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.

• BEREC plays an important role in ensuring a consistent and sound regulatory regime for the telecoms sector in Europe. As such, BEREC’s annual work programme should be relevant and focused on a set of core issues.
• The electronic communications sector continues to face pressure on revenues that increasingly restrict its network investment capacity. BEREC’s work in 2013 should primarily focus on creating a stable regulatory framework that incentivises private investment in high-speed broadband networks.
• Against this background, ETNO welcomes the explicit objective of the draft work programme to boost the roll-out of next generation access networks (NGA). ETNO has equally supported the initiative of BEREC’s 2012 Chairman for a high-level dialogue with stakeholders on how to improve the EU investment climate. ETNO would like to see a concrete implementation of these objectives in the 2013 work programme and its specific work streams.
  
• BEREC and the European Commission should cooperate to ensure the stability and clarity of regulatory guidance at EU level. For example, BEREC’s recent consultations on Draft Common Positions on Best Practices for Markets 4, 5 and 6 lacked relevance and clarity due to a lack of alignment with ongoing Commission work.