Greece. 1. DIGITAL AGENDA TARGETS AND ECONOMIC INDICATORS Broadband Indicators (January 2014) 1 Speed Greece EU Average Percentage (in %)

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1 1 Greece 1. DIGITAL AGENDA TARGETS AND ECONOMIC INDICATORS Broadband Indicators (January 2014) 1 Speed Greece EU Average Percentage (in %) Growth (in %) 2 Percentage (in %) Growth (in %) Fixed broadband From 144 Kbps 99,6 0 97,1 2 coverage 3 NGA 4 26, ,8 15 From 144 Kbps 26,3 8 29,9 4 Fixed broadband From 30 Mbps 0,4 N/A 6,3 47 penetration 5 From 100 Mbps 0 0 1,6 78 Mobile broadband Basic (HSPA) 99,5 0 97,1 1 coverage LTE 54, ,9 125 Mobile broadband penetration 36,3 6 61,1 5 Greece stands below the EU average in broadband penetration as a percentage of population, fixed and mobile. Mobile broadband penetration is one of the lowest in Europe. According to the Eurobarometer survey 7 household broadband penetration also stood at 49% in 2013, well below the EU average of 60%, while 37% of the households have mobile internet access on their mobile phone, against an EU average of 52%. On the other hand, mobile broadband coverage stands above the EU average. Greece has made progress towards the achievement of the DAE targets over the past years. The absence of a broadband plan, however, raises concerns as to the ability of Greece to fulfil the DAE targets on time, amidst the prevailing economic crisis. In addition, Greece starts from a low point as it lags significantly behind in terms of high-speed and ultra-high speed broadband coverage. This appears to have been understood by the Greek authorities, who expect to adopt a National Broadband Plan by June Source: coverage data: studies by IHS and VVA for 2013, and by Point Topic for 2012; penetration data: figures provided by Greece to the European Commission via the EU Communications Committee (COCOM) for the Scoreboard of the Digital Agenda for Europe. For more information see Error! Hyperlink reference not valid. 2 Increase over the figure of a year earlier, expressed as a percentage. E.g. if there has been an increase from 20% in January 2013 to 30% in January 2014, that would be a 50% growth. 3 Coverage is the availability of the network for those who want to subscribe to the service, as % of the population. See also the Glossary. Coverage data is from December NGA fixed broadband includes FttH, FttB, FttO, VDSL, Cable with Docsis 3.0 or higher, and other NGA. See also the Glossary. 5 Penetration is the number of subscribed lines per 100 inhabitants. See the Glossary for a more detailed explanation. 6 While there has been no change in the definition of mobile broadband, there has been a change in the way one of the providers applied the definition. As a result, no comparison with the previous years can be provided. 7 Special Eurobarometer 414, E-Communications and Telecom Single Market Household Survey Report, March 2014, available at

2 2 The launch of the assignment procedure of the rural broadband project raises expectations that the remaining gaps in fixed basic broadband coverage will be filled within 30 months from the assignment, since the network operators will have to deploy networks offering connectivity of at least 8 Mbps (download) and at least 1 Mbps upload. The project will contribute to the achievement of the second target of the DAE, albeit with a considerable delay: within 30 months, the contractors should be able to offer services of 30 Mbps to at least 45% of the targeted population, including residential departments of more than 400 inhabitants. At the end of the contract (15 years), the network should be able to offer 30 Mbps in all the covered areas. Greece is putting together a new plan for the achievement of the third target of ultra-highspeed broadband. This project should address several strategic issues such as ownership (government or private investors or joint), technologies, and above all, ensure viability and financing. With regard to high-speed mobile broadband, Greece should make available by 30 October 2014 the 800 MHz band, which, combined with the 2,6 GHz band, is expected to play a significant role in the achievement of the DAE targets. 2. COMPETITIVENESS IN THE SECTOR Revenues and investment in the electronic communications sector Revenues 6,534 billion 6,436 billion 6,051 billion Increase N/A -1,4 % -3,5 % Investment 1,1 billion 0,942 billion 0,729 billion Increase N/A -11 % -22 % Amidst the economic crisis, the revenues in the electronic communications sector have further decreased. This trend is continued in , for which, on the basis of preliminary figures, the decrease in revenues is even steeper (-12% in 2013). Regarding investments we observe a steep drop in 2012, but this trend is expected to be reversed in 2013, for which investments are estimated to amount to 780 million (an increase of 7%). 3. MARKET DEVELOPMENTS This difficult economic environment moved the sector into a phase of consolidation and cooperation. While the market is preparing for additional consolidation, the agreement of Vodafone and Wind to share their 2G and 3G networks has been cleared by the regulator. In the broadband market, the launch of the incumbent's VDSL services has led its market share in the fixed broadband to stop decreasing for the first time after many years (from 43% in January 2012 it increased to 44% in July 2013 and dropped back to 43% in January 2014), slightly above the EU average of 42%. The importance of speed is confirmed in regards to household internet connections by the Eurobarometer survey, which showed that competition is driven firstly by price (82%) and secondly by the maximum download speed (59%) (compared to an EU28 averages of only 71% and 41% respectively).

