Sustainability in telecommunications and space keynote

"Dear Deputy Permanent Representative of Hungary to the European Union,

Dear Member State representatives,

Dear representatives of EU institutions and international organisations,

Dear representatives of companies, associations and NGOs,

Dear academics,

Ladies and gentlemen,

I am honored to join this event on sustainability in the telecommunications and space sectors and I would like to thank the Hungarian Presidency of the Council of the European Union for inviting BEREC – the Body of European Regulators for Electronic Communications – to share its expertise on these issues. I am really delighted of this opportunity to present what is at stake.

Let me share with you today a story.

This is the story we lived as telecom regulators, a three-step story, while embracing digital sustainability challenges.

• First step is the awareness,
• Second step is the assessment of the digital environmental footprint, and its striking, if not frightening figures,
• Third step is the measures to act responsibly for future generations' access to the digital society

Let start with the first step: the awareness

Over the past 5 to 10 years, there was a growing collective and societal awareness of the environmental impact of digital technologies.

In the wake of the scientific community’s warnings, collective and societal awareness of global warming has grown fast in many European countries. More recently, citizens and NGOs were taking up the theme of sustainability of digital technologies and calling on decision-makers to mitigate climate change.

For instance, in France, but also here in Belgium, in 2019 and in 2020, citizens and NGOs have challenged the need of 5G technology, leading to a real political debate in some countries. In addition, for the first time in our 25-year history, we were brought to court by NGOs on the basis of environmental challenges regarding 5G spectrum auctions.

Sustainability is not only an environmental issue, it has also become a societal concern and a question of acceptability of future digital technologies. These calls from the public and these new expectations in terms of sustainability encouraged us to take environmental issues into account in our work at national level first, and at European level then.

As a regulator dedicated to connectivity everywhere and for everyone, convinced of the benefits of digital technologies, we decided to ask ourselves how to ensure that future generations will be able to enjoy them too.

And let’s get an idea out of the way now: digitalisation can be a driver for the decarbonization of other sectors, for sure. But this in no way exempts it from making its own efforts and reducing its own impact.

This is an evidence if we want to respect the 2015 Paris Agreement which sets out a common framework for keeping global warming well below 2°C, with a target to pursue efforts to limit it to 1.5°C.

Following this global commitment, the European Union has established in its strategy the goal to reduce net greenhouse gas emissions by at least 55% between 1990 and 2030 and to make Europe climate-neutral by 2050.

This is much more than just a political ambition. With the adoption of the European climate law, it has become a legal obligation for the EU. This is how the story begins: a collective awareness enshrined in a broader context.

Second steps of the story: what’s at stake?

Albert Camus, famous French writer, once wrote: “One always has exaggerated ideas about what one doesn't know.”

This is why the first thing to do is to know and to understand the environmental impact of the digital sector.

Thus, in order to increase our knowledge and get a collective comprehensive overview of the situation, we addressed the metrology topic. And we were faced with striking figures. I don't want to overwhelm you with figures, but some of them speak for themselves:

• Digital technologies account for 3 to 4 % of total greenhouse gas emissions worldwide, and also for 10% of electricity consumption.
• And this is only increasing. If no actions are taken, the digital carbon footprint could triple between 2020 and 2050, and the electricity consumption could double over the same period of time.
• 80% of the carbon footprint is generated by the manufacturing phase of all digital equipment and 65% to 90% of the environmental footprint depending on the observed criteria is generated by end-user devices (such as televisions, smartphones and computers for instance).

1. It is also very important to realize that

the environmental impact is Multicriteria: it is not limited to greenhouse gas emissions. Metals and minerals depletion and their long-term availability or water consumption are other examples of impacts to be considered.

the environmental impact is also Multi-stage: all stages of the life cycle must be taken into account: manufacturing phase, distribution phase, use phase and end-of-life phase such as recycling;

and in addition: the environmental impact is multicomponent: we need to break down digital technologies into three material components: devices, networks and data centers. But we must not underestimate also the impact of digital services and data, the growth of which will necessarily lead to new requirements for networks, data centers and terminals. We'll be talking more on this later.

Now we know a bit more of the ”big picture” of the situation : impacts are multiple, digital technologies’ carbon footprint is already significant and it could potentially triple by 2050 if nothing is done. This logically brings us to the next step of the story. What can we do?

Step Three: Let’s act, let’s act together

This chapter is the longest, because there’s a lot we can do.

BEREC, the Body of European Regulators for Electronic communications has progressively developed a new expertise regarding the different aspects of sustainability of digital technologies, including electronic communication networks and services.

It is all the more important, as BEREC is a technical advisor to the European institutions. We aim at providing our contribution and expertise to assist the implementation of digital targets of the European Green Deal and the United Nation’s Agenda 2030.

And whether it is BEREC at EU level, or Arcep at French level, our goal is to provide robust neutral inputs and recommendations to policy-makers and society as a whole.

First action is Data-driven regulation

Let me first precise what I mean, as a regulator, when I praise data-driven regulation: it is the use of the power of information to understand the market and shed light on how it operates in a factual manner, to then steer it more effectively in the right direction.

Practically, four steps are needed:

1. First: Collect environmental data and improve measurement quality, to better assess environmental issues. Why collecting environmental data matters? It is simple: once we have a better understanding, we can act more effectively to promote sustainable digital technologies. A number of national regulatory authorities have already started to collect environmental data or will soon do it, such as Arcep in France since 2020. BEREC has worked to develop robust sustainability indicators.
2. Second: Inform all stakeholders: decision makers, market players and end-users and allow the implementation of appropriate measures;
3. Third: Provide incentives for economic actors to adopt environmentally sustainable behavior;
4. Fourth: Empower end-users by making data available and information to the general public

As an example of Data driven regulation, and it will surely concern some of the participants today, we are soon expecting, from the European Commission, the publication of a Code of Conduct for stakeholders, that will bring transparency on the sustainability of telecom networks and services. This should be a follow-up to a Commission study published in March 2024 on the identification of common indicators, which took on board the results of BEREC’s initial work on sustainability indicators.

