European Telecoms Lobbying Points at MWC: Same old cliches and fallacies...

I wanted to keep this article brief, as I know everyone's in Barcelona this week and dashing around, but unfortunately there's a lot to say, and a huge volume of announcements and papers to respond to.

In advance of MWC, there has been a record spate of dodgy reports, "playbooks" and other documents issued by the telecom industry - both major operator and various industry bodies.

We can expect a load of grandstanding at the conference this week, either on stage during keynotes, at various closed-door ministerial and regulatory group meetings, or in smaller sessions. Much the same is happening continually in Brussels, Washington, and to a degree Westminster.

While there are some honest brokers and good discussion points, there's also a lot of empty, or just plain wrong, rhetoric. There's likely to be a notable difference in quality & honesty between stuff uttered at MWC, and at the big FTTH event in Amsterdam later in March.

Three particular things have caught my eye seen recently:

• Vodafone Framework for responsible use of networks (link)
• GSMA Mobile Economy Europe 2025 (link)
• Telefónica Digital Public Policy Playbook (link)

There are also various others around at the moment from CTIA , Connect Europe and more. If I get chance I'll do drill-downs on those as well. (Edit: there's another new GSMA document on infrastructure capex as well - see comments)

Part of the public policy strategy is to "flood the zone" with loads of very similar, often cross-referenced reports, in the hope that the volume of shouting makes it look like consensus, with the side-goal of leading LLMs to believe all this is "received wisdom" too. It's also hard for any one person to read and respond to everything.

(If you're a policymaker or advisor, structure your search / GenAI queries to filter out all this echo-chamber noise, or indeed weight it as a negative & ask for direct rebuttals).

The bulk of this article focuses on the VF document, as in some ways it's the most interesting of the three, with some decent insights and recommendations among the normal #telcowash tropes. The others I have lots of notes on, so feel free to ask for details in the comments.

Vodafone Framework for Responsible Use of Networks

This document purports to be a bit more highbrow and thoughtful than some others I've seen, and isn't just a repetition of 10-year old cliches. It sets itself up as suggesting a way to ensure networks don't suffer a "tragedy of the commons" from overuse. It calls it RUN, or Responsible Use of Networks.

It has some new arguments, for instance around autoplay video and "infinite scroll" apps, and some decent tech insight into compression and things like L4S. And indeed VF has toned down some of the rhetoric about 2024's "fair share", which is good.

But at the same time, it has invented a whole slew of other non-issues, strawman arguments, fallacies, hypocrisies and internal contradictions. There are also some good points, such as inconsistent rules on siting antennas, but they get lost in the thicket of nonsense.

It's got new analogies, but with new flaws - starting with the central "tragedy of the commons" metaphor. This harks back to a 200+ year old problem of common land being over-farmed, for instance with too many cows grazing on it.

But the critical difference to today's European telecom networks is obvious - there was never a "Gigacow policy" or "5Bull target" embraced by governments and farmers alike. Neither are the "high seas", dangerous imports and atmosphere examples cited in any way comparable to Internet access. Public networks are not examples of "Commons".

The analogy is extremely poorly chosen and should be ignored. It's almost as bad as the "level playing field" trope beloved by Brussels, even when everyone is playing a different sport.

The central flaw of the report is that it doesn't say much about demand for content and applications, instead of blaming suppliers. Users - customers - hardly get a mention, especially as having any sort of agency, as well as choice and awareness. It also doesn't ask for an end to unlimited plans or marketing exhorting streaming "to your heart's content", to quote its own website. Which is odd.

