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ESOA responds to Telecoms Framework review consultations

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18 December 2015

The EMEA Satellite Operators Association (ESOA) submitted its response to European Commission’s Public Consultation on the review of the Telecoms Framework.  The digital divide remains an important obstacle to full connectivity of EU citizens.  EU should take concrete measures to reduce it and include satellite broadband applications within the scope of Universal Service Obligation among other proposed solutions. Increasing the current take-up of connectivity and services is a pre-requisite for identifying future connectivity needs.  ESOA believes that investment priorities should not be directed away from the primary objective to fulfil users’ needs everywhere, notably in providing significant step change in connectivity, even if not of “very high-performance".

 ESOA also believes that the implementation of the current regulatory framework has so far not succeeded in enforcing a fair, proportionate and non-discriminatory treatment of all electronic communications providers which contribute to the connectivity goals in Europe. Especially important is to maintain and implement key principles of the existing Telecoms Regulatory Framework, namely: technology neutrality, promotion of efficient investment and innovation (while taking into account existing and upcoming investments), avoidance of interference, encouraging an efficient use of spectrum and compliance with ITU Radio Regulations.

 Only a mix of different technologies will guarantee the best user experience and will ensure actual delivery of services.  It is essential that while building the next generation networks & services, the technology neutrality principle is maintained.  Incentivising new infrastructures should not hamper the development of existing solutions that have emerged from the market forces alone.  Long term investments require predictability and security in accessing radio spectrum.  Any demand for additional spectrum allocations should be very carefully analysed. Market demand analysis ought to be based on a neutral and thorough evaluation of user data and traffic density in order to avoid the adoption of policies that unduly favour certain technologies and platforms.  Spectrum sharing can be a welcomed solution, but not when it impedes the growth of existing services, causes harmful interference or hampers the efficiency of hybrid broadcast – broadband solutions.

 Aarti Holla, ESOA Secretary General, commented: ‘’Hybrid solutions, which combine broadcast networks for distribution with broadband networks for interactivity, can provide new and innovative services everywhere, even in rural and very remote areas’’.

 ESOA’s full response to the Public Consultation questionnaire will be published at the same time as the European Commission disclosure of all responses.

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