DCNN (Un)Fair Share and Zero Rating: Who Pays for the Internet? | IGF 2023

Audience

The discussion surrounding Europe’s influence on Latin America’s policy decisions is of great interest. While the sentiment towards this topic remains neutral, it is acknowledged that everything discussed in Europe has a significant impact on Latin America’s policy agenda. This highlights the interconnectedness between the two regions in terms of policy-making.

The development of the interconnection ecosystem has been a notable achievement for the internet technical community. Previously, all the interconnections between ISPs and content providers used to happen in Miami. However, a significant effort has been made to develop a completely new interconnection ecosystem. This development has been positively received and is seen as a step forward in enhancing access for people and supporting industry, innovation, and infrastructure, in line with SDG9.

On the other hand, the adoption of new policies by countries like Brazil can have negative consequences. When a country adopts a particular policy, companies are required to pay and comply with the law, which may result in additional costs. As a result, companies may choose not to bring their caches and peerings into exchange points. This policy change can disrupt the existing system and have an adverse effect on telecommunications companies and content providers. The smaller stakeholders, such as small ISPs, small platforms, and small internet companies, will be particularly affected by such changes. The disruption caused by this policy change is expected to be significant, with results similar to the current scenario.

The European telecom sector is facing several challenges, with a major concern being the cost involved. The sector has experienced a decrease in revenues by 30% since 2011. Furthermore, the returns on investment for the capital employees have been lower than those in the US. This negative trend highlights the need for attention and potential solutions to address the financial health of the sector.

Investment in networks is considered of utmost importance. The focus remains on the quality of networks, along with the need to improve coverage, especially regarding 5G networks. The current adoption rate of 5G in Europe stands at 15%, underscoring the room for growth and the importance of investing in network infrastructure. These investments align with the goals of SDG9, which include industry, innovation, and infrastructure.

Another suggestion put forth during the discussion is the idea of redistributing funds from over-the-top (OTT) platforms to support telecommunications services, particularly in rural areas. This proposal aims to utilize the funds obtained from OTT platforms as a source for a Universal Service Fund, which can be dedicated to strengthening telecommunications services in areas with limited connectivity. This concept resonates with the focus of the SDGs on reducing inequalities (SDG10) and industry, innovation, and infrastructure (SDG9).

In conclusion, the discussion on Europe’s influence on Latin America’s policy decisions provides valuable insights into various aspects of policy-making, interconnection ecosystems, the impact on small stakeholders, challenges faced by the European telecom sector, the importance of investment in networks, and the potential of redistributing funds for rural telecommunications services. While some of these points have positive implications, others highlight concerns and challenges, making it a diverse and multifaceted discussion.

Maarit Palovirta

The telecommunications market in Europe faces limitations in investment for infrastructure due to its unique market structure and intense competition. Compared to the United States and Japan, Europe has a more fragmented market with 38 telecom operators serving over 500,000 customers, creating challenges in securing investment for vital infrastructure like 5G networks.

Additionally, heavy sector-specific regulations and restrictions on mergers hinder the growth of European telecom operators. Pricing regulation further limits their flexibility in pricing services. Limited investment in telecommunication infrastructure impacts service quality, trust, and sustainability, leading to decreased customer satisfaction. Efforts are being made to measure the environmental sustainability of the sector.

Despite these challenges, the European Commission deems the existing open internet principles valid and not in need of revisiting. However, operators in Europe face a one-sided obligation to deliver any traffic regardless of size or form, limiting their ability to manage data traffic.

Investments in private networks are applauded, despite creating regulatory asymmetry. The impact of these investments needs evaluation in relation to access network investment. Addressing the lack of coverage and capacity in some areas requires investment and enhancement.

The European Commission aims to deliver a new regulatory framework to tackle industry challenges and supports open discussions with stakeholders. They advocate for a check-up of the internet ecosystem and regulation framework. In conclusion, the telecommunications market in Europe faces limitations in infrastructure investment due to its unique market structure and competition. Sector-specific regulations and pricing restrictions further hinder operator growth. Limited investment affects service quality, trust, and sustainability. However, the existing open internet principles are deemed valid. Investments in private networks are praised, and efforts are being made to address coverage and capacity issues. The Commission aims to deliver a new regulatory framework and supports open discussions to address challenges in the industry. A comprehensive evaluation of the internet ecosystem and regulation framework is advocated.

Kamila Kloc

The issue of concern over internet fragmentation due to the practices of telecom companies and big tech companies is gaining significant attention. These practices have the potential to create a division between users and services, ultimately leading to increased inequality. The original intention of the internet was to be an open and interconnected environment, but certain practices have disrupted this ideal.

Limited internet access poses a significant drawback, especially for economically disadvantaged individuals. In Brazil, for instance, many people rely on public Wi-Fi or have limited access to home Wi-Fi. Towards the end of the month, when data allocations are nearing their limit, accessing the internet becomes challenging. As a result, individuals are left with restricted access to only a few apps or websites, exacerbating existing inequalities.

Additionally, limited internet access can contribute to the spread of misinformation. When people are unable to verify the information they receive due to restricted access, it becomes easier for unverified or false information to circulate. This situation leads to an increase in disinformation, undermining the goal of an informed and educated society.

The practices of zero rating and fair share also adversely affect consumers, particularly in economically disadvantaged regions. Zero rating is often presented as a way to provide free and unlimited access to specific apps or services. However, in practice, it can restrict individuals’ choices and tie them to specific apps. Furthermore, fair share practices, aimed at increasing revenue for telecom companies, may result in increased prices and reduced service quality. These practices further disadvantage consumers, especially those in economically vulnerable communities.

When discussing open internet access and methods to expand access, it is crucial to prioritize the well-being of consumers. The focus should be on finding solutions that ensure equal access to the internet for all individuals, irrespective of their socioeconomic status. Addressing the distortion of the telecom market, whether through existing or potential practices, is essential to prevent further inequality.

To summarize, the concern over internet fragmentation and limited access resulting from the practices of telecom companies and big tech companies is of growing importance. These practices can lead to a digital divide and increased inequality among users and services. Limited internet access exacerbates this inequality and hampers individuals’ ability to verify information, facilitating the spread of misinformation. The practices of zero rating and fair share also harm consumers, particularly in economically disadvantaged areas. It is crucial to prioritize consumers’ welfare when discussing open internet access and explore equitable approaches to expand access for all.

Artur Coimbra

The internet architecture has significantly changed over the past 15-20 years, with content now being located closer to users. This transformation has led to the emergence of micro data centers, content delivery networks, and caching infrastructures, revolutionizing the way content is delivered. Additionally, there has been a remarkable reduction in data storage costs, with prices decreasing by as much as 98% or 99% during this period. These changes have not only made the service more affordable and efficient but have also resulted in cost savings for IP transit contracts.

While these developments have brought benefits to users and content providers, telcos are facing pressure from large digital platforms to provide content for free. Previously, telcos charged both content providers and users through IP transit contracts. However, due to pressure from big tech platforms, telcos are now compelled to provide content without charge, leading to a shift towards a one-sided market. This transition has placed telcos in a challenging position as they are unable to increase charges for users due to legal restrictions on data caps and other market factors.

A market solution is seen as a positive approach to address the pressure telcos face from big tech platforms. Creating a healthy and sustainable network is an incentive for both telcos and big digital platforms, emphasizing the need for a market-driven solution.

It is important to differentiate whether the pressure telcos experience is a result of bargain power or market power exerted by big tech platforms. If the pressure is due to bargain power, it is considered a norm within the business environment. However, if it is a consequence of market power, then it becomes a structural issue that necessitates intervention from regulators and legislators. This distinction is crucial in determining the appropriate course of action.

In Brazil, regulators are adopting an evidence-based approach to define the problem before seeking a solution. Gathering evidence and understanding the issue better is seen as essential for achieving the objective of increasing funds available for network investment.

When designing the concept of a fair share, careful consideration must be given to ensure sufficient funds are allocated to network investment. If the fair share results in pricing competition among users, the available funds for investment could be depleted. Therefore, striking a balance between fair treatment and maintaining adequate investment funds is vital.

In conclusion, the evolution of internet architecture has brought about positive changes, including cost reduction and improved services. However, telcos now face challenges due to pressure from big tech platforms. Finding a market solution and distinguishing between bargain power and market power will be crucial for maintaining healthy networks. Regulatory intervention may be necessary in cases involving market power. The regulator in Brazil is adopting an evidence-based approach to addressing the issue at hand. Designing a fair share concept that enables investment without depletion of funds is of utmost importance.

KS Park

The standard payroll rule implemented among internet service providers (ISPs) in South Korea has had several negative consequences. This rule has resulted in inflated internet access fees, which have put a financial strain on both ISPs and content providers. Content providers have been required to pay more as their host ISPs send more data to other ISPs. Consequently, South Korea’s transit IP fees have become significantly higher than those in Frankfurt and London, reaching ten times and eight times the respective fees in those cities in 2021. As a result, public interest apps, such as the COVID location announcement system, have been unable to fully function due to the exorbitant internet transit fees.

Furthermore, the presence of paid peering has caused confusion and violated network neutrality. A significant portion of internet traffic goes through paid peering points, which has led to concerns about unfair share violation and the lack of network neutrality. The confusion surrounding whether network share and unfair share violation are a result of paid peering persists.

Regulations from both the Federal Communications Commission (FCC) and the Body of European Regulators for Electronic Communications (BEREC) do not explicitly condemn paid peering, leaving room for uncertainty and complications in enforcing network neutrality.

