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    Have your say – Digital infrastructure (white paper)

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    White Paper – ‘How to master Europe’s digital infrastructure needs?’

    About this initiative: This White Paper analyses the multiple challenges Europe currently faces in the rollout of future connectivity networks. It presents possible scenarios going forward to address those challenges, attract investment, foster innovation, increase security and achieve a true Digital Single Market.

    Feedback period: for stage 5 it is 22 February 2024 – 30 June 2024

    Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14168-White-Paper-How-to-master-Europes-digital-infrastructure-needs?_en

    Feedback from Europeans for Safe Connections

    1. INTRODUCTION …………………………………………………………………………………………………….. 3

    The introduction of the White Paper – How to master Europe’s digital infrastructure needs? clearly shows many advantages that are expected from the digital developments. However, in a proper policy document the negative side of developments need to be addressed as well, to achieve the desired results. Only security threats are . The paper clearly lacks a view on the side effects of digitalization.

    Although in various European countries significant disturbance of social life and development of children due to digitalization is understood and policies related to this are already implemented and the first legal measures are taken, these side effects are ignored in this policy. Decades ago Dr. Manfred Spitzer published the science behind known side effects, as described in his book Digital Dementia. Many other scientists endorse his view and add weight to it. Where the brain development of children is hindered by technology the future is at stake.

    We see a debate in science about the health effects of EMFs (electromagnetic fields) from both analogue and digital equipment. We are sorry to see that the EU is ignoring this scientific development by only considering the views of the formal committees that are shown to be related to just one of the scientific schools. The views of the many scientists who see unwanted health effects and effects in nature in their research are not taken into account. Peer reviewed research and even heavily peer reviewed research showing serious long term health effects, is set aside. The advice from the European Environmental Agency in the report ‘Late lessons from early warnings’ is ignored. As a result, industry is not required to produce digital equipment without side effects of EMFs for health of people and nature. The EU is accepting the outcome of the clever but short-sighted lobby from industry.

    We also see a big impact of digitalization, as promoted in this white paper, on the environment and energy consumption. Without a dedicated policy to limit these impacts digitalization will likely impede the objectives of the most important other EU policy: The Green Deal. The facts that clearly prove these side effects are widely available and should not be overlooked or ignored.

    2. TRENDS AND CHALLENGES IN THE DIGITAL INFRASTRUCTURE SECTOR. 5

    2.1. Europe’s connectivity infrastructure challenges………………………………………………….. 5

    There is no study that shows any beneficial effects of 5G on the environment and health. On the contrary, many studies show adverse effects.

    We suggest EU allows 5G only for industrial buildings, residents have the right not to be exposed to radiation from 5G and have the right to revoke such transmitters in their vicinity.

    5G in agriculture threatens biodiversity. Provide fibre optic cables and limit wireless radiation.

    Remote healthcare can take advantage of the stability and reliability of fibre optic cables as the backbone for wireless communications and is more resilient to vulnerabilities, failures and attacks.

    The European Commission’s huge investment in technologies that can’t guarantee that health and environment will not be damaged is not balanced by high-quality independent research. Who will be responsible for the exposure of the population to harmful radiation from the highly dense 5G/6G telecommunications infrastructure?

    Among the technologies mentioned in the document, it is possible to support the development of digital infrastructure by completing optical networks (i.e. through cables with optical fibres). Wireless networks, including mobile networks, must be reduced due to the health and safety risks they pose. For example, according to the International Agency for Research on Cancer (IARC), which is part of the World Health Organization (WHO), radio frequency electromagnetic fields are classified as a possible human carcinogen. This means that they are included in group 2B. (https://www.iarc.who.int/wp-content/uploads/2018/07/pr208_E.pdf). The EPRS (Health effects of 5G) identifies EMF as proven to be harmful for (male) reproduction, possible for female reproduction and likely carcinogenic.

