[Chapter-delegates] [European-chapters] ISOC contribution- Net Neutrality - BEREC consultation- Deadline 28 October.

[Christopher Wilkinson]

Dear Frédéric:

Thankyou for this draft which I have now read.

In general the ISOC staff draft and the ISOC-ECC response are  
sufficiently different in philosophy and content that we need both  
documents.
I will finalise the ISOC-ECC response, as announced, (it has been in  
consultation since 8 October with a reminder on 18 October) referring  
to the staff response as an Annexe or a Link.

Regarding your staff document, I have only a few comments:

1.	I very much appreciate the didactic style and rigorous taxonomy. I  
hope that BEREC readers will, likewise.

2.	Regarding VoIP, I disagree to treat it expressly as an IP-based  
service in this context. That may be arguable from a strictly  
technical point of view, but commercially, today, the distinction will  
be seized upon by certain operators to justify their existing  
preferences and practices to block or over-charge for VoIP. Please  
find language (or deletion) to exclude that outcome.

3.	Mobile and fixed networks: The short paragraph on page 4 is too  
weak. Who is to decide what is a well-justified exception? Again, we  
already know that regulatory ambiguity in this area is likely to lead  
to discrimination. Particularly if G4 licenses are over-priced at  
auction.

Best regards,

Christopher.



On 25 Oct 2011, at 18:34, Frederic Donck wrote:

> Dear Colleagues,
>
> I would like to share with you some very recent development wrt the  
> "Network Neutrality" dossier in Europe.
> As you certainly remember, the European Commission said it would  
> rely on the European Body of Regulators for Electronic  
> Communications (aka "BEREC", a body which is composed of European  
> NRAS) to further develop the European principles at regulatory level.
>
> You will find below the draft guidelines which the 'BEREC' has  
> released at the beginning of this month for consultation.
> Stakeholders are invited to send their answers by the 2nd of  
> November 2011.
> http://erg.ec.europa.eu/doc/berec/consultation_draft_guidelines.pdf
> http://erg.ec.europa.eu/doc/berec/consult_info.pdf
>
> This is a very short deadline but we nevertheless thought it would  
> be very important to provide BEREC with an ISOC contribution.
> Please find below an ISOC preliminary draft response in which:
> - we applaud BEREC on the quality of these draft guidelines, which  
> are well aligned with principles that the Internet Society has long  
> espoused.
> - we are especially supportive of the focus on the end-user  
> perspective, and the observation that unrestricted offers of  
> Internet service are paramount is very welcome.
> - we provide BEREC with common terminology in relation to Internet  
> service, along with metrics to help understand the extent to which  
> Internet service is actually available versus a plethora of more  
> restricted offerings.
>
> In view of the very short deadline, would you please share you  
> thoughts and/or support by return, and no later than Friday 28  
> October COB.
>
> thank you very much in advance
>
> Best Regards
> Frederic
>
> Frederic Donck
> Director European Regional Bureau
> Internet Society
>
> www.isoc.org
>
>
>
> <ISOC_Response_BEREC_NN_guidelines-mdf.docx>
>
>
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