NOTE
Response from the Danish Government to the public consultation on
EU guidelines for the application of state aid rules in relation to the
rapid deployment of broadband networks
The Danish Government supports initiatives aimed at the fulfilment of
the Commission’s broadband goals for 2020 including the revision of the
guidelines on state aid for broadband networks. It is the Danish Govern-
ment’s view that there may be differences in the types of initiatives need-
ed in Member States and it is, therefore, important to retain flexibility for
Member States in how these goals are met.
The Danish Government welcomes the added clarity which the revised
guidelines provide on the considerations and examinations to be carried
out before state aid may be used. It is especially important to safeguard
the incentive for private investments in broadband infrastructures and to
ensure that the granting of state aid does not distort competition. This
follows from the Danish Government’s view that broadband deployment
should continue to be market based as a main rule.
The Danish Government suggests that the guidelines should be based on
functional requirements for both basic and NGA networks. The guide-
lines should be technology neutral and choices of technology should only
be made when project preparation is finalised based on which technology
meets the functional requirements in the specific case. It therefore follows
that specific technologies should not be mentioned e.g. in the NGA defi-
nition. Recent years have seen developments in which speeds different
broadband technologies can deliver, or can be expected to deliver within
a few years. Thus, the guidelines should be flexible as to choice of tech-
nology but they should set functional requirements.
Where it is necessary to provide state aid, it is the Danish Government’s
view that there should be a requirement that the technology used can de-
liver speeds above 30 Mbps. This suggestion is based on the Commis-
sion’s 2020 broadband goals for all Europeans to have access to speeds of
above 30 Mbps. In order to achieve the long term goal, state aid should
only be given to technologies that can deliver speeds above 30 Mbps.
Furthermore, it should be possible for Member States to decide that state
aid is only given to projects able to deliver speeds above 100 Mbps in
support of the Commission’s 2020 goal for uptake of broadband as well