07 November, 2022

ETNO response to the public consultation on BEREC draft Work Programme 2023

ETNO welcomes the opportunity to provide input towards BEREC’s Work Programme 2023. 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 establishing structured cooperation mechanisms with EU institutions and other competent authorities.

ETNO would like to have the possibility to contribute to the BEREC work for 2023 and the coming years in the best way possible. Thus, we would like to stress the importance to have longer consultation periods to provide comments to reports and reply to consultations. We think setting consultation periods of 6 to 8 weeks would allow for a more efficient process and enrich the input provided.

In addition, ETNO deems of the utmost importance stakeholders are always involved and properly consulted; in fact, we note with disappointment that for some BEREC studies (such as for instance the one on the evolution of competition dynamics of tower and access infrastructure companies not directly providing retail services and the external study on the trends and policy/regulatory challenges of cloudification, virtualisation and softwarisation of telecommunications) no consultation with stakeholders is planned.

For questions and clarifications regarding this position paper, please contact Xhoana Shehu (shehu@etno.eu).