broadband wireless access as proposed in the Commission Communication “Reaping the full benefits of digital dividend in Europe”.Therefore, ETNO supports the identification of a reserved harmonised sub-band of the 470 – 862 MHz for bi-directional broadband communications and favours a flexible channel plan with different options, also extending below 790 MHz, in order to be applied in particular national situations.

30 May, 2008

CP083 - ETNO Common Position on the use of creosote for impregnation of telephone poles

Under the revision of the Biocide Directive 98/8/EC, creosote which is widely used to impregnate telephone poles, may be banned, being considered as hazardous. ETNO considers that a controlled, continued use of creosote for the impregnation of telephone poles should be permitted. A ban would result in very high costs and radically increased carbon dioxide emissions as currently there is no sustainable alternative.

30 May, 2008

EC097 - ETNO Expert Contribution on IP Addressing in a post IPv4 World - Principles

This Expert Contribution is additional ETNO's Common Position CP082 2007/10 regarding the exhaustion of the IPv4 address space, which was presented to both RIPE and ICANN.

30 Apr, 2008

RD284 - ETNO Reflection Document on the draft programme outline and schedule of the 3rd IGF meeting, ahead of the 2nd open consultation

This document describes how telecommunications network operators in ETNO view organizational and certain Internet Governance Forum (IGF) content issues. It contains suggestions for improvements for the Forum’s third meeting in Hyderabad, 3-6 December 2008. These views were submitted to the 2nd open preparatory consultation meeting, held in Geneva on 13 May 2008.

30 Apr, 2008

RD283 - ETNO Reflection Document in reply to European Commission stakeholder Consultation on Levies

ETNO welcomes the opportunity to comment on the Commission’s Stakeholder Consultation on Fair Compensation for Acts of Private Copying. ETNO recognises the importance of rights holders to be properly compensated, but believes that the system of copyright levies is outdated and not suited to the European Information Society. Instead, remuneration should be, as far as possible, directly directed towards the usage and the relevant users rather than on all users through levies.

30 Apr, 2008

RD282 - ETNO Reflection Document in reply to the European Commission consultation on “Creative Conditional Access”

This is ETNO's reply to the Conditional Access Consultation. In ETNO’s view, cross-border pay-TV markets are, and will remain, fragmented mainly because of the linguistic factor and therefore there is no significant commercial interest in developing these broadcasting markets. The risk of overlapping regulation between different areas, such as between Conditional Access and Digital Right Management systems, should be carefully avoided.

30 Apr, 2008

RD281 - ETNO Reflection Document on Termination Rates

Considerable work has been invested by operators and regulators to develop and implement Termination Rates (TR) regulation. This has led to valuable, accepted regulatory practices on which business is based and which should not be unnecessarily disrupted. The experience currently gained should be integrated in the future Recommendation.

30 Apr, 2008

EC096 - ETNO Expert Contribution in reply to the consultation on “the Future Role of CEPT”

This document is ETNO's reply to the CEPT consultation of industry and partners about its future structure and mission. The paper formulates a view on 14 of the 19 Questions CEPT put forward.

29 Feb, 2008

RD280 - ETNO Reflection Document in reply to the Creative Content Online consultation

The position paper is ETNO's reply to the consultation following the publication of the "Communication from the Commission on Creative Content Online in the Single Market", COM(2007)836 final of 03.01.2008.

29 Feb, 2008

RD279 - ETNO Reflection Document in response to the public consultation on the CEPT Report 019

ETNO welcomes and supports the basic conclusions of the CEPT Report 019. However, as less experience is currently available with this new concept, ETNO suggests taking a careful “case by case” / “band by band” approach.

29 Feb, 2008

RD278 - ETNO Reflection Document in Response to the Notice of Inquiry from the United States Department of Commerce on the Midterm Review of the Joint Project Agreement with ICANN

This is ETNO's reply to the NTIA inquiry on “The Continued Transition of the Technical Coordination and Management of the Internet’s Domain Name and Addressing System: Midterm Review of the Joint Project Agreement” (Docket No. 071023616–7617–01).

29 Feb, 2008

RD277 - ETNO Reflection Document in response to the ERG consultation on best practices in wholesale unbundled access (ULL) and bitstream access (BSA)

ETNO has significant concerns on the procedure and the approach adopted in the consultation of best practices in the field of wholesale ULL and BSA. ETNO believes that some of the best practices described by the ERG document are efficient and operational in several European countries. Others appear disproportionate, inefficient or potentially irrelevant.

29 Feb, 2008

RD276 - ETNO Reflection Document on the IGF Advisory Group

This document describes how ETNO sees certain issues related to the work of the Advisory Group, which is an integral part of the IGF preparatory process. More specifically, ETNO address the issues of transparency and rotation of its members, in reply to the relevant call of the IGF Secretariat.

29 Feb, 2008

RD275 - ETNO Reflection Document in reply to the IGF Questionnaire “Taking stock and the way forward”

This document describes how telecommunications network operators experienced the Rio Internet Govenance Forum and contains suggestions for the third IGF meeting in New Delhi as regards organizational and content issues. Furthermore this document reflects standing ETNO positions on Internet governance and the IGF process as such.

31 Jan, 2008

EC095 - ETNO Expert Contribution commenting on EGEA Committee “Operational Needs for Access to Emergency Services”

In this Expert Contribution, ETNO presents its comments on the document “Operational Needs for Access to Emergency Services” EGEA07 -02 v1.3, issued following the 18 December 2007 Expert Group on Emergency Access (EGEA) meeting. Detailed remarks are formulated on various paragraphs. In particular, ETNO finds that the currently non-existing video calling functions suited for sign language and lip reading as well as IP-based real time platforms should be mentioned as part of the supplementary operational needs instead of the core requirements.

31 Jan, 2008

RD274 - ETNO Reflection Document on the ERG draft Common Position on symmetry of mobile/fixed call termination rates

This is the ETNO reply to the ERG public consultation on the draft Common Position on the symmetry of mobile/fixed call termination rates. ETNO supports the principle of symmetry between FTRs and between MTRs in each country, but not between FTRs and MTRs. Furthermore, the Association thinks asymmetric TRs should disappear from regulation as fast as legally feasible.

31 Dec, 2007

RD273 - ETNO Reflection Document on a common European approach to the use of the spectrum released by the Digital Dividend

ETNO welcomes the European Commission Communication on reaping the full benefits of the digital dividend in Europe via a common approach to the use of the spectrum released by the digital switchover. ETNO believes that a spectrum sub-band for bi-directional wireless access networks should be coordinated at EU level, as proposed by the Commission.

30 Nov, 2007

RD272 - ETNO Reflection Document on the draft ERG Common Position on best practice remedies for relevant markets for “wholesale leased lines”

ETNO calls into question the “objectives” identified in the draft Common Position. It is unclear how these have been established and how they relate, in particular, to the relevant articles of the EU Access Directive.

30 Nov, 2007

RD271 - ETNO Reflection Document on the draft ERG 2008 Work Programme

ETNO looks forward to a continued interaction with ERG and hopes that in 2008 ERG adheres to high quality standards, impartiality and transparency in its work, including adequate deadlines for stakeholder consultations. ETNO encourages ERG to thoroughly review the conception of its Common Positions on remedies harmonisation and hopes the impact of technological and market developments will be fully included in its work on future regulatory challenges.