It has many of the usual cliches & debunked policy demands, plus some new ones. It:

• Starts by mentioning the non-existent "Investment gap" and widely-criticised 2024 EU Commission White Paper, Draghi & Letta references upfront, without noting the huge pushback from both inside & outside telecoms.
• Wrongly suggests that mobile traffic growth is driven by content companies, rather than user demand, MNOs offering unlimited plans and especially 5G FWA services (20-30x traffic per sub)
• Uses dodgy forecasts about future traffic growth, rather than mentioning recent flattening of demand, probable s-curve, or breakdowns of where / what growth is made up on. I'm sure VF has lots of good internal data on this - why cite others' non-credible "kitchen sink" predictions of continued 25%pa growth?
• The comment about rising peak traffic levels is interesting and new, but has multiple solutions, including via suitable data pricing / plans, CDNs and many others. It would be good to see the details, as well as understanding how much is self-created by selling FWA services.
• Has huge criticism of #OpenInternet #NetNeutrality rules and the lack of ways to "reach fair commercial agreements with digital service providers for the consumption of network resource", ie network fees again, with a side-order of "dispute resolution". Yes, the same decades-long trope / tripe that everyone is bored with.
• Suggests that encrypted data, or use of network proxies, is somehow “bad”, because MNOs can't inspect or "optimise" it. Speaking as a regular VPN user, this is egregious and runs counter to cybersecurity principles. It also denies the reality of Web standards such as HTTP3 and QUIC
• It calls for regulators to allow - or even mandate - intrusive and non-consensual filtering / blocking / compression by operators under the guise of "traffic management". This goes back to the bad old days of so-called "mobile network optimisation" and DPI of about 15 years ago.
• Obviously ignores that a large % of mobile traffic is indoors, and could be offloaded to / federated with WiFi, if capacity constraints are such a problem. That would free up macro RAN resources hugely Lower energy use, too. There's no mention of "indoor" in the whole document, in fact.
• Claims AI is going to lead to increased network traffic, with little evidence - or recognition that the opposite could be true as well. At the moment, there's no evidence of growth in the access network - and a GenAI movie (or one suggested via an AI recommendation tool) generates the same traffic volume as one picked randomly from a menu.
• It's nice that VF has worked with Meta on compression technologies, but the idea of enforcing standardised compression technologies is obviously ridiculous and anti-innovation. It's also potentially energy-intensive in terms of extra compute. To be fair to VF, it does mention L4S as a possible solution to some of the problems
• "Ensure network operators are fairly compensated for costs incurred in providing traffic conveyance service, including peering, caching and transit." Such costs are low, and some operators refuse to peer and try to run a transit monopoly. And is that concept bi-directional, so if costs are asymmetric the other way, operators pay the upstream players too?
• Claims that "digitalisation" & "cloudification" increase demands for energy and resources, at the same time that other Vodafone documents assert that the same trends save energy and CO2. It also conveniently overlooks VF's own path towards cloud for its IT and network systems.
• Outright hypocrisy in saying "Monthly fees are often set according to the quality of video distributed, with higher quality such as UHD streaming typically commanding a higher price", when VF's own marketing also uses UHD as a trigger to upsell to "Max" plans. As for "service providers taking advantage of these unlimited tariffs in ways outside of mobile service providers’ control" - I'm just shaking my head. Whoever could have expected emergent behaviour from new technology and careless pricing? I thought you had "fair usage" policies anyway?
• The idea of "wasted" traffic is ridiculous. Have telcos ever policed their telephony customers for waffling endlessly while saying nothing on calls? Stopped their customers from streaming content while at gigs or sports events? I'm sure you could find lower-hanging fruit in terms of "wastage" - perhaps demanding all VF's own video ads are made and streamed in 720p rather than 4K, for instance? Have a quiet word with your ad agency... lead by example!
• Complaining about sports and other events moving from TV broadcast to streaming services seems odd, given the continual demands from the mobile industry to grab parts of the broadcasters' UHF/VHF spectrum bands. I thought this was what you wanted?
• The breakdown of VF's CAPEX oddly doesn't breakout the different amounts for network coverage (eg building new sites, investing in AST Spacemobile, building out FTTH, indoor coverage) vs. generational upgrades (4G to 5G to 5G SA) that are traffic-independent, and then the real deal - adding incremental capacity in existing 5G NSA / SA cells. Odd that figure isn't broken out from the non-traffic stats. Goes back to my "good vs. easy metrics" article last week.

