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The Hunt For A Connected Continent Part II

I've received what I assume must be a first batch of e-mails with stakeholder consultation documents on the new telecoms package. Please see my previous post for more details. First of all, find the reply of the European Commission here. And these are the consultation documents the Commission has so far wished to reveal:

UPDATE (2014-05-22) : better mapping of the disclosed document stakeholder identities.

ARD (organization for German Broadcasters, member of the EBU.); BT  (former British state monopolist); B-Sky-B (British Sky Broadcasting Group, a cable provider); Bouygues (french mobile operator and network owner); CCIA (computer and communications industry association, mostly american IT firms); BEUC document is appended to the Bouygues document(!); CDT (american industry-funded NGO, moderate); COLT (British telecoms operator for business services); Coop Voce (Italian MVNO, note also EAFM); EAFM (finance industry something European association for virtual mobile network operators - mobile operators without their own base station infrastructure); European Broadcasting Union (public service television stations in Europe); European Competitive Telecoms Association; European data protection supervisor; European Newspapers and Publishers Association; ETNO (incumbent operators, former state monopolies); Forbrukerombudet (danish consumer group??); GSMA (mobile network infrastructure owners and builders); KPN (former dutch monopolist); Liberty Global (world's largest cable provider, owner of UPC et c); Postmobile/Postemobile (simultaneously documents from Belgian MVNO Postmobile and Italian MVNO Postemobile - which are different companies and as is seen by scrolling the pdf); ReWheel (Finnish telecoms competition analysis firm); Verizon (one out of the two American network owners); Vodafone (world's largest mobile network owner).

Organisations I can't immediately identity: ARD, Coop Voce, COLT and Postmobile. UPDATE (2014-05-22): The Commission seems to have received inputs from both Postmobile and Postemobile, which in fact appear to be two separate entities. However, both are on first-name basis with Roberto Viola who's the general-director of DG CNCT, so reasonably he is aware that they are in fact separate stakeholders for the purpose of this disclosure, not the same.

Note that BEREC - the European Body of Regulators for Electronic Communications, seems not to have been asked for inputs! This means the European Commission has essentially cut the member states out of the preparatory process for this legislation.

Also notable is that BEUC - the European Consumer organisation - seems not to have been given the chance to provide inputs even though the European Commission explicitly refer to them in their Impact Assessment (Annex I, page 103 of the document and onwards). (UPDATE (2014-05-22) : see latter half of the Bouygues document for BEUC inputs). Neither does the Commission appear to have received stakeholder inputs from Deutsche Telekom, Telefonica or TeliaSonera despite these three actors being explicitly mentioned by the impact assessment. The European Commission has not asked European Digital Rights initiative, despite this being the most active group for digital rights in Brussels for the past three years.

This will require a follow-up, definitely.

UPDATE (2014-05-22) : Please also see DG CNCT General-Director Robert Madelin's blogpost on the above document request. Robert Madelin is looking "to respond to Amelia Andersdotter's blog post on the Hunt for the Connected Continent, which I think takes too narrow a view of the interactions that have taken place around this package." My original request was for "all the relevant stakeholder inputs", which unfortunately was too exhaustive a request for the EC to understand what I meant. In my clarifying request I seem to have made the semantic mistake of referring to "documents" which the EC has interpreted to mean "documents which are presently in existence and archived as stakeholder inputs in the specified context", rather than for instance "a document listing all the meetings that the Commissioner and her staff have engaged in around this meeting with various stakeholder groups or thinktanks which is not presently compiled but which could be compiled in order to ensure the utmost transparency of the legislative procedure of the European Union)."


ARD är förmodligen det tyska public service-paraplyet. De har lite annan organisation än SVT pga delstater.

Dear Ms Andersdotter,

Please note that EAFM is the European Association of Full MVNOs, it is the association of companies which are active on European mobile markets, and are independent (in terms of ownership and control) from established mobile network operators (MNOs).

The goal of EAFM is to create a more openly accessible market for Full MVNOs, in order to contribute to the growth of the fast-moving mobile communications sector, to ensure that consumers and business users have a wider range of diversified services to choose from and to develop competition on the retail mobile market to their benefit.
The EAFM members believe that Full MVNOs can stimulate innovation in the telecom sector.

For more information on our association and our actions regarding the Connected Continent, you can visit

ARD: organization for German Broadcasters, member of the EBU.
Coop Voce: Italian MVNO
COLT: British telecoms operator
Postmobile: Belgian MVNO (owned by post operator Bpost)

Dear all,

Thank you for these clarifications which are useful both to me and my readers. I also note that I have in fact mislabelled EAFM which does not do finances at all, but rather MVNO:s. This will be changed in the text.

Of particular interest in the inability of the Commission to speak of which groups they have counselled prior to drafting the proposal at all, or after the proposal is drafted. The only clarifying circumstance the Commission brings to not disclose that information is confidential business information, and I've inquired with the EC what that means. I'm expecting an answer in June at earliest.

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