The concept of mandatory paid peering is also met with negative sentiment. Implementing mandatory paid peering would likely lead major companies such as Google and Netflix to disconnect from the network rather than pay access fees. If content providers burdened with peering fees disconnect, regulators would have limited options without fundamentally altering the nature of the internet.

Despite these issues, the principles of freedom to connect and not charging for data delivery remain positive aspects of the internet. These principles are considered the foundation of the global product of the internet and enable users to connect freely without being burdened by data delivery charges.

On a positive note, despite a five-fold increase in data traffic, the cost of network maintenance and development has remained constant over the past five years due to technological advancements. This demonstrates the efficiency and progress made in maintaining networks and supporting the growing demand for data.

Turning to the topic of 5G, Korean telecoms have faced challenges in delivering good connectivity despite forcing consumers to purchase 5G phones. This has resulted in consumer dissatisfaction and the filing of class-action lawsuits against telecoms. Additionally, the government in Korea has taken away the 5G bandwidth license from certain telecoms, further complicating the situation.

European telcos, on the other hand, have managed to maintain profits despite falling revenues, thanks to the decreasing cost per unit of data. They have been able to offset the declining revenues by reducing the cost of data delivery.

However, it’s important to note that declining profits of telcos do not guarantee the maintenance of privacy. The Korean case, for example, indicates that despite falling costs and sustained profits, privacy has not been adequately protected.

In conclusion, the standard payroll rule among ISPs in South Korea has had negative effects on both ISPs and content providers, causing financial strain. The presence of paid peering has raised concerns about unfair share violation and violated network neutrality. Despite these challenges, the principles of freedom to connect and not charge for data delivery are key pillars of the internet. Technological advancements have enabled the cost of network maintenance and development to remain constant despite increased data traffic. Challenges with 5G connectivity and lawsuits have arisen in Korean telecoms, while European telcos have maintained profits through reduced data delivery costs. However, the declining profits of telcos do not guarantee the protection of privacy.

Konstantinos Komaitis

Applying old telecoms rules to the internet is widely regarded as detrimental, as it would result in unanticipated barriers to entry. This approach is seen as nonsensical, considering that telecoms rules operate under the pretext of the Internet Governance Forum. The argument against these rules is based on the belief that they would hinder competition and impede innovation in unpredictable ways.

It is also argued that the internet infrastructure is not solely dependent on telecom operators. A diverse range of actors, including technology companies, contribute significantly to the development and maintenance of the internet ecosystem. Content and application providers play a vital role in supporting internet infrastructure, as exemplified by their contributions through CDNs, data centers, and cloud services. Therefore, portraying only telecom operators as the sole contributors to internet infrastructure is inaccurate.

The issue at hand also revolves around network neutrality, and concerns have been raised regarding the potential discrimination against certain applications and counterproviders. These cases highlight the violation of network neutrality principles, not only from a technological standpoint but also in terms of economic fairness.

The debate around Universal Service Funds (USFs) has garnered criticism from various perspectives. Telefonica, for instance, suggests that Europe should not replicate the USA’s approach to USFs and instead advocates for direct payments as a more suitable solution. Additionally, Komaitis questions whether telecom companies genuinely desire a discussion centered on USFs, suggesting a misalignment of interests.

Criticism is also directed towards Europe’s telecom model, which is deemed as setting a poor example. Komaitis specifically points out flaws in Europe’s approach and highlights the need for a more effective model.

Notably, over 20 organizations globally, including Brazil, India, Europe, and the United States, express similar concerns about the infrastructure issue, indicating a widespread and significant global concern. This highlights the need for a global dialogue and deliberation on infrastructure, led by civil society organizations.

Komaitis stands firmly against the current method of discussing infrastructure and believes that it needs fundamental changes. He argues that the current conversation around infrastructure is primarily driven by telecom operators, neglecting the perspectives and interests of other stakeholders.

In conclusion, applying outdated telecoms rules to the internet is widely seen as detrimental and likely to create unforeseen barriers. The internet ecosystem relies on diverse actors, including technology companies, and portraying only telecom operators as contributors to infrastructure is misleading. The issue at hand encompasses concerns over network neutrality, technological and economic discrimination, universal service funds, Europe’s telecom model, and the need for a more inclusive and global discussion on infrastructure. Komaitis takes a stance against the current infrastructure dialogue and calls for a change in approach.

Thomas Lohninger

In the discussion surrounding the telecom industry, several key points emerge. Firstly, the practice of zero-rating, which allows users to access certain online content without incurring data charges, is prevalent in many nations. This practice controls how users experience the internet by incentivising them to use certain services for free.

Concerns have also been raised about the shift in the telecom industry towards prioritising profit over quality. Some argue that this focus on profit optimisation may lead to a deterioration in the overall user experience. Critics suggest that this approach could result in the elimination of local caching services, potentially increasing costs for consumers.

The concept of net neutrality is also a contentious issue. It is argued that network fees are inherently incompatible with the principles of net neutrality. Those who support net neutrality argue that all users should have equal access to the internet, without any discrimination or preferential treatment based on payment.

Opponents of a proposition that violates net neutrality predict that it would be harmful to society and the internet ecosystem as a whole. They argue that such a proposition would violate the principle of net neutrality and would primarily serve the profit margins of telecom companies. Instead, they suggest that the concerns and needs of society should be the deciding factor, rather than simply focusing on telecom companies’ profits.

Commissioner Thierry Breton has faced criticism for not upholding due diligence standards. His previous role as CEO of France Telecom has led to accusations that he broke his promise in the European Parliament. In response, some countries, such as Germany and the Netherlands, have issued letters to the European Commission, urging it to uphold due diligence standards.

Furthermore, when it comes to network investment, there is evidence suggesting that simply investing more money in improving the network infrastructure may not necessarily result in better quality for users. This challenges the notion that money is the main bottleneck in network rollout.

The influence of corporate interests on the decision-making process within the European Commission is also a point of concern. The appointment of the former CEO of France Telecom to the commission is seen by critics as an example of corporate capture. This has led to the promotion of potentially damaging ideas that have been rejected by stakeholders other than telecom companies.

Additionally, the creation of a major telecommunication oligopoly in Europe is viewed by some as an unfavorable outcome. Instead, it is argued that a more desirable model for the telecom industry would involve competition and cooperation among multiple players, rather than domination by a few.

There are also diverging opinions regarding the nature of telecommunications. Some argue that it should be treated as a public utility, prioritising public access and welfare. On the other hand, there are those who disapprove of market deregulation in the industry, likely due to concerns about inequality and the integrity of the market.

In conclusion, the telecom industry has sparked various debates and concerns. The practice of zero-rating, the shift towards profit optimisation, net neutrality, corporate influence, network investment, market deregulation, and the nature of telecommunications as either public utilities or market-driven entities are all key topics of contention. Clear arguments have been presented from different perspectives, each supported by specific evidence and rationales. The discussions highlight the complex challenges faced by the telecom industry and the importance of carefully considering the potential consequences of various policy decisions.

Jean Jaques Sahel

The analysis of the speakers’ views on the internet ecosystem and its impact on consumers, innovation, and infrastructure provides valuable insights. One of the key points emphasised by the speakers is the need to enhance the open internet to drive innovation and foster digital transformation. They argue that strong emphasis should be placed on preserving the open nature of the internet, as it has been a game-changer in providing access to information for people globally. They also highlight how the internet has become an essential tool for everyday life and the economy as a whole.

Efforts to improve internet connectivity should not only focus on urban areas but also on reaching the last 5-10% of the population in hard-to-reach areas. The aim is to bridge the digital divide and ensure that everyone can benefit from the opportunities offered by the internet. In this regard, it is important to facilitate the easier deployment of internet infrastructure, making it more accessible to remote communities.

The analysis also recognises the significant contributions made by content and application providers in the internet ecosystem. These providers play a crucial role in driving innovation and creating products that attract customers. Additionally, they fund infrastructure such as subsea cables, which help transport traffic more efficiently and save costs for internet service providers (ISPs). The speakers argue that content and application providers should be acknowledged for their massive contributions and the positive impact they have on the network infrastructure.

Regulatory frameworks and market evolution were also discussed as important factors in shaping the internet landscape. The speakers suggest that improvements can be made to regulatory frameworks, both in Europe and worldwide, to accommodate new technologies and seize emerging opportunities. They highlight the need for a forward-thinking approach that embraces the positive aspects of the evolving market.

Stakeholder inclusion was another aspect that was emphasised. The speakers argue that all stakeholders, including consumer organisations, civil society organisations, industry, academics, and the technical community, should be invited to speak at internet governance events. This inclusive approach ensures a well-rounded and diverse perspective in decision-making processes.

Evidence-based decision-making was also highlighted as a crucial factor in internet governance. The speakers emphasised the importance of utilising expert analysis from organisations such as BEREC, telecom regulators, OECD, and the German Motor Police Commission, among others. This approach promotes informed decision-making that considers the implications and potential challenges related to internet governance.

In conclusion, the analysis highlights the need to enhance the open internet, extend connectivity to remote areas, recognise the contributions of content and application providers, improve regulatory frameworks, embrace market evolution, foster stakeholder inclusion, and prioritise evidence-based decision-making. These actions will ultimately contribute to a more accessible, innovative, and inclusive internet ecosystem.

Luca Belli

The analysis examines three perspectives on zero rating and the increase in internet traffic. The first perspective asserts that zero rating is less common in the global north, but prevalent in the global south. In the global south, large platforms have been subsidised through zero rating for the past 10 years, resulting in these platforms generating most of the internet traffic. This prevalence of zero rating has created a new kind of poverty known as “data poverty,” whereby users quickly exhaust their data allowances, similar to running out of money. This perspective presents a negative sentiment towards zero rating and its impact on internet access and digital rights, thereby emphasising the need for fair share.

