European Utilities Telecom Council
EUTC
The EUTC is a non-profit international organisation bringing together stakeholders from the energy and telecommunications industries to bridge European utilities and telecommunications manufacturers to foster a digital, secure, and efficient net zero transition of the energy sector.
ID: 743143938227-72
Lobbying Activity
Response to Roadmap for artificial intelligence and digitalisation for energy (RAID-E)
5 Nov 2025
The European Utilities Telecom Council (EUTC) welcomes the opportunity to contribute to this call for evidence on AI and Digitalisation for Energy. EUTC represents the EUs utilities and critical infrastructure operators that design, deploy, and maintain mission-critical telecommunications networks across the continent. These networks form the digital backbone of the modern energy system, enabling secure, resilient, and real-time communication essential for grid operations, renewable integration, and consumer participation in the energy transition. AI and digitalisation will redefine how Europes energy system is planned, managed, and secured. To succeed, this transformation must rest on trust, interoperability, and cybersecurity. EUTC supports the Commissions ambition to develop a Strategic Roadmap for Digitalisation and AI in Energy and calls for explicit recognition of the essential role of utility telecommunications networks in enabling safe, effective AI and digital tools. EUTC welcomes the proposed three-layer framework combining hard law, strategic guidance, and sector-specific rules. For utilities, energy applications of AI are high-risk and must integrate compliance with the AI Act, NIS2, and the Cyber Resilience Act from the design stage. Coordination among DG ENER, DG CNECT, and ENISA is crucial to ensure consistent implementation tailored to energy sector operations. Access to energy data, cloud infrastructure, and trusted digital services should be governed by technology-neutral, interoperable, and transparent principles, avoiding vendor lock-in and ensuring data sovereignty. Funding instruments should prioritise secure, sector-specific AI deployments rather than general-purpose tools. Moreover, AI applications must align with market and grid codes governing balancing, forecasting, and cross-border operations, embedding AI-readiness into future revisions of these codes. Cybersecurity, data integrity, and trustworthiness are prerequisites for the digitalisation of critical energy infrastructure. AI models used in energy operations must be cyber-resilient by design, meeting CRA and NIS2 requirements. Operational decisions must remain auditable and explainable, and data exchange should rely on European open standards and strong access controls, especially in cloud or hybrid environments. Europe must also strengthen its own AI ecosystem to ensure sovereignty, security, and integrity in energy digitalisation. EUTC supports creating a European AI Incident Repository with proportionate, sector-specific reporting and response protocols. AI and digitalisation in energy depend on reliable, low-latency, and cybersecure communications, conditions that public telecom networks cannot always provide for mission-critical operations. The roadmap should therefore recognise dedicated utility telecommunications networks as core enablers of digitalisation and AI integration. It should also ensure regulatory support and equitable spectrum access for utilities, promote interoperability between private and public networks, and encourage cross-sector infrastructure planning across electricity, hydrogen, heat, and water systems. EUTC advocates for a balanced framework that promotes innovation while safeguarding public interest. The roadmap should foster collaboration among utilities, regulators, research bodies, and technology providers to develop sector-specific AI use cases. It should enable SMEs and municipal utilities to access digital tools and funding without excessive administrative burden and prioritise workforce skills, including training on AI oversight, ethics, and data security. EUTC recommends that the roadmap integrate utility communication infrastructure as a precondition for safe AI deployment, develop sector-specific guidance for the AI Act, NIS2, and CRA, ensure coherence across energy, telecoms, and data policy, facilitate equitable access to radio spectrum and funding for AI-enabled private networks.