31 Oct, 2007

RD270 - ETNO Reflection Document on the Consultation Paper “Possible introduction of an optional reverse charge mechanism for VAT – Impact on businesses”

ETNO finds it is the responsibility of fiscal and law enforcement authorities to tackle VAT fraud. This responsibility should not be placed on businesses, while we furthermore consider the proposals will not effectively tackle the problem. They will create unforeseeable, substantial administrative costs for businesses that we demonstrate running into many millions of Euros for just one operator. This equally runs counter to the overall objective of reducing burdens on businesses as established in the Lisbon Strategy.

31 Oct, 2007

RD269 - ETNO Reflection Document in response to the TABD Industry Consultation on the Transatlantic Economic Council

The views in this Reflection Document were presented to TABD on 12 October 2007.

31 Oct, 2007

CP082 - ETNO Common Position on IPv4 Exhaustion

Exhaustion of IPv4 public address space is anticipated to happen in 2010. This requires urgent action by all stakeholders in order to manage the exhaust process and facilitate transition to an alternative solution. ETNO proposes a series of principles to assist in understanding selecting the most appropriate managed solutions.

28 Sep, 2007

RD268 - ETNO Reflection Document in reply to EC “Questionnaire for an EU Strategy for International Co-operation on ICT”

This ETNO Reflection Document holds the Association's 36 page reply to the European Commission questionnaire on international co-operation on ICT.

28 Sep, 2007

EC094 - Expert Contribution to the CEPT / NNA / HESC Workshop on 116 implementation

Expert Contribution with ETNO views on 116 implementation, presented at the CEPT / HESC Project Team workshop held at ERO Copenhagen on 19 September 2007.

31 Aug, 2007

RD267 - ETNO Reflection Document in reply to the consultation “Preparing for the Second Meeting of the IGF”

This Reflection Document describes how telecommunications network operators view organizational and content issues, in preparation of the next Internet Governance Forum in Rio de Janeiro in November. It has been submitted to the IGF Secretariat as ETNO input to the 3 September 2007 consultation meeting.

31 Aug, 2007

EC093 - ETNO Expert Contribution on “Proposals for additional 116 numbers to be included in the Decision following the public consultation” - COCOM07-31

The Association calls for a strict application of the selection criteria defined in the "Decision 2007/116/EC on reserving the national numbering range beginning with ‘116’".

29 Jun, 2007

RD266 - ETNO Reflection Document on ERG consultation on Regulatory Principles of NGA ERG (07)16

The Reflection Document is ETNO’s reply to the ERG Consultation Document on Regulatory Principles of NGA (ERG (07)16). The latter describes Next Generation Access roll-out and the regulatory implications stemming from FTTCab and FTTB/H scenarios, in particular adjustments to the Recommendation on relevant markets susceptible to ex-ante regulation and the EU Regulatory Framework.

29 Jun, 2007

EC092 - ETNO Expert Contribution to ECC NNA WG on Calling Line Identification Integrity

The ECC NNA WG has made some proposals to update its decision on Calling Line Identification. The purpose of this Expert Contribution is to list the issues and the concerns that ETNO has identified in relation to the justification and the content of the Decision. Unfortunately there is a lack of detailed information to support the proposed changes, and the proposed changes do not reflect a technologically neutral approach.

29 Jun, 2007

RD265 - ETNO Reflection Document on a functional separation remedy in telecoms

Functional separation on a voluntary basis – irrespective of the underlying reason – should remain the decision of individual companies. ETNO is concerned that current Commission discussions on a potentially mandatory functional separation remedy are out of touch with the realities of today’s competitive multi-platform telecommunications markets.

29 Jun, 2007

EC091 - ETNO Expert Contribution with Initial Assessment of Numbers for CHI

This ETNO Expert Contribution is a contribution to ITU-T SG2 commenting on document TD 72 Rev.1 (PLEN/2) "Report of Ad-hoc on Numbers for Childrens’ Helplines" of the February 2007 SG2 meeting.Read more

31 May, 2007

EC090 - Expert Contribution to the ITU-SG2 Correspondence Group on Child Helplines and Emergency Harmonisation, responding to proposed contribution TD CH

A paper circulated to the ITU Child Helpline and Emergency Harmonisation Correspondence Group, written by the ITU-T SG2 Chair is a proposed input paper to the next SG2 meeting. This ETNO Expert Contribution paper proposes a response submitted by the ETNO Office to the Correspondence Group, outlining certain issues and raising further questions over the source material.Read more

31 May, 2007

RD264 - ETNO Reflection Document responding to the EC Public Consultation on a proposed framework for the selection and authorisation of operators to provide Mobile Satellite Services (MSS) across Europe in the 2 GHz frequency bands

ETNO welcomes the proposed approach for a Pan-European MSS Selection and Authorisation Process at the EU level and agrees with the MRP based procedure.ETNO supports the general view that the regulatory framework to be applied to the 2GHz MSS bands must be based on principles which are demonstrably transparent, fair and non-discriminatory. ETNO takes the view that any station of the Complementary Ground Component (CGC) shall constitute an integral part of the Mobile Satellite System and shall be controlled by the satellite resource and Network Management System.

31 May, 2007

RD263 - ETNO Reflection Document on a European Common Position for WRC-07 agenda item 1.4 concerning the band 470-862 MHz

ETNO believes that the success of the development of innovative services is based on extensive cooperation between the different economic sectors involved in electronic communications and on an appropriate use of the radio spectrum resource. Therefore, ETNO urges European Administrations not to miss the opportunity to have a worldwide harmonised allocation for the Mobile Service at WRC-07 in the band 470-862 MHz for the introduction of innovative communication services.

31 May, 2007

RD262 - ETNO Reflection Document in Response to the Green Paper on the Review of Consumer Acquis

ETNO believes that DG SANCO needs to approach the exercise with care. Attention must be given to the possibility that the benefits of new one-size-fits-all measures may be outweighed by their costs. The focus should instead be on specific problems where application of Better Regulation principles shows an unambiguous case for action at EU level. In the e-commerce sector, there is a need to consider adaptation of consumers’ traditional rights to new technology in a number of areas.

31 May, 2007

RD261 - ETNO Reflection Document in response to the ITU Consultation on Resolution 102 (Rev. Antalya, 2006)

The Position Paper is a reply to the ITU consultation on Resolution 102 (Rev. Antalya, 2006): ITU’s role with regard to international public policy issues pertaining to the Internet and the management of Internet resources, including domain names and addresses.Details of the consultation are here.

31 May, 2007

RD260 - ETNO Reflection Document in response to the European Commission Questionnaire on new Free Trade Agreements

ETNO welcomes the effort of the EU Commission to launch free trade negotiations with a set of key regions and countries to the extent that they grant EU telecoms operators an additional layer of market access and juridical security to the one that might hopefully be achieved in the WTO Doha Round. The elimination of foreign equity restrictions and the ability to provide fixed and mobile telecom services, including convergent services, on an equal footing with local operators as well as transparency and regulatory predictability through full application of the Reference Paper, a better

30 Mar, 2007

CP080 - ETNO Common Position on the reuse of CCA and creosote impregnated telephone poles

In its Common Position on the reuse of CCA and creosote impregnated telephone poles” ETNO highlights the importance of harmonising their reuse and proposes to allow the re-sale of all used poles, including creosote and CCA poles. This would substantially reduce the overall amount of waste and the associated environmental burden.

30 Mar, 2007

RD259 - ETNO Reflection Document on “Baseline Security for Network Operators”

This paper presents an overview of issues that require resolution and a proposal for amendments to the text developed by the Focus Group on Baseline Security for Network Operators set up under ITU-T Study Group 17. Changes are prosposed particularly to the technical and collaboration baseline sections of the draft guidelines.

