European Competitive Telecommunications Association

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ECTA welcomes new Commission study on targeted harmonisation for a successful Digital Single Market
Recommending more consistent availability of active wholesale access products across the EU

Brussels, 16 December 2015: The European Commission recently published a study conducted by WIK and TNO on harmonisation of access and interoperability products. Active wholesale access products are essential for ensuring that end-users – be they consumers or enterprises – benefit from choice, competitive offeringsand get the quality they need as well as value for money.


The aim of this study was to investigate the supply and demand conditions for active wholesale access products across the European Union in order to understand whether there was a case for harmonised and/or standardised wholesale products across the EU, and if so, what would be the best mechanisms to achieve this.

ECTA welcomes the conclusions of this report, which in particular indicates that harmonisation of these products could improve provisioning conditions, quality and consistency for multi-national business customers. Harmonisation is of tremendous importance for the provision of high quality services to business users as these customers who are generally multi-site expect to find the same variety of services and the same quality of service across borders. This is the reason why it must be ensured that access bottlenecks encountered by business service providers are effectively tackled by means of increased, consistent and effective harmonisation.

As a consequence, ECTA welcomes the recommendation that attention should be given to ensuring a common understanding concerning the specification of active wholesale access products (such as VULA -virtual unbundled local access and Ethernet bitstream) as it will provide a clear guidance to National Regulatory Authorities when defining regulatory obligations and scrutinising reference offers.

ECTA would like to take this opportunity to remind that wholesale active products are key for challenger operators to compete at retail level notably in circumstances where physical unbundling is not economically or technically feasible. It should not be forgotten that physical unbundling products are the key enablers of network investments by competitive operators. Indeed, the prior harmonisation of local-loop unbundling (meaning the ability of challenger operators to rent the last mile of the infrastructure of another operator, traditionally the incumbent for a fee, in order to offer services) was very successful. It enabled, through differentiation and innovation, vibrant broadband competition to take place. This trigerred lower, affordable prices for consumers and at the same time higher revenues for the telecoms industry as a whole. The key objective of the telecoms framework review should be to repeat this success story benefitting both end-users and the telecoms sector in next generation, fibre-based broadband.

Physical unbundling products are the main wholesale products used by altnets and they also need to be harmonised as physical unbundling and virtual unbundling (i.e. VULA) are not substitutable products. 
Virtual access such as VULA does not allow for the degree of innovation or differentiation that is needed as alternative operators remain dependent from the incumbent. VULA products should however be defined the closest possible to physical unbundling.

Challenger operators are still today often provided with inadequate wholesale access products (in terms of product characteristics, availability, specifications etc), a situation which dramatically affects their capability to compete at the retail level and in turn what is on offer for end-users and at what price. Consequently, ECTA strongly supports the recommendation of the TNO/WIK report that a streamlined set of standardised wholesale products and minimum service standards should be provided under the EU telecom framework.

ECTA (the European Competitive Telecommunications Association) is the pan-European pro-competitive trade association that represents more than 100 of the leading challenger telecoms operators across Europe. For over a decade, ECTA has been supporting the regulatory and commercial interests of telecoms operators, ISPs & equipment manufacturers in pursuit of a fair regulatory environment that allows all electronic communications providers to compete on level terms. Our members have been the leading innovators in Internet services, broadband, business communications, entertainment and mobile. 
Aurélie Bladocha, Senior Public Affairs Manager: +32 (0)478 786100 This email address is being protected from spambots. You need JavaScript enabled to view it.


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