3 3 In the fixed voice market, the incumbent OTE remains the leading operator although its market share for all types of calls by traffic volume has decreased over the past year to 52,2% for 2012 compared to 56,8% as of 2011, and 62,8% in The share of VoIP operators almost doubled in 2012 (from 4,3% in 2011 to 8,5% in 2012). The mobile market reached 13,6 million lines (123% penetration in October 2013) and carries significantly more voice traffic than the fixed networks (58%). The market share of the incumbent's competitors has grown slightly over the past year gaining almost 1,5 percentage points during 2012 and almost 2 percentage points during 2013.There are at present three mobile network operators in the Greek market while no MVNO is providing services yet. Prepaid services dominate the preference of consumers (64%). While mobile broadband penetration has increased, and smartphone penetration has passed from 19% in Q to 24% in Q3 2013, according to data from the mobile operators, only a few consumers in Greece make cheaper calls over the internet on a handheld service (13%, against an EU average of 21%). According to the 2014 Eurobarometer survey, 49% of the households in Greece subscribe to bundled offers, above the EU28 average of 46%. The bundled offer penetration in terms of subscriptions per population stands however at 51% in July 2013, representing an increase of 6 percentage points compared to July 2012 (EU average 66%). The double play and triple play penetrations were at 49,9% and only 1,4% respectively, representing an increase of 5,8 percentage points for the double play and a decrease of 0,3 percentage points for triple play compared to the previous year. The low take up of triple play is explained, according to the operators, by the poor quality of the local loop and by the availability of content via satellite. The average revenue per user in mobile communications dropped to 168 (from 190 in 2011) experiencing a steeper decline than the reported EU average of 187 (down from 195). 4. MARKET REGULATION In 2012, the Greek NRA, EETT, adopted decisions in the Market for wholesale 8 and retail 9 leased lines, as well as in the market for voice call termination on individual mobile networks 10. With regard to leased lines, OTE has been designated as having SMP both in the wholesale and the retail markets. In the retail market, EETT maintained the obligations of transparency and non-discrimination, but lifted the regulatory obligations of price control and accounting separation. In the wholesale markets, it maintained the entire set of regulatory obligations. With regard to market 7, designating all mobile network operators as having SMP for the termination of calls on their networks, EETT initially applied benchmarking on the basis of prices applied in Member States where a BU-LRIC model has been applied. On the basis of this benchmarking, it applied a 3-step glide path for the reduction of the mobile termination / / /1343.