30 Mar, 2007

CP079 - ETNO Common Position on the draft “Directive on the identification and designation of European Critical Infrastructure” and the report on “Availability and Robustness of Electronic Communications Infrastructures”

ETNO welcomes the Commission’s initiatives that will lead to a common approach at EU level and better protection of ECI. The position paper highlights the importance of coherent action across all sectors and countries, the need to respect proportionality and complementarities and to create a level playing field among all operators. ETNO supports all ten recommendations proposed in the ARECI study, except number seven on standardisation that should remain an industry-lead activity.

28 Feb, 2007

RD258 - ETNO Reflection Document on review of the E-Commerce Directive

ETNO Members believe that the Directive has been a success. On the one hand, it provides a degree of legal certainty that is sufficient to encourage new investment, avoid distortions of competition and prevent barriers to the Single Market. On the other hand, its provisions are sufficiently flexible to accommodate the rapid evolution of technologies and markets. Consequently, there is no need for revision of the Directive. Indeed, in view of the scope for unintended consequences inherent in any revision attempt, such a step should be actively avoided.

28 Feb, 2007

RD257 - ETNO Reflection Document on the Audiovisual Media Services Directive proposal – Post European Parliament first reading and adoption of Council “general approach”

Following completion of the EP’s First Reading and adoption of a “General Approach” by the Council, ETNO believes that a number of issues still need be addressed in order to avoid unintended consequences and mitigate the harmful effects of the Directive’s extension to on-demand services. The definitions in Article 1 of the future Directive require particular attention.

31 Jan, 2007

RD256 - ETNO Reflection Document on the EC consultation paper on modernising the value added tax treatment of vouchers and related issues

The Position Paper focuses on changes to the way vouchers (which are prevalent in the mobile industry for consumers) are taxed, because disparate EU wide treatment means that these may be supplied in such a way that either no tax or double tax results. The EU Commission has issued a consultation paper which ETNO has contributed to, with the intent of having further dialogues with the Commission so that a sensible and pragmatic solution results.

31 Jan, 2007

RD255 - ETNO RD on the draft ERG Common Positions on "Best practice in bitstream access remedies" and "Best practice in wholesale unbundled access including shared access"

• ETNO calls into question the policy “objectives” identified in the ERG draft common positions. It is unclear how these objectives relate to the objectives and principles of the EU Regulatory Framework.• ETNO is very concerned with a number of the specific proposals for remedies to be applied on the markets for wholesale broadband access and unbundled local loops.• ETNO invites the ERG to withdraw the proposed drafts and, if at all, continue the process with new proposals.

31 Jan, 2007

RD254 - ETNO RD on the ERG consultation documents "Effective Harmonization within the European Electronic Communications Sector” and “Harmonisation – The Proposed Approach”

• ETNO believes that the implementation of the EU Regulatory Framework should follow a consistent set of principles derived directly from the EU Directives. • No one-size-fits all approach should apply with regard to regulatory measures. • ETNO is very concerned with the development of “Principles of Implementation and Best Practice” (PIBs) for individual remedies.

31 Jan, 2007

RD253 - ETNO Reflection Document on “Issues arising from discussions on Numbering Resources for Child Helpline International”

ITU signed an MoU with Child Helpline International (CHI). Subsequent activities in ITU T SG2 have raised a number of issues associated with the possible allocation of numbering resources that require clarification, if any implementation is to be successful in support of CHI.

29 Dec, 2006

RD252 - ETNO Reflection Document on the ERG IP interconnection consultation

ETNO believes it is premature to predict how points of interconnection and interconnection rates will be affected by a future NGN interconnection structure. A well-functioning interconnection market will find its own balance. The move towards NGN has the potential of removing existing bottlenecks; basic conditions to favour this are the existence of competition and the reliance on market forces. ETNO is therefore concerned about the underlying tendency to intervene on issues such as technical interfaces, protocols, technologies or QoS.

29 Dec, 2006

RD251 - ETNO Reflection Document on the ERG Broadband market competition report 2006

The ERG broadband market competition report does not attempt a robust empirical analysis of different broadband markets in the EU nor does it provide a sound economic underpinning for its assertions on the effects of regulation on broadband markets. ETNO remains greatly concerned with the ERG policy approach to broadband regulation. The ladder of investment approach as applied by ERG risks further delaying the emergence of sustainable competition and perpetuating a fragmented and inefficient market structure on European broadband markets.

30 Nov, 2006

RD250 - ETNO Reflection Document on the ERG draft Principles of Implementation and Best Practice for WACC calculation

Corrections for efficiency by a national regulatory authority (NRA) are unjustified in view of a market-driven determination of the cost of capital. Each of the discussed methodologies to calculate a divisional Weighted Average Cost of Capital (WACC) has serious drawbacks. PIBs should caution against a divisional calculation of WACC, which does not correspond to divisions of a company that already separately calculate their cost of capital.

30 Nov, 2006

RD249 - ETNO Reflection Document on the draft ERG 2007 Work Programme

ETNO welcomes the very significant improvements in the transparency of ERG work, which risks however being undermined by the blurring of IRG and ERG activity. ETNO invites the ERG and the European Commission to develop a clearer idea of what kind of harmonisation is desirable to ensure an adequate and proportionate implementation of the regulatory framework. The objectives of further ERG work on harmonisation are not clearly outlined in the Work Programme. Furthermore, work on innovative and emerging markets should be guided by a bias against intervention.

31 Oct, 2006

RD 248 - ETNO Reflection Document on the Commission Communication on a Review of the EU Regulatory Framework for electronic communications networks and services

The Reflection Document gives a detailed overview of ETNO positions on the following aspects of the 2006 E-communications regulatory Review:

31 Oct, 2006

RD247 - ETNO Reflection Document with Comments on the Commission draft Recommendation on relevant product and service markets in the electronic communications sector

The proposed draft Recommendation is over-inclusive, i.e. subjects more markets to regulation than would be justified under the 3 criteria test set up by the Commission. As a result, many markets with a more advanced market development risk being subject to inappropriate regulation, impeding investment and stronger growth in Europe. To ensure harmonised principles across the EU and safeguard against inappropriate intervention at national level, the revised Recommendation should oblige NRAs to apply the 3 criteria test on each national market prior to regulatory intervention.

31 Oct, 2006

RD246 - ETNO Reflection Document in reply to the ECC Consultation on the draft new ECC/DEC/(06)MM

ETNO supports the Decision itself with the deletion of the explanation of the term â€œdesignateâ€ in the Scope of the Decision, the removal of the WAPECS reference and the addition of a call for â€œfair competitionâ€ in the decides section.

31 Oct, 2006

EC088 - ETNO Expert Contribution on Community Framework for State aid for Research and Development and Innovation

ETNO thinks the framework requires some important adjustments. Focusing on smaller players may lead to the exclusion of whole sectors of the European economy. In particular ICT major actors could a priori not be allowed to benefit from state aid. Given the application of stringent ex ante rules for dominant players, we consider that the existence of a general interest and a market failure are necessary and sufficient conditions for granting state aid.

31 Oct, 2006

RD245 - ETNO Reflection Document in reply to the public consultation on Content Online in the Single Market

In reply to the EC consultation on Content Online, ETNO gives its opinion on aspects such as data protection, content licensing, copyright infringement, DRM interoperability, Net neutrality, cultural diversity, and DRM and rightsholder remuneration.

