24 September, 2021

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



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