The second perspective critically examines operators who claim to promote fair share. It argues that these operators are responsible for implementing business models that have led to the exponential increase in internet traffic. Therefore, their assertion of fair share appears self-serving and contradictory to their own actions. This viewpoint highlights the negative consequences of these business models and expresses a critical sentiment towards operators’ claims of fair share.

The third perspective focuses on the shift in telecom operators’ perspectives on increasing internet traffic. It points out that, until the pandemic, telecom operators, especially in countries like Germany, encouraged high video consumption through schemes like BingeOn. However, it is now intriguing that these very operators consider the increase in traffic problematic. This observation indicates a change in their perception and raises questions about their motivations and inconsistencies in their approach.

Overall, the analysis emphasises the negative impact of zero rating on internet access and digital rights, highlighting disparities between the global north and south. It also critiques operators for claiming fair share while implementing business models that contribute to the surge in traffic. The shifting perspectives of telecom operators further highlight the need to scrutinise their motives and actions. These insights underscore the importance of addressing the issue of zero rating, promoting responsible consumption and production, and reducing inequalities in global internet access.

Luca Belli:
is a member of the Brazilian Consumers Pacific Information Policy Lead and Global Telecoms Policy Lead at Google. Then we will have K.S. Park, who is Professor of Regulatory Affairs at Aetno. Then we’ll have Thomas Loninger, who is Executive Director at Epicenter Works. And last, but of course not least, Konstantinos Komaitis, that is non-resident fellow at why we are here and what is the aim of today’s session. We want to discuss the emerging tensions on the fair share or unfair share, as K.S. was reminding us, debate, and also which kind of connection exists with the previous debates that we have been discussing over the past years, especially zero rating debate, net neutrality debate. Over the past year and a half, especially, we have been witnessing that the proposed solution may not be so effective. So the reason why we have today such diverse panel is precisely to try to understand what are the different standpoints in this debate and try, ideally, to come to some common ground and maybe even policy suggestion for the future. Now, without further ado, I would like to give the floor to our first speaker, Artur Coimbra, from the ANATEL, the Brazilian Telecoms Regulator. Artur, you have been working a lot on telecoms over the past. I don’t want to reveal your age, so I’ll just say that you have a certain experience in this. So please, Artur, the floor is yours. Thank you, Luca.

Artur Coimbra:
Good morning, everyone. I’m here representing ANATEL, the Brazilian regulator. And let me just start by saying, to disappoint you, and say that as the so-called fair share or unfair share, I mean, network fee, is an intended solution to a supposed problem that we’re still assessing, I’m not here ready to say whether it’s fair or unfair. But I just want to provoke the debate with some elements. ANATEL, for example, has just disclosed this night the results, the mapping results of arguments of its call for subsidies that it made three months ago. And we had 627 individual contributions on this topic that were mapped and disclosed a few hours ago. And now we’re going to dive into the arguments and provide an outcome of all the contributions that we received. Let me just start by saying that internet architecture has changed a lot in the last 15 or 20 years. So in the golden age of internet, we had the users, we had the content, which was present in big data centers, expensive infrastructure, located in a few places in the world. And between them, connecting users to the content, they were just the network itself through IP transit contracts, bringing content to the user. So the point is that in the last 15 years, data storage costs reduced by 98% or 99%. So it was a great revolution on micro data centers, content delivery networks, caching, and other kinds of infrastructure that brought the content near the user and changed the landscape of internet architecture. So today, you not necessarily need a full set IP transit contract to bring the content to the user. And instead, many, many providers are getting the content just across the street in a micro data center and bringing it to do. It’s better for everyone because it’s cheaper. The service is better. You save money on IP transit contracts. So theoretically, everybody wins. But alongside that phenomenon, we’ve seen the growth of some gatekeepers that are gaining more and more economic relevance and adding value to the network, in fact. And people want to access internet to get to that specific content. That brings a lot of negotiating power over big digital platforms. So when there’s a CDN and the content’s near the user, and the operator has to deploy its own network to get that content without receiving nothing for the traffic, instead of using an IP transit contract by which the operator used to receive the payment from the content provider and, in the end, by the user, well, there was a two-sided market that has become a one-sided market. So that’s what it is, the plea that telcos say. And there’s another issue. The other issue is that, in many cases, telcos plea that they cannot charge the user more for the consumption of a huge amount of data due to legal restrictions on data cap or to other market factors. So in the end, the argument is that you had a two-sided market by which you charged the content provider with the IP transit contract. And then you also charged the user. Of course, he’s the user. And this two-sided market is becoming a no-sided market. So this pressure, which could be a competition pressure, it’s certainly a negotiation pressure. So this pressure raises the question, which is necessary to be answered before we decide if the fair share is fair or not. And the question is, is this pressure that big tech, big platforms are putting on telcos, is this pressure the result of a bargain power or of a market power? This is the main issue. If it’s bargain power, it’s part of the game. Just go ahead. If it’s market power, then there’s a structural issue that must be tackled by regulators and by legislators and so on. So this is the main question that should be answered before we decide what to do with this. Anatel is working on it. But my final line here, and I think that the great takeaway of this discussion is that they’re both on the same side of the boat. Telcos and big digital platforms, they both depend on healthy, sustainable networks. Otherwise, it’s bad for everyone. So that is an incentive for them to try and find a market solution, which would be great for everyone. And I really trust on that happening. And we hope that. We just hope for the best.

Luca Belli:
OK, so thank you. Thank you very much, Artur, for these initial points. Very well explained. And now let’s stay in Brazil, but from a consumer perspective to understand a little bit more the complete picture of this evolving discussion. Please, Camila, the floor is yours.

Kamila Kloc:
Thank you so much, Luca, for the opportunity, and also for you that are here in this time of the morning. In Brazil, we have this context of this public consultation made by Anatel. But we have also a bigger context in Brazil in discussions about the neutrality, zero rating. And it involves not only the telecom authority in Brazil, but other several authorities. For example, zero rating practices were already analyzed by the competition authority in the past. And now the Ministry of Justice has been pressured also to analyze these practices in terms of consumer law. And this pressure was made by civil society. So to present myself, I am a specialist in digital rights and telecommunications in the Brazilian Institute of Consumer Protection. And we are part of a network on digital rights, including access to internet. And we are trying to raise these issues from more of a consumer perspective. And I think that this is the biggest challenge on that. Because when we are talking about fair share or unfair share, we are talking about big companies. We are talking about big techs versus big telcos, the new companies, like the traditional companies. And the ones that suffer the most are consumers in the end. So to answer directly the question, yes, for most part of the Brazilian society, definitely for EDEC and from the Coalition Networks in Brazil, it is unfair share if we have to fee companies to these kind of services. We are very concerned of internet fragmentation. And we are very aware that the motive, the reason that the internet is successful is that internet was created to be an open environment, an internected environment. And once we do practices like this, we separate. We created more of second and first class users, first and second class services in the internet. Since the commissioner have already talked a little about the consultation in Brazil, I would like then to focus on how the unfair share connects to zero rating. And for this, in the last few years, we’ve been working so hard to present not only these critics and these arguments against this kind of practices, but also to bring data on that. In Brazil, we have a strong organization that makes internet connectivity research every year, which is CETIC, which is related to the Internet Brazilian Steering Committee. But we also have been developing a research in EDEC to bring this data. And nowadays, we are also developing research with Anatel. But to focus on this research that EDEC conducted in 2021, pandemic time, sorry, if I’m not mistaken, one of these two years. But we’ve been interviewing the Brazilian poorer classes to understand how do they use internet and how these kinds of limitations, for example, the zero rating ones, affect their lives. So we found out that people with lower classes may have mobile phone internet just for 21 days a month. So 21 days of 30 days. What this means? This means that in the last days of the month, people are depending on Wi-Fi, public Wi-Fi, or home Wi-Fi, which not everyone have. And people rely more on mobile phone access. And this kind of access is limited. It’s not based on speed. It’s based on data franchise. And once the internet is over, you have some kind of access. But which kind of access do you have? You have access just to some limited apps, some limited companies, which in Brazil are the big techs in the end, especially meta. This brings some issues that I know that I’m expanding a little the scope of this lookup. But it’s important to say that when we are talking about telecom, when we are talking about access, we are talking also about other rights. So disinformation is also a huge issue that is a consequence on all of that. Because once people do not have access to confirm the information, they receive some information, for example, in WhatsApp or Facebook, and they share it without confirming it. So we have to talk about these issues, not only talking about net neutrality, not only talking about internet access, which would be in the center, but to talk how this affects several other rights. So thank you so much, Luca.

Luca Belli:
Thank you very much, Camila. So to start stressing this connection between the fair share and zero rating, and actually to add a little bit of element of complexity, I think that maybe for people in the global north, if we can say so, where zero rating is not that common, this does not sound evident. But in global south country, observers are a little bit puzzled when they hear this debate about platforms contributing more to network fees, because platforms have been subsidized, basically, with zero rating for the past 10 years. And I think we have been speaking about this issue several times over the past years, the fact that zero rating actually would have created this kind of situation where large platforms are responsible for most of the traffic, precisely because they have been subsidized, sponsored for free with zero rating in most global south countries. So it’s interesting to see that nowadays, after having offered this traffic, and as Camila was saying, in some parts, some weeks, the last week, is a new kind of poverty in many countries. At the end, you finish your data allowance, like you finish your money. And then as you don’t have more money to go to the supermarket, you only have data allowance to have social media, basically. But that is not something that has happened, because the internet is like that. It’s a result of a specific business model. And many of us have questioned that business model. But now it’s surprising to see that, on the other hand, we see operators that may claim fair share when this, if you want to say, large use of the network is the precise result of this business model that has been enacted over the past 10 years precisely by operators. To understand a little bit more of the complexity, let me give the floor to Jean-Jacques, that has been also dealing with these issues for, I don’t want to reveal again your age, but for a lot of time. Thank you. Thank you, Luca.