29 Sep, 2006

RD244 - ETNO Reflection Document on RFID

ETNO acknowledges the benefits of the RFID technology and welcomes the initiative of the EC regarding this broad consultation.Â ETNO believes that the use of radio frequencies should be harmonised to avoid interferences and thatÂ there is a need for adequate standardisation to allow interoperability. The AssociationÂ thinks there is sufficient regulation in place to deal with frequency management issues as well as with privacy issues.

31 Jul, 2006

RD243 - ETNOÂ Response to Notice of Inquiry from the U.S. Department of Commerce on the Transition of the Technical Coordination and Management of the Internet Domain Name and Addressing System

ETNO strongly supports the private multi-stakeholder model ICANN is built on. While ICANN has undertaken major improvement in order to respond to the issues and concern of its stakeholders, ETNO is confident that ICANN is maturing as an organisation to address the future and that the goal should be to transition as soon as possible to an International Organisation in its own right.

31 Jul, 2006

EC087- ETNO Expert Contribution commenting on CoCom06-24: Guidelines on implementation and roadmap for Commission Decision on reserving the number range beginning with "116" for harmonised numbers for harmonised European services.

ETNO takes note of the draft Commission Decision, as published in CoCom06-24 and finds that the decision has come a long way since it was first introduced. Although the document represents an effort to decide upon outstanding issues, as identified in earlier ETNO contributions, a number of these issues still exist that need to be resolved.

31 Jul, 2006

EC086 - ETNO Expert Contribution on the introduction of Multimedia Services in particular in the frequency bands allocated to the broadcasting service â€“ RSPG Opinion

ETNO supports the ideas proposed by RSPG to facilitate the introduction of multimedia services in the European Union. A coherent authorisation scheme, ensuring competition on a level playing field needs to be implemented. Harmonised use of broadcasting frequencies at the European level should be favoured.

31 Jul, 2006

RD242 - ETNO Reflection Document on the Strategic Development of ITU

This ETNO Reflection Document on the strategic development of ITU focuses on the following four main missions of the Union:

30 Jun, 2006

RD241 - ETNO Reflection Document on draft ECC Decision on the designation of the bands 880-915 MHz, 925 960 MHz, 1710-1785 MHz and 1805-1880 MHz for terrestrial IMT-2000/UMTS systems

ECC PT1 started to work on a draft ECC Decision on the designation of the bands 880-915 MHz, 925-960 MHz, 1710-1785 MHz and 1805-1880 MHz for terrestrial IMT-2000/UMTS systems.ETNO expects UMTS/IMT-2000 deployment in GSM bands from the year 2007 in some countries and therefore supports a timely completion of the work on this draft ECC Decision.

30 Jun, 2006

RD240 - ETNO Reflection Document as an input to a future European Commission Communication on SPAM

ETNO members are fully committed to develop active measures to combat unsolicited commercial communications (spam). ISPs and network operators are focusing on awareness raising, technical measures like filtering and the use of various kinds of lists.Â ETNO believes that a consistent and co-ordinated approach by all stakeholders involved (private and public) at the international level is needed.

31 May, 2006

EC085 - ETNO Expert Contribution on â€œDraft ECC Report 86 â€“ Draft Report on Consumer Abuses and Fraud Issues relating to High Tariff Services

ETNO supports the intent of the ECC Report but by making both general and detailed comments, it seeks to demonstrate that other actions are required to address abuse and fraud. There are omissions from the Report that need to be addressed for it to be comprehensive and complete. Not enough is made of the role of revenue sharing or the lack of an appropriate regime that high tariffs numbers exist in.

31 May, 2006

EC084 - ETNO Expert Contribution on â€œDraft ECC Report 87 - The future of numbering

The European Telecommunications Network Operators' Association (ETNO) has carefully reviewed the Draft ECC Report 87 â€œThe future of numberingâ€.The purpose of this Report is unclear. Its scope is restricted to the â€œfuture of E.164 numberingâ€, but does not take much into account new services. For most of the countries the Report does not take into account the technical problems industry could face when implementing the scenarios depicted to route the calls, charge the calls and negotiate interconnection agreements.

31 May, 2006

EC083 - ETNO Expert Contribution on draft decision ECC /DEC/(06)EE on the harmonised conditions for devices using Ultra-Wideband (UWB) technology in the frequency band 3.1 â€“ 4.8 GHz

Interested parties have been invited to comment on draft ECC/DEC/(06)EE. In particular views are requested on a possible phased approach in the band 4.2 â€“ 4.8 GHz without mitigation techniques. ETNO has a strong preference for not allowing devices to be operated temporarily without mitigation techniques (on a phased basis). Instead, ETNO recommends permitting only those devices which have implemented mitigation techniques such as DAA.

31 May, 2006

EC082 - ETNO Expert Contribution on the harmonised use of radio spectrum by equipment using ultra-wideband (UWB) technology in the European Union

ETNO supports the technical requirements contained in ECC/DEC/(06)04, which enable the harmonised long-term introduction of UWB devices in Europe while ensuring adequate protection of existing radio services from harmful interference. ETNO is equally in favour of their replication in a European Commission Decision pursuant to the Radio Spectrum Decision in order to implement these conditions within the EU single market.

28 Apr, 2006

RD239 - ETNO Reflection Document on the draft WIPO Treaty on the Protection of Broadcasting Organisations

ETNO Members share serious concerns regarding the draft Treaty which are linked to the documentâ€™s failure adequately to distinguish different technologies. In order to guarantee a technology-neutral approach, the text needs to be revised so that closed telecoms networks are clearly covered.

28 Apr, 2006

RD238 - ETNO Reflection Document on Â« Net neutrality Â» in the US - framing the debate

The purpose of this document is to clarify the â€œnet neutralityâ€ debate that has recently taken place in the US.

31 Mar, 2006

EC081 - ETNO Expert Contribution in response to the â€œStudy on collective use of spectrumâ€ performed by a consortium of behalf of the European Commission

Based on its Members' responsibilties, ETNO thinks a â€œcollective useâ€ of spectrum should be limited to some bands and technologies to remain manageable with regard to QoS and interference and the effective use of spectrum.

31 Mar, 2006

EC080 - ETNO Expert Contribution on the â€œInternet Assigned Numbers Authority (IANA) policy for allocation of IPv6 blocks to Regional Internet Registriesâ€

ETNO supports the proposed global â€œInternet Assigned Numbers Authority (IANA) policy for allocation of IPv6 blocks to Regional Internet Registriesâ€ and welcomes the open and transparent process used in the development of this proposal.Read more

31 Mar, 2006

RD237 - ETNO Reflection Document on the Communication from the Commission to the Council and the European Parliament on the Review of the Sustainable Development Strategy

ETNO welcomes the Communication from the Commission on the review of the European Sustainable Development Strategy, in which a number of key actions are proposed for the coming years.Â The Association broadly supports the document.

28 Feb, 2006

EC079 - ETNO Expert Contribution to the Film on Line project â€“ follow up of the Enlarged Meeting on Film on Line, January 13, 2006

The Association strongly supports increased collaboration between all stakeholders as illustrated by its workshop: "Any content, any platform, any time, anywhere" (March 2005).Â However, development of a dialogue and identification of common solutions requires a balanced approach which takes the interests of all concerned parties carefully into account. Against this background, the paper provides comments on the three following areas covered by the EU project: co-operation to fight piracy, improving the ability of Film on Line, and Content on Line.

