Position papers

ETNO's position papers present its member-companies' views on a wide range of technical, regulatory and trade issues to European Union decision-makers, national governments and the general public.

They are developed either internally by ETNO working groups or, occasionally, in co-operation with third parties such as other industry associations.

Click here for definitions of ETNO Position Papers and Expert Contributions.

  • Position papers

    ETNO response to the feedback period on the EU energy efficiency directive (EED)

    The European Telecommunication Network Operators' Association (ETNO) welcomes the European Commission opportunity to provide feedback to the revised EU energy efficiency directive (EED).

    As stated in our response to the EC public consultation earlier this year, we believe efficient use of energy is key to achieve the Green Deal objectives. The original objectives of the Directive are still highly relevant, and in general they have helped to increase awareness and knowledge related to energy, which is often still seen a plain commodity.

    The ICT sector, including telecom networks, has been taken decisive and continuous actions to improve energy efficiency through a variety of measures. Complementary to that, it is worth highlighting once more that the telecommunications’ greatest positive environmental impact lies in its potential to enable other sectors of the economy to reduce their own emissions and energy consumption.

    Digital solutions are indeed a pre-requisite for achieving the EU Green Deal’s goals across different sectors of the economy and society. The enabling potential has a contribution across all sectors of the economy, including manufacturing, transport, buildings, healthcare and public administration, that can only achieve carbon neutrality by accelerating their digital transformation. For example, the recent ETNO BGC report1 quantified this enabling potential measuring up to 15% of emission reductions resulting from full digitalization (including smart cities and buildings, transportation, industry IoT and blockchain applications, and energy).

    Telecommunication companies have invested and continue to invest heavily in the build-out and upgrade of energy efficient and high-speed network infrastructure and data centres, as well as in the development and deployment of ICT services. This results in increased energy efficiency in the provision of mobile and fixed services. As indicated in the 2021 ETNO State of Digital Communications2 , the carbon intensity of ETNO companies decreased in 2019, with emissions at 27 grams per EUR earned as opposed to 29 grams in 2018. ETNO companies also reduced their use of non-renewable energy by 23% and increased their use of renewable energy by 24% in one year.

    In 2019, ETNO companies deployed 70.9% of the total network investment in Europe. At the same time, and despite telecom operators’ large investments, the EU faces an investment gap for digital infrastructure. Once built, 5G and fibre networks will have cost Europe around €500 billion.

    Against this background, ETNO takes the chance to provide suggested amendments to the EED, which aims at clarifying and improving aspects that are important for our sector.

    19 November, 2021 Read more
  • Position papers

    ETNO views on RED revision on Universal Charger

    We welcome the initiative by the European Commission to achieve important objectives on consumer choice, reducing cost for the consumer, and reducing waste and environmental impact.

    To achieve these important goals, the co-legislators should be guided by the principle of future-proof regulation: the universal charger needs to follow technological development, and the Directive must allow for this, to avoid consumers, businesses and the market at large being ‘locked-in’ to a technological specification which could be outdated and not reflect the state of the art, nor meet future standards of efficiency. This can be supported by open standards and specifications, also ensuring competition on the supply side of the charger market.

    Furthermore, while the Commission’s proposal makes an important step in the direction of unbundling, we believe that the legislation should aim for full unbundling in order to realise the full environmental benefits, and ensure competition at the level of pricing of the unbundled chargers.

    19 November, 2021 Read more
  • Position papers

    ETNO comments on the draft BEREC Report on the regulatory treatment for fixed and mobile backhaul

    ETNO welcomes the opportunity to comment on the draft BEREC “Report on the regulatory treatment for fixed and mobile backhaul” (“the report”) to express its views and conclusions. ETNO would like to share the following analysis on the report. In general terms, ETNO considers that at present, the current regulatory framework (EECC, BCRD) has the necessary instruments and obligations on the different relevant markets included in the EC 2020 recommendation, to be able to address any competition issues that may arise in the future. Therefore, we do not consider the potential regulation of mobile backhaul to be justified or proportionate, as no competitive issues have been identified in the relevant retail market that would request to consider backhaul as a relevant market susceptible to be regulated.

    9 November, 2021 Read more
  • Position papers

    ETNO’s submission to the BEREC public consultation on the draft BEREC Work Programme 2022

    ETNO welcomes the opportunity to provide comments on the draft BEREC’s Work Programme 2022. We believe that BEREC should in general focus on the ongoing tasks as mandated by EU legislation, as defined in the EECC, the Open Internet Regulation, roaming and intra‐EU calls, for example. We support BEREC’s commitment to establish structured cooperation mechanisms with EU institutions and other competent authorities.  

    9 November, 2021 Read more
  • Position papers

    ETNO-GSMA position paper on European Commission proposal for an Artificial Intelligence Act

    ETNO and the GSMA welcome the initiative of the European Commission to propose a Regulation on Artificial Intelligence, and notably the central role of the risk-based approach, which keeps citizens at the centre and is based on a robust ethical framework. Nevertheless, the risk-based approach requires more precision in order to achieve the intended results. It is encouraging to see that the legal focus is put on the use of AI and its impacts to society, rather than the technology itself.

    5 November, 2021 Read more
  • Position papers

    ETNO POSITION PAPER on the Consumer Credit Directive

    ETNO welcomes the European Commission’s initiative in proposing a Consumer Credit Directive, repealing and updating the current Directive (2008), and bringing consumer protection law with regard to credit agreements up to date, as part of the New Deal for Consumers.

