Dear Minister Patuanelli

I represent the hundreds of ITALIAN entrepreneurs who for YEARS have been providing internet access to millions of citizens, especially those located in the most disadvantaged areas of the country.

The increase in recent weeks of measures that lead citizens to make daily and continuous use of remote activities is raising the need for high-speed connections, and since we have long been reporting to the MISE and the Communications Regulatory Authority (AGCOM) how an ACTION BY YOUR MINISTRY could allow a DIRECT AND IMMEDIATE improvement in connectivity performance. Fixed Wireless Access provided to millions of citizens served by our companies, I kindly ask you to urgently verify what I write further below:

1) through the use of radio links that utilize licensed frequencies, it is possible to achieve a rapid (a few weeks) and significant increase in the bandwidth available on the backbones of Internet providers (from doubling to tenfold), which would automatically result in a substantial improvement in the bandwidth delivered to end users in terms of overall capacity and quality (similar to fiber optics).

2) Licensed POINT-TO-POINT frequencies do not represent a scarce resource (in Italy their current use is below the 2% of the total availability)

3) the current amount of administrative contributions makes economically prohibitive use licensed point-to-point frequencies to create backbones to serve areas with a few dozen/hundred users. Moreover, Italian administrative contributions are the HIGHEST in Europe and are up to 10 times greater than those required by other European countries.

4) the use of licensed POINT-TO-POINT frequencies is economically regulated by the provisions of theattachment 10 art.5 of the current Communications Code and by virtue of the provisions of Article 220 of the same communications code LEI, in agreement with the Minister of Economy and Finance, it can be modified at any time with a simple MINISTERIAL DECREE that is immediately operational.

5) for years ALL political forces in parliament have been proposing the reduction of the amounts of administrative fees for licensed point-to-point frequencies, always receiving a denial from the competent Ministries, arguing that this reduction would lead to a decrease in revenue from administrative fees.

We ask how it is possible that the full and immediate digital integration of citizens in disadvantaged areas is held hostage by the few million euros from the revenue of administrative fees imposed on licensed frequencies, while at the same time we can afford public aid on Vouchers for billions of euros.

We therefore urgently request you to intervene to make this public good, largely unused, a truly available tool to combat the digital divide and to put an end to the enormous distortion of competition between large national operators and small local operators, represented by the quantity discount mechanism contained in annex 10, which allows a difference of the 400% between the administrative contribution paid by a small user and that paid by a large user of the exact same PUBLIC GOOD.

We therefore ask you to intervene URGENTLY also considering the fact that AGCOM, following our reports sent last spring to the Telco and Consumers table (https://www.agcom.it/en/tavolo-telecomunicazioni-e-consumatori), has certified that what we reported is true (https://www.agcom.it/documents/10179/19002772/Comunicazione+30-06-2020+1593530891688/ad1cbe0c-ba57-463b-a018-af14ea07878c?version=1.0).

We therefore propose that you do not wait any longer and impose that the quantity discount of the 75% be applicable to all operators with fewer than 50,000 users.

With this formula, small operators will immediately increase the use of licensed point-to-point frequencies, resulting in an increase in revenue that will mitigate, if not even eliminate, the potential decrease in revenue caused by the application of the 75% discount to entities with fewer than 50,000 users, while the revenue from all other entities will remain unchanged.

Knowing the great attention it pays to small Italian companies and the country's digitalization issues, we are confident that it will not want to miss out on such a simple, effective, but above all, rapidly implementable measure.

Best Regards

ing Dino Bortolotto

President of Assoprovider