At the beginning of this year, the European Commission initiated a discussion about the future of the electronic communications sector and its infrastructure. The main focus was to determine if all parties benefiting from digital advancements should contribute to the necessary investments in the area. To address this, the Europeana Foundation joined forces with Creative Commons and the International Federation of Library Associations and Institutions (IFLA) to provide a joint response.
In our joint response, we appreciate the European Commission’s efforts to improve broadband access and expand network capabilities, enabling innovation. However, we express our concerns regarding the potential establishment of a legal basis for telecom companies to demand payments from content and application providers for traffic generation. This could compromise net neutrality and the principles of an open and fair internet, which we strongly value and defend.
Our joint submission emphasizes the specific impacts this development would have on knowledge and cultural heritage institutions. The Europeana Foundation, Creative Commons, and IFLA represent organizations and individuals involved in galleries, libraries, archives, museums, and other sectors facilitating the sharing of knowledge and culture, particularly online. We play crucial roles in serving European communities by providing resources, services, and fostering creativity and innovation to create a trusted digital environment.
The Europeana Foundation, as the guardian of the European data space for cultural heritage, actively works towards a vision where access to culture remains open and accessible to all. We fear that these new potential fees would negatively affect the institutions and communities we support. As repositories of vast amounts of data, we are responsible for collecting, preserving, and making various forms of media and information available to the public. While individual users may not utilize the entirety of our collections, collectively serving our communities requires handling large amounts of data. Additionally, we cater to academics and researchers who may require comprehensive access to datasets for their public-interest activities.
Under the proposed conditions, institutions like ours may be classified as “large traffic generators” and subjected to new fees. As organizations serving the public, we already face significant budget constraints, and such fees would further limit the services we provide. Instead of allocating our resources to fulfill our missions, we would essentially be contributing to the profits of telecom operators.
In our joint response, we highlight several alternative ways to support an open and affordable internet. These include expanding wireless services, promoting community networks, updating universal service funding, and collaborating with knowledge and cultural institutions that already work on providing internet access to local residents. We hope that these ideas, among others, will be the main focus as the consultation progresses.
The Europeana Foundation, Creative Commons, and IFLA are ready to cooperate with the European Commission and other stakeholders to explore alternative approaches that ensure an open internet and equitable treatment of data traffic for all, in line with the principle of net neutrality.