Response to EC consultation on 'Open Internet and Network neutrality in Europe'

Not surprisingly, I tend towards the co-regulatory rather than self-regulatory, and consumer transparency rather than 'where are the dead bodies?' approach towards net neutrality. The full submission is here. Here's a flavour:

The European Commission is to be congratulated on its broad terms of reference for its ‘Public Consultation on the Open Internet and Net Neutrality in Europe’, acknowledging the role of an open and interoperable Internet for the future of digital innovation in the knowledge economy. This is very well captured in Commissioner Kroes’ Speech 10/300 at Open Forum Europe 2010 Summit: 'Openness at the heart of the EU Digital Agenda' Brussels, 10th June 2010. My response attempts to map my answers to both the specific questions and the overall framework for interoperability and transparency set out by Commissioner Kroes in this and other public speeches.

This broad consultation stands in stark contrast to the very limited telecommunications economics oriented consultations conducted by the UK Ofcom[1] and other national regulators within the BEREC consultations. This reflects the paucity of network neutrality information supplied by most national governments as published in the 15^th Implementation Report[2].  The issues surrounding network neutrality are far too broad to be captured by such narrow approaches, and the consultations carried out by BEREC members are therefore unlikely to produce useful outcomes from the perspectives of COM(2010) 245 and the European Union’s Digital Strategy.

---

[1] http://chrismarsden.blogspot.com/2010/06/draft-reply-to-ofcom-network-neutrality.html

[2] http://chrismarsden.blogspot.com/2010/05/uk-to-ec-no-net-neutrality-issues-that.html

Now back to the book...