While network sharing can reduce the carbon footprint of the telecoms sector, the industry believes it should be agreed voluntarily, rather than mandated by regulators
BEREC’s draft report explores the scope for regulation to improve the environmental performance of telecoms
On 5 December 2024, the Body of European Regulators for Electronic Communications (BEREC) published its draft report on Infrastructure Sharing as a lever for ECN/ECS Environmental Sustainability, simultaneously launching a public consultation that runs until 31 January 2025. The report comes in response to the EU Green Deal and the UN’s 2030 Agenda, as BEREC examines how regulatory tools can help enhance the environmental performance of the telecoms sector by minimising the carbon footprint of network deployment and operation. A previous report from BEREC in 2022 also outlined ways to limit the impact of the digital sector on the environment, highlighting the importance of infrastructure sharing as well as the deployment of more energy efficient technologies, such as fibre.
Infrastructure sharing can reduce CO2 emissions, energy consumption and e-waste
BEREC’s draft report outlines a number of ways in which greater infrastructure sharing in telecoms can support Europe’s sustainability efforts:
Fewer physical structures, e.g. towers and ducts, need to be built, with the reduction in duplicate infrastructure lowering the environmental impact of the industry;
Infrastructure sharing allows for more efficient energy usage, reducing the energy consumed by each network, particularly in data centres and mobile networks;
Fewer materials would be needed for shared new infrastructure, reducing the extraction of raw materials needed for infrastructure deployment;
An overall reduction of CO2 emissions;
There would be less need for land, which would reduce deforestation and land clearing typically required by the building of new infrastructure; and
The reduced need for the replacement and disposal of electronic devices and components can lower e-waste.
Most EU Member States have recognised that infrastructure sharing can benefit environmental sustainability in their legislations
In the EU, the European Electronic Communications Code (EECC) – specifically, Article 44 – provides national regulatory authorities (NRAs) with the power to enforce co-location and infrastructure sharing on telecoms operators. Most Member States have transposed this article of the EECC into national law. According to the report, 18 EU countries have directly referenced the environmental benefits of infrastructure sharing, however, only two of these countries have actually imposed co-location and infrastructure sharing based on the provisions of Article 44. The Croatian regulator, HAKOM, imposes co-location and physical infrastructure sharing on operators under certain circumstances, such as the availability of free space for deployment. In contrast, in Spain, the Ministry of Digital Transformation has been granted powers in line with Article 44, rather than the regulator. However, as BEREC’s report only covers the work of NRAs, it therefore does not include information of how the Spanish Government is imposing infrastructure sharing and co-location.
Stakeholders argue the importance of a balance between voluntary and regulation-enforced infrastructure sharing
BEREC’s draft report details the views of key stakeholders on the issue of infrastructure sharing and environmental sustainability. According to Connect Europe, infrastructure sharing agreements can be bureaucratic, difficult and dependent on a range of factors, such as the size of the networks connected. It sees the need for improved regulation and clarity for voluntary and commercially viable network sharing agreements, arguing that a more flexible framework is required by operators. To improve regulatory clarity, Connect Europe considers there should be a clear presumption of the legality of active radio access network (RAN) sharing – suggesting that without consistent rules for legitimate sharing, it can be difficult for operators to identify the boundaries of sharing agreements. The European Competitive Telecommunications Association (ECTA) echoed these points in its own comments to BEREC, noting that the majority of current mobile infrastructure sharing agreements in Europe have come as a result of commercial negotiation rather than regulatory intervention. Stakeholders were generally in agreement that as well as finding an efficient balance between developing infrastructure sharing through regulation and commercial agreements, regulatory stability is also of utmost importance to give operators a clear framework in which to make these agreements.
