03 September, 2021
ETNO comments to the Draft RSPG Opinion on the role of radio spectrum policy to help combat climate change
The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Draft RSPG Opinion on the role of radio spectrum policy to help combat climate change.
We also positively acknowledge that many of our comments provided in the response to the RSPG Questionnaire were taken into account in the RSPG report on the role of radio spectrum policy to help combat climate change, published in June 2021.
ETNO overall supports the RSPG’s focus on sustainability and climate change as a key important horizontal principle and high-level priority.
In general, ETNO believes that efficient spectrum policy and managements also supports climate goals. With sufficient spectrum resources available and by avoiding unnecessary deployment and operation limitations and requirements, spectrum regulators can support to reduce climate impacts.
As stated in our previous comments, any regulatory policy unreasonably entailing an investment unfriendly environment for the sector (e.g. high spectrum awards prices, unjustified restrictions to co-investment, administrative complex procedures for deployment, stricter limits of EMF exposure than the ones European Council recommends) would be counterproductive for the ability of the operators to invest in upgrading the networks in compliance with more efficient and climate neutral standards.
We also take the chance to highlight once more that telecom networks are not only making substantial progresses on sustainability and circular economy targets in their own operation, but they are the backbones of major CO2 reductions enabled by digitalization, across different sectors of the economy and society.
Sectors as diverse as manufacturing, transport, healthcare and the public administration can only achieve carbon neutrality by accelerating their digital transformation. This enabling potential can go up to - 15% of the global CO2 emissions.
Finally, ETNO would like to express its willingness to contribute to the debate and support RSPG’s activity on climate change and we are ready to engage in the debate and provide with our expertise.
 RSPG21-026final_RSPG_Report_on_Climate_Change.pdf (rspg-spectrum.eu)
 BCG study for ETNO, 2021 “Connectivity and Beyond: How Telcos Can Accelerate a Digital Future For All” available here
Read the full document at the link below.