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.
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.
- The ERG broadband market competition report bases itself mainly on an empirical analysis of different broadband markets in the EU. Yet, the report does not attempt a robust empirical analysis of data from these markets nor does it provide a sound economic underpinning for its assertions on the effects of regulation on broadband markets. It is characterised by a patchy analysis of existing data, contestable underlying assumptions and partly subjective conclusions from the presented evidence, which do not respond to the regulatory challenges in today’s broadband markets - in particular, as differences in quality /capacity of broadband offers are not considered. This makes it an inappropriate basis for a regulatory policy on EU broadband markets.
- ETNO remains greatly concerned with the ERG policy approach to broadband regulation reflected in the draft report and previous ERG documents. 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.
- ETNO reiterates its proposal for an alternative approach to broadband regulation based on an economic rationale, as submitted to ERG in previous contributions.