14 December, 2023

ETNO comments to the RSPG Draft Work Programme for 2024

The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Radio Spectrum Policy Group (RSPG) Draft Work Programme 2024.

ETNO welcomes the planned work items that have potential to support meeting the Digital Decade targets and the increasing society demands for mobile communication in future. We note that active involvement of stakeholders is important and would welcome regular stakeholder involvement on the various work items. Active participation of RSPG members in the stakeholder events would be appreciated, otherwise the events easily become a forum only between stakeholders. Moreover, debriefings after the plenary meetings could help increasing mutual understanding and agree on a way forward to support best-in-class digital infrastructure deployment.

Europe has a huge investment gap in telecom networks and services (€174 billion as estimated by the European Commission[1]), in conjunction with overall declining or flat revenues in the sector, returns below the cost of capital, weak market valuations and high levels of debt. Spectrum policy is a critical to support investment in the sector. It also plays a role in addressing challenges related to climate change.

Thus, we propose that RSPG considers economic and environmental impact analysis as a core part of their opinions. We note that the RSPG opinions and recommendations are not backed up or justified by analysis on socio-economic benefits. We also note that the climate-related work has so far been a separate activity, and not concretely linked to the other opinions and recommendations.

Read the whole document at the link below. For further questions, please contact Xhoana SHEHU, Policy Manager at ETNO (shehu@etno.eu).



[1] Exploratory consultation - The future of the electronic communications sector and its infrastructure, European Commission, February 2023

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