31 Jan, 2006

RD236 - ETNO Reflection Document in reply to the European Commission call for input - Recommendation on relevant markets

The Recommendation is a key instrument of the EU Regulatory Framework for enabling the Commission to guide the transition of the e-communications sector towards the increasing application of general competition law. As the Commission was largely bound by an Annex to the EU Framework Directive in the choice of market areas to be included in the first list of relevant markets, the current review provides the first objective assessment of the remaining need for ex-ante intervention in the European e-communications sector.

31 Jan, 2006

RD235 - ETNO Reflection Document - ETNO contribution to the 2006 Review

ETNO believes that a thorough â€˜root and branchâ€™ review of the current EU telecoms regulatory policy is necessary to deliver the optimal regulatory conditions for a period of time that will reach beyond 2010. The electronic communications sector is undergoing unprecedented challenges globally, requiring innovative firms accelerated capacity to adapt to these challenges. The current system providing inefficient incentives and assistance to market players needs to come to an end in Europe.

31 Jan, 2006

RD234 - ETNO Reflection Document in response to the call for input on the forthcoming review of the EU regulatory framework for electronic communications and services (Radio Spectrum aspects)

ETNO considers that significant changes to the current regulatory framework â€“ i.e. the Framework Directive, Authorisation Directive and the Radio Spectrum Decision â€“ are not necessary. The objectives established by the Radio Spectrum Decision are considered relevant. Regarding institutional aspects, the collaboration between RSC, ECC and ETSI provides an appropriate basis to deal with the various spectrum issues of interest for Europe.

31 Jan, 2006

RD233 - ETNO Reflection Document on the revised draft ERG Common Position on the approach to appropriate remedies in the ECNS regulatory framework

The revisions to the CP as proposed by ERG in the present consultation will in ETNOâ€™s view not contribute to a more focussed, proportionate and consistent regulatory approach to remedies under the NRF. Whatever the final outcome of the current ERG consultation, ETNO calls on the European Commission, national policy makers and individual NRAs to continue to actively address the issue of the application of proportionate remedies under the NRF.

31 Jan, 2006

RD232 - ETNO Reflection Document on the EC Green Paper on a European Programme for critical infrastructure protection

ETNO supports this initiative and favours an all hazards scope, with an emphasis on terrorism in the first phase. ETNO would wish an EU approach to be limited primarily to establishing best practice guidelines, sector by sector. This best practice should aim at a harmonization of recovery objectives and prioritization for services recovery. It will be telecommunications operatorâ€™s sole decision which protection measures and business continuity plans they will implement to reach the guidelines objectives.

31 Jan, 2006

EC078 - ETNO Expert Contribution commenting on draft ECC/REC/(05)09 â€“ Customer Protection in case of misuse of international E.164 Resources

The Expert Contribution contains ETNO comments on ECC draft Recommendation (05)09 on the customer protection in case of misuse of international E.164 resources.Â The Association has doubts concerning the effectiveness of the proposed Early Alert System (EAS).

30 Dec, 2005

December 2005 EC077 - ETNO Expert Contribution on GSM onboard aircraft (GSMOB aircraft)

ETNO generally supports the possibility to facilitate the use of mobile handsets onboard aircraft, but considers that a number of issues need to be solved before an introduction of GSMOB aircraft can take place.

30 Dec, 2005

EC076 - ETNO Expert Contribution in response to the public consultation on draft ECC Report 80 - Enhancing harmonisation and introducing flexibility in the spectrum regulatory framework

ETNO welcomes the draft ECC Report 80. ETNO takes the view that â€œFlexibilityâ€ should be considered in a broader way and that the â€œInterrelation between harmonisation and flexibilityâ€ is more complex than stated in the draft ECC Report.

02 Dec, 2005

December 2005 RD231 - ETNO Reflection Document in response to the ERO Questionnaire on the use of the former TFTS bands in Europe

The European Telecommunications Network Operators' Association (ETNO)Â proposes to designate the upper part (1800 - 1805 MHz) of the former Terrestrial Flight Telecommunications System (TFTS) band to UMTS/IMT-2000.

01 Dec, 2005

RD230 - ETNO Reflection Document on the draft Directive on criminal measures aimed at ensuring the enforcement of intellectual property rights and the draft Decision to strengthen the criminal law framework to combat intellectual property offences

While endorsing better enforcement of intellectual property rights as a general aim, ETNO argues that the Commissionâ€™s proposals will have unintended consequences in a number of areas. Particular concern is expressed about the application of criminal sanctions to patent violations, and the potential criminalisation of technologies and services with both lawful and unlawful uses.

25 Nov, 2005

November 2005 RD229 - ETNO Reflection Document on Best Common Practice for Numbering Misuse ProtectionÂ

The European Telecommunications Network Operatorsâ€™ Association (ETNO) supports Study Group 2 chairman's proposal in developing guidelines for Member States and Sector Members to combat misuse.

31 Oct, 2005

October 2005 EC075 - ETNO Expert Contribution on Data retention in e-communications - Councilâ€™s Draft Framework Decision, Commissionâ€™s Proposal for a Directive

This document analyses some of the most relevant technical aspects involving the impact that the implementation of a generalised data retention obligation would have for ETNO companies as e-communications services providers.Read more

31 Oct, 2005

October 2005 RD228 - ETNO Reflection Document on the draft ERG 2006 Work ProgrammeÂ

Transparency should remain a key issue for the work of the ERG in 2006. ETNO welcomes increased efforts by ERG decision makers to engage in a dialogue with market players. ETNO invites the ERG to identify deregulation as a priority for its work in 2006.

30 Sep, 2005

September 2005 RD223 -Â ETNO Reflection Document on the impact of a Commission Decision for the 2.6 GHz bandÂ

In ETNOs view the designation of the 2.6 GHz band to IMT-2000/UMTS has positive impacts on the competition in the internal market, the EU competitiveness compared with other regions, on R&D, on consumers, and on employment and the labour market. ETNO agrees that a Commission Decision for the 2.6 GHz band would give a clearer sign to industry, users and regulators.

30 Sep, 2005

RD222 -Â ETNO Reflection Document in response to the public consultation on Wireless Access Platforms for Electronic Communications Services (WAPECS)Â

The present regulatory framework for radio spectrum management enabled pan-European development of high quality radio communication services in terms of service availability, network interoperability, free equipment circulation and economies of scale for the benefit for all parties involved, i.e. manufacturers, network operators, service and content providers, and last but not least end customers.

30 Sep, 2005

RD221 - ETNO Reflection Document summarising ETNOs views on the 7th Framework Programme proposals

The paper expresses ETNOâ€™s views in relation to the 7th Framework Programme (FP7) preparation. The separation of objectives between Cooperation (the most important and driver behind the others), Ideas, People and Capacities is considered positive. In terms of budget, resource allocation to IST in FP7 should be in line with these objectives, and tend towards 25 % of the Framework Programme.

30 Sep, 2005

EC074 - ETNO Expert Contribution commenting on Commission Issue Papers in preparation of the review of the TVWF Directive

The Expert Contribution contains ETNO comments on Television without FrontiersÂ Issue Papers 1, 3, 4 and 5. On the rulesÂ applicable to the audiovisual content services, ETNO is concerned about the legal uncertainty that may arise as a result of the review of the Directive, at the very moment when the ICT sector is fully engaged in rolling-out new value-added broadband services.The Expert Contribution contains ETNO comments on TVWF Issue Papers 1, 3, 4 and 5.

