On 2 November, the GSMA submitted its views on the BEREC draft Work Programme for 2017, calling upon BEREC to further strengthen its interaction with stakeholders, particularly in terms of the level of professional discussion between the industry and BEREC experts on the substantive issues.
The BEREC 2017 Work Programme rightly focuses on providing input on important issues related to competition, investment and the internal market, as well as the empowerment and protection of end-users. In providing its views on the BEREC draft Work Programme for 2017, the GSMA addressed each of the strategic BEREC priorities and highlighted some of the most important planned work actions:
The GSMA welcomed BEREC’s plans to investigate the device sector to preserve and promote end-users’ capacity to have access and to contribute to the various content and applications on the Internet. However, more clarity is needed on how the market assessment will be carried out from the content provider perspective in the context of mobile ECS markets.
In the context of convergence of fixed and mobile networks, BEREC should perform an overall assessment of the innovative nature of fixed/mobile convergence also taking into account the dynamic nature of such market segment.
When it comes to facilitating mobile connectivity in ‘challenge areas’, BEREC should keep relevant stakeholders informed about the development of the report on the subject, especially as it directly impacts mobile operators.
With regards to the assessment of the obstacles to the deployment of IoT services, BEREC should not underestimate the impact of the existing sector-specific rules. When it provides its opinion on the proposed European Electronic Communications Code (EECC), BEREC should take into account that the EECC could place further burdensome obligations on M2M services. The GSMA has provided the industry’s position on the EECC and would welcome a continuous dialogue with both BEREC chairs and BEREC Expert Working Group on this important topic.
The GSMA has also proposed that BEREC add a work stream to its Work Programme to study the role of platforms and related competition problems. The findings of such a study could be used by the European Commission to inform its decision (expected by mid-2017) about whether to take further legislative action on this topic.
In terms of the Roaming Regulation, BEREC should arrange a regular exchange with BEREC Expert Working Group on the changes that will occur, once the Roaming FUP and wholesale regulation are available.
Finally, the GSMA welcomed BEREC’s plan to update the survey on Member States’ experiences of universal service obligations. BEREC should gather views on the current functioning of the universal service obligations from telecommunications operators, as well as the EU Member States.
BEREC plays an increasingly important role in ensuring a consistent and proportionate regulatory approach in the EU and the GSMA looks forward to continued and enhanced cooperation with BEREC in 2017.