Objection to Group 2 Proposals – Impact on Small Internet Providers in Ukraine
Dear Members of the Working Group, I would like to express my strong objection to the proposals listed under *Group 2: Possible Additional Fees, Discounts and Incentives*, especially the proposal to increase the "PI assignment fee to EUR 1,000". There are approximately 4,000 Internet providers in Ukraine, most of which are sponsored by around 300 LIRs. These small providers form the backbone of the country’s Internet connectivity. If the PI assignment fee is increased from EUR 75 to EUR 1,000, these costs will inevitably be passed on to small providers. For many of them, especially under wartime conditions, such a fee would be unaffordable. Ukraine is currently in the midst of a full-scale war. Many small ISPs: * repair damaged networks, * operate during power outages, * invest in generators and batteries, * support schools, hospitals, and local authorities, * work with very limited financial margins. An additional fee from EUR 1,000 would represent a serious financial shock and could force many small ISPs to cease operations. Connectivity in Ukraine depends primarily on small local ISPs rather than large national operators. Weakening them means weakening the resilience of Ukraine's entire network and society. I would also like to remind the Working Group that Ukraine is ranked among the "Top-10 countries worldwide in terms of network resilience", precisely because of its highly diversified ISP market. This decentralised structure has proven to be a key factor in maintaining connectivity during wartime. Any measure that financially pressures small providers risks undermining this resilience model. For these reasons, I believe that this proposal will seriously harm the market for small Internet providers in Ukraine and should not be put to a vote at all in its current situation. Thank you for considering this feedback. Best regards, Olena Kushnir
participants (1)
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Олена Кушнір