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3. Universal Access obligations under Universal Service Directive
Universal access to public fixed telephony network is the core element of universal service obligations prescribed by Universal Service Directive. The very concern of access to public telephony network is access problems in remote and low-population regions where competition can hardly be produced. However, universal access obligation does not belong to economic regulation regime but to the non-economic universal service regulation regime. In the view of Belgacom, the Commission should clearly separate non-economic regulation from economic regulation when defining the relevant markets. The definition of relevant markets under the new directives should only concern economic regulation. Any possible remaining concerns in relation to access to public telephony network can be solved through the Universal Service Directive.
4. Conclusion
Belgacom believes that a tendency towards effective competition on the retail fixed access market is increasingly visible and that these markets are not anymore characterized by high and non-transitory entry barriers because wholesale regulation sufficiently allows market entry in the retail fixed access market, based on the corresponding wholesale market 11 (local loop unbundling).
Therefore Markets 1 and 2 can be eliminated from the list of relevant markets.
B. Fixed Telephony Service Market (Market 3-6): Eliminated
1. Market Structure: Competition has been established on Belgian fixed telephony market
1.1 An oligopolistic market
In fixed telephony, some 30 alternative providers are declared with BIPT. Around ten of those control their own connections on the main PSTN/ISDN network. About 15 use carrier select or preselect. Two operators provide access to voice telephony via cable.
The last report of the European Commission on liberalisation showed that in Belgium, the shares of the four main operators need to be added to cover 90% of the market. Only the UK, Sweden and Denmark have a more diversified offer, while Germany and Austria are similar to Belgium. In all other countries, four or less operators are enough to have 90% of the market covered.
1.2 Effective competition on international fixed telephony market (Market 4 and 6)
On international fixed telephony market, the market share of Belgian alternative operators reached to more than 60% of the total number of international call minutes. Another indicator of effective competition is the fact that Belgacom has completely lost its significant market power on this market.
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