ETNO response to the RSPG Consultation on the draft Work Programme for 2022 and beyond

The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the RSPG draft Work Programme for 2022 and beyond.

In general, we consider that the draft work programme is comprehensive and covers the key issues of interest. We encourage to have an active dialogue with stakeholders, and we positively acknowledge that the stakeholder involvement, e.g. in focused workshops, is noted in many work items. However, for the time being, it looks that such workshop is only planned for Mobile Technology Evolution work item. ETNO proposes that stakeholder workshops, or other forms of stakeholder involvement that are organized in addition to the public consultations, are planned for each work item in a timely manner to allow contributions to be taken into account when developing the final deliverables.

Furthermore, ETNO emphasizes the importance of spectrum in reaching the European Union Digital targets. The telecom industry is engaged to fulfil the 2025 Gigabit and 2030 Digital Compass objectives. However, we need RSPG to carefully consider in all its work how to reflect the targets in well-designed spectrum policy.

In order to support the targets and connectivity demands of society, it is important that sufficient spectrum availability is ensured also in future for public mobile networks with reasonable price and conditions. Otherwise, we risk staying far behind the targets. This is critical, as European mobile and fixed telecoms service revenue decreased by 18% over the decade between 2009 and 2019 while the level of investment sustained by telecom operators has remained stable. Communication services in the EU have suffered earlier and deeper price erosion than other global leaders such as the US, South Korea or Japan.

Additionally, prices and customer spending on digital communications services in Europe remain low (reflected by low ARPU) in comparison to these other regions1. A recent report has estimated that an additional €150bn of investment is needed for full 5G roll-out in the EU. This relates to costs of upgrading existing coverage networks to 5G, increasing densification of networks to offer higher capacity services, and providing enhanced capability services. In addition, a further €150bn is required to upgrade existing fixed infrastructure and roll out FTTH to provide gigabit speeds in Europe¹.

^{1. https://etno.eu/component/attachments/attachments.html?task=download&id=7973}