15 December, 2020
ETNO comments to the draft delegated regulation on criteria defining environmentally sustainable activities
The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the draft Delegated Regulation on a climate change mitigation and adaptation taxonomy.
Investment towards environmentally sustainable projects and activities will be crucial to meet the EU’s climate and energy targets for 2030, and in general to advance on the content and the ambition of the European Commission’s strategy of the European Green Deal.
A clear definition of what is “environmentally sustainable” is absolutely required to scale up green investment.
ETNO fully supports the EU taxonomy role as an essential facilitator of the EU Green Deal, with the purpose of channelling long-term sustainable finance into sustainable activities.
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 other ICT Services. In 2018, ETNO companies deployed 70.5% of the total network investment in Europe (€34.4bn, fixed and mobile).
There is a common understanding among decision makers that climate targets will not be achieved without the crucial role of ICT as enablers, including the need for connectivity. As such, digitalisation and connectivity are key instruments for dealing with the most pressing environmental challenges affecting society at large: for instance climate change, water shortage, circular economy, pollution, and loss of biodiversity. In fact, digital solutions are a critical pre-requisite for achieving the EU Green Deal’s sustainability goals across different sectors of the economy and society. It is worth noting that telecom operators are not included in the Emissions Trading System (ETS), hence they are not considered as an energy-intensive sector, but rather as an effort-sharing one and a strong enabler for other sectors. Against this background, ETNO is concerned that the Green Taxonomy will miss a crucial opportunity to contribute to reaching ambitious climate targets.
Besides this crucial role for the whole economy, and to take advantage of all the benefits of digitalization, telecom providers have taken decisive and continuous action to cut carbon emissions and increase energy efficiency in their own networks.
If the Delegated Act will also address the aspect of “greening of” networks, we would propose to base this concept on a definition of sustainable networks that provides the required legal certainty and strong incentive to invest in technologically up-to-date networks including FTTH and 5G networks. The proposal of the Expert Work Group falls short in this regard.
Services based on the Internet of Things (IoT), Cloud or Big Data require a strong digital infrastructure and enable more efficient use of resources across a variety of sectors. This includes manufacturing, agriculture, mobility, transport/logistics, energy, healthcare, education, public administration and many more. There is clear scientific evidence that those sectors, through uptake of digital infrastructure and digital services, have the opportunity to become more productive, more modern and more service-oriented, while dramatically reducing their carbon footprint.
At the same time, and despite telecom operators’ massive investments, the EU faces an investment gap for digital infrastructure. Once built, 5G and fibre networks will have cost Europe around €500bn. Therefore, the Green Taxonomy urgently needs to contribute closing this gap, providing the right investment incentives.
To correspond to the identified key role of ICT, the Green Taxonomy urgently requires a strong emphasis of ICT’s “greening by” activities.
For this purpose, the delegated regulation should explicitly mention not only criteria on energy efficiency in digital infrastructure (covering both network transformation and development of new digital infrastructure e.g. 5G networks and data centers), but also services that realize ICT sector’s enabling potential to contribute to climate change mitigation, energy and resource efficiency of other sectors. The latter aspects should take into account both current technology and solutions (e.g. IoT and cloud computing) and also emerging or future technology and solutions (e.g. 5G-related connectivity, crowd and data insights) aiming at promoting innovation in networks and services.
The current public consultation, which aims at finalizing the draft delegated regulation to establish an EU classification system for green investments, is an important step to properly define an EU Taxonomy for sustainable investments and avoid greenwashing.
Therefore, ETNO has decided to take this opportunity to share changes to text and the corresponding rationale.
Read the full document at this link.
 See ETNO’s The State of Digital Communications 2020, available here https://etno.eu/library/reports/90-state-of-digi- 2020.html
Deloitte for GeSI, Digital with Purpose, 2019