4 4 rates (MTRs), according to which the symmetric MTRs were set at 1,01 euro cent as of 1 January In December 2012, EETT adopted an amendment to the July decision in order to base MTRs on a BU-pure LRIC model applicable as of January 2013 and resulting in the final MTR price for years 2013, 2014, For the year 2013 the set MTR is 1,269 euro cent, and for the following years the MTR is further reduced. This decision has not been consulted under the Article 7 procedure; EETT however notified it as its finally adopted measure. In June 2013, EETT notified the third round of review of (i) the market for local and long distance calls provided through the public telephone network at a fixed location for residential and non-residential customers and (ii) the market for calls to non-geographical numbers provided through the public telephone network at a fixed location for residential and nonresidential customers. EETT defined a single market, which included local, long distance and calls to non-geographical numbers for residential and non-residential customers. It noted that the overall market share of OTE, with reference to the volume of traffic, has decreased from 2007 to 2012 by about 22,9 percentage points, to 53,3%. In addition to the significant decline of the overall market share of OTE, EETT also observed a downward trend in the prices charged by OTE, a potential for expansion and competition by alternative operators and a tendency towards effective competition. EETT thus proposed to lift ex ante regulation from these markets. In early 2014, EETT notified the third round of review of the markets for (i) call termination on individual public telephone networks provided at a fixed location, (ii) call origination on individual public telephone networks provided at a fixed location, and (iii) transit services in the public telephone network. EETT concluded that the market for transit services no longer warrants ex ante regulation, because the three criteria test is not fulfilled. Due to the deployment of alternative networks and the development of direct interconnection, the market is no longer characterised by high and non-transitory structural entry barriers, thus no longer fulfilling the first criterion. With regard to the market for call termination, EETT proposed to designate all 18 fixed network operators active in Greece as having SMP on their respective voice call termination markets at a fixed location. While welcoming EETT s notification of BU-LRIC based fixed termination rates, in its Article 7 decision the Commission pointed to EETT s delay in the implementation of the Termination Rates Recommendation. Moreover, the Commission expressed concerns that the rate that EETT considers being BU-LRIC could incentivise inefficient market entry. This is because it is based on the assumption of an increasing market share, which is not in line with the primary objective pursued by a BU- LRIC model, i.e. to mimic a competitive market which supports only efficient operators. The Commission urged therefore EETT to ensure that the FTRs result from a BU-LRIC model would ensure an efficient entry and are modelled already in 2014 on the basis of an efficient operator s market share that has been stable over time. In the market for call origination, EETT proposed to designate the incumbent as having SMP and proposed a price control obligation based on top-down LRAIC+ methodology, but explained that the call origination prices could deviate from the output of the top down model in case OTE wants to recoup the cost difference between the top-down LRAIC+ termination rates and the pure BU-LRIC model termination rate, which could lead to an increase of the call origination charges in Greece. The Commission alarmed EETT that shifting costs from the wholesale call termination market to other regulated services may hinder competition. The Commission therefore called upon EETT to make the necessary adjustment to its final measure as well as

5 5 to reflect it in its subsequent assessment of OTE s request to recoup certain costs which are no longer recovered through the termination tariff from the call origination regulated products. 5. BROADBAND PLANS AND FINANCING While Greece has not yet notified its National Broadband Plan, its drafting is, according to the Greek authorities, significantly advanced. The current plan foresees a public consultation in the second half of May 2014 and the completion of the plan in early June. The market is longing to see the views of the Government, in particular with regard to the feasibility and the financing of the highly advertised project FttH. Moreover, Greece has announced the national-wide WiFi project, which foresees, at a first phase, the deployment of around WiFi hot-spots spread over the country. The WiFi hotspots will be deployed in indoor and outdoor public areas, indicated by the municipalities (e.g. squares, libraries etc.). The project aims at promoting the use of ICT in Greece and at inducing broadband demand. The Ministry released at the end of the first quarter of 2014 its draft Strategy for the Digital Development. In parallel, two State Aid projects received clearance. On 16 January 2014, the Commission adopted a decision not to raise objections with regard to a 5-years prolongation of the State Aid scheme Broadband development in Greek rural areas, which was approved by the Commission on 10 November The aid ensures a step change in terms of broadband availability, as it allows the deployment of an NGA network in areas where no such network exists and where there are no plans to deploy one in the near future. The provisions of the initial scheme remain unchanged: the project provides for the creation of an open access network in white areas (covering 40-45% of the territory) with a population of residents (5% of the population). Public funding amounts to around 161 million. The contractors will have to build a network within 2 years and operate it for a period of 15 years. In November 2012, the Commission cleared the second phase of the Metropolitan Area Networks (MAN)/Fibre to the Home (FttH) project, pursuant to which the Greek authorities would select the concessionaires who would operate the already built MANs (72 fibre optic networks of around km that interconnect more than public administration sites). The contracts were signed in February 2014 with two concessionaires, the incumbent OTE and Intrakat. 6. INSTITUTIONAL ISSUES 6.1. The National Regulatory Authority EETT 11 is responsible for the main tasks assigned to national regulatory authorities under the regulatory framework. The Ministry of Infrastructure, Transport and Networks is competent for defining the general policy, in particular in the area of spectrum, but delegated spectrum management to EETT. EETT exercises powers outside the electronic communications sector, in the area of Postal Regulation. 11 Εθνική Επιτροπή Τηλεπικοινωνιών και Ταχυδρομείων (Hellenic Telecommunications and Postal Regulation Committee), governed by Νόμος 4070/2012, Ρυθμίσεις Ηλεκτρονικών Επικοινωνιών, Μεταφορών, Δημοσίων Έργων και άλλες διατάξεις (Law 4070/2012, Regulations for Electronic Communications, Transport, Public Works and other provisions).