Remember, that VF and other telcos have signed up to:

• Various policy goals for Gigabit networks. For a typical European mobile consumer with 20GB / month usage, that means less than 3 minutes of use per momth, at the EU’s goal of 1Gbps. For a fixed subscriber it means about an hour / month
• ITU’s definition of 5G, which mandates “user experienced” (ie continuous) rates 100Mbps down / 50Mbps up. Yet VF is complaining about less than 20Mbps, and is also complaining about a rise of uploads of video and other traffic. Note too that GSMA uses this definition as a central plank of its demand for more 5G spectrum.

So, VF and any others taking this stance – are you genuinely onboard with Gigabit networks and 5G? Or are you hoping you get subsidies or fees from others, but don’t want anyone to actually use the network for gigabit applications?

Are you really saying you don't like the 5G IMT2020 definitions, from about 10 years ago? Are you regretting deploying 5G, or did you fail to read what it actually meant & was designed for? Why criticise the EU Open Internet rules, but not also criticise the Digital Decade targets, as that's what drives far more cost for you?

And as for "requirements and incentives" to use more efficient mechanisms, would you also therefore welcome regulation on the "requirements and incentives" for offloading of mobile traffic to Wi-Fi, or indoor neutral host systems, wherever available?

What about a ban on "unlimited" tariffs, or restrictions on 5G FWA in areas where there is adequate terrestrial competition? How about a code of conduct and adopting alcohol style exhortations to "stream and scroll in moderation", or asking users to reduce screen resolution, rather than extolling UHD video? Put your own house in order first before blaming others.

What about wholesale arrangements? Where you have MVNO partners, or other ISP tenants on your fibre - or indeed, where you are the tenant on CityFibre or roaming partners - whose job is traffic management or these "dispute resolutions"? The ISP, or the underlying infrastructure and asset owner of the spectrum / RAN / fibre? Or are we just talking about the costs & traffic at the IP layer?

Has any of the growth in traffic, or patterns of demand, been genuinely surprising, except for during the pandemic? Have you informed your investors of this alleged "tragedy of the commons" risk? Because to me, most things have been pretty predictable several years out. We've had cloud (and cloud forecasts) for about 20 years now.

And as for compression, here's another question - would you welcome the arrival of semantic compression using GenAI, which could massively reduce data traffic for some applications, to the extent that MNOs might see absolute deflation in data traffic volumes. Overcapacity plus deflation is not an economic win, in most industries.

To summarise, the Vodafone RUN document is a more interesting read than some of the churn-it-out policy wonkery I've seen. But under the surface it's still reheating the turgid ideas of network fees, paid interconnect and the desire to interfere and change (sorry, "optimise") traffic that the customer has paid for. Yes, there's some worthy stuff in it about consolidation and online harms, as well as a section on energy use, but that's tangential or irrelevant here.

(Note: the PDF is in clunky double-page format, rather than a scrollable / readable layout suitable for mobile phones. It's 7MB too, with lots of irrelevant and "wasteful" stock photos. Ironic.)

GSMA Mobile Economy Europe 2025

This is a mix of the GSMA's usual market report stuff - subscribers, revenues and so on - with some more policy-based recommendations and observations tacked on.

It claims, rather implausibly, that the mobile ecosystem contributes €1.1trillion to GDP. It then makes a series of recommendations for policies that it suggests could rectify the situation where Europe's "key network-performance and consumer-adoption metrics showing that it is falling behind some of its global peers".

Most of these are the usual tedious litany of Jurassic-era telco tropes:

- "fairness in the Internet value chain" (i.e. "let us try to extort more cash from content & application providers by acting as gatekeepers")

- "a pro-investment approach to EU spectrum policy" ie clear more bands for national MNO licenses, despite that being inefficient, lazy and impinging on the growth areas of satellite, private networks, unlicensed networks (& defence). It's notable that virtually every other organisation - including European regulatory groups like RSPG and BEREC - have been skeptical or outright critical of the spectrum harmonisation idea.

• Repetition of the usual Draghi Report fallacy about 6GHz, which I wouldn't be surprised to find was originally itself cut-and-paste from a GSMA document in circular fashion.
• Wants regulation of interconnect, even though BEREC notes the market works perfectly well already. It also fundamentally contradicts the objectives of MNOs to have a role in AI and edge-compute, as a dense mesh of multi-party interconnect is essential

The points about easing M&A make some sense, but do not acknowledge the different structures of mobile and fixed/fibre worlds and the need for different regulatory stances. Its suggestion for more recycling of network equipment is fine, but obvious.

