[bestbits] Global letter to Europe's regulators to defend net neutrality. Deadline to sign on: 25 April

[Maryant Fernández]

Dear all,

I'm writing on behalf of a coalition of NGOs that are putting together a
letter to the Body of European Regulators for Electronic Communications
(BEREC) on the net neutrality guidelines they need to issue by 30 August
2016. [1] Please, find the letter attached and below.

This is the list of the current signatories:
https://docs.google.com/spreadsheets/d/11YLPOVtG1ScqH_2KR1GU07fbpzCjRUrZ98FFmm9gd5g/edit#gid=0
If you want to sign on, please let me know or put the name of your
organisation and contact person here
<https://docs.google.com/spreadsheets/d/11YLPOVtG1ScqH_2KR1GU07fbpzCjRUrZ98FFmm9gd5g/edit#gid=0>.
Deadline: 25 April
Launch date: in principle, 26 April

Thanks and best,
Maryant

[1] Article 5(3) of the EU Regulation on net neutrality:
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32015R2120
Background info:
https://edri.org/edris-first-input-on-net-neutrality-guidelines/

------------------
26 April 2016

Global open civil society letter to the Body of European Regulators of
Electronic Communication (BEREC) in support of strong net neutrality
guidelines

The signatories of this letter support BEREC and its members in their
task to provide guidelines on the implementation of the EU Regulation
2015/2120.1 The new EU regulation creates a basis for strong and stable
net neutrality safeguards. We therefore encourage BEREC and the 28
national telecom regulators to bring an end to the uncertainty and
establish strong net neutrality guidelines. Clear guidelines will ensure
a digital single market, with the freedom and legal certainty to provide
services across borders and consumer choice.

We urge you to respect the Regulation's goal to “ensure the continued
functioning of the internet ecosystem as an engine of innovation”,
respecting the Charter of Fundamental Rights of the European Union.
Since the inception of the Internet, net neutrality has been a vital
precondition for freedom of expression, freedom of assembly, competition
and freedom to conduct business.

The success of the US and Indian consultations should boost BEREC's
work. 3.7 million comments were submitted to the US Federal
Communications Commission (FCC)'s consultation, while over one million
comments were submitted to the Telecom Regulatory Authority of India
(TRAI). These are probably the biggest direct democratic engagements in
any telecom regulatory issue in history.

Now it is the European Union's turn. BEREC decided to put the
consultation at the very end of its decision making process, with very
little time to analyse the feedback and let alone take it into account.
We encourage you to reconsider the limited and tight deadline for
responding to your public consultation, so you can duly consider
citizens and stakeholders' input when finalising the guidelines. A
flexible approach to the deadline will have no negative consequences,
but will add credibility to the process.

In the elaboration of the guidelines, we ask you to consider the
following points:
- "Services other than internet access services" (also known as
"specialised services") need careful consideration. Weak guidelines
could permit the circumvention of all net neutrality safeguards.
- Zero-Rating is a harmful practice that restricts consumer choice,
distorts competition, undermines the freedom to seek, receive and impart
information and the freedom to conduct business. The Regulation should
be understood as prohibiting this abuse.
- Traffic management should be as application-agnostic as possible.
Class-based traffic-management risks discriminating against services,
harming user choice, discouraging to use encryption and would contradict
transparency requirements established under the Regulation.

The difficult questions you are faced with in these months are not about
theoretical business models. You are setting the limits and safeguards
for the future of the Internet in Europe and ensuring that Europe will
not be globally disadvantaged by anti-competitive restrictive practices.


Signatories:

-- 
Maryant Fernandez Perez
Advocacy Manager
European Digital Rights
Rue Belliard 20 
B- 1040 Brussels
http://edri.org

Tel: +32 2 274 25 70
PGP: D59A 1D3F 50CC 231B DCFE 3F2C 92FA 6F29 3D74 0B42
@edri | @maryantfp

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