Netnod replies to EC white paper on digital infrastructure

On 24 February 2024, Netnod was given the opportunity by DG CONNECT to comment on the European Commission’s White Paper “How to Master Europe’s Digital Infrastructure Needs?” (COM(2024)81, hereinafter “WP”). Netnod believes that the WP does not take into account the design and architecture of the Internet, and does not recognise the importance of the Internet for society.

Netnod’s comments can be summarised as follows:

1. The leitmotif of the WP concerns further convergence and vertical integration of networks in the EU, which is contrary to the Internet model and contrary to the findings of BEREC.
2. The WP confuses access technologies, such as 5G, copper and optical fibre, with backbone infrastructure, which for all intents and purposes is only optical fibre. The commission needs to take account of the fact that 5G and copper are access technologies, which do not provide end-to-end connectivity, only access to backbone networks.
3. The WP does not in any meaningful detail discuss the Internet. The commission should consider that digital and electronic communication today is based on the Internet architecture using an Internet infrastructure. 

It is Netnod’s view that the divergence between DG CONNECT and BEREC is problematic.

Please read the full answer below (pdf) for further details.