Unsurprisingly, the word "indoor" does not appear once in the entire report, despite in-building applications accounting for 70-80% of mobile use, and therefore (roughly) €750-850bn in mobile ecosystem value. GSMA is happy to bang on about healthcare, education, industrial automation, gaming, XR and much more - and pitch its Network APIs as mechanisms to help them - without saying anything about ensuring they can actually access the network inside the buildings where they are used. This is either incompetent or disingenuous. There is no option 3.

Amusingly, it compares the counts of 5G base stations between Europe and other regions, but ignores the fact that a high % of those used in China & South Korea are specifically for indoor use.

The document makes no mention of flattening data traffic volumes, private networks, MVNOs, network sharing, private networks, neutral host, integration with Wi-Fi etc - all of which are important for European telecom policymakers to consider.

It mentions network APIs at some length, but without data on numbers of developers engaged or actively using the APIs. It also doesn't consider the role of APIs for internal use within operators.

I'm sure there are plenty of other GSMA policy documents floating around this week, but this was just a weak attempt to bolt on the usual cliched policy demands, to a generic market report.

Note: William Webb did a good takedown recently too, specifically on GSMA's dodgy forecasts of data traffic (link)

Telefonica Public Policy Playbook

Written as presentation-style document, this covers pretty much all aspects of policy and regulation relating to tech, not just networks. It includes everything from AI governance to protection of children.

From a network policy point of view, there's not much new in it, just rehashes of the usual EU White Paper / Draghi / Letta fallacies and unreasonable demands. There's more focus on particular laws and policy instruments such as a call to "review the EU Merger Control Regulation". A section on cell broadcast for warning about natural disasters was sort of cool.

Otherwise, you know the drill - interconnect fees, spectrum harmonisation, deregulation, Net Neutrality, comparisons with US & China, network sustainability ("fees, please"), easier consolidation etc, mostly under the guise of enabling EU Single Market and Digital Decade goals.

It's probably the "whiniest" of the three papers here, and the one that most exemplifies how the industry is stuck and still trying to fight old battles, rather than genuinely pursue innovation.

"Stop encouraging artificial competition"

"Failure to expand [spectrum] capacity would result in network densification"

"Cost-benefit study for low power local networks eg 3.8-4.2GHz & unlicensed uses"

Repeating the lie of "large traffic generators". No, users generate traffic. Stop lying, it's an unedifying spectacle and I'm sure your investors are unimpressed.

"Restoring balance on the Internet" is straight out of the 2013 ATK study for then-ETNO & rehashed the 2024 "fair share". It's a dead parrot, nailed to its perch, with TeF as the shopkeeper trying to convince John Cleese it's just restin'.

"Binding dispute resolution mechanism".

I haven't read all the technology parts in detail, but rolled my eyes at the reference to metaverse developers defining network quality parameters though APIs. And apparently virtual worlds need a "level playing field". Well, at least someone is certainly in a virtual reality, even if it's just the author...

Overall, I wouldn't really recommend spending the time on this, at least the telecoms / network bits. Maybe the stuff on AI is better, but if it's like the Metaverse section, you might be better off asking ChatGPT instead.

Conclusions

Congratulations if you got this far. Overall, we can expect a continued focus on large telcos and their various trade associations on the same themes we've heard for years or even decades.

Policymakers should be highly wary of these glossy PDFs, and always ask for 3rd party commentary and critiques of them, especially if they seem to have a coordinated message repeated in multiple documents. (Interconnection, "balanced Internet" and so on).

There are some interesting themes in here, such as the compression discussion in the VF report. It's just a shame they get used to justify the initial, unreconstructed positions of the operators, rather than actually used to drive innovation.

Edit: on spectrum, sovereignty, network infrastructure and other issues in Europe, consider that from now on, the military probably has a better claim on retaining its existing spectrum assets and arguably reclaiming or sharing some of the commercial bands.