    2.2. Technological challenges……………………………………………………………………………………. 7

    The quotation from the document: “The ability of European suppliers to … become leading global providers of 6G equipment will largely depend on how they navigate the broad technological changes in the industry and embrace the paradigm shift that comes with them (see section 2.4.1). The 2023 Beyond 5G/6G Roadmap of EU and US industries is a welcome development in this regard.

    Our comment: 5G has not been environmentally assessed, let alone 6G!

    The quotation from the document: “New business models and entirely new markets are emerging from technological developments around the App Economy, IoT, Data Analytics, AI or new forms of content delivery such as high-quality video streaming.

    Our comment: The EU is founded on common principles of democracy, the rule of law, and fundamental rights. Therefore the EU needs to address the interests of ordinary citizens. Based on the above, we consider it essential that citizens are always fully informed about all the features and consequences, including all risks and that they always have the opportunity to refuse these technologies or switch off the wireless mode without incurring any sanctions or disadvantages.

    2.3. Challenges of achieving scale in EU connectivity services ……………………………….. 10

    2.3.1. Investment needs……………………………………………………………………………………. 10

    The quotation from the document: “…reaching current Digital Decade targets for Gigabit connectivity and 5G may require a total investment of up to EUR 148 billion…There is an estimated cloud investment gap in the EU of EUR 80 billion until 2027.

    Our comment: How much money will be invested into health impact studies and environmental impact studies?

    The quotation from the document: “However, for future upgrades, e.g. 6G or WiFi 6 the required network densification is likely to increase by a factor of 2-3 by the end of the decade at least in high-density demand areas.

    Our comment: So the exposure of the public will increase dramatically.

    The document talks about the competitiveness of the EU in the field of wireless technologies, the legislative framework for their rapid development, their resilience and sustainability. But the document does not address the health risks of digital infrastructure, the impact on the environment and the consequences for the Green Deal.

    • In what way does the commission want to reflect the rapid development of digital technologies in connection with research on the health risks, the environment and the Green Deal of these developments?
    • In what way does the commission want to solve the current health risks that are already confirmed, need to be researched in the near future, or are at the stage of research in connection with wireless technologies (e.g. the rapid development of technology used by children and adolescents, increase in mental illnesses also in connection with excessive use of social networks, occurrence of ElectroHyperSenzitivity)

    We hereby ask the commission for a proposal that will also create a framework for funding science and research in connection with the safety of digital technologies in the area of health risks.

    2.3.2. Financial situation of the EU electronic communications sector …………….. 11

    2.3.3. Lack of single market…………………………………………………………………………….. 13

    2.3.4. Convergence and level playing field………………………………………………………. 15

    2.3.5. Sustainability challenges………………………………………………………………………… 16

    The quotation from the document: “The ICT sector accounts for between 7 and 9% of global electricity consumption (forecast to rise to 13% by 2030), around 3% of global greenhouse gas emissions, and increasing amounts of e-waste. Yet, if properly used and governed, digital technology can help cut global emissions by 15%, outweighing the emissions caused by the sector. For instance, smart building design has the potential to generate energy savings of up to 27% and smart mobility applications have been shown to be able to reduce transport emissions by up to 37%. Connected and Automated Mobility is expected to be one of the main drivers to decarbonise the transport sector and 5G is expected to be one of its main enablers. However, significant further efforts are needed to apply digital technology systematically and make sure it powers solutions carefully designed according to circular, regenerative principles.

    Our comment: To sum up:


    ConsumptionSavings / Cuts
    Electricity13% *[1]? *[2]
    CO23% *[3]15% *[4]

    *[1]

    • Digital industry consumes 10% of electricity, equal to 100 NUCLEAR power plants.
    • If ICT were a country it would rank third after China and the U.S. for electric energy consumption.
    • Digital industry consumes 3 times the consumption in energy, materials, water of a country like France or the UK. ICT requires 12.5% of global copper production, 15% of Palladium, 70% of Gallium, 85% of Terbium

    *[2]

