RD295 - ETNO Reflection Document in response to the Commission Recommendation on regulated access to Next Generation Access Networks (NGA)
ETNO is very concerned that the draft Recommendation does not yet provide the required response to the increased risks involved in NGA investment and therefore will not facilitate those investments in Europe. ETNO supports the stated goals of the Commission to promote investment and competition in NGA and to foster sustainable infrastructure-based competition. The Association welcomes the more targeted ‘graduated approach’ to regulation which takes account of different competitive conditions in different regions in particular with regard to infrastructure competition.
ETNO is very concerned that the draft Recommendation does not yet provide the required response to the increased risks involved in NGA investment and therefore will not facilitate those investments in Europe. ETNO supports the stated goals of the Commission to promote investment and competition in NGA and to foster sustainable infrastructure-based competition. The Association welcomes the more targeted ‘graduated approach’ to regulation which takes account of different competitive conditions in different regions in particular with regard to infrastructure competition. ETNO finds the Recommendation should remain neutral as regards the technology used for the roll-out of fibre networks to premises and the aspect of legal certainty should be re-enforced in the Recommendation.
The Reflection Document highlights in detail the draft Recommendation elements where significant changes are required, which includes the issues of regulatory response to investment risk (introducing the concept of risk sharing), gradation of remedies and geographic segmentation, the need to address symmetric sharing obligations, pricing principles for existing assets, the approach to new markets, and the choice of technology and network architecture.
Annexed to the Reflection Document is an elaborate economic analysis of “Competition dynamics in broadband networks and the competitive impact of NGANs”.
Executive Summary: Only a tenth of the fibre lines deployed in East Asian economies and less than half of those deployed in the US have been built in the EU. However, such investments would positively effect productivity growth, the competitiveness of EU businesses and help preserve and create employment in the EU.
The Commission Recommendation on NGA could play a vital role in creating a virtuous circle for NGA investment by reducing regulatory risk to improve conditions for NGA investment, while supporting competition through open access to economic bottlenecks.ETNO is very concerned that the draft Recommendation does not yet provide the required response to the increased risks involved in NGA investment and therefore it will not facilitate those investments in Europe. Despite several positive starting points, key elements of the draft should therefore be adapted or revised accordingly.
In the Position Paper, ETNO supports the stated goals of the Commission to promote investment and competition in NGA and to foster sustainable infrastructure-based competition. ETNO welcomes the more targeted ‘graduated approach’ to regulation which takes account of different competitive conditions in different regions in particular with regard to infrastructure competition. The Association finds that the Recommendation should remain neutral as regards the technology used for the roll-out of fibre networks to premises and the aspect of legal certainty should be re-enforced in the Recommendation.
The Recommendation should introduce the concept of risk sharing which allows a fair distribution of risk between the investor and access seeker. The proposed project-specific risk premium alone will not solve the lack of incentives for widespread NGA roll-out in Europe. The Reflection Document highlights in detail the Recommendation elements where significant changes are required, which includes the issues of regulatory response to investment risk, gradation of remedies and geographic segmentation, the need to address symmetric sharing obligations, pricing principles for existing assets, the approach to new markets, and the choice of technology and network architecture.
Annexed to the Reflection Document is a detailed economic analysis of “Competition dynamics in broadband networks and the competitive impact of NGANs”.