RD419 - ETNO Contribution to the Public Consultation on the draft BEREC Report on enabling the Internet of Things BoR (15) 141

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Introduction

ETNO welcomes the opportunity to contribute to the BEREC Draft Report on Enabling the Internet of Things. Machine-to-Machine (M2M) / Internet of Things (IoT) is one of the fastest growing technological phenomenon with new solutions introduced on all walks of life from the automotive to utilities and health services. This world of connected objects is opening a whole new field of opportunities for ICT to increase social and economic welfare of Europe and the world at large.

Considering the impact of IoT it is crucial for the regulators to understand the market dynamics and we applaud BEREC for the draft report which draws a clear picture of the key characteristics and challenges. On the same note we stress that IoT is a nascent phenomenon with value chains, business models, markets and services in continuous motion finding their place to most efficiently meet and seize the technological opportunities and respond to market demand. All deployments have their merits and we believe that markets will eventually pick the most efficient solutions and that regulators should refrain from forcing or favouring specific models. For the time being we see little need for new regulatory interventions and where considered necessary, these measures should be clear, balanced and technologically neutral. Unwarranted regulatory action would only hinder competition, stifle innovation, raise costs, and stifle investment.

As spectrum is not touched in the individual questions of the Report, we note here in the introduction that we agree with BEREC´s view concerning the availability of adequate spectrum resources for M2M services. ETNO supports the view that NRAs should monitor market developments and spectrum use, and if demand for additional spectrum is identified, the established processes via ETSI and CEPT should be applied.

ETNO recognizes that M2M services are currently provided on unlicensed and licenced frequency bands, but we see that in the future only licensed frequency bands and systems can cater for the need of coordinated connections by guaranteeing interference-free and reliable M2M communication, as well as efficient use of spectrum.

Hereunder are our comments to the questions raised in the Draft Report. The considerations provided in the different answers apply to the whole Report, as many concepts are repeated
more than once in different parts of the Report. 

1. How do you evaluate the three options mentioned above (extra-territorial use of national E.164 and E.212 numbers, use of global ITU numbering resources, use of a European numbering scheme) for the provision of M2M services? Which of these solutions is preferable to address the need for global marketing of connected devices? Should these
solutions be used complementarily?

M2M services are offered in an international context. We therefore see a growing need for a harmonized and coherent market conditions to deploy services across borders. However, any additional regulatory intervention should be carefully measured considering the impact and costs incurred for the market actors and the industry at large.

A common approach followed by all individual European regulators is encouraged to avoid diverging positions creating different and complicated market conditions to deploy the M2M
or other services. The need for harmonization is especially required as in this context of M2M where the use of numbering resources is no longer linked to one country/one regulator. A
decision of one national regulation in this domain will influence the market conditions in other countries. A coherent regulation is therefore necessary. The European regulators should
further negotiate at international level to create a similar harmonisation at international level.

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Read the full reflection document here.