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.

• ETNO calls into question the policy “objectives” identified in the ERG draft common positions. It is unclear how these objectives have been established and how they relate to the objectives and principles of the EU Regulatory Framework for electronic communications and to the relevant articles of the EU Access Directive in particular. 
• 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. There is a lack of economic analysis of the possible conditions of competition, including the interaction between remedies on different wholesale markets and of the effects of the proposed remedies on competition and investment in the field of broadband.
• ETNO invites the ERG to withdraw the proposed drafts and, if at all, continue the process with new proposals that are based on the objectives of the EU Directives in place and that respect the principle of proportionality of regulatory intervention which is one of the main principles of the EU legal framework.