Netnod have sent comments to the Swedish Ministry of Infrastructure on the memorandum with ID I2019/02319/D The memorandum is a proposal regarding implementation of Directive (EU) 2018/1972 of the European Parliament and of the Council of 11 December 2018 establishing the European Electronic Communications Code.
Netnod have made comments related to legislation related primarily to Article 80 and 113 of the directive.
Comments related to Article 80 discuss the need for the dark fibre product in the access network to be available on the wholesale market according to non-discriminatory terms, which Netnod believe is extremely important.
Comments related to Article 113 point out that the primary distribution mechanism for digital radio today and in the future is over the Internet, and that, because of this, the regulator should focus on Internet access to vehicles of category M instead of specific receivers for specialized protocols for audio transmissions.
You can read the Netnod response, in Swedish, here.
Netnod provides critical infrastructure support ranging from interconnection services and Internet Exchanges to DNS services, root server operations and activities for the good of the Internet. As innovators at the core of the Internet with a worldwide reputation for our services and the expertise of our staff, we ensure a stable and secure Internet for the Nordics and beyond. Netnod’s range of activities include: running interconnection services and the largest Internet Exchange in the Nordics (länka till, https://www.netnod.se/ix) providing secondary DNS services to partners, enterprises and some of the largest TLDs in the world (länka till, https://www.netnod.se/dns) operating I-root, one of the world’s 13 root name servers (länka till, https://www.netnod.se/i-root) providing Time and Frequency (NTP, NTS and PTP) services for Sweden (Länka till https://www.netnod.se/time-and-frequency) Established in 1996 as a neutral and independent Internet infrastructure organisation, Netnod is based in Sweden and fully owned by the non-profit foundation TU-stiftelsen (Stiftelsen för Telematikens utveckling).