    • The Internet is celebrated as an example of tertiarization of the economy (a shift to the tertiary sector in macroeconomics) while, in reality, we are increasingly talking about data centres, data farms, Hubs, information highways.
      • There are 3 million data centres in the world that are less than 500 sq. m. in size, 85,000 of intermediate size, 500 as big as a soccer field!
      • 99% of data passes through a huge number of land and undersea cables. They are needed to allow transmission of even the simple ‘like’.
      • For maximum reliability and speed of transmission these servers are working at 60 % of their capacity, and squandering a huge amount of electricity and water due to cooling.
      • In spite of the assumptions reported, we underline that an ‘intramundane’ grid of data centres, hydroelectric power plants, coal-fired power plants, strategic metal mines, etc., etc., has been created which is also producingvery rapidly growing pollution.

    *[3]

    • Digital industry produces 4% of global CO2 emissions (double that of civil aviation).

    *[4]

    • The United Nations Conference on Trade and Development (UNCTD) states that digital deployments will lead to a 15% CO2 savings. But we wonder about the impartiality of it, as the technical committee Smarter2030 by GeSI, that should be unbiased, consisted of 17 experts when 13 of them were provided by private organizations (like BT, Deutsche Telecom, Huawei, Microsoft, Verizon …!)

    Note: What do you mean by “properly used and governed smart building and smart mobility“? Who decides what is proper and what is not? And if not proper, who will control remotely the building/vehicle?

    2.4. Need for security in the supply and in the operation of networks………………………. 17

    2.4.1. Challenge of trusted suppliers………………………………………………………………… 17

    2.4.2. Security standards for end-to-end connectivity ………………………………………. 17

    2.4.3. Secure and resilient submarine cable infrastructures ………………………………. 18

    3. MASTERING THE TRANSITION TO THE DIGITAL NETWORKS OF THE

    FUTURE – POLICY ISSUES AND POSSIBLE SOLUTIONS ………………………………………. 20

    3.1. Pillar I: Creating the “3C Network” – “Connected Collaborative Computing”…… 20

    3.1.1. Capacity building through open innovation and technology capabilities … 20

    3.1.2. Way forward………………………………………………………………………………………….. 22

    3.1.3. Summary of possible scenarios………………………………………………………………. 24

    Our comment: How about scenario 4. Ask EU citizens whether or to what extent to allow digital innovations. The European people have not been asked whether they prefer cable or wireless digitalization and in particular they have certainly not been involved in a discussion on the pros and cons of wireless rollout.

    3.2. Pillar II: Completing the Digital Single Market ………………………………………………… 25

    3.2.1. Objectives ……………………………………………………………………………………………… 25

    3.2.2. Scope of application ………………………………………………………………………………. 25

    3.2.3. Authorisation …………………………………………………………………………………………. 27

    3.2.4. Addressing barriers to core network centralisation…………………………………. 27

    3.2.5. Radio spectrum………………………………………………………………………………………. 28

    The pursuit of economic growth and profit by telecommunications operators, industrial companies or other entities should not prevail over the primary need to protect the environment, sustainable management of natural resources and the right to health. For example, we refer to what we believe to be a neglected analysis of the environmental, energy, and health impacts of 5G wireless technology in the Impact Assessment of the Gigabit Infrastructure Act, Part 1 (p. 51, footnote 150).

    It has become standard practice in the medical, automotive and food industries to test these products and services for public health risks before they are placed on the market. The EC should stop the deployment of 5G and 6G, as it first owes the residents of the member states a study on the health effects. The fact that only economic impacts have been carried out and there is no analysis of impacts on health and the environment is also evident from the report of the Regulatory Scrutiny Board.

    3.2.6. Copper switch-off ………………………………………………………………………………….. 31

    Our comment: The end user must always be able to switch to a cable connection, e.g. via optical fibre and in case of incompatibility of the end-device with the new cable connection, the costs of this transition must not be borne by the end user. Furthermore wireless activity of equipment should be clear to the user and the user should be able to switch it off easily.

    3.2.7. Access policy in a full fibre environment……………………………………………….. 32

    We welcome the expansion of optical connectivity, as long as this optical connectivity is not an accelerator for further wireless connectivity, e.g. 5G and 6G rollout (SAWAPs / FWAs), but it should ensure the reduction of wireless emissions for residents.

