OpenLobby.EU
Explore

FTTH Council Europe ASBL

FTTH Council Europe

The FTTH Council Europe is an industry organisation with a mission to advance ubiquitous full fibre-based connectivity to the whole of Europe.

Lobbying Activity

Response to Europe’s digital decade: 2030 digital targets

9 Mar 2021

The FTTH Council believes that the roadmap is appropriate and covers the relevant topics. At a high level the FTTH Council would note the primacy of having appropriate infrastructures in place – VHCN in fixed and 5G/6G in mobile. Without appropriate infrastructures in place it becomes impossible to deliver the other aspects being identified in the roadmap. It is also agreed that “The vision must be accompanied by specific instruments to deliver it for the benefit of EU citizens, leaving no territory and no individual behind. Such ambition requires setting concrete digital targets in cooperation with Member States and based on strong principles, and a system to monitor progress towards the objectives of the Digital Decade.” and the FTTH Council notes that while it is of course necessary for the market and private investors to deliver mass market connectivity – it must also be noted that (a) certain high cost and hard to reach areas in Europe where no business case is viable can require public funds to deliver connectivity so that all citizens can avail of the economic but also societal benefits of such connectivity but also (b) that certain Member States, through slow transposition or less efficient enforcement are getting suboptimal outcomes from a network connectivity perspective than other Member States. The FTTH Council believes that this monitoring exercise can intervene directly in the first instance and highlight concerns about performance in the second. For instance, the benefits of the digital decade will be uneven if one of the large Member States falls behind the others. Forecasts conducted by IDATE for the FTTH Council Europe predict that fixed FTTH/B coverage will reach approximately 85% by 2026. However, this masks significant differences between Member States with Germany’s 4.8% of homes passed in 2020 compared to Spain’s 62.3%. The coverage gap will narrow with Germany’s 59% of homes passed in 2026 and 83.2% in Spain. In order to avoid uneven results, some countries will need to do more if they are to catch up. Other objectives including the greening of the European economy is intrinsically linked to the availability of VHCN networks both fixed and mobile. In the first instance VHCN networks (FTTH/B and 5G) use significantly less energy. The question of measurement is an important one. The FTTH Council Europe notes with concern the highlighted investment gap frequently cited between Europe and the US in terms of network investment– this is a matter of concern because the FTTH Council Europe can see that in terms of VHCN availability, Europe significantly outperforms the US market as a measure of homes passed or homes connected. In mobile, while the US cites greater 5G availability, it is also the case that many European mobile operators outperform their American cousins on the basis of their 4G networks. A good example is the ongoing consultation on the Broadband Cost Reduction Directive (BCRD). A much more effective BCRD should lower the cost of network deployment (it ought to also improve the environmental profile of new network deployment). Measured on ‘investment value’ a good BCRD would lower European cost of deployment and therefore performance if measured as value spent. On the other hand the quality of the fibre put in the network is important. High quality materials are needed to ensure a long lifetime of the network (reducing maintenance and replacement costs). Quality materials will also be necessary to ensure that the fibre infrastructure is capable of supporting future technologies and coexisting technologies. Some measurement that captures material quality should be possible to ensure that network lifetimes are maximised, and at a minimum they should adhere to national product standards (which is not always the case today in Europe).
Read full response

Response to Evaluation of State Aid rules for broadband infrastructure deployment

27 Jul 2020

The FTTH Council Europe makes three points: 1. The need for a seamless alignment of network objectives under the State Aid rules for Broadband and the new regulatory framework (EECC) being applied by national regulators. The new regulatory code, referred to as the European Electronic Communications Code (the “EECC” or “the Code”) has a principal objective to foster investments in the new Very High Capacity Networks (VHCNs). VHCN is essentially about investments in fibre networks. In the case of fixed networks, it is defined as “Fibre to the Home” or “Fibre to the Building” (or its “equivalent” but, as defined, it is difficult to see how it can have a practical equivalent and BEREC’s list of equivalent characteristics imply fibre networks). The clear objective is to drive fibre as deep in the network as possible. We believe that as a matter of consistency with the EECC, assessments under the State Aid Rules should be made looking through the prism of whether investments funded by the State meet the basic criterion of being classified as VHCN. Consequently, anything which doesn’t fall in the category of VHCN should not qualify for funding. 2. The need for alignment of geographic areas under the State Aid rules and the relevant regulatory framework being applied by NRAs. Although entry barriers are high, they are not evenly so throughout a Member State. Measures in recent years lower barriers to entry by enabling sharing of civil infrastructures and in-building wiring and widened the scope of infrastructure-based competition. It seems likely that multiple VHCN enabled networks could be deployed in urban areas where the cost of deployment will be lower compared to deployment in other areas. An enhanced use of a revised Broadband Cost Reduction Directive ought to help with this objective. The EECC’s preferred approach relies heavily on infrastructure-based competition. The possibility for commercial FTTH deployment in less dense areas where costs per unit are normally higher are likely to be more limited. In order to be consistent with the EECC, urban areas ought to be outside the scope of State Aid interventions based on the characteristics of the area being covered because areas could be commercially viable even if not in current business plans. Even in less dense areas innovative deployment techniques and efficient usage of existing assets can allow the commercial coverage area to be larger in the future than it has been in the past. While a case-by-case approach is necessary, a national consultation with operators as described below could add to the overall assessment. 3. The need to adapt State Aid rules to VHCN network investment – prevent crowding-out and anti-competitive misuse On the one hand investors rightly point out that capacity constraints means that for some EU countries a full VHCN deployment would not be possible within 3 years and that this alone could leave large swathes of a Member State open to a State Aid intervention. The FTTH Council Europe believes that flexibility in the respective EU rules is necessary to allow solutions like – for example - national consultations with the operator community which can help identify an appropriate timeframe for private FTTH/B deployments. This timeframe may vary by Member State depending on how much VHCN has already been deployed. On the other hand, those who would block State Aid investments in order to preserve monopoly positions in copper are becoming more and more sophisticated in delaying or blocking the use of State Aid. For instance in an EU market that saw a lengthy tender process that has been awarded to one party with approval under the State Aid rules (SA.23179 National Broadband Scheme Ireland) was being undermined by an incumbent operator who firstly changed the geographic scope of its network build out and subsequently sought to re-enter the tender process with radical price revisions. The net result of this episode was a delay of several years.
Read full response