27 Sep, 2005

September 2005 RD227- ETNO Reflection Document on re-assessing the "ladder of investment" in the context of broadband access regulationÂ

ETNO is greatly concerned with the current ERG approach to broadband regulation as laid out in its "Broadband market competition report" [ERG(05)23], based on the ladder of investment concept. ETNO contests that such approach could ensure adequate incentives for investment in infrastructure and that the ladder of investment, in particular as currently interpreted by the ERG, is a suitable means to promote sustainable competition in todayâ€™s broadband markets.Â Â

16 Sep, 2005

September 2005 RD226 - ETNO Reflection Document on the report of the Working Group on Internet Governance

ETNO finds the definition of Internet Governance adopted by the Working Group is appropriate. ETNO shares the views that further international dialogue and cooperation must be encouraged for aspects linked to the security of the Internet, cybercrime, and spam. In ETNOâ€™s view necessary investments in infrastructure, applications and services must be supported by a positive, market-driven approach.Â

16 Sep, 2005

September 2005 RD225 - ETNO Reflection Document on the European Commissionâ€™s Public Consultation on the Digital Divide

Widespread availability of broadband access is a worthy political, social and economic objective, and ETNO believes that broadband development offers advantages well beyond the Information Society sector.

15 Sep, 2005

September 2005Â RD224 - ETNO Reflection Document on the European Commissionâ€™s Communication "i2010 - A European Information Society for growth and employment"

ETNO welcomes the new Commission strategy for the sector because it is both an ambitious and comprehensive plan. ETNO feels that the new i2010 initiative is an opportunity to undertake concrete policy initiatives to develop the long-term sustainability of the industry and its contribution to European competitiveness and welfare.

31 Aug, 2005

CP077 -Â ETNO Common Position on the draft Commission Decision on reserving the 116 number rangeÂ

ETNO provides operators views to be taken into consideration concerning the draft Commission Decision on reserving the number range beginning with 116 for harmonised numbers for harmonised European services, as stated in working document CoCom05-25.

31 Aug, 2005

EC073 - ETNO Expert Contribution on Cross-border access to non-geographic shared cost numbers (CoCom05-24)

COCOM05-24, raises a number of issues regarding "cross-border access to non-geographic shared cost numbers in the EU". ETNO believes that there are issues that need to be addressed before further progress can be made.

31 Aug, 2005

CP078 - ETNO Common Position on Freephone services in Europe - follow up (CoCom05-23)

ETNO provides operatorsâ€™ views on the CoCom follow-up document on freephone services in Europe (document CoCom05-23).ETNO provides operatorsâ€™ views on the CoCom follow-up document on freephone services in Europe - document CoCom05-23. ETNO welcomes the views taken in this document and shares the positions being expressed. Some issues still exist that need to be addressed before implementation can occur. These issues are explained in this Common Position.

31 Aug, 2005

RD220 - ETNO Reflection Document on the Communication on Global Partnership in the Information Society: EU Contribution to second Phase of WSIS

WSIS objectives must remain in line with present and prospective market realities, in order not to destabilize the development of the Internet. WSIS orientations should favour productivity, sustainable growth, investment and innovation. ETNO finds it would be counter productive to reopen issues settled during the first phase of the Summit.

12 Aug, 2005

EC072 - ETNO Expert Contribution on CEPT/ECC report 70 on Services based on HESC

ETNO provides operatorsâ€™ views to be taken into consideration concerning the CEPT/ECC report number 70 about services based on HESC.

30 Jun, 2005

ETNO Common Position CP076 on misuse of E.212

ETNO recognises that strict adherence to E.212 principles identifies the country and the network of the customer and rejects the use of foreign MCC/MNCs. This should be preferred as the primary way to resolve the issue of usage of E.212 codes.

30 Jun, 2005

JUNE 2005Â RD218 - ETNO Reflection Document on principles for the 11th Implementation Report

ETNO welcomes the Commissionâ€™s yearly Implementation ReportÂ as a comprehensive and valuable source of information on EU communications markets.Â ETNO believes that the forthcoming 11th Report should be drafted in a most transparent manner in order to generate an outcome which is as sound and reliable as possible.Â

30 Jun, 2005

RD217 - ETNO Reflection Document on the revision of the Television without Frontiers Directive

In ETNO's view, the review of the TV without Frontiers Directive should not extend into an all-encompassing content regulation.The key criterion for regulation should be the degree of userâ€™s control as opposed to publisher control. Many of the obligations found in the current Directive are justified by reference to the user's lack of control in the context of traditional broadcasting.Â Consequently, future obligations should remain limited to services which are characterised by a similar lack of control (broadcasting services).

09 Jun, 2005

MAY 2005 EC070 - ETNO Expert Contribution on Harmonisation and Flexibility in the context of radio spectrum management

ETNO considers the standardisation of radiocommunication equipment and the harmonisation of radio spectrum as the basis for a successful development and placing on the market.Nevertheless, a more flexible use of radio spectrum could facilitate a more efficient radio spectrum use. ETNO takes the view that sufficient experience has to be gained before appropriate regulation modifications can take place and favours a careful and progressive approach. The EC and the CEPT should be involved in order to adopt a common approach in the end.

31 May, 2005

EC071 - ETNO Expert Contribution on 116 and Freephone Services.

The European Commission's submission to the April 2005 CoCom Committee (document 05-08) was intended to provide an update concerning two specific areas, 116 and cross-border freephone.In reviewing the paper, ETNO's Numbering Experts working group identified many issues with regard to the approach that the European Commission indicated.Â This paper identifies many of these issues and recognises that it is only through a continuous dialogue with all industry parties that successful, commercially viable solutions will be reached.

04 May, 2005

RD216 - ETNO Reflection Document on the future use of the band 2010-2020 MHzÂ

The band should remain designated1 to UMTS/IMT-2000, with flexibility regarding TDD and FDD operation. In the case of FDD operation, pairing with the 2.6 GHz extension band, the former upper TFTS band 1800-1805 MHz and the lower TDD core band 1900-1920 MHz should be considered.

12 Apr, 2005

EC069 - ETNO Expert Contribution - Response to Questions asked by EEC NNA PT HESC

This expert contribution addresses questions, as risen by ECC NNA HESC, concerning issues related to the use of the 116 number as number for freephone services for significant public interest. As many questions and issues remain, this contribution should be considered as a first step in clarification concerning the harmonised use of 116 as freephone service.

31 Mar, 2005

RD215 - ETNO Reflection Document on EC consultation: VAT - The place of supply of services to non-taxable persons

The EU Commission has in 2004 made proposals for the place of supply rules for VAT purposes to be amended for B2B transactions, and has recently made similar proposals for B2C transactions.

31 Mar, 2005

RD214 - ETNO Reflection Document on the ERG consultation on Wholesale Broadband Access via Cable

ETNO welcomes the ERG consultation on Wholesale Broadband Access via Cable.

31 Mar, 2005

RD213 - ETNO RD on article 29 WG working document on data protection issues relating to IPR

ETNO presents its views on the Art. 29 working document taking account of the need for clarification of the application of data protection principles in the field of DRM and enforcement of copyright.

18 Mar, 2005

EC068 - ETNO Expert Contribution on emission masks for generic Ultra-Wide Band (UWB) applications

As already stated in earlier position papers, ETNO considers the adequate protection of radio services of prior importance concerning the introduction of generic UWB applications.In order to allow suitable UWB emission limits, ETNO suggests to distinguish between the kinds of UWB applications, the data rates and also to take into account mitigation techniques (e.g. indoor usage, duty cycle, etc.). ETNO proposes a possible set of emission masks for UWB communication applications in the frequency range 3.1-10.6 GHz.

