Yes. Thank you for this.

I had started to wonder whether BEREC was not acting in some ways like a 
"stalking horse" for Council.

It will get even more interesting.

Gordon


On 20 May, 2014, at 16:54, Innocenzo Genna <[email protected]> wrote:

> Hello all,
> 
> the ’90 telecoms liberalization was made with (flexible) directives, not 
> (rigid) regulations. Also the european regulatory framework for electronic 
> communications services consists of directives, not regulations (the only 
> exception were ULL, for certain time, and then roaming).
> Berec is implicitly challenging the legal instrument chosen by Kroes for the 
> Single Market, i.e. a regulation.  In the past Berec made various analysis 
> about net neutrality infringements throughout Europe, and the result showed 
> quite a diversified situation being caused by absence of rules rather then by 
> the existence of different national legislations. This is the reason why 
> Berec would consider adequate to regulate this matter via a directive rather 
> than a regulation.* 
> 
> However, the original sin (i.e. Kroes’s regulation covering a plurality of 
> different areas) is there and there is no room to change it, in my opinion. 
> However, it could be possible that the Council cut out the entire NN reform 
> and decides that it will be part of the program of the next Commissions. The 
> latter option has been already proposed for other areas of the Single Market 
> proposal.
> 
> I am following the working groups of the Council in the matter of the Single 
> Market and I see that many member States are reiterating their objections 
> against both the proposal of the Commission and the amendments of the 
> Parliament. Thus, the situation is not very promising for the proposal, which 
> will be radically reduced.
> 
> Inno 
> 
> * The use of a regulation is quite intrusive and it has been challenged 
> frequently by national authorities: for example, a proposed regulation for 
> the roll-out and reduction of costs for high-speed networks was converted 
> into directive by the Council and the Parliament. The same challenge was made 
> against the new privacy regulation of Commissioner Reding. In the latter 
> case, however, reding was able to resist because an harmonized directive 
> already existed (95/46/EC), therefore the escalation into a regulation could 
> be justified.   
> 

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