    The Commission should prioritize communication technologies based on wired (i.e. cable) connections (to homes, businesses, data centres) as it is the most sustainable communication technology solution in terms of energy, maintenance and cost-effectiveness. We mean the infrastructure that connects the path from the data centre to the end user. It also supports the objectives of the Ecodesign Directive, which we have also commented on.

    Is it worth mentioning that cable connections are also more secure and more reliable than wireless. Wired connections are almost always faster (unless in a totally RFI-free environment) because wireless connections are prone to data packets being corrupted by Radio Frequency Inter-ference (RFI) which then have to be resent and hence reduce the overall effective data transmission speed.

    3.2.8. Universal service and affordability of digital infrastructure ……………………. 35

    3.2.9. Sustainability …………………………………………………………………………………………. 35

    The quotation from the document: The Commission … introducing ‘transparency measures for electronic communications operators on their environmental footprint’ at EU level. Such transparency efforts could … make ICT greener (‘green ICT’) and have it enable the greening of other sectors (‘ICT for green’)

    In this regard, the Commission could also assess the metrics to estimate the net carbon impact of digital solutions in climate critical sectors such as energy, transport, construction, agriculture, smart cities and manufacturing, as developed by the European Green Digital Coalition.

    Our comment:

    • The energy sector (and legislators) assure that with the new, more efficient technology you will consume less. This is absolutely not true as has been well demonstrated in the past, e.g. with the steam engine in the 19th century: the energy savings generated by technical progress was counterbalanced by the increased use of machines; other examples are phone communication, when the cost of a single call was dramatically decreased the number of calls increased significantly. This means that the EU cannot rely on the new technology to reduce energy consumption on its own, but must impose specific policies to reduce overall energy consumption.
    • Transport: A connected car has 150 control units, and produces 25 GB/hr with processing power demand equal to 25 personal computers! One million connected electric cars produces as much as the entire world’s web-connected population. The more ‘autonomous’ the car will be, the more it will depend on the infrastructure around it! These facts call the EU to introduce a policy to direct this foreseeable counterproductive development.
    • Water is needed in agriculture. But artificial intelligence is seen as a giant energy hog, with huge water footprint. As well as cryptocurrency mining has. In its Environmental Sustainability Report, Microsoft quantified a 34% increase in water consumption between 2021 and 2022. In the 2023 study researchers highlighted a serious environmental and social issue that a large AI model can evaporate a staggering one million litres of fresh water per training session. This information has been kept secret, but is now available. A training session could also consume 1,287 MW of energy and release up to 550 tonnes of CO2 to the environment. As the availability of fresh water in itself is becoming an important issue, these facts call the EU to introduce a policy to direct this development in order to prevent lack of fresh water.
    • Smart cities and other mobile communication: Ericsson predicts that 2025 5G users will consume 200 GB/month which is 10-14 times more than 4G!
    • Manufacturing a smartphone is responsible for half of its environmental footprint and 80% of its WHOLE life cycle energy expenditure. Another example is the MIPS (Material Input Per Service unit = amount of resources required to manufacture a product or service):
    • To produce a steel bar requires 10 times more resources than its final weight.
    • For a television: 200 – 1000 more
    • For an integrated circuit: 16,000 times more!

    Currently, however, the life cycle of a smartphone is only a few years. This needs to be dramatically extended and repairability needs to be introduced to reduce e-waste.

    Industry reports that energy consumption from wireless devices and networks will grow exponentially, by 160% until 2030 and 5G Radio Access Network will increase global CO2 emissions by approximately 250 megatonnes. A 2019 German study, funded by E.ON, found that 5G will significantly increase energy consumption in data centres and boost data demand, resulting in increased energy consumption of ~3.8 TWh per year by 2025 (the electricity used by 2.5 million German residents). Chinese 2023 study reveals carbon trap and significant energy increase associated with 5G rollout. Moreover, data centres with artificial intelligence hardware consume 20 times more energy than traditional server-based data centres.