04 Mar, 2005

EC067 - ETNO Expert Contribution commenting on the Commission's initial criteria for revising the list of standardsÂ

ETNO agrees that the list of standards needs revision to be short and focussed. ETNO finds that the general approach taken by the Commission and a number of the proposed criteria are reasonable.
The criteria need however clarification and amendments to create a flexible framework for standardisation and to avoid interference with commercially driven standards.

12 Feb, 2005

RD211 - ETNO Reflection Document on the FCC Notice of Inquiry on Mobile Termination Charges (FCC 04-247, IB Docket No. 04-398 in the Matter of the Effect of Foreign Mobile Termination Rates On U.S. Customers)

ETNO shares the view of the majority of stakeholders replying to this consultation that there is no rationale for the Federal Communications Commissionâ€™s (FCC) intervention concerning foreign mobile termination rates.

31 Jan, 2005

CP075 - ETNO Common Position on ITU-TSB proposal for the future administration of IPv6 addresses

ETNO believes that the current rules and organisation for IPv4 and IPv6 address management by the private sector is to be maintained, above all to guarantee the most appropriate technical operation and economic savings.

26 Jan, 2005

EC066 - ETNO Expert Contribution on the ECC PT7 proposal for categorisation of frequency bands

ETNO considers the four categories of frequency bands currently under consideration in ECC to be useful.

16 Jan, 2005

RD210 - ETNO Reflection Document commenting on the ERG Working Paper on the SMP concept

We welcome the ERG's effort in its Working Paper (WP) to interpret and harmonise the use of this concept so it better meets the actual state of competition in the relevant markets. ETNO is not convinced that the ERG Working Paper on SMP adds much value to the Commission Guidelines on SMP.

16 Jan, 2005

RD209 - ETNO Reflection Document on the proposed European Regulators Group Work Programme 2005

ETNO welcomes the more focussed approach of the ERG's Work Programme for 2005 compared to last yearâ€™s.

14 Jan, 2005

RD208 - ETNO Reflection Document on the European Commission Document on the draft Directive on the New Legal Framework for Payments in the Internal Market Version 5.0 (26/11/04)

ETNO is grateful to the European Commission for the opportunity to follow the debate on the New Legal Framework for Payments in the Internal Market within the Payment Systems Market Group and being able to provide comments on the last version on the future Directive.

14 Jan, 2005

RD207 - ETNO Reflection Document on the European Commission Communication on Challenges for the European Information Society beyond 2005

ETNO welcomes the opportunity to provide the European Commission with its views on the future of the Information Society policy beyond 2005.

24 Dec, 2004

RD206 - ETNO Reflection Document in response to DG External Relations' Consultation "Strengthening the EU-US Economic Partnership"

ETNO welcomes the European Commission's consultation on EU-US Economic Partnership.

23 Dec, 2004

RD205 - ETNO Reflection Document commenting on the "Draft ECC Decision on harmonised utilisation of spectrum for IMT-2000/UMTS systems operating within the band 2500 - 2690 MHz" (ECC/DEC/(05)XX)

ETNO supports the adoption of the â€œdraft ECC Decision on harmonised utilisation of spectrum for IMT-2000/UMTS systems operating within the band 2500 - 2690 MHzâ€ as it provides confidence for manufacturers and operators to make the necessary investments and also strengthens the CEPT position on WRC-2007 agenda item 1.9 regarding the protection of terrestrial services against harmful interference from satellite operations outside Europe.Read more

14 Dec, 2004

RD204 - ETNO Reflection Document commenting on the "First annual report on radio spectrum policy in the European Union" (COM(2004) 507)

ETNO is in favour of evolutions in radio spectrum management with the potential to improve its usability for operators and users and welcomes the Commissionsâ€™ cooperation with CEPT on this subject.

14 Dec, 2004

RD203 - ETNO Reflection Document commenting on Auctions and Beauty Contests

ETNO provides operators views to be inserted into the draft ECC Report on Auctions and Beauty Contest.

14 Dec, 2004

RD202 - ETNO Reflection Document on Content-related issues

ETNO is eager to express its views on several content-related issues from a telecom sector perspective i.e. against the background of new business models and distribution channels enabled by convergence and the development of broadband. In order to facilitate the flow of legitimate on-line content and thus the development of a strong broadband industry across Europe.

02 Nov, 2004

RD201 - ETNO Reflection Document on Copyright Review

ETNO agrees that only minor adjustments are necessary to ensure the consistency of the existing legislation. The Association fully endorses the Commissionâ€™s analysis where the alignment of the Software and Database Directives with Article 5(1) of the Information Society Directive is concerned, in order to provide intermediaries with greater legal certainty.

18 Oct, 2004

RD200 - ETNO Reflection Document on COM(2004)353 "Science and technology, the key to Europe's future - Guidelines for the future European Union policy to support research"

The general guidelines and objectives provided in the European Commission document are largely shared by ETNO. The involvement of the main participants - Industry, Manufacturers and Service Providers - is indeed essential. European competitiveness is a key objective for the industry and therefore our sector must play a leading role in defining the agenda. Industryâ€™s involvement should be used to help steer the collaborative programmes.

28 Sep, 2004

EC065 - ETNO Expert Contribution commenting on Draft ECC/DEC/(04)LL

ETNO's preferred solution would be an introduction of Short Range Radars in the 79 GHz range right from the beginning because its member companies operate a significant number of fixed service links in the frequency bands intended to be covered also by automotive Short Range Radars at 24 GHz.

16 Sep, 2004

RD199 - ETNO Reflection Document on ECC Recommendation (04)07 on designation of 116 number range for possible future harmonized European short numbers

ETNO has considered the Recommendation adopted by the Working Group â€œNumbering, Naming and Addressingâ€ to designate where possible the number range beginning with 116 for future harmonized European services.ETNO strongly recommends that before further decisions on the use of 116 are considered, European industry wide consultations should be undertaken.

15 Sep, 2004

EC064 - ETNO Expert Contribution on AD ratio for IPv4 addresses allocation

ETNO has considered the proposal to replace the fixed utilisation criteria of 80% in IPv4 address space allocation, by a criteria based on AD (Assignment Density) ratio. ETNO strongly support the proposal and suggest selecting an AD ratio of 0.966.ETNO further suggest to the RIRs to monitor the impact of this measure on address consumption and periodically report on it to the addressing community.

15 Sep, 2004

EC063 - ETNO Expert Contribution with respect to the "Study on conditions and options in introducing secondary trading of radio spectrum in the European Community"

Following the invitation from the European Commission, ETNO is pleased to provide some views on the study from Analysys, DotEcon, Hartson & Hogan related to spectrum trading presented during the Workshop on 15 July 2004. Besides giving general remarks concerning the recommendations in the study and their appropriateness for Europe, ETNO comments on two particular aspects: interference management and bands/services suitable for spectrum trading

14 Sep, 2004

RD198 - ETNO Reflection Document on Traffic Data Retention

ETNO is seriously concerned over new proposal for a Council Framework Decision re-opening the debate on data retention tabled by four Member States on 28 April 2004. The proposal entails unpredictable financial and confidentiality implications for industry and individual users.

