Cable Europe welcomes the opportunity to submit further comments on the Commission’s work in progress on updating the Recommendation on Relevant Markets.
Cable Europe notes that in general the markets in which its members operate have become more and more competitive, with genuinely positive outcomes for consumers being the norm. To a large extent this high level perspective seems to be evident in the Commission’s approach. Although the Commission is more suggestive of the inclusion of cable networks in the relevant wholesale product markets this appears to be based on a belief that regulation will be withdrawn. Whilst agreeing with the overall objective of this approach, it runs risks of complicating the market analysis procedure while a more orthodox approach of leaving cable networks outside the product market and considering the impact of Cable in the market analysis procedure would lead to the same outcome.