19 November, 2021

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.

© ETNO 2021
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