31 Aug, 2004

RD197 - ETNO Reflection Document on the Commission's Consultation Document on VoIP

For ETNO it is essential that the regulatory treatment of the various VoIP services reflects in a harmonised way across the EU the characteristics of each specific service, so that innovation and service development are pro-moted but also so that no regulatory arbitrage vis-Ã -vis regulated PATS (publicly available telephone services) is possible e.g. regarding intercon-nection, number allocation and service obligations.

29 Jul, 2004

RD196 - ETNO Reflection Document in response to the Questionnaire for industry prepared by IDATE, AEGIS and BIRD & BIRD on behalf of the European Commission on availability of information on radio spectrum in the European Union.

ETNO would like to summarize its views regarding the availability of spectrum information...As follows:

20 Jul, 2004

RD195 - ETNO Reflection Document on the European Commission Consultation Paper on the application of the E-money Directive to mobile operators

The tentative conclusion that "e-value stored on mobile phone pre-paid cards that is used to pay third party products and services is indeed likely to be e-money" seriously concerns ETNO members, many of which have leading European mobile affiliates.

28 Jun, 2004

RD194 - ETNO Reflection Document on IST Work Programme 2005 / 2006

To select successful IST projects that will have a good uptake and downstream deployment of their results, ETNO believes that the appropriate involvement of major sector players is essential. The research ambitions of major European IST sector players are not adequately represented in the Integrated Project (IP) evaluation process.

22 Jun, 2004

RD193 - ETNO Reflection Document on the European Commission Communication on the Management of Copyright and Related Rights in the Internal Market

ETNO presents its views on the Commission Communication taking account of the need for more high-quality content to attract users to broadband networks and stimulate the development of e-Europe. Regarding collective rights management, the Association underlines the need to end the legal and de facto monopolies enjoyed by EU collecting societies so that rights acquisition for on-line services can be made less time-consuming, complex and expensive.

18 Jun, 2004

RD192 - ETNO Reflection Document in response to the ECC WG FM Questionnaire on the use of the former TFTS bands in Europe

ETNO proposes to designate the upper part (1800 - 1805 MHz) of the former TFTS band to UMTS/IMT-2000. This proposal is consistent with the Commission policy goals regarding the Information Society and fosters global harmonisation as this band is already identified for IMT-2000 in the ITU-R Radio Regulations. The use of the lower part of the former Terrestrial Flight Telecommunications System TFTS band (1670 - 1675 MHz) for the Mobile Satellite Service (MSS) according the WRC-03 results is supported.

07 Jun, 2004

RD190 - ETNO Reflection Document on Market Analysis Procedures in Accession Countries

ETNO continues to fully subscribe to the concept of harmonisation throughout Europe and finds that the New Regulatory Framework (NRF) should be applied equally in Accession Countries (AC) and EU15 countries.

24 May, 2004

EC062 - ETNO Expert Contribution in response to the Consultation to develop an RSPG Opinion on World Radiocommunication Conference 2007

ETNO is pleased to provide its early views on agenda items and strategies for the next World Radiocommunication Conference in 2007. Positions expressed at this early stage of the WRC-07 preparation are subject to further refinement. From the network operatorsâ€™ point of view, the WRC-07 agenda items related to spectrum for the Mobile Service, i.e. UMTS/IMT-2000 and systems beyond, are the crucial ones.

20 May, 2004

EC061 - ETNO Expert Contribution on radio spectrum designation for Ultra Wide Band applications

ETNO Members operate a significant number of radio services within the frequency ranges currently under study in ITU and CEPT for the deployment of Ultra-Wideband (UWB) applications. These radio networks embody significant investments of network operators, but also from citizens using the corresponding terminal equipment.

29 Apr, 2004

CP074 - ETNO Common Position on the sponsored Top Level Domain applications for .tel

ETNO has serious reservations about the .tel and .Tel sTLDs proposed to ICANN.

22 Apr, 2004

EC060 - ETNO Expert Contribution on 24 GHz Short Range Radars penetration rate and cut-off date

ETNO Members operate a significant number of fixed service links in frequency bands also intended to be used by automotive Short Range Radars at 24 GHz.Therefore, ETNO is in favour of an introduction of Short Range Radar technologies in the 79 GHz range right from the beginning. However, in the light of a compromise solution, ETNO could go along with the SRD/MG proposal A, i.e. a maximum penetration rate of 5.9% and 2010 as the cut-off date for 24 GHz Short Range Radars.

20 Apr, 2004

RD189 - ETNO Reflection Document on Unsolicited Commercial Communications (SPAM)

ETNO members are fully committed to develop active measures to combat unsolicited commercial communications (spam). Telecom operators are focusing their efforts on awareness raising, technical measures like filtering and the use of various kinds of lists.ETNO believes that public authorities (EC, OECDâ€¦) can play an important role in co-ordinating and harmonising the implementation and use of reliable black lists.

31 Mar, 2004

RD188 - ETNO Reflection Document in response to RSPG's public consultation on secondary trading of rights to use radio spectrum

ETNO believes that the current spectrum management regime already allows the orderly introduction of necessary adaptations with regard to radio spectrum user needs. However, the introduction of spectrum trading could offer additional incentives, in particular concerning the flexible use of radio spectrum.

30 Mar, 2004

RD187 - ETNO Reflection Document commenting on possible revision of the Commission Recommendation on the provision of leased lines in the European Union, Part II â€“ Pricing of wholesale leased line part circuits

ETNO operators are concerned with the proposed recommendation for several reasons: (1) When remedy price control is needed the Recommendation and the use of benchmarks may in practice replace the application of targeted 'cost orientation' obligations based on a specific market analysis which has to follow under the new regulatory framework.

30 Mar, 2004

RD186 - ETNO Reflection Document commenting on the possible revision of the Commission Decision on the minimum set of leased lines

ETNO finds that the minimum set of leased lines which constitutes one of the Recommendation's relevant markets (and several sub-markets) does not match the overall principle of technology neutrality. Some of the leased lines types (analogue) of the minimum set put an undue burden on operators and may prevent development of markets and technology.

08 Mar, 2004

EC059 - ETNO Expert Contribution on ECC draft Decision on ETNS Conventions

ETNO has studied the draft ECC Decision on European Telephony Numbering Space (ETNS) Conventions â€“ document ENF362.

30 Jan, 2004

EC058 - ETNO Expert Contribution on the Commission Mandate to CEPT on 5 GHz RLANs

ETNO supports the Mandate given to CEPT concerning Radio Local Area Networks (RLANs) within the 5 GHz band as this harmonisation will enhance spectrum efficiency, user acceptance and consequently RLAN development in general. ETNO is happy the Commission took this initiative in light of the outcome of WRC-03.Read more

19 Jan, 2004

RD185 - ETNO Reflection Document on Consultation Document: Draft Joint ERG/EC Approach to Appropriate Remedies in the New Regulatory Framework

ETNO is concerned with the joint ERG/EC Consultation document on remedies, since the chosen approach remains by and large theoretical and is not linked to many of the real issues governing the telecommunications market. The documentâ€™s focus is largely on a "behavioural approach".

09 Jan, 2004

CP073 - ETNO Common Position commenting on the Work Programme of the Radio Spectrum Policy Group (RSPG)

ETNO considers the proposed 17-point RSPG Work Programme to be complete, requiring no additional points. This paper offers comments on each of the work items, paying particular attention to wireless access platforms, convergence with digital broadcasting and spectrum trading. ETNO has a strong interest in RSPG work and is looking forward to a close cooperation with the group in the future.