6 6 Resources of the national regulatory authority Personnel Increase [ ] % 4,7 % 0 % Budget 61,9 Million 81,2 Million 59,1 Million Increase [ ] % 31,2 % -27,2 % Administrative charges 12 14,05 Million 13,00 Million 13,32 Million Administrative costs 13 14,13 Million 13,38 Million 12,78 Million The NRA has full control over spending of its budget, subject only to an independent audit. Cooperation with consumer protection authorities has been smooth. The Members of the board of EETT are appointed for a term of office of four years that is renewable only once. Law 4070/2012, transposing the 2009 Reform Package into national law, had changed the selection procedure of the Head and of the Members of the Board of EETT, by providing that the selection of all members of the board would be carried out by a decision of the Conference of the Presidents of the Hellenic Parliament after proposal of the Committee for Institutions and Transparency. The role of the Minister was only formal, (issuing the act of appointment) However, Law 4199/2013, which was adopted after the expiration of the mandate of the previous board of EETT, restored the previous procedure of law 3431/2006, under which the decision to appoint the President and the two Vice-Presidents lies with the Council of Ministers acting on a proposal from the Minister of Communications and an opinion of the Committee for Institutions and Transparency of the Hellenic Parliament. Under this procedure, the Minister alone nominates the other Members of the board. The change appears to have been motivated by the need to avoid locking in the case whereby the Conference of the Presidents was not being able to reach a decision. The market has however conceived the change of the appointing method as a regression comparing to the procedure provided by Law 4070/2012, which was never applied. The NRA remained without a board from early September until late December 2013 and was not able to take decisions, not only regulatory, but also individual. This delay has negatively affected all areas of intervention, such as ex-ante market regulation, the ex-ante price control on regulated products, permit granting, numbering, the auctioning of the DTT and 3,4-3,6 GHz bands spectrum. EETT is accountable to the President of the Parliament and to the Minister of Infrastructure, Transport and Networks and to whom it delivers an annual report, available at The annual plan of the NRA does not need approval. The decisions of EETT can be reviewed or suspended only by the Administrative Courts. In 2012, EETT adopted 507 decisions, of which 49 were challenged before the Courts. Of these decisions, 8 were fully and 13 partially upheld by the Courts. In 2013, from the In the sense of Art. 12 of the Authorisation Directive (Directive 2002/20/EC as amended by Directive 2009/140/EC). 13 Idem.

7 7 decisions issued, 137 were challenged of which two were upheld by the Courts, while the others are still pending. Due to the economic crisis in Greece and the measures adopted to control the public deficit, EETT has been invited to abide to a stricter control by the Central Government. Important elements of such stricter control are: (a) All salary payments are to be incurred by a central payment authority and not by EETT itself; (b) All contracts above are to be procured through a central bureau of public contracts and not by EETT (thus annulling EETT s procurement policy); (c) EETT s economic data must be submitted on a monthly basis to the National Statistics Authority and the General Accounting Office, in order to enable the government to monitor the implementation of EETT s annual budget. The Commission is assessing the compatibility of these measures with the requirements of the Regulatory Framework Authorisation The European Commission had in the past raised concerns over the implementation of the general authorisation regime, in particular with regard to the inclusion of a notification requirement that was not needed for the identification of the provider. In particular, in order to register under the General Authorisation regime, the previous EETT Regulation on General Authorisation required electronic communication providers to provide a proxy, having a postal address in Greece and speaking the Greek language. This is no longer the case, since the new Regulation on General Authorisation (EETT 676/41/ ) does not include address or language requirements for providers established in the EU or the EEA Taxation The electronic communications sector is heavily taxed in Greece. In particular, the Greek State continues to levy a specific tax on mobile electronic communication services. The amount of the tax is progressive, varies from 12 to 20% and is imposed on the overall amount charged to the consumer, on top of the 23% VAT. 7. SPECTRUM MANAGEMENT In February 2014, EETT completed the assignment procedure for rights of use of frequency for Digital Terrestrial Television. Only one provider expressed interest for the one national coverage licence and none for the 13 regional licenses. All licenses were assigned to the network operator Digea for a price of Previously, Greece had amended the joint ministerial decision defining the dates of the 34 analogue switch-offs that will be needed for the transition to digital broadcasting. According to this decision (46157/1815/Φ150), the last switch-off was scheduled to intervene 315 days after the assignment of the rights of use (approx. end of 2014). By Decision of 17 October 2013, 14 the European Commission granted Greece a derogation from the obligation of Article 6(4) of Decision n 243/2012/EU (RSPP) to allow the use of the 800 MHz band for electronic communications services by 30 October 2013, because of 14 C(2013)6765.