Response to Review of the Broadband Cost Reduction Directive (Directive 2014/61/EU)

17 Jul 2020

The FTTH Council Europe welcomes the decision to revise the BCRD and believes that with appropriate revisions it can assist the deployment of FTTH across Europe. Changes since 2014 - The Commission’s policy objectives and the means of achieving them have shifted significantly as expressed through the EECC. European policy now wishes to see investment in VHCN which is defined as FTTH/B and its equivalent. The BCRD can support the EECC objective of getting VHCN networks widely deployed and quickly. It needs to be implemented more effectively than it has in the past if the logic of the EECC is to be coherent with a logic that requires competitive builds where cost effective. - We have done significant cost modelling work (see attached document) which points to considerable cost savings where FTTH and 5G deployments are co-ordinated. FTTH/5G co-ordination should be a major part of any new BCRD proposal since this is a new and very significant source of synergies and cost savings. - Making the effective implementation of the BCRD the responsibility of NRAs would give an important focus to its implementation and would allow that authority to develop access processes and pricing that would be effective for access to physical infrastructures that support the deployment of fibre networks. The BCRD should seek to move away from the current ex-post access pricing mechanism towards a more appropriate ex-ante pricing mechanism. - The exemptions for wholesale only operators appear to be effective. Once a fibre network deployment is started those utility physical infrastructures are typically exempt from any access obligations to preserve their incentives to invest and maintain their business case. This approach should be maintained in consistency with the EECC. Ineffective implementation a)Failure in institutional design While the Council acknowledges the efforts that have been made such as the use of a single information point it notes that no agency or department has overall responsibility for the effectiveness of the BCRD. Given the experience that NRAs have with access procedures and pricing, they ought to be designated lead agency for implementing the BCRD. This would allow the BCRD to move to a standard ex-ante regulatory regime. Currently the most operative parts of the BCRD require access to be sought and subsequently a dispute to establish access and prices. b)Inability to systematically designate access prices While the dispute resolution procedure permits prices to be set in the event of a dispute, the mechanism or requirement for such price setting is not specified. If the NRA is designated as lead implementing agency, they would be in a position to issue ex ante guidelines for the definition of access prices and conditions which would guarantee a consistent application. This would allow greater clarity on what those deploying network might expect and is also likely to diminish the number of disputes since a common costing methodology would apply. The FTTH Council believes that dispute resolutions procedures that relate to in-building access warrant revision. Guidelines could guide building owners in their relations with those deploying network. A fibre-ready label In-building wiring ought to be addressed through building codes to ensure that all network owners are able to service customers without the need to deploy multiple fibre infrastructures within the building. And NRA can play an important role in advising on an appropriate revision to the relevant agency/department. Considering the evolution of the technology & the future needs of our Connected Society and Economy, we believe that the requirement of a Broadband-ready building now ought to be fibre ready or have the passive infrastructure that would allow fibre to be deployed quickly and easily. The FTTH Council Europe therefore proposes the introduction of a fibre-ready label for new buildings and major renovations. More details can be found attached.
Read full response

Meeting with Margrethe Vestager (Executive Vice-President)

2 Jul 2020 · To discuss the key priorities of the Commission and the sector

Meeting with Andrus Ansip (Vice-President) and

22 Jan 2019 · Fibre investments, fibre-5G convergence

Meeting with Andrus Ansip (Vice-President) and

15 Jan 2018 · Very high capacity networks, telecom reforms, investments

Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)

10 Sept 2015 · Connectivity, telco framework review

Meeting with Eric Mamer (Digital Economy)

2 Sept 2015 · DSM

Meeting with Markus Schulte (Digital Economy)

20 Jul 2015 · Telecommunication Policy

Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)

22 Jan 2015 · Investment in broadband, regulatory framework