GSMA对数字十年政策计划审查报告证据征集的回应

GSMAresponse to theCall for Evidencefor the Report onthereview of theDigitalDecadePolicyProgramme Introduction The GSMAwelcomes the opportunity to submit feedback to the European Commission’scall for evidence for the Report on the review of the Digital Decade Policy Programme(DDPP). European telecoms are the backbone of Europe’s digital competitiveness.Widespreadavailability ofstate-of-the-art,secure and resilient connectivity infrastructure isequallycrucial for the EU’s overall competitiveness vis-à-vis other world regions andthefundamentalambitionof the Digital Decade 2030 to“[promote] a human-centred,fundamental-rights-based,inclusive,transparent and open digital environment”.Competitiveness should be at the core of EU’s strategic thinking, and can only beachievedwithastrengthened andfinanciallysustainableEU telecommunicationssector, thatand enables thenecessary investments into connectivity infrastructure,cybersecurity, and advanced digital services for the overall benefit of European citizens,industry, and the public sector.Financially healthy telecom operators will enable Europeancompanies to compete globally.A financiallystrongtelecommunications sectorcapable ofundertaking the required investmentsshould be added to the Digital Decade 2030generalobjectives in Article 3, which alreadycontains a reference toa‘competitivedatacloudinfrastructure’ (article 3, paragraph 1(e)). Given the long timelines of major digital investments, particularly large-scale, capital-intensive digital infrastructure, a more long-term and predictable policy framework,could greatly enhance planning certainty. Today, all together, building full gigabit coverage for Europe is estimated to requiresignificantinvestment.The GSMAi 5G index shows Europe lagging,on average,significantly behind other regions on 5G coverage and speeds12,While public funding canbe useful, it isunlikely to bridge that gap on its own. It is alsoimportant to ensure that itdoes not crowd out private investmentsand that it is used only in cases of market failure. Yet another challenge of EUdigital infrastructure markets is its fragmentation comparedto other regions of the world. Thispreventsreaching the necessary economies of scale,which in turn limit our possibilities to invest in more resilient networks and innovativeservices for our customers, end-users and industries alike.Fragmentation of policieshasalso taken a toll on our industry’s global competitiveness,vianumerousnational divergences and gold-plating in areas where EUharmonisationmakes perfect sense,such aspro-investmentspectrumlicencing andusagerules. Efforts to address this fragmentation should focus on harmonization and enabling scale,while ensuring that any measures taken are risk-based, proportionate, and do notunnecessarily restrict access to innovative, best-in-class global technologies. Theobjective is to strengthen Europe’s competitiveness and resilience through open, fair,and non-discriminatory policies. For the DDPP, the priority at this stage is not to define new targets or KPIs. Instead, whatis needed is,first,agenuinely ambitious reform of thetelecomregulatory frameworkwiththe DNA—one that enables the EU to meet the targets already in place.Second, we urgeareform ofEU competition policyto foster investment and enable scale.Finally,stakeholders’ involvement in the DDPP process could be further enhanced. Below, we highlight some key areas to improve telecom operators’ investment capacityin best-in-class connectivity networks and services. 1.Thefinancial sustainability of the sector Achieving the DDPP’s ambitious targets requires a consistent investment policy. The objectives are mostly relevant but jeopardized by a structural investment gap, Thisinvestment gap entails both the cost of completing FTTP deployment and of providing a “full5G servicecoverage” with “additional base stations and small cells”, notably for the mid orhigh range 5G frequency bands. European operators have already invested nearly~€200bnsince the launch of 5G networks in 2019. The current European regulatory framework, still focused on static price competition in acontext of market fragmentation, prevents European operators from reaching the scaleneeded to deploy 5G Stand Alone (SA) and Edge Cloud according to the targets setby theCommission3. Achieving these ambitious targets requires a paradigm shift towards an'Investment-First'policy: facilitating in-market consolidation, supporting a spectrum policy that provides long term investment certaintyand establishing a level playing field with Large Traffic Generators(LTG), who currently have a free-ride on European networks. Inparallel of the difficulties toderiveadequate returns, European operators have increasingpressure on their capacity to finance their investments, as in 2023 the ratio of Net Debt toEBITDA peaked at 2.57, the highest level in years4. This constraint adds to the high capitalintensity these operators are maintaining, with a 21.4% capex