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.
ETNO agrees with the draft Recommendation on the issue of symmetry of TR between different mobile networks and between different fixed networks respectively and encourages adopting a faster glide path to reach such symmetry. We acknowledge that the level of symmetric TR may be derived from the costs incurred by an efficient operator model but strongly disagree on essential elements on how such models should be built.

ETNO welcomes the possibility to express its position on the regulation of termination rates (TR) in Europe. ETNO would like to highlight that 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.

ETNO agrees with the draft Recommendation on the issue of symmetry of TR between different mobile networks and between different fixed networks respectively and encourages adopting a faster glide path to reach such symmetry.

Our organisation also acknowledges that the level of symmetric TR may be derived from the costs incurred by an efficient operator model but strongly disagrees on essential elements on how such models should be built.