    12 October, 2021 Read more
  • Position papers

    ETNO response to the European Commission public consultation on the revision of the Horizontal Block Exemption Regulations and Guidelines

    The response to this consultation is available here. 

    Additional views on network sharing are available here.  

    7 October, 2021 Read more
  • Position papers

    Cyber Security Rating – a rising challenge for EU industries

    The financial crash that occurred in the United States in 1837 prompted the need for risk assessment for investors. The power of financial rating agencies in influencing investors has grown in importance over the past decades, due to a number of significant events (the collapse of Enron in the US; the US Subprime mortgage crisis; the late 2000 financial crisis; and the Greek national debt crisis). Following increased complaints and impact of such agencies, this has led to the creation in Europe of the European Securities and Markets Authorities (ESMA). Since 2010, credit rating agencies need therefore to comply with ESMA rules.

    Cyber rating is now being introduced in continuity with financial rating. In 2015, Standard and Poor’s was the first agency to announce that it was taking cyber risk into consideration when calculating its rating. Cyber rating initiatives in general have been booming over the past five years and there are now several US-based agencies that produce cyber ratings, such as Security ScoreCard, BitSight, Panorays, VisibleRisk etc.

    Those credit rating agencies are looking for KPIs that assess cyber security risk coverage. Today, companies are more and more using these ratings when considering to enter into business arrangements; they can influence the decision of a company to work with another. It appears that EU governments are also increasingly working with cyber rating agencies. Developing ratings in our complex and interconnected world is understandable and welcome, as long as the methodologies used are transparent, reliable and robust, considering their huge business impact especially on EU companies.

     

    24 September, 2021 Read more
  • Position papers

    ETNO response to the Call for feedback by the Platform on Sustainable Finance on the draft report on preliminary recommendations for technical screening criteria for the EU taxonomy

    The European Telecommunication Network Operators' Association (ETNO) welcomes the ongoing work by the Platform on sustainable finance and its relevant role in providing advice on the further development of the EU taxonomy. We thus appreciate the opportunity to provide feedback on the draft report on preliminary recommendations for technical screening criteria.

    ETNO fully supports the role of the EU taxonomy as an essential facilitator of the EU Green Deal. Channelling investment flows towards environmentally sustainable projects and activities will be crucial to meet the EU’s climate and energy targets for 2030 and beyond. Therefore, the EU taxonomy urgently needs to provide the right investment incentives, both when it comes to economic activities with the highest negative environmental footprint as well as economic activities that can support the green and circular transition.

    Digital solutions are a pre-requisite for achieving the EU Green Deal’s goals across different sectors of the economy and society. The enabling potential has a contribution across all sectors of the economy, including manufacturing, transport, buildings, healthcare and public administration, that can only achieve carbon neutrality by accelerating their digital transformation. For example, the recent ETNO BGC report(1) quantified this enabling potential measuring up to 15% of emission reductions resulting from full digitalization (including smart cities and buildings, transportation, industry IoT and blockchain applications, and energy).

    Against this background, ETNO is concerned that the EU taxonomy has so far missed the opportunity to adequately address the role of the ICT sector in the technical screening criteria adopted as part of the Climate Delegated Act and in the preparation of the next set of technical screening criteria, which are the subject of the present consultation. The EU Taxonomy urgently needs a stronger emphasis on ICT sector’s “greening of” and “greening by” activities, which have a much deeper and broader impact across sectors of the economy and of the society.

    In this regard, the EU taxonomy has in particular failed to reflect the crucial role of the telecommunications sector, which is the infrastructure necessary for digitalization. Telecommunication companies have invested and continue to invest heavily in the build-out and upgrade of energy efficient and high-speed network infrastructure and data centres, as well as in the development and deployment of ICT services. This results in increased energy efficiency in the provision of mobile and fixed services. As indicated in the 2021 ETNO State of Digital Communications(2) , the carbon intensity of ETNO companies decreased in 2019, with emissions at 27 grams per EUR earned as opposed to 29 grams in 2018. ETNO companies also reduced their use of non-renewable energy by 23% and increased their use of renewable energy by 24% in one year.

    In 2019, ETNO companies deployed 70.9% of the total network investment in Europe. At the same time, and despite telecom operators’ large investments, the EU faces an investment gap for digital infrastructure. Once built, 5G and fibre networks will have cost Europe around €500 billion.

    A clear framework for access to long-term and sustainable funds through EU taxonomy can prove crucial for efforts to include all European regions in the Gigabit Society and for the transition towards energyefficient networks such as 5G and fibre.

    1 “Connectivity and Beyond: How Telcos Can Accelerate a Digital Future For All” https://etno.eu/library/reports/96-connectivity-and-beyond.html

    https://etno.eu/component/attachments/attachments.html?task=download&id=7973

     

    24 September, 2021 Read more
  • Position papers

    ETNO comments to the Public Consultation on the Data Act

    ETNO welcomes the opportunity to comment on the measures being explored by the European Commission in preparing the Data Act. This document complements our response to the public consultation questionnaire with regards to the two specific sections on business-to-government data sharing for the public interest and on business-to-business data sharing, building on our recent feedback to the Commission’s Inception Impact Assessment (IIA) on the Data Act.

    3 September, 2021 Read more
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