Second action: the need to encourage environmental accountability of all digital players

As we have seen, most of the digital technologies’ carbon footprint is generated by the manufacturing of devices.

But the impact of digital services should not be underestimated because the digital use has an impact on all the components of digital technology.

Let’s take an example of a common service like streaming a movie through an online streaming platform.

You need of course one or several devices: your smartphone or your TV…. You also need to use networks to convey larger and larger video streams. Data centers are also mobilized to store and compress video files in many formats. Obviously, these digital infrastructures need energy and emit greenhouse gases, and also require raw materials for their construction. As a result, and despite better efficiency, the more digital services the more resources required in the end.

Hence, the interdependence between the elements of the digital value chain, that is to say terminals, networks, data centers as well as services must be considered as a whole in the development of public policies addressing the environmental impact of digital technology.

Environmental regulations are now applied to some digital players notably to improve environmental transparency and energy efficiency. For instance, Europe is already acting on most of the protagonists of our story:

• On Data centers, with the Energy Efficiency Directive
• On End-user devices, with the directive on common rules promoting the repair of goods
• On Telecoms networks and services, with the upcoming Code of Conduct which I mentioned earlier,

However, one the key heroes of the story is yet to be taken onboard: digital services. There is a solution to address this: ECODESIGN.

Ecodesign is also a key principle to balance environmental targets with the path to digitalization.

In fact, some national and European ecodesign policies have already been introduced for digital products, but the ecodesign of digital services is a relatively new topic.

Despite their perceived immateriality, digital services play a significant role in environmental impacts, due in particular to the attention-grabbing strategies of certain platforms and the development of energy-intensive applications such as Generative AI-based services.

To put it more bluntly: Instagram, TikTok, YouTube and Netflix are way more concrete than pixels. To address this issue, BEREC outlined the importance of promoting the ecodesign criteria at EU level in order to develop digital services sustainable by design.

In France, we have published few weeks ago a general policy framework for the ecodesign of digital services. This is a set of good practices for content and application providers to reduce the environmental footprint of their services.

Let me give you three examples of questions that designers and developers should answer before developing a digital service:

1. Can the digital service be used on older model devices?
2. Does the digital service display content without infinite scroll?
3. Does the digital service use videos with an efficient compression method that is adapted to the content and the viewing context?

This is quite simple, and it is really useful, for reducing the number of new devices, new network equipment or new data centers which are key actions for reducing environmental impact.

Therefore, BEREC warmly welcomes the acknowledgment of the European commission in its White Paper on digital infrastructure needs, of the importance to work on the environmental accountability of content and applications providers. We are ready to contribute to this.

The second key hero of the story is the end-user.

As underlined by BEREC latest report, regulatory authorities have a great experience on end -ser’s rights protection and can play a greater role to enhance user-centric environmental communication. They can help end-users to know what’s at stake, what are the good practices and help them to use their rights.

Third action: integrate sustainability into public bodies’ traditional activities

It also seems important for public bodies to be able to integrate sustainability objectives into their day-to-day activities. This is also Commission intention to encourage this further.

If BEREC supports the possible inclusion of sustainability objectives in the EU regulatory framework for electronic communications, we should also make it clear that action can be taken now, without waiting for changes in the law. For instance, BEREC is currently exploring how infrastructure sharing and its promotion by regulators can support environmental targets.

And now: what still needs to be done

There is yet much to be done collectively, and the timing is perfect to act.

You public policy makers, you legislators, you digital players, you NGOs or academics, we regulators, are at the forefront of this challenging and stimulating task.

I would like us to explore simultaneously and together three paths:

1. The first one is to pursue and deepen everything I have just mentioned at European level, in particular scale up “sustainability by design” – This is of the utmost importance.
2. The second one is to act at international level: ITU’s Council has been actively working on promoting the sustainability of digital technologies. The OECD is also key to promote this topic and has taken the challenge onboard. International institutions are key to collective endeavor! We must strengthen their work with even more ambitious objectives.
3. The third one is to take into account new digital technologies such as Satellite constellations and Generative AI tools and make them sustainable by design from now on.

Let me tell you my fears:

• Satellite constellations: they are fantastic for many purposes, no doubt, and especially in communications. But can we really imagine having thousands and thousands of satellites launched every year in space without any specific environmental rules? Can we design conditions in which having tens of thousands of satellites is sustainable? I think that we have the responsibility to address collectively this question.Artificial intelligence: this is another key issue. Despite their ambitious sustainability goals, Microsoft and Google have recently publicly revealed that their emissions of carbonic gas have been rising, and they have blamed in particular generative AI take-off. As I mentioned earlier, we’re all convinced of the benefits of digital technologies, and the use of AI in particular, but we need to ensure that future generations will be able to enjoy them too.

We need to make sure that companies are developing and scaling sustainable AIs tools. If we want to take advantage of the tremendous potential of AI for health, climate understanding, education, the economy and society in general, let's make sure it's designed sustainably.

My epilogue will be very brief:

I presented you the three first chapters of the story of the sustainability of digital technologies. There are a lot more chapters to write together collectively.

There is no such thing as fate. We are in a situation where we can build desirable digital technologies that will not only fulfill our needs today, but also for generations to come, within our planet boundaries.

Thank you very much."