8 8 exceptional circumstances due to the delay in the analogue switch-off and the economic crisis. According to the derogation Decision Greece shall ensure that the use of the entire band for electronic communications other than broadcasting can start by 1 November However, it appears that according to the rollout timetable of the Greek authorities, at national level the switchover process will only be completed on 15 December The band will nevertheless be available for the deployment of electronic communication networks in the large cities, representing at least 60% of the population. The Greek authorities plan to offer the 2,6 GHz band along with the 800 MHz in one auction. Currently a public consultation document for both bands is under preparation by EETT and is expected to be available in early May The public consultation documents will include the draft tender and spectrum rights of use documents in order to speed up the licensing process. However, there is uncertainty over the availability of this band, since the incumbent uses part of it for the provision of the Universal Service in remote areas and has contested before the Court a 2001 decision by EETT, which reduced the duration of its license, which was meant to expire in 2020, to Last, in early 2014, EETT completed the assignment procedure for the rights of use of spectrum in the 3,4-3,8 GHz bands. Only the incumbent showed interest to acquire rights of use. On 20 March, ΕΕΤΤ granted one right of use of radio-frequency to OTE (3,440-3,470 GHz and 3,540-3,570 GHz) for a price of 2,542 million. That leaves the larger part of the 3,4-3,6 GHz and the full band of 3,6-3,8GHz band available for use in the future. Spectrum in the 900, 1800 and 2100 MHz bands has already been re-farmed and spectrum rights are now technology neutral. LTE has been introduced in the Greek market in 2013, by two of the MNOs that have deployed the technology in the 1800 band. Territorial coverage, however, is still very low. The regulator cleared in July 2013 an agreement between Vodafone and Wind to share parts of their 2G and 3G networks. The agreement has a 15-year duration and implementation started by the creation of a joint venture company, Victus Networks to undertake part of the construction of their networks and in effect promote site sharing. The previous year, the two MNOs had explored the possibility of a merger, of community dimension, but did not materialise. Greek legislation appears to set maximum EMF exposure limits at only 70% of the thresholds recommended by the Council Recommendation 1999/519/EC. This drops at 60% in the vicinity of schools, nursing homes or hospitals. 8. RIGHTS OF WAY AND ACCESS TO PASSIVE INFRASTRUCTURE In 2012, the procedures for granting rights of way were simplified through a new Ministerial Decision. The procedure is nationally defined, but mostly locally implemented. Transparency regarding the procedures for granting rights of way is ensured, via their publication by the competent permit granting authorities. However, electronic submission of requests is not yet available. When the deadline for granting rights of way for the deployment of fixed networks has passed, the request is deemed approved. In the area of antennae and base stations permit granting, EETT acts as a light one-stop-shop, receiving the requests and dispatching them to the competent authorities. Since September

9 9 2012, one-stop-shop system (ΣΗΛΥΑ) is operational, and since December 2012, electronic submission of the requests is available. However, more streamlining is necessary. In particular, a number of competent authorities still lack ICT resources to handle the requests electronically, and EETT is submerged with a great number of requests. The absence of a board for the period between September and December 2013 had a negative effect on the backlog of cases. According to estimations of the Mobile operators, there are over pending requests for antennae permits in Greece. According to EETT approximately of them constitute backlog pending for more than a year and due to delays of issuing permits from other authorities than EETT. The existence of a large number of unlicensed antennas and base stations lead the Ministry to prolong the deadline given to the Mobile operators to ensure the licensing of already deployed antennas by two more years. It appears that a ministerial decision removed the need for all electronic communications operators wishing to deploy their fibre networks to pay upfront all the fees to obtain the necessary rights of way. In early 2013, the Ministry has published a tender for developing a passive infrastructure mapping registry, limited to the telecommunication infrastructure. The announced budget was ,50 and the duration of the project is 15 months from the date of the signature of the contract (April 2014). The mapping will concern infrastructure both from public and private operators, while a Ministerial Decision will further define the format for the provision of the data. Information will be depicted on maps, but access to it will not be publicly available, in order to protect business secrets. According to a Ministerial Decision adopted at the end of , NGA wiring is mandatory for new buildings. 9. ACCESS AND INTERCONNECTION A schedule appears to have been negotiated between operators for the migration of fixed networks towards IP interconnection architecture. It will take approximately 5 years to complete the transformation, starting at the end of CONSUMERS ISSUES The European emergency number 112 Greece remains one of the Member States with the least awareness of the Single European emergency number. Only 5% (EU28: 58%) of the Greek respondents to the Eurobarometer Report of 2013 responded that they would call 112 in case of emergency and only 10% know that 112 can be used in all the 28 Member States (EU28-41%). With regard to the technical specifications, it is still not possible in Greece to access 112 by SMS. However, the new PSAP will soon offer, according to the authorities, the functionality of video and text Number portability With regard to portability, respondents of the 2014 Eurobarometer survey in Greece find it very (43%) or fairly (44%) easy to change provider (the EU28 averages are 33 and 43% 15 N 41020/819, ΦΕΚ 2776/B. 15 October 2012.