Read full responseResponse to European grid package
30 Jul 2025
The European Utilities Telecom Council (EUTC) welcomes the European Commissions consultation on the European Grid Package and underlines the essential role of mission-critical telecommunications networks in ensuring a secure, resilient, and digitally enabled electricity grid. Representing utilities that operate private telecommunications infrastructure across Europe, EUTC stresses that these networks are fundamental to grid reliability, data protection, and real-time coordination, especially in light of decentralisation, electrification, and renewable integration. EUTC urges the European Commission, ACER, and both TSOs and DSOs to explicitly recognise utility telecommunications infrastructure as an integral component of European electricity grid planning and operation. The European Grid Package should formally incorporate communications infrastructure into network planning, operational security, and technical interoperability frameworks. The Association supports the Packages focus on accelerated permitting, digitalisation, and infrastructure efficiency. However, EUTC calls for a more integrated network perspective that acknowledges the interdependence of electricity with hydrogen, heat, and water systems. These cross-sectoral linkages are critical to managing renewable intermittency and ensuring cost-effective energy storage and distribution. Permitting rules, especially those under the General Infrastructure Access rights, must be clarified and enforced to allow utility operators to deploy communications infrastructure, including optical fibre, on an equal footing with traditional telecom providers. Public networks cannot meet the strict latency, security, and resilience requirements of energy operations, and reliance on them could expose the energy system to systemic risks and inefficiencies. EUTC also highlights the importance of equitable access to radio spectrum for private utility networks. Current spectrum allocation policies, heavily oriented toward commercial or public actors, fail to address the operational needs of critical infrastructure. To enable utilities to deploy secure, cost-effective private networks, regulatory frameworks must provide access to suitable spectrum bands under conditions reflecting their public service mission, while avoiding cost burdens on energy consumers. This issue is particularly acute in multi-energy utility environments, where asymmetries in digital and telecom infrastructure policy lead to inconsistent support across electricity and gas networks. EUTC urges coherent policy development to ensure consistent treatment of all critical energy sectors in terms of communications capabilities and digitalisation support. A secure and effective digital architecture for Europes grid must treat utility telecommunications as a foundational enabler. EUTC calls for: -Formal regulatory recognition of communications infrastructure in grid planning; -Streamlined administrative and permitting procedures; -Targeted policy support for innovation and deployment of private utility telecom networks. Furthermore, the digital layer of Europes energy system must be cross-sectoral, supporting secure, interoperable communications not only for electricity but also for gas, hydrogen, heat, and water, ensuring a resilient, integrated infrastructure for the energy transition. EUTC remains committed to working closely with EU institutions and stakeholders, offering its technical expertise to ensure that secure telecommunications networks are embedded in the future European grid architecture.
Read full responseResponse to Digital Networks Act
10 Jul 2025
The European Utilities Telecom Council (EUTC) welcomes the European Commissions initiative to shape the forthcoming Digital Networks Act (DNA) and presents this contribution on behalf of utility operators managing mission-critical telecommunications infrastructure across Europe. These dedicated, often privately owned networks play a vital role in the energy, water, and transport sectors by enabling secure, resilient, and interoperable communications essential for real-time grid operations, renewable integration, and disaster response. EUTC urges the Commission to formally recognize utility telecoms as foundational components of Europes digital and green transitions. The DNA must acknowledge these networks not as secondary verticals, but as central backbones of critical infrastructure. Their inclusion in resilience benchmarks, coverage targets, and funding instruments is necessary to avoid regulatory oversight and ensure their robustness and futureproofing. Key recommendations are: - Formal recognition of utility networks as critical infrastructure: The DNA should explicitly classify utility telecoms as critical to the functioning of essential public services. This recognition would align with the broader EU policy context, including the Gigabit Infrastructure Act, NIS2 Directive, and Critical Entities Resilience Directive. - Flexible spectrum access below 1 GHz: Given the diverse national landscapes and absence of a harmonized EU-wide utility band in the short to medium term (20252040), the DNA should endorse flexible, localised approaches to spectrum allocation. These include licensed sharing, geographic licensing, and lightly licensed regimes to facilitate access to sub-1 GHz bands, crucial for wide-area utility coverage. - Support for narrowband-to-broadband transition: Utilities operate in a transitional environment, maintaining legacy narrowband systems (e.g., SCADA) while deploying broadband. The DNA should support dual-mode operations through mechanisms like authorised shared access, ensuring coexistence without service degradation. - Operational resilience and power backup: Blackstart and islanded operation requirements necessitate telecom systems that remain functionally independent of the public power grid. The DNA should mandate minimum backup durations (e.g., 2448 hours), promote co-investment in backup systems, and ensure that shared physical infrastructure access does not undermine resilience. - Equal treatment under the Gigabit Infrastructure Act (GIA): Utility network operators must be granted the same streamlined permitting rights and infrastructure access as traditional telecom providers. National authorities should be guided to treat utilities equitably in permitting, rights-of-way, and dispute resolution processes. Furthermore, grid digitalisation projects should be eligible for GIA and future DNA funding mechanisms. - Governance and representation: To ensure utility-specific challenges are integrated into DNA implementation, governance structures (e.g., expert groups, fora) must include formal representation from associations like EUTC. This guarantees balanced input on policy development, particularly in areas such as spectrum planning and infrastructure investment. In conclusion, EUTC stresses the urgency of aligning the DNA with the real-world operational, technical, and resilience needs of Europes critical infrastructure sectors. This includes delivering a framework that enables predictable spectrum access, fosters interoperability, and recognises utilities as co-equal actors in the EUs digital ecosystem. By embedding these principles, the DNA will advance the vision outlined in Article 8(2) of the 2012 Radio Spectrum Policy Programme, ensuring spectrum policy serves vital distribution networks, including smart energy grids and water systems. EUTC remains committed to supporting the European Commission with technical expertise and continued engagement as the DNA legislative process unfolds.