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.

Therefore at least types of leased lines linked to a particular type of infrastructure such as analogue leased lines should be removed. In the market place leased lines are replaced by other and more flexible types of transmission capacity services. ETNO therefore sees no justification for amending the minimum set with further types of leased lines.