FTTH Council Europe Response BEREC Draft WP Response

 The FTTH Council welcomes this Draft Work Programme document and the opportunity to give further comments. 
The FTTH Council Europe notes that there is a considerable regulatory evolution underway and that there are a number of broad trends taking place today which are driven by market dynamics and which will evolve independently of the change in the regulatory environment but which have significant impacts on regulation. The first is a very strong push towards FTTH in Europe – this is driven by a number of factors over and above the inherently superior performance characteristics of these networks (for instance much lower operational costs, growing demand for higher bandwidth and the evolution of higher bandwidth services). This transition is driving a significant change to the market structure as investors in FTTH are often new entrant operators (not existing smaller operators but genuinely new entrants) in the market. These new entrants do not suffer from the replacement effects of existing operators and so, very often what is seen in the market is the existing operator, a new FTTH operator plus (normally at least) a CATV operator in the urban areas but perhaps no investor in the rural areas. This in turn leads to very significant challenges for NRAs and BEREC with regard to appropriate regulation, which may vary by geography. The FTTH Council Europe believes the Guidelines on Article 22 will have particular importance in that context and will participate fully in that consultation.

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