"The European Commission has released a 41-page document named 'A Digital Agenda for Europe'.
It was first time we have had such an agenda, and we would like to congratulate the Commission for its work.
In the weeks to come, many organisations and individuals will study the agenda, and will find a number of issues to praise the Commission for.
However, we would like to focus our attention to several key items, which we believe it did not address.
The Commission suggests improved governance and transparency of collective rights management, while in fact the EU lacks the mechanism used by Google and other content providers, which cut deals with copyright holders so that people can today download content legally from YouTube and other sites.
The copyright holders in most if not all EU member states have built a system which corrupts government officials, spreads false information about so-called piracy, and encourages the inclusion of these countries in the US Trade Representative's Special 301 Report.
This problem is not addressed in the Digital Agenda.
Furthermore, the Agenda claims 'Europe needs to push ahead with the creation, production and distribution (on all platforms) of digital content' - which is trying to solve a problem with administrative measures, rather than letting the market solve it. The conclusion that solving the problem requires "innovative business models, through which content would be accessed and paid for in many different ways" shows that the Commission still believes in the old, analogue model of dealing with copyright.
The models exist and are there: it is the copyright holders who don't want the new digital deal.
This is the area where the Commission has wasted so many opportunities to address the problem and suggest solutions that it clearly shows a lack of expertise, skills, people and vision at the Commission level.
Channelling international cybersecurity cooperation as part of discussions on Internet governance, for example, shows that the Commission does not understand, or is not addressing properly, the need to bring all actors together.
While the discussions on Internet governance have a long history and the EU has played an active role there, they are not the right place for action. This is easy to prove even by just pointing to the fact that neither the USA, Russia or China use these discussions to deal with cybersecurity.
Trying to move ENISA into the field of cybersecurity shows that the Commission has fallen victim to internal EU bureaucracy. ENISA was created as a temporary body which is doing specific work. It could continue doing this, but it is not the right body to deal with cybersecurity.
The Commission should already have created the office of EU cybersecurity coordinator, following the example of countries that have taken similar steps, namely Bulgaria and the United States.
The right way to deal with cybersecurity is in several steps, which the Commission has not listed in the Digital Agenda - and that's an issue which might cost the global and European markets dearly and will undermine users' trust and confidence.
In the action plan, the Commission suggests a number of moves, which seem primarily aimed at spending more money than achieving concrete results. What is lacking there is a comprehensive policy review and recommendations on how to move forward, both strategically and tactically. The proposed moves seem to be driven by different groups at EU level, who aim to keep their own space and not allow stronger coordination.
The cyber-security part of the Digital Agenda clearly shows that the EU is trying to deal with new challenges by using its own analogue tools. It is a sign that the EU is lagging behind the major countries dealing with cyber-security, but it also shows that perhaps the EU is reaching too far beyond what its current needs are.
After all, if EU citizens do not care about cyber-security, that means it is not a serious problem for EU society. This is where the Commission should have stepped in as leader of the EU, with clear statements on the dangers of not addressing cyber-security properly, and then lead the effort of bringing together all stakeholders - businesses, non-profit organisations and citizens - to secure EU cyberspace.
This is another area where the Digital Agenda seems to be more of an analogue one. The Commission still talks about broadband as the solution to the constantly growing needs of European users, but does not take into account the fact that the easiest way forward is to see what member states have done to boost high-ast speed Internet in their own territories.
The Digital Agenda wants to see more than 50% of EU web users online at speeds above 100 Mbps by 2020. This is not an ambitious goal. It shows that the Commission is searching for too little, too late, rather than ensuring the conditions for massive investment and fast delivery of fibre to the home (FTTH). The Commission believes that the deployment of high-speed Internet depends on the development of 'comprehensive policy, based on a mix of technologies,' which of course is only one of the possible ways to deal with the issue, but certainly not the one that will bring results fast.
The Commission makes another mistake by believing that there is a need for 'strong public intervention' and that EU and national policies should 'lower the costs of broadband deployment in the entire EU territory'.
In the action plan on this subject, the Commission again proves the suggested measures are part of the analogue agenda.
See for yourselves:
- The European Commission wants to spend more EU money, rather than opening the road for innovative and entrepreneurial European citizens, who could create the businesses to provide FTTH at affordable prices.
- The Commission wants to attract capital through credit enhancement - in other words, taxpayers risk their money, rather than ensuring the conditions for smooth work of Internet Service Providers.
We would like to draw the attention of the Commission to its own studies of the EU market, as well as to a survey commissioned by the FTTH Council Europe and undertaken by the Yankee Group and Stratix Consulting.
Both clearly show that aiming at broadband is not the right solution for the communication problems of the EU.
Coming from Bulgaria, clearly we would highly recommend the Commission to study the Bulgarian example of bringing Internet to the people at speeds ranging between 100 Mpbs and 1 Gbps.
This is done without the help of any of the institutions mentioned in the Digital Agenda as the ones responsible for delivering high-speed Internet to EU citizens."