Search

RD337 - ETNO Reflection Document on the BEREC consultation “Electronic communications services: ensuring equivalence in access and choice for disabled end-users”

RD336 - ETNO Reflection Document commenting on draft BEREC Report on relevant market definition for business services

ETNO welcomes this public consultation by the Body of European Regulators for Electronic Communications (BEREC) on its draft report on relevant market definition for business services, BoR (10) 46.ETNO concurs with many of the principles identified in the report and encourages BEREC and national regulatory authorities (NRAs) to continue to refer to the SMP-guidelines of the European Commission[1] when delineating separate or common markets for busines

RD335 - RPOL BEREC FS guidance

As ETNO argued[1] during the 2007-2009 ‘Telecoms Review,’ the proposed introduction of functional separation into the Framework was not based on any cost-benefit analysis or regulatory impact assessment. Instead, it was politically motivated, linked to NRAs reliance on mandatory unbundling and the concept of the ‘ladder of investment’ in their implementation of the Framework.

EC106 - ETNO Expert Contribution on the ECO Questionnaire related to the Revision of ECC Report 003

The document is ETNO's reply to the ECO Questionnaire on the potential revision of ECCReport 003.ETNO welcomes the opportunity to express its views on the future of the Fixed Service in Europe.The attached replies are offering comments on the questions asked by ECO in relation to the potnetial revision of the ECC Report 003 on the use of Fixed Service in Europe.

RD334 - ETNO Reflection Document commenting on the draft BEREC Work Programme for 2011 agreed by the BEREC Board of Regulators

ETNO welcomes the new role of BEREC in working towards consistent and proportionate regulation in Europe under the revised EU regulatory framework for electronic communications.We encourage BEREC to prioritise its work in 2011 by taking into account the political goals of the “Digital Agenda for Europe” to achieve a high degree of high-speed broadband availability and take-up in the European Union.ETNO calls upon BEREC to address two urgent regulatory challenges regarding current and future broadband markets in its work programme (WP):

RD333 - ETNO Reflection Document on the future of electronic commerce in the internal market and the implementation of the e-Commerce Directive

ETNO welcomes this consultation on the future of electronic commerce in the internal market and the implementation of the Directive on Electronic Commerce. The current EU legal framework on e-commerce - in particular the provisions related to intermediaries’ liability - strike the right balance amongst the interests of the different stakeholders. The framework respectd fundamental principles and rights, in particular freedom of speech, freedom of access to the internet and the right of privacy.

EC105 - ETNO Expert Contribution – Cost accounting for key access products in the transition to NGA

ETNO made this proactive submission to the Directorate-General for Information Society & Media to raise the issue of pricing of key wholesale access product on copper-based broadband networks and its impact on investment in next generation access networks (NGA).

RD332 - ETNO Reflection document - Comments on the Draft ECC Report 155 on “Number Portability Procedures”

Number portability is a fundamental element to consolidate competition on the market. ETNO urges Member States to take a very cautious approach when transposing the Directives into national legislation.Too far-reaching requirements which could be unrealistic for operators and unreliable for customers should be avoided. The practical implementation and the duration of service interruption are critical issues.Consumers should not be faced with loss of service beyond one day or preferably less.

RD331 - ETNO Reflection document - Comments on the Draft ECC Report 154 on the Evolution of geographic numbers

ETNO finds the scarcity of numbers is not a reason for removing requirements for geographic information.A specific need for nation-wide location number portability for geographic numbers should be assessed in the market before considering it as a reason to support location independent numbers evolution.Nation-wide location number portability is a one way move which induces significant costs due to technical and business impacts.

RD330 - ETNO Reflection document - Comments on the Draft ECC Report 153 on Numbering and Addressing in Machine-to- Machine (M2M) communications

ETNO agrees that national numbering policies for M2M communication are required to support the potential demand for M2M applications and endorses the conclusion of the report that no harmonised approach is needed in Europe, regarding the solutions to address the impact and needs on numbering and addressing of M2M services.