    With real growth in data traffic, it is clear that energy efficiency cannot prevent a significant increase in 5G power consumption. Especially if the Commission follows its action plan to deploy up to 800 base stations per square kilometre, serving up to one million connected 5G and IoT devices per square kilometre. As indicated above, 5G base stations consume more power than 4G, despite their better efficiency, so the transition of existing 4G infrastructure to 5G is unlikely to reduce consumption on the antenna and wireless infrastructure side. Compared to previous generations of mobile connectivity, base stations operating over software-defined 5G networks are entirely dependent on software algorithms controlled from data centres. The blanket rollout of 5G will lead to a huge increase in energy consumption due to the power requirements of the huge number of base stations, but the massive additional energy consumption will fall on the data centres that control all these stations. Besides this the increased burden on the environment, there will also be a huge rise in ubiquitous wireless radiation. The exposure to this has not been adequately tested for health risks.

    More issues:

    • Emerging connected (autonomous) AI-based vehicles are gathering vast amounts of information from their sensors and cameras in real time. A connected car can have 150 control units and produce around 25 Gigabytes of data per hour. Data centres, the brains of autonomous vehicles, require massive computing power, equal to 25 personal computers per vehicle, to process and analyse such a huge amount of data, either from the vehicles or from traffic monitoring systems, so that the vehicles can make the right decision in a fraction of a second. If self-driving cars become widespread, they will be a significant source of unaccounted carbon emissions that could exceed the global emissions of existing data centres, a recent study warns. One million connected vehicles generate as much data as the entire internet-connected population of the world. The level of autonomy determines the vehicle’s dependency on surrounding infrastructure.
    • Polluter pays principle: Ensure that if companies with data centre or telecommunications infrastructure harm the environment or human health, the polluter pays principle is applied. Companies operating data centres or telecommunications infrastructure with an environmental impact should provide transparent data to the public on their management of energy, water and natural resources.
    • The Commission should more carefully assess all technologies before they are deployed to ensure that they do not cause massive damage to the environment and natural resources in the future. In cooperation with the design industry these foreseeable negative footprints need to be addressed.
    • Green deal: The Green Deal is based on the idea that ICT technologies will solve the situation. Existing evidence suggests that ICTs are contributing to further burden on the environment and human health rather than solving it. We also believe, based on the scientific facts shown above, that many of the European Commission’s actions on technology issues are counterproductive to the implementation of the Green Deal.

    3.2.10. Summary of possible scenarios………………………………………………………………. 36

    3.3. Pillar III: Secure and resilient digital infrastructures for Europe ……………………….. 37

    3.3.1. Towards secure communication using quantum and post-quantum

    technologies…………………………………………………………………………………………………………….. 38

    3.3.2. Towards security and resilience of submarine cable infrastructures ……….. 39

    3.3.3. Summary of possible scenarios ……………………………………………………………… 40

    4. CONCLUSION……………………………………………………………………………………………………….. 41

    The first line of the conclusion in the Whiter paper: “As we are at the crossroads of major technological and regulatory developments, it is of tantamount importance to debate these developments broadly with all stakeholders and like-minded partners.

    Given the huge discrepancy in understanding the likely impact and the ignored interests, this is a fundamentally wrong attitude in this policy paper. The EU Commission should be open to all citizens, not only the like-minded partners. This EU approach is mainly a one-sided economy-and technology-focused one, actually reflecting a fundamental problem in the EU.

    For the benefit of all the EU should be much more focused on development of moral values, justice, human qualities, education, improving access to relevant information, improving the environment, quality of life, strengthening historical memory and applying the precautionary principle.

    Best regards
    Europeans for Safe Connections
    This feedback was sent from a wired internet connection
    – No use of harmful radiation
    – Less electricity consumption
    – Increased data security

    Link to our feedback: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14168-White-Paper-How-to-master-Europes-digital-infrastructure-needs?/F3470278_en

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