Jean Jaques Sahel:
Good morning. I mean, I’ve been dealing with the open internet since I first tried the internet in 1993, because it’s always been open, although it was very, very slow, I have to admit, in 1993. Certainly from where I connected at the time in Marseille, it was like a 56k modem connection linking three universities. That was the only one connection. Now we have 12 subsea cables arriving in Marseille. We have fantastic connectivity. Although I’ve been actually hearing people complain that we have too much, too many cables arriving at the city. So we need to know what we want anyway. But that’s kind of part of the discussion in a way. I think generally speaking, it’s great to be at the IGF and in forums like this, where among stakeholders across different parts of the ecosystem, we can look at the concerns that there are. And we can try to look at the evidence, share ideas for what could be improved. And I think what we all care about here is, at the end of the day, how can we get a good internet tool? An internet that’s affordable, that’s got good speed, good capacity. And why do we want that? Because, well, it’s enjoyable for people, hopefully, but it also can support digital transformation. It can help our societies. It can help our economies. It can help us as people every day. That’s really the end goal. So connectivity as a means to support wider benefits to the economy and society. And that’s the end goal. And so when we get to this debate of network usage fees, as they are referred to in some places, I actually think it’s a false debate. And it was a false debate when it was first mentioned in something like 1999. You can see the quotes. They were pretty much the same as what’s been said by some people, actually sometimes the same people then. It was a fake debate 10 years ago. Not to say we shouldn’t have the debate, but I think we need to move on. I think the reality is that, and I think most of us in the room know this, we are an ecosystem in the internet, starting with users and encompassing essential elements in this virtuous cycle that we have. And these essential elements are the telecom operators, network operators, and the content and application providers. There is a virtuous dynamic where there is innovation, there are content and services created that appeal to customers or to consumers, users, and then they subscribe to the internet. And I think that’s been working well for 40 years. It’s still working well today. That’s what the open internet is about. It’s innovation without permission that boosts this whole ecosystem and supports the benefits that the internet has been bringing us. And when we think about this from a business perspective, when we, as a company, look at ISPs, telecom operators, we see them as essential partners, both indirect partners in the sense that we create content and applications for our users. They provide that connectivity that users want to access our content services. So there’s a nice indirect element, indirect dynamic. And then we have direct relationships. We partner with telecom operators on a huge amount of things. And it’s been like that for many years. We do it for commercial reasons. They might resell our cloud or add bundles of YouTube premium, for instance, perhaps in their own subscription packages. But we also do some infrastructure work with them. So for instance, increasingly, we help them with storing some of the network aspects, elements in our cloud. They use some of our data analytics to optimize their networks and make cost savings. Or indeed, we look at much more innovative things. For instance, we have a joint 5G research center with one of the large operators in Europe. So we have all sorts of direct partnerships as well. It’s a very dynamic and generally very fun way of doing things. and fruitful environment and I think that’s the sort of thing that we’d like to focus on, this virtuous ecosystem. So going back very briefly on network fees because there’s been some great points made, I think it’s been shown already, the introduction of these fees would be very unhelpful to consumers, to competition and also to the technical workers of the Internet, to the efficient routing of Internet traffic. Many stakeholders have said that, including a number of governments, telecom and competition regulators and efforts. We need to focus instead on real problems, thinking about how we can get the open Internet to really favor innovation and encourage users to use it, to enjoy the Internet and support digital transformations. I think we need to join forces together and look at the genuine issues. Think about things like how do we reach the last five or ten percent of the population that live in difficult to reach areas? How can we use a mix of interesting new technologies perhaps to reach them as an example? How can we continue to facilitate making it easier to deploy infrastructure like to lay fiber or to lend submarine cables or to make more spectrum available for instance on an unlicensed basis so that we can facilitate things like Wi-Fi offload which take the strain off the networks. How can we bring basically resiliency and diversity to connectivity and support the use of the open Internet for the good of society, the economy and us as users people. Thank you.

KS Park:
Excellent. Thank you very much Jean-Jacques. And actually now I would like to give the floor to KS Park because South Korea is actually what the only example of a country where this kind of fees have been introduced and so it would be interesting to understand what is the result of the concrete result in the Internet ecosystem of this of the implementation of this model. So standard payroll obviously works like tax on Internet to be exact taxation on speaking online because to speak online you have to push out data onto the network so the more you speak the more you have to pay somebody. Just like in the days of you know snail mail and telephony to send a letter out you have to buy a stamp to make a phone call you have to pay the telecom company. So this has made this created now the rule was instituted only among ISPs and using that as an excuse the policymakers did not consult with the consumers and content providers. So the standard payroll applies only among ISPs but the economic impact of that of course trickles down to content providers because ISPs hosting popular content providers will end up pushing out more data to other ISPs because users on other ISPs will want to access that popular content and you know accessing the content means the data files made up of HTML will have to be pushed out to the users. So that creates this incentives across the board among ISPs to host popular content or any content and that has increased you know that basically removed the competition among ISPs in selling their services to in hosting good content on their network and that has increased the internet access fees. Well I mean it didn’t really increase what happened was up you know that because of the technical advancement that Arturo talked about the internet access fees are falling by 20% every year but Korea it didn’t happen so that continued for about the rule was instituted like 2016 and now it’s almost seven years now over seven years the what actually immediately even 2017 the internet access fees or in technical terms is transit IP transit fees in South Korea was clocked at what was measured to be eight times that of Paris five six times to Los Angeles in New York and the trend worsened in 2021 the internet access fees or IP transit fees became ten times Frankfurt eight times London. You can see the the financial a very hostile financial environment that startups have to domestic startups I say domestic because the domestic ones have to buy internet access from local telcos and like 2021 Korea’s answer to Netflix called the watcher video streaming service was paying 10% of its revenue as internet access fees. In 2020 public interest app like COVID location announcement system it’s also app the the operator complained that because of high internet transit fees they cannot fully function they cannot meet all the demand so that’s what’s happening with the domestic content and overseas content providers they also have a problem because because of this you know this this incentive this the this incentives among ISPs from hosting popular content applies both overseas content when they are on the cache servers I mean I should have talked about how data storage has become cheap and then now the content is coming across the street so a lot of content is being served through cache servers on the network of Korea’s ISPs but even hosted a cache server has become you know unpopular among ISPs because they have to bear the center pay burden so they are charging increasing the you know what is technically paid peering fees that they have charged the overseas content so twitch which is a popular gaming platform they could not continue making the payment so you know they could do two things they could charge the uploaders from Korea for uploading right because it is because of them or they could charge the contents that are popular among Korean eyeballs right it is those contents that are generating more payment burden on twitch they couldn’t do that because I mean you know making people pay is a very unfair so what they did was they intentionally degraded that service they lower the resolution to to 750 so only in Korea you know users are watching at a lower resolution than other parts of the country so a lot of users are leaving a lot of gamers are also leaving because you know Korean gamers video will be watched more by Korean eyeballs and that is and if Korean eyeballs are you know getting lower resolution Korean gamers will leave and this I mean we can we can extrapolate that to like Netflix I mean you know squid game is popular Korean titles they are yes world popular but they are yes the word popular but they are also initially popular with the Koreans too right it’s it’s a Korean eyeball heavy contents and if Netflix is required to pay Korean ISPs for accessing Korean consumers they’ll have to reduce investment in Korean heavy Korean eyeball heavy titles so that is the situation in Korea I hope you guys don’t learn this lesson or learn the lesson either way and I hope I have a few minutes later to talk about some of the general yeah thank you very much KS for this insight and actually I think I propose we finish with the all

Luca Belli:
the presentation so that we then have a good moment for discussion because I’m sure there will be a lot of remarks comments and occasions to discuss more this let’s move now to Europe that is now the center has been the center of the attention of the past year at least for a consultation from the European

