RD311 - ETNO Reflection Document with Comments - In the Matter of Broadband Study Conducted by the Berkman Center for Internet and Society – NBP Public Notice #13

ETNO believes that a robust empirical approach is required, if independent research and analysis are to be used for policy advice. In our non-exhaustive review of the qualitative country case studies in the draft report, “Next Generation Connectivity: A Review of Broadband Internet Transitions and Policy from Around the World”  (the “Berkman study”), ETNO has found numerous factual errors, inaccuracies and inconsistencies. These call into question the quality and objectivity of the empirical work conducted, and the empirical foundation for the study’s main regulatory findings on ‘open access’ policies.

• The European Telecommunications Network Operators’ Association (ETNO) believes that a robust empirical approach – whether qualitative or quantitative – is required, if independent research and analysis are to be used for policy advice;
• In our non-exhaustive review of the qualitative country case studies in the draft report, “Next Generation Connectivity: A Review of Broadband Internet Transitions and Policy from Around the World” (the “Berkman study”), ETNO finds numerous factual errors, inaccuracies and inconsistencies;
• In the following, ETNO would like to highlight some of these shortcomings, which call into question the quality and objectivity of the empirical work conducted, and the empirical foundation for the study’s main regulatory findings on ‘open access’ policies;
• In doing so, we wish to support the objective of the Federal Communications Commission (FCC) for “enlightened, data-driven decision-making.