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29 Dec, 2006

RD252 - ETNO Reflection Document on the ERG IP interconnection consultation

ETNO believes it is premature to predict how points of interconnection and interconnection rates will be affected by a future NGN interconnection structure. A well-functioning interconnection market will find its own balance. The move towards NGN has the potential of removing existing bottlenecks; basic conditions to favour this are the existence of competition and the reliance on market forces. ETNO is therefore concerned about the underlying tendency to intervene on issues such as technical interfaces, protocols, technologies or QoS.

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insight
29 Dec, 2006

RD251 - ETNO Reflection Document on the ERG Broadband market competition report 2006

The ERG broadband market competition report does not attempt a robust empirical analysis of different broadband markets in the EU nor does it provide a sound economic underpinning for its assertions on the effects of regulation on broadband markets. ETNO remains greatly concerned with the ERG policy approach to broadband regulation. The ladder of investment approach as applied by ERG risks further delaying the emergence of sustainable competition and perpetuating a fragmented and inefficient market structure on European broadband markets.

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insight
30 Nov, 2006

RD250 - ETNO Reflection Document on the ERG draft Principles of Implementation and Best Practice for WACC calculation

Corrections for efficiency by a national regulatory authority (NRA) are unjustified in view of a market-driven determination of the cost of capital. Each of the discussed methodologies to calculate a divisional Weighted Average Cost of Capital (WACC) has serious drawbacks. PIBs should caution against a divisional calculation of WACC, which does not correspond to divisions of a company that already separately calculate their cost of capital.

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insight
30 Nov, 2006

RD249 - ETNO Reflection Document on the draft ERG 2007 Work Programme

ETNO welcomes the very significant improvements in the transparency of ERG work, which risks however being undermined by the blurring of IRG and ERG activity. ETNO invites the ERG and the European Commission to develop a clearer idea of what kind of harmonisation is desirable to ensure an adequate and proportionate implementation of the regulatory framework. The objectives of further ERG work on harmonisation are not clearly outlined in the Work Programme. Furthermore, work on innovative and emerging markets should be guided by a bias against intervention.

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insight
31 Oct, 2006

RD247 - ETNO Reflection Document with Comments on the Commission draft Recommendation on relevant product and service markets in the electronic communications sector

The proposed draft Recommendation is over-inclusive, i.e. subjects more markets to regulation than would be justified under the 3 criteria test set up by the Commission. As a result, many markets with a more advanced market development risk being subject to inappropriate regulation, impeding investment and stronger growth in Europe. To ensure harmonised principles across the EU and safeguard against inappropriate intervention at national level, the revised Recommendation should oblige NRAs to apply the 3 criteria test on each national market prior to regulatory intervention.

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insight
31 Oct, 2006

EC088 - ETNO Expert Contribution on Community Framework for State aid for Research and Development and Innovation

ETNO thinks the framework requires some important adjustments. Focusing on smaller players may lead to the exclusion of whole sectors of the European economy. In particular ICT major actors could a priori not be allowed to benefit from state aid. Given the application of stringent ex ante rules for dominant players, we consider that the existence of a general interest and a market failure are necessary and sufficient conditions for granting state aid.

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