10 10 respectively). The European Commission services investigated concerns raised regarding a provision of the new Telecommunications Law allowing providers to refuse number portability in case of unpaid invoices. According to the Regulator, this led to a significant increase in the number of rejections for the request for number portability. This issue has been addressed through a new Law (4146/2013), according to which providers are not allowed to refuse number portability in case of unpaid invoices. This change is however only applicable since March Contractual obligations EETT has started a pilot project aimed at the development of a tool to provide consumers with comparative data on tariffs. Furthermore, it imposed fines on the mobile operators for charges imposed on consumers for inadvertent data consumption. According to the 2014 Eurobarometer survey, Greek consumers now have a high level of awareness of their data consumption limits under the terms of their contract (35% against an EU28 average of 26%); still more than 50% of the Greek subscribers are not aware of their consumption limits. 12% of the respondents to the survey had to pay extra costs for additional data consumption, less than the EU average of 14%. Consumers using bundled products responded massively (88%) that they can easily compare the services and prices of their offer with competitive offers (EU28: 69%), although they do not appear to regularly receive updated information about changes to tariffs and packages (50% close to the EU28 average of 53%). Greek consumers are also more aware (54%) of their maximum download speed, than the average Europeans (34%) Other consumer issues The number of consumer complaints filed with EETT remained relatively stable in 2012 (almost , compared to in 2011) but presented a sharp increase in 2013 (12 000). The trend in 2012 was also confirmed by the number of calls received by the Consumer's Ombudsman and the consumer association EKPIZO. During 2012 and 2013, most of the complaints concerned number portability issues (mainly rejection of applications), questioning of charges and surcharges, line faults, cancellation of applications, and multimedia information services (though this has been decreasing in 2013). A substantial number of complaints concerned the legality of antenna installations, although this is steadily decreasing from 2011 onwards. In 2013 EETT noticed a sharp increase of consumer complaints concerning (fixed and mobile) internet services (availability, quality & billing). 11. UNIVERSAL SERVICE The following services are included in the scope of universal service: (a) Provision of access at a fixed location, (b) Directory enquiry services and directories, (c) Public pay phones, and (d) Special measures for disabled users. Furthermore, there are special arrangements for disabled end-users. There is no legal provision defining the minimum requirements for functional access to the Internet within the scope of universal service. For the period , OTE is the designated universal service provider for directory enquiry services and directories. In March 2014, EETT published a call for expression of interest for the provision of one or more elements of the Universal Service. The cost of the universal service in Greece for the year 2010 is estimated by the designated operator OTE to

11 11 be at more than 83 million. The incumbent requested financing of the unfair burden. By decision of 11 April 2013, EETT requested OTE to provide further information and to apply a number of recommendations, having found that the method for calculating the unfair burden of the provision of the Universal Service was not correct. Lastly, it was reported that unreasonably high charges are imposed by certain local authorities to the designated operator for installing pay-phones on public space. 12. NET NEUTRALITY Legislative situation Quarterly reports monitoring the quality of services are published by EETT. Traffic management practices in the mobile market were reported, with regard to VoIP. This is not perceived by the consumers and mobile phone users in Greece are second in Europe to report that there are no difficulties accessing online content over the mobile phone (63% against an EU average of 52%). EETT has developed an application verifying the existence of traffic blocking ( Quality of service EETT is responsible for quality of service implementation, the monitoring of the quality of service in the sector and specific aspects such as internet speed and other parameters. The regulator already operates a tool for measuring the speed of internet access. This effort is highly relevant in Greece, where 55% of the respondents to the Eurobarometer survey reported that the download/upload speed of their Internet connection does not match the terms of their contracts.