Maarit Palovirta:
Commission so Marit Etno has been one of the main proponents of this fees so please marry the floor is yours thank you look and thank you to the organizers of the panel it’s very nice actually to hear global views as you know we’ve been discussing this in Europe a lot mainly amongst ourselves but it’s really really I think fruitful to also have this global exchange and just to go to the title of the workshop so many of you know that zero rating is is no longer a reality in Europe so I will focus my comments on the on the fair contribution as such and perhaps for the sake of well the audience today who maybe you haven’t followed all the discussions in Europe I will start with a few few thoughts on on how do we see the telecoms market at the moment in Europe and I already heard some of the keywords from from the different interventions namely to do with the kind of market structure and competition and the different dynamics that are related regarding consumers of course and and society as a whole so I’ll try and give you a bit of a background here as a kind of a starting point so indeed we do have been now for nearly two years advocating and have tried to bring some well kind of describe the context around this fair contribution issue from our perspective and the markets in Europe as we see today is and many of you puppies saw that the European Commission published the summary results of the public consultation just two days ago so I’ll use one of the quotes that they put into that which came from the ethno GSM a reply and is with regards to the competition so in Europe when we look at the number of operators in the EU markets the number of operators that are serving more than 500,000 customers so more than half a million customers in Europe is 38 in the US that is 7 in Japan that is 4 so the market structure in the EU is significantly different that it is in many other parts of the world that could be comparable to Europe that means that as we are in an industry of heavy capex investment so digging fibers into the ground building towers for 5g etc that requires a lot of money a lot of effort by by many people and it means that simply this current market structure does not allow for proper investment into these infrastructures that actually our society wants our consumers want that’s our policy makers and politicians want that and also we want that but the current market structure simply doesn’t allow for that the return on investment doesn’t allow for the investment. We have some regulatory specific circumstances in Europe so we have competition policy that restricts mergers so telecom operators are not encouraged or allowed really to merge with each other for the moment just to simplify things we have still some heavy sector specific regulation for the telecom sector for example on pricing so we have pricing regulation you have all heard maybe about the roaming rules in Europe wholesale prices they are all fixed prices so flexibility to price services is limited and just to give you an idea that also the competition in the market due to the fact that well there is this kind of sticky prices situation but also the fact that there are so many players is that despite the very heavy inflation that we also I think in our country’s last year the telecom sector in Europe was the only industrial sector where the price growth was negative so the prices went down despite the inflation and this is because of the heavy competition pressure on the industry and the pricing elements that I just described so there are some real pain points in the European telecom market that may not necessarily exist in other parts of the world. Now when we look at the consumer impact of course the main point of operators is to provide good services for the consumer and affordability certainly is a key issue and I think I just provided some elements why Europe has the most affordable some of the most affordable internet services in the world but also other important factors are things like quality so if we don’t invest sufficiently quality eventually will suffer trust if we don’t invest you know and update security and make sure that we are you know bringing the new layers into the networks also this factor will suffer and this will at the end we believe will start well making our consumers unhappy as well so it’s not only a question about prices in Europe it’s about these other factors so we are really looking at this from this kind of more holistic perspective and maybe a third factor I would like to raise because we talk a lot about societal welfare at the moment so you know security is certainly one thing but sustainability environmental sustainability is also important so we are now developing different kinds of KPIs in Europe to try and make sure that all industry players including operators and networks are as sustainable as possible and that of course means that we do not only measure but we also again invest in networks to make sure that in always possible we try and make them as sustainable as possible so that’s a little bit where we come from in Europe and so you know I’ll kind of we see that our hands are at the moment a little bit tight and I would like to maybe touch on the net neutrality point as well you know very well that Europe is is one of the very few well countries or regions in the world where we have net neutrality open internet regulation and you may also know that the European Commission evaluated this regulation I think it was earlier this year and asked many stakeholders including us if we should reopen this regulation if we indeed reconsider it perhaps and as the Commission has also many times said publicly that no stakeholder came forward asking for reopening of the regulation and indeed so etno together with again the GSMA so representing really 80-90 percent of the European telecommunication markets said we are happy with the open internet principles the regulation the text okay you may argue if it’s you know the best as we kind of look at the developments in our industry today but it is not worth opening it because we still believe that the principles are valid and this of course from our perspective also then I’m going to enter a little bit to the market asymmetry that we see related to the contribution it means that we as operators have a must carry obligation just again to simplify things so operators will carry any traffic how big how small in whatever shape or form coming from whoever to the end user today in Europe or if they don’t then they of course risk going to the court which you know some operators might want to do but in general I don’t think this is the case and so there is a one-sided obligation to deliver traffic and again this then gives us very limited possibilities to manage and try and optimize the data traffic and this is as and as we know that this is something that has again gone up quite a lot so we are in a situation we have where we have pressure on investment but we also have them pressure on on this kind of increasing digitization of our society which of course we all welcome but we need to make sure that you know we have a balance between the networks that are supposed to deliver this and our key part of our internet ecosystem and then this kind of services and content part so maybe I’ll just stop there and happy to then chip in later. Thank you very much Mariette for providing your time.

Luca Belli:
I would like to thank you for the opportunity to be here, and I would like to thank you, Luca, for providing us a very good overview of the telecom market in Europe, and speaking about the consultation, I know that also Thomas has been very active into participating in this, and might have also a different perspective on it, so please, Thomas, the floor is yours.

Thomas Lohninger:
Thank you very much, and I would like to thank you, Luca, for the opportunity to be here, and representing the telecom industry in this round, it might not be easy, and I think it’s always a pleasure if we get to have this exchange, and these honest exchanges are necessary for moving the debate forward. Martin and I had a very similar debate, actually, last IGF, in Ethiopia, and I’m a little bit saddened that we always need to have these debates in other corners of the world, and while I’m not a big fan of the idea of zero rating, and I don’t know if that’s happening in Brussels, it’s very rarely that voices from consumer protection or civil society are present there, so maybe that’s a good reason for having the IGF, I think. Anyway, I would also like to touch on the issue of zero rating and network fees, because, yes, we have no more zero rating in Europe, but still, those two things are very much connected. Zero rating by the IGF is a very, very common practice in many nations, and here you have to hit theero rates as the free market is in control how the user experiences the internet. If you look at the political statements, zero rating was a very common practice happening in all but one member states and it is, as Lucas described, incentivising the user to use the internet for free. So the free market is now becoming the problem, it is now cluttering up the pipes. And I want to also maybe focus in a little bit on why there is such a drastic shift that we are discussing here. Internet connection used to be something altruistic, it is something where nerds put cables together in order to make the internet whole, to allow global end-to-end connectivity, and that’s usually done and then the user is able to use the internet for free. And the free market is now becoming a place where we are optimising quality, and with this proposal we will drastically step away from that. We will optimise for profit, we will maybe no longer have local caching service. We would need, like we see in South Korea now, make a far longer travel in order to get to the data that we want. And it would become more expensive, ultimately, either the prices that we as consumers have to pay or the quality we have to pay for it. And I think this is a very important point, because maybe that’s not clear for everyone, why net neutrality is inherently incompatible with network fees. Everybody agrees that even in the oldest version of net neutrality, you cannot have paid fast lanes. You cannot have one railway for everyone, and then a faster railway where you have to pay in order to be on it. And in fact, you only get good quality with Deutsche Telekom, a big German provider right now, if you pay them. You will suffer every night, every peak hour, with your service, if you don’t have a paid connection into their network. And, yes, technically speaking, they are not slowing down the traffic within their network. They’re just ensuring that the entrance to their network is a bottleneck that’s always congested. And funny enough, their prices to have these interconnections are 10, 20, 30 times more expensive than everyone else’s. It is very important to make a pause here. We are now one and a half years into this debate, into the 2020 iteration of it. For the first time, we have a public record from the consultations in Brazil and in Europe on what happens. We have a public record from the consultations in Brazil and in Europe on what happens. And we have a public record from the consultations in Europe on what everybody has said. I only had time to look at the European one, but I think it’s interesting to just list the people who have contributed, the organizations and what they’ve said. We have the conglomerate, the body of all Telekom regulators that say this violates net neutrality and is dangerous for the Internet ecosystem. We have the private organizations who have the logic and provide consensus. We have multiple organizations that went on to their statement. And it’s not just the regulators, it’s the public broad casters, it private broad casters, the journalistic associations. We have the ITF community from the ITF downwards. We have the ITF from the ITF upwards. We have the ITF from the ITF downwards. And, of course, the copyright industry. Disney is on the same side as Google and as consumer protection organizations. So this is a coalition of unlikely allies. And to conclude, maybe, I think actually we don’t have a problem with the market structure in Europe. We have a problem with the market structure in the EU. So, I think, it’s important to say that, yes, telecoms are making profits. Just not big enough profits, but if whole society is complaining and saying, stop, this will hurt us, maybe the profit margins from telecom companies shouldn’t be the deciding factor if everybody else gets hurt by such a proposal. And, lastly, I also want to say that now almost five months ago, the European Commission on Telecommunications, the EPC, announced that it would be giving up on this proposal, funny enough, on the same day when it was announced, that Commissioner Breton is giving up on this proposal for this legislative term. To remind you, Commissioner Thierry Breton used to be CEO of France Telecom. And as a European, I have to say I’m shamed by the way he has broken every word in the European Parliament, but I am shamed by the way he has broken every word in the European Parliament. So, please, Germany and the Netherlands issued letters to the Commission saying exactly the same. Please uphold due diligence standards, and at least when Europe influences a worldwide debate like in India and Brazil where everyone is referencing Europe, we should set ourselves to a higher standard. Thank you.

Luca Belli:
Thank you very much. I think it’s a very good point, and I think it’s also on one of the points that you mentioned about the very large and diverse spectrum of stakeholders that participated to this consultation, raising some concern with the effectiveness of this proposal. And I think that, honestly, if we had the same consultation with the European Commission, we would have had a much better result. And I think it’s a very good point, and I agree that it is, with all due respect for Google, of course, there is a need, maybe, to have a better regime, a more effective regime of taxation, but I think the fundamental question here is that maybe the goal, the way forward is not really to tax the traffic that is injected in the network because consumer demanded, but they also demanded that the network be redistributed in a more effective way so that then the benefits can be redistributed socially, right? So I think that we, virtually everyone would agree that a fair share, some kind of fair share is not a bad idea, but maybe this type of fair share is not really the solution that, for the problem, right, if you want larger redistribution of wealth. So I think that, again, it’s a good point, and I agree that it’s a good point, and I agree that there are a lot of international elements, maybe also shared by Constantinos that has been working a lot on internet policies, infrastructures, for the past decades, again, not revealing anyone’s age here, so please, Constantinos, the floor is yours. ≫ Thank you, Luca, good morning, everyone, and thank you for showing up, I really thought that this would be an empty room.

