Finnet-liitto ry
Finnet
Edistää edunvalvonnan keinoin kaksisuuntaisten vähintään gigabitin valokuituyhteyksien ulottumista jokaiseen kotiin ja edesauttaa jäsenyhtiöiden menestystä tavoitteen saavuttamisessa.
ID: 469366031914-03
Lobbying Activity
Response to Digital Networks Act
11 Jul 2025
Finnet Association (later Finnet) is representing group of Finnish fibre operators and is a associate member of FTTH Council Europe (later FCE) and Finnet share FCEs statement in many part of this consultation. Find below Finnets additions or replacement to FCEs statement. Simplification: Finnet sees that all the fiber operators - whole sale or open access operators - should be managed by same rules in access regulation. Accessregulaton: The existing SMP- and access regulation does not necessarily promote fibreinvestments anymore; instead, it can slow down investments by traditional operators who have been targetet by ex ante SMP regulation. The existing EECC and its access regulation is very complex, expensive and should be renewed, simplified and replaced by general competition law. Present SMP is based on an idea of an incumbent copper network owner. In the FTTH/FTTB market the term incumbent is not relevant anymore, because there are many players in the market who can invest and who have been investing in fibre networks more than the traditional incumbents. In the present SMP the definition of market sizes is problematic. For example in Finland the regulation is considering each city or municipality with more than 5000 households as a separate market. As a result the first one to build fiber to replace the copper in a city or municipality becomes a SMP. At the same time big cities like those in the Helsinki region, with altogether 650.000 households, become non SMP-areas as there are multiple operators building fiber in these cities. However there can be areas bigger than a small municipality where there is only one investor and still there is no SMP in that city. The old incumbent keep the competitors out of the market by saying that they have no lines to lease. An other issue is the market analysis, which count only fiber, cable or copper based internet access subscribers. As we see today, in the market the customers can get internet access via many different technologies, like FWA or Docis, and many of those alternative access technologies are not regulated. We should look at total internet access market shares instead of the shares only fibre or copper customers. Many fibre networks owners avoid SMP-status today by claiming that their network is an open access network. There is no exact rules how to define open access networks, but we have seen some cases where there are only a couple of ISPs offered. Those players are then left out of the SMP regulation. It is not fair and symmetric regulation at all. All network operators should be regulated by same rules. Lightening and simplifying regulation would create a more competitive market environment and it will speed up the copper switch off. The goal to achieve 1 Gbit/s in 2030 to every european household is an ambitius goal and needs still a lot of investments and the risk of overbuild must be avoided by open and fair regulation. Regulatory reform requires a change of mindset, moving away from detailed and cumbersome rules towards more flexible approach. According to EECCs and its predecessors original aim, SMP regulation should move from ex ante regulation to ex post general competition regulation, where all fibre access cables should be open for lease with fair and undiscriminant rules. If SMP- regulation were considered necessary in some respects, its use should be a rare exception in the future, not the rule. We would like to compare this new access regulation model to be a same kind of game changer like EU-wide roaming rules were ten years ago. Copper Switch off: Finnet sees that the current ex-ante regulatory framework has not been beneficial to FTTH investments, because ex-ante regulation is not taking in the account that any one can invest to the fibre networks and only the old incumbents has been regulated in EECC. In Finland there is no need to copper switch off regulation or rules, because in our country copper is almost switced off
Read full responseMeeting with Elsi Katainen (Member of the European Parliament)
28 Oct 2024 · Tietoliikenneyhteydet