09 November, 2021

ETNO’s submission to the BEREC public consultation on the draft BEREC Work Programme 2022

ETNO welcomes the opportunity to provide comments on the draft BEREC’s Work Programme 2022. We believe that BEREC should in general focus on the ongoing tasks as mandated by EU legislation, as defined in the EECC, the Open Internet Regulation, roaming and intra‐EU calls, for example. We support BEREC’s commitment to establish structured cooperation mechanisms with EU institutions and other competent authorities.  

Concerning the strategic priorities and work items for 2022, ETNO will hereby provide some comments and suggestions.

• Strategic priority 1: “promoting full connectivity”

ETNO strongly supports BEREC’s strategic priority 1 that aims at promoting full connectivity and access to electronic communication networks. To achieve that, a successful implementation of the EECC should be pursued and pro-competitive infrastructure sharing promoted. ETNO supports BEREC’s intention to take stock of national experiences of the implementation of the EECC and to exchange good practices in this regard. We would also encourage BEREC to include stakeholders in this exercise to capture different perspectives in the initial assessment.

• Strategic priority 2: “Supporting sustainable and open digital markets”

We encourage BEREC’s work on improving the functioning of digital markets. ETNO is fully invested in ensuring contestable and fair markets in the digital economy.

• Strategic priority 3: “Empowering End-users”

We believe that some of the planned work items relating to this strategic priority would benefit from assessment by BEREC. However, since the EECC is still in the implementation phase in the Member States, BEREC should refrain from making new proposals that risk legal certainty for operators. Concerning BEREC’s considered work on “Compensation in the case of early termination of contracts”, ETNO believes that operators would benefit from guidance to clarify the flexibility for telecoms operators with regard to this provision of the EECC, and ensuring a balance of the interests of the parties and ensuring that the value of the contract is respected.

 

Read the full document at the link below.