Konstantinos Komaitis:
So I think that one of the things that has happened in the past 20 years is that we have been attempting to think of the internet, which is a new medium, by applying old rules, and telecoms rules have been one such rule that we have been trying to apply ever since I remember starting in this field, and this is really a bad idea, because telecoms rules operate under the pretext of the Internet Governance Forum, and it doesn’t make any sense, and it doesn’t make really sense, because it will create, really, barriers to entry in the most unpredictable of ways. We are at the Internet Governance Forum, and all of us are talking about how to support the open, global, and interoperable internet, and there’s really no question that if we apply this policy, the open and global and interoperable internet, we will be able to do that. We will be able to do that. In the internet, the great thing about the internet is that really there is no network that is more important than another network. The more networks connect with one another, the bigger the value for the networks themselves, and also for their customers. And this also creates more resilience, because the more networks you have, the more decentralized the system is, and you are avoiding single points of failure. So, the Internet Governance Forum has created a system that works, that doesn’t require regulatory intervention, and it, of course, has allowed to have low barriers to entry. And, of course, it has fostered all these very collaborative relationships, which I’m sure collaboration is very challenging in the best of times, but so I’m sure that collaboration is challenging in this instance, but let’s not forget that the internet, the open internet, is an outcome of collaboration amongst many different and diverse actors. So, that was my first point. The second point is about the infrastructure and the idea that currently, or at least that’s the way the policy, this policy idea has been framed, is that there is only one actor contributing to infrastructure, and these are telecom operators. And this is not necessarily true, right? Technology companies, content and application providers, are contributing heavily in the internet ecosystem and its infrastructure, CDNs and data centers, and cloud services being clear examples. And the OECD is actually working on a report, which hopefully will be released next month, but the scoping paper made a really, really strong case about the diversity of infrastructure, and that it comes from the most unpredictable places that we can imagine. Municipalities. Contribute in internet and broadband infrastructure. Pension funds. HEDS funds contribute in infrastructure. Of course, telecom operators. Technology companies. Tower companies. So, we see a whole huge ecosystem where different players contribute to make sure that we have a reliable, secure, and sustainable infrastructure that can support the increasing demands on the internet. And, of course, we see a whole huge ecosystem where different players contribute to make sure that we have a reliable, secure, and sustainable infrastructure that can support the increasing demands of users, because the fact of the matter is that there is an increasing demand. Right now, everybody wants to stream video, and that is what it is. But there is this collaboration, if you want, that is happening. People are coming all together in order to make sure that networks can actually support this. So, I think that, in the end, the ECJ has been, has tried to ease the concerns that this is not a network neutrality issue. But I would bet, well, not a lot of money, because I don’t have them, but I would bet money on it that if that case were to go before the ECJ, it would have been a very, very different outcome. In Europe, I think we’ve heard it from everyone, we have the open internet regulation, and between 2020 and 2020, we have the open internet regulation, and between 2020 and 2021, there have been four cases that, and two of them actually said that the, it’s not just the technology discrimination that violates network neutrality, meaning that, you know, when you’re blocking or you’re throttling traffic, but it’s also economic discrimination. And two in particular cases focused specifically on that, on the idea that if you choose certain applications and counterproviders to making those deals and not apply those deals to everyone else, this is also against the open internet regulation and network neutrality. So we have to be clear about this, that this is predominantly about internet neutrality, and, again, I appreciate the effort to try to make it less so, but that is not really the case. And I will stop there.

Luca Belli:
Thank you. Thank you very much, Konstantinos. And actually, one of those cases, the Telenor case, was precisely about also zero rating, and it’s good to see, to hear from Marius that Europe now has abandoned this policy that many of us have criticized over the past year, but it’s also good to remind that until the pandemic times, in countries like Germany, there were, like, models like BingeOn that were literally, as the name suggests, it was an invitation to binge on video, and so the fact that now the telecom operators consider this increase in traffic as something problematic may be curious for those who were used to see the very same telecom offering for free video traffic, and encouraging users to use it as much as they can carelessly, actually, through BingeOn models. I think we have had a lot of very interesting suggestions so far, and I would like to hear from you. Thank you. Thank you very much, and I’m very happy we still have half an hour for debate, because I’m sure there will be a lot of debate. Now, let me start by opening the floor, because I know that you are not only very brave to be here at AFPA State in the last day, but I see a lot of people that may be interested in sharing comments or asking questions. So if you want to ask questions or share your ideas, please, you can line up and use this mic. Otherwise, we can, I think, go on. I think we may have, I’m sure we’ll have reactions here from the panel. If you have any questions, just raise your hand or line up there. Otherwise, we can start with the reactions here. Yes. Okay, yes. I think one confusion on whether network or fair share and unfair share violation of network neutrality is because of the presence of paid peering. Although it doesn’t account for a lot of traffic, I mean, well, it doesn’t account for a lot of connections. Most connections, more than 99.99% are settlement-free peering. But even through that small number of connections, a lot of traffic goes through that.

KS Park:
So if you look at the data from RCEP, the French regulator, although the number of connections is mostly settlement-free peering. In terms of volume of traffic, sizable portion of internet traffic go through paid peering points. But that does not ‑‑ and then, you know, FCC has not clearly, FCC in the U.S. or even BEREC have not clearly said, you know, that this is not the case. So I don’t think it’s a problem. I think it’s a problem. But I also think it’s a problem. I think, you know, the US government and the French government have not clearly said, you know, open internet regulation applies against paid peering. So what Telcos ‑‑ I mean, Telcos are not really saying it, but, you know, to be a Telcos advocate to make their arguments more reasonable, they may be saying that, oh, you know, this is a paid peering that has existed before, and, you know, Google has paid orange, paid peering fees, and Netflix has paid, Comcast paid peering fees before. So we just want to make it rule to make it more fair, and this does not violate net neutrality. But what they are forgetting is that this will, number one, will not be enforceable. Well, actually, it’s the same point. There is no number one or number two. It’s the same point. This will not be enforceable, because it will be mandatory paid peering, but what has really supported the information revolution is two rules. Freedom to connect and net neutrality. Okay? So freedom to connect and no freedom to charge for data delivery. These two rules are actually, you know, they are not enforceable. So freedom to connect and net neutrality. Freedom to charge for data delivery. These two rules are actually the two sides of the same coin. It is because the network participant, it is because ISPs are bound to this rule that they cannot charge for data delivery. They can charge only for connection capacity, not for data delivery. It is because of this what Mary called one-sided obligation, although I don’t think it’s obligation, it is more like an obligation. Thank you. exchange of promises over between ISPs to sell this global product to the Internet. It is not really an obligation imposed externally. But anyway, it is because of this one-sided obligation that all ISPs have a freedom to connect or not connect. And if a mandatory paid peering is imposed, what’s going to happen is Google, Netflix, they can say, oh, you know, we don’t want to pay fees to access customers in your network. And then they’re going to just connect. And the eyeballs in that country will no longer access Google. If all these content providers burdened with peering fees don’t connect, what are the regulators going to do? I mean, there’s really not much we can do if we want to keep the Internet as it is. So I think it’s unenforceable, and I think it is really pulling the rug under the fundamentals of Internet architecture, which is freedom to connect or not connect and remover of data delivery fees. Mary talked about how prices are falling. I want to ask whether your costs have been falling also. Because of the advancement of technology, putting together KPEX and OPEX, even with the catapulting of data traffic like five times, the network maintenance cost and development cost have remained the same in the past five years. So I thank you very much for the very extensive points, KS.

Maarit Palovirta:
And now, Merit, please, the floor is yours to reply. Yes. Maybe just on immediately on that question, the costs, no, they’re not falling. And if you read carefully the summary of the consultation, actually, there was some general language around that as well. They are not, of course, able to quote numbers because these are commercially sensitive, but the costs are not falling, no. I wanted to comment on the IP interconnection market because there is this, in Europe and much globally as well, still this very old-fashioned way to think that IP interconnection means peering and transit. And that’s the market, and that’s the base for competition. Now, in the last years, we’ve seen reports, including by BEREC, including by Analysis Mason, that, in fact, CDNs should now be considered a substitute to transit and peering. So in fact, the market definition has effectively changed, and we should be looking at a market that also includes the CDNs. Now, if you look at the CDNs that, for example, many tech players have in Europe, these are, of course, often proprietary infrastructures, and they’re also infrastructures where these owners and the operators of these CDNs, they sell capacity at a price to whoever needs capacity, so whoever needs their content to be delivered. And these prices, because they’re proprietary networks, are not publicly known. They are not considered in a market analysis when we look at the peering markets. And we actually are very happy to see that BEREC now, in their program for next year, have quite an ambitious kind of a task. So they will be reassessing the IP interconnection market, and very much also taking into account the CDNs, the role of CDNs, and how have they contributed to the IP interconnection market, because this is, of course, a development that has substantially changed the scene in the last five years. And the last assessment that BEREC did was five years ago. So I think that when we talk about the regulatory asymmetry, this is one example of such asymmetry. And if you look at the internet ecosystem a bit more widely, we recently were with Jean-Jacques in the same BEREC workshop talking about submarine cables, undersea connectivity. And there we see a little bit the same phenomenon. So we have these public cables where you sell capacity to others. Some of them are in consortia, including with European operators, consortia with some of the big tech companies. But there is a substantial amount of cables that are purely private. And for example, European operators don’t have the investment capacity to be running many private cables like that. But then, of course, we hear that about now, about 70% of, for example, the traffic between the US and EU goes through these private cables. So not actually being in the public best effort internet. And we are again here observing that the telcos who in consortium are now operating these cables that are publicly available and sell capacity. We should also think about what does that do to neutrality? So some content gets a real highway in a proprietary network, whereas other content has to go through these operated publicly available channels at a kind of best effort level. And we really applaud, I think it’s great, I mean, this is not a regulated market. So I think it is great that, of course, that companies find that you invest and there’s good things. But again, going back to the regulatory asymmetry, then when we look at the positioning of how this traffic then comes into, in our case, Europe, and is then divided and goes through the national networks, we need to look at the market power. What does it do in this kind of bigger picture? And hence, we are very much also then welcoming the BEREC’s upcoming work on this. They will do work on the entry of caps into the ECN market in European language, so content providers into the telecom markets. They are also going to be analyzing the role of cloud computing in this context. And also then doing a kind of a holistic mapping of the submarine connectivity scenario. So I think that that will give us a bigger picture. And I understand that the fair contribution, it’s very difficult sometimes to define because it is a very specific point in that ecosystem. But we need to look at the bigger picture and then see what is the impact of this interconnection point vis-à-vis the access network investment in Europe. Thank you very much for this. And actually, it will be very useful also then to study the methodology that BEREC will develop to this kind of study that could even be used as a good practice exported, maybe globally. I’m sure that Jean-Jacques has a reaction to your reaction, so please, Jean-Jacques.

Jean Jaques Sahel:
Thank you. I want to pick up on both Mariette and KS’s points, and I want to start by thanking Mariette because I think it’s been a debate that’s really interesting where there have been these accusations flying about fair contributions saying that content and applications providers do not contribute. But as Mariette has just explained very extensively, there are pretty massive contributions by content and applications providers. Of course, as Konstantinos was saying before, I think it was you, content and application providers help this ecosystem by providing the content and services without which, frankly, no one would pay telecom operators for an internet subscription. The only revenue that a telecom operator would make if it weren’t for the content and applications that we invest in would be telephony and SMS. If they want to go back to that, that’s fine. They don’t have a must-carry obligation for the internet. They can stop being internet providers because the internet is about a network of network. Once you connect to one endpoint, you have access to the global network. That’s what the internet is about. But you don’t have to provide that service connecting to the global internet, the global unique open internet. You can provide private networks. That’s a very profitable business. Or indeed, you can invest in new types of technologies that are related, like CDNs. You can be a CDN operator, and in fact, a lot of telecom operators have developed great CDN services, which they’re making a lot of money on. So going back to the contributions by content and application providers, so there’s that massive investment by content and application providers in innovating, in creating products that will delight customers and encourage them, therefore, to subscribe to internet service provider services and upgrade their subscriptions to things like 5G, for instance, or Fiber. Then you mentioned CDNs, and I think that’s really important. Yes, there are CDNs. What do CDNs do? They help to transport traffic much more easily, and so that’s another payment that content and application providers can make in order to deliver the traffic to end users with better quality, another form of contribution. And then you mentioned things like subsea cables, and the great thing about that is that whether they are private or public, or a mix of public and private networks, again, they help to bring traffic much faster, more efficiently, and save massive costs for ISPs, because instead of ISPs having to fetch the content from another part of the world, the traffic is brought by those content and application providers, 99% of the way to the user, and the telecom providers can do the last mile. That’s a huge cost savings for the operators. Cloud service is the same way, and when we look at how the cloud and associated services and some of the data analytics and AI can help to optimize network to support operators, which is what is happening today, again, it’s saving costs for ISPs, and it’s providing new avenues for monetization for the telcos. So as a summary, we’re in a situation where there is absolutely zero point in claiming that there is no contribution by the content and application providers sectors, because there is enormous contribution, as just exposed by Marit, and more importantly, I think we should look to the future, we should look at new technologies, we should look at the evolution of this market, as BEREC and OECD and others are doing, and look at the positives of how we can move forward together. There are improvements we can make to regulatory frameworks in Europe and elsewhere, in Brazil, etc. I think we should focus on that, on the real problems, look at the evidence, look at how we can help each other as an ecosystem, focus on that, rather than some people trying to instigate fights and fake battles when there’s none to be had, and that would do a disservice

Luca Belli:
to everyone. Excellent. Thank you very much for this. I see there are questions, and I also see there is one, at least, from the audience, so let’s start with the question from the online… So let’s start with the question on site, and then if we can have some of these online participants speaking, we can do it, otherwise we will only stay with the… Otherwise, the online participant can type the question and we will read it. Okay, thank you, Luca. Good morning, everybody.

Audience:
My name is Raul Echeverria, I’m from Latin America Internet Association, and this is… I don’t know if you know, but everything that is discussed in Europe has a huge impact in the policy agenda in Latin America, and this is not the exception. So it would be very funny that Europe abandoned the idea of moving ahead with this, and we will have probably some decisions, policy decisions, in some countries in the region. Some years ago, all the interconnection between ISPs and content providers used to happen in Miami, and in the last few years, the Internet technical community has done a huge effort to develop a complete new interconnection ecosystem, and has had a very positive impact in the access for the people. So what would happen if, for example, we are discussing this now in Brazil and also in the Caribbean, and that is very interesting, because it’s a kind of paradox, because Brazil is probably the country that has invested more in exchange points in the world, maybe. And the Caribbean is probably one of the places who more needs improved interconnection. So it doesn’t make sense that those are the two places that we are discussing this. But so what will happen? Who will win with this? As the colleague pointed out, 99 percent of the people are informal and for free. Why this? Is it because the content providers are ISPs and telecoms are stupid? No. It’s because all of them understand that they are adding value to each other. And so the market already spoke. So what will happen with that? What will happen, in my view, is that if a country like Brazil adopt a policy on this, obviously, companies will pay what they have to pay, and they will follow the law. But so they will not have incentives to bring their caches and do peerings in the exchange points and to bring the caches into the telcos infrastructure. So they will say, OK, we will pay what we have to pay, but now you have to pick our contents in Miami. So we are going 15 years back. And they will say, ah, and don’t forget. Obviously, it will not be informal. Now we will have to sign some contracts. So we will involve our legal departments, and it will take one year to have the contracts in place. Ah, and it will not be for free. We will have to negotiate that. At the end of the day, the situation will be the same than now. They will pay exactly what they have to share, to have a zero sum in the agreements. So there will not be winners, but there will be losers. Who are the losers? Small ISPs, small content providers, small platforms, small Internet companies. That will be the end of the tale at the time of starting negotiations with the other parties. So I think that the disruption will be huge, and at the end of the day, the result for telcos and content providers will be probably the same. Thank you very much, Raul, for providing these additional points. Do we have our remote participant, participant speaker? Can he or she speak? I don’t see any satisfactory reaction from the technical team. Hello? Oh, yeah. Oh, Gonzalo. We meet again. Hello, Luca. Hello. I don’t see you. Hello. Please. Hi. This is Gonzalo. I work for Telefonica, an ISP present in Europe, an ETNO member, so working with Marek on the first issue. I just wanted to address a few of the comments that have been raised during the session regarding the cost of the networks are going down and related to revenues, and also related to how this virtual cycle is benefiting all of us. I would like to stress that the telecom revenues have been decreasing for the European telecom sector 30% since 2011, where, for example, in the US, those same revenues have been increasing 18%. And at the same time, the returns of investment of the capital employees, which actually takes into account the revenues, the cost and investment, has been lower to 6% in Europe, where in the US, for example, that’s at the level of 14. And actually, that means that in Europe, the returns are lower than the cost of capital. So the money that we have to pay to get the funds for those investments is costing us more than the returns that we make on those investments. So that means that this is not really a virtuous cycle. It is not a situation where we all benefit. In fact, it was the case at the very beginning of the internet, but it is not the case anymore. It seems that when telecoms returns are lower than the cost of capital, we are losing money on every investment that we do. So basically, what we aim with FairShare is actually trying to foster the investments and to keep up the investment for the quality of the networks that the European needs. And for example, we can see that even though investments have been at levels of 20% over revenues, which is similar to the rest of the world, in terms of investment in euros per capita, in Europe, we have been at levels of 100 euros, where in US, that’s 200 euros per capita. And that has meant that, for example, the coverage of 5G networks, the take-up of 5G in Europe is 15%, whereas in Korea, it’s 50%, or in the US, it’s 40%. So Europe is already falling behind in the development of networks, and that’s why we want to change the situation. And one last comment on the comment from Mr. Bertone, I think that we have read a different publication, because what I see that Mr. Bertone has commented is that he wants to go ahead with a Digital Network Act. And the fact, I have not seen any place that it has been delayed till 2025. If you see how a legislative process works in Europe, it is impossible to implement a legislative process in one or two year time. So actually, even though the process might be starting, the proposal might be coming up in early 2024, it’s impossible. to have this passed through the European Parliament before the general elections for the parliament taking place in June. So actually, I don’t see any delay there, but being realistic and taking into account that the processes in Europe take two years the least and in some cases, as you have seen with privacy, DMA and so others, it takes more than three, even four times. Thank you. Thank you. Thank you very much, Gonzalo, for these elements.

Luca Belli:
I think we have less than 10 minutes left, so I would ask all of the panelists to have a last chance to provide a final remark, some food for thought, because we have already had a lot of very interesting comments, discussions. Sorry? This was not the question. Okay, I thought there is another question. What is the question? But maybe this question from the, so let me also thank Shilpa Singh from the University of Melbourne, who is our remote moderator. So do we have a question from the online participant? Can you take a mic? Can we pass a mic? So this question may inspire your last thoughts. And yes, you.

Audience:
Please, Shilpa. Yeah, my very rough understanding for contribution is to redistribute the money from OTT to telecoms. My question is to share what. In the previous session that this person organized, this person shared the same opinion, and is it okay if it is treated as this particular money is used as a universal service fund for rural areas?

Luca Belli:
To improve the whole balance sheet to telecom is not adequate in her opinion. Okay, excellent. So I think the question is whether if this money would be used to improve universal service funds or for other uses. You can reflect on this question while you think about your final thought.

Kamila Kloc:
So I would like to start maybe with Camilla, and so we follow the order. Let’s say one minute per person. I’m gonna be quick. I can see like a battle of titans in here of different industries, which is also important to understand all of the arguments, but beyond of these arguments and beyond of the argument that we’re mostly focused also in the global north, like I can understand that Europe has a different context, but we are talking about two practices that harm consumers. Zero rating, which continues to affect the global south, favoring tax, by alleged the free and limited access, which in practices is a bundle, like it obliged people to use some apps. And fair share that might favorize telcos and potentially increases the prices and reduce quality as we were talking about Korea. So in both cases, we are talking about the distortion of telecom market, of present practices or future practices, but in the end, we are talking about, we are not focusing on how this affects consumers in the end, we’re talking about industry’s interests. So let’s focus on consumers when we’re talking about this on open internet access, on meaningful connectivity and how to increase access, not only on how we can impulsionate companies. So thank you.

Luca Belli:
Thank you.

Maarit Palovirta:
So just to the question that we said, yes, of course, from our point of view, these funds would be going towards investment and especially in those areas where we don’t have coverage, but also in capacity. But going to my final comment, I would like to say that Thomas was saying that it might be difficult for us to be here, but I would like to say it’s actually a real pleasure because we took a decision early on in this discussion, actually, before we published the very first report, that we want to have the discussion with everybody, with all stakeholders openly ourselves and not hiding behind think tanks or consultancies. I think that we are trying to live true to this intention that we had. And I think I will provide one personal thought and one political thought. Personal thought, I think this is a very healthy checkup of the internet ecosystem to see where we are today. And in the case of Europe, where we have a kind of intense regulatory framework to see what needs to be done there. And a political message comes from our friend, all of our friend, Thierry Breton, who in the LinkedIn post two days ago, says that we need, quote, a bold, future-oriented, game-changing Digital Networks Act to redefine the DNA of our telecoms regulation, unquote. And I’m just really pleased, and we put a statement out at non-GSMA that the commission has this ambition to actually deliver a new regulatory framing for us. And this, we hope, means that there will be fair contribution, but we also hope very much that they will address some of the pain points on competition, on scale, on sector-specific regulation

Luca Belli:
that I was describing earlier. So thank you. Thank you. So my final message would be, as a regulator in Brazil, that we really should assess and define precisely the disease that we want to heal before prescribing the medication.

Artur Coimbra:
So you have a commitment of regulator in Brazil of having an evidence-based approach. And well, if the problem is lack of money for investment in networks, we should design a model that allows more money for investment in networks. And for example, depending on the way you design a fair share, you may or may not reach that objective. So if there’s a competition between prices and you create a fair share, there’s a great chance that this money runs away by lowering more and more the prices, because there’s competition overpricing for the user, and so no money is left for investment. So this should be designed in a way to get what we really want, which is money for investment. So that’s the final message that I bring, that the commitment of Brazilian regulator that we’ll make all the effort to gather evidence to try and define the disease before prescribing the medication. Excellent. Indeed, evidence-based policy should be based on evidence. And we are very happy that this panel is providing a lot of very good thoughts on how to collect this evidence. Final round of…

Luca Belli:
Thank you, and thanks again for having us.

Jean Jaques Sahel:
We’ve been trying to organize a workshop at the IGF. We did a proposal, really balanced panel, et cetera. It wasn’t accepted, so I’m really glad that Luca and team organized this. Really, really glad that we were able to be together and here as representative of all stakeholder groups. And I think that’s one of the things that’s come out here. All stakeholders should be invited to speak. I hope that we can see that across all those discussions, that we can have consumer organizations, civil society organizations, alongside industry, academics, technical community being regularly and proactively invited to speak at these events in Brussels, in Brasilia, and elsewhere. I think that would be fantastic to see in the future. And then I think what we’ve also heard is that there’s clearly, from all the speakers, including Etno, that it’s quite clear that there are massive investments, contributions by content and application providers, including to network infrastructure. And so CAPS can contribute fairly. And I think that’s quite a clear conclusion here. Yeah, I think just going back to what Arthur was rightly saying, this should be about evidence. I think there’s just a lot of lobbying arguments that are flying around, quotes from this, from that. I think we should focus on expert analysis, BEREC, telecom regulators, OECD, German Motor Police Commission, and others who are studying this. And indeed, as Marit was saying, it should be taking a broad, holistic perspective on the market and its evolution, absolutely. So we look forward to further analysis of what’s already been produced by these expert organizations and also what they’re already starting to work on next. And just to finish up, I think really important what we’ve heard already, just starting with the Global South perspective, let’s remind ourselves what this is all about. This is about access to information at the end of the day. This is what the global and open internet brought us. We did not have such an amazing access to the internet globally through a simple connection to one network just 30 years ago, or indeed 20 years ago, or indeed 10 years ago in many parts of the world. And it’s thanks to the work of many telecom operators, content providers, local communities that have developed this, et cetera, et cetera, and the technical community in this room and in this venue are to be thanked for all of that. And so let’s be really careful in these debates that we don’t tinker with the foundational open nature of the internet that means that we have access to all this information and this utility that is good for consumers, for us as users, for our everyday lives and our everyday economies, and it has and will continue to boost those economies and benefit our societies in the future. Let’s not tinker with that. Let’s not end up with information winners and losers, whether it’s in the global south or the global north. This is about the global internet, whether it’s north, south, west, or east, and we shouldn’t tinker with this basic open foundations.

KS Park:
Thank you. Correction. I think somebody said Korean telecoms are profiting a lot from the standard pay model so they could afford to increase the 5G coverage to what? 50%? Well, that is because only Korean telecoms with their oligopoly hold on the market, they sold the new phones only with the 5G features. So consumers are forced to buy 5G phones, but the connectivity is, 5G connectivity is so bad that there are 5G consumers filing Class X and lawsuits against telecoms right now, and so bad that 5G bandwidth license was taken away by the government. So, you know, no rose picture there. And I think this answer is the last question that just came in. Will telcos use the new revenues from standard pay model for developing more network? I don’t think so. I mean, monopoly, when it becomes profitable, it becomes self-perpetuating. They want more profit. Korea case shows that’s not the case. I mean, we are in Japan. Internet penetration rate, both Japan, Korea at the top, that’s just penetrate, like where the internet is. In terms of connectivity, if you use a, I’ve never used a Wi-Fi this fast in Korea. The difference between Japan and Korea, big telcos in Korea are not participating in internet exchanges. There is no internet exchange in Korea. Big telcos in Japan, they are all participating in big internet exchanges in Japan. In terms of connectivity across the country, Japan is much better. When I said cost is falling, I meant cost per unit of megabyte that is delivered. That is definitely falling. Somebody’s lying. If somebody’s saying that it’s not falling, therefore, you know, despite the falling revenues, because of the falling cost, that’s why the profit is being maintained by European telcos. But the final question, it’s unfair, right? I mean, if it’s becoming so unprofitable that, you know, profitable that you cannot maintain privacy,

Luca Belli:
maybe we should turn telecoms into public utilities. A lot of interest in those. Yes, go ahead. I see applause in the room. Yeah, I want to go back to the question again. So as Spark has perfectly outlined, even if that money were to be invested in the network,

Thomas Lohninger:
the quality that we as users would experience would still be worse than we have today. And there’s also ample studies and evidence that money is actually not a bottleneck in network rollout. So very often, there are other factors at play. And so, particularly in the context of Europe, it would not really help us solve the problems in rural areas that we still have. And to me, really, I want to close on what I deem to be the most shameful thing as a European here, talking about this issue with now this ludicrous idea having become picked up by so many other world regions. And there’s only one reason for that, corporate capture of the European Commission. I mean, a former CEO of France Telecom has managed to make his way into the commission, warmed up a 10-year-old idea that at its face is just crazy for everyone. And now we have a public consultation with everybody’s voices proving that it is crazy, proving that it is refused by everyone except the telcos. And what is the response that we hear today from Telefonica? Oh, we don’t make enough money. Sorry. But if that is your sole argument, then yeah, maybe we should really rethink business models. And ultimately, what Digital Networks Act or whatever it is called, there will be something. I mean, Breton has to deliver for his cronies at least something that will deregulate the market. And I fear that, again, that this will go against the success recipe for telecoms, which is competition and cooperation. We don’t need like the US, an oligopoly of a few very big mafia-like telecom companies. And yeah, I think I’ll leave it at that.

Luca Belli:
The final word to Cosentino. Oh, great. Thank you so much.

Konstantinos Komaitis:
So very quickly, to the last question about USFs, we were having a conversation yesterday. I don’t think that we could discuss USFs, but I don’t think that this is what telcos want. Here I have, it’s a blog post from Telefonica saying why Europe shouldn’t copy the USA’s Universal Service Fund. So, and why the direct payments is actually a better option. And Europe really is setting a very bad example. And this is why, and this will be sort of a pitch, there is a global concern from civil society. There was a statement that was released yesterday. More than 20 organizations from around the world, civil society organizations, co-signed it. Brazil, India, in Europe, the United States, they express the same concerns about the same issue. And I think that it is time that if we want to have a conversation about infrastructure, let’s have it. But this is not the way to do it. Because obviously, no one really wants this conversation to happen apart from telecom operators. All right, I think what we said today

Luca Belli:
that there is also other ways of having the conversation. And I’m very happy we had a lot of different views represented. I would like to thank everyone for their effort, not only to be here at AFA SAIT, to fly here, or even to contribute as Gonzalo did while in Europe. So a lot of very good ideas, a lot of food for thought. I think that everyone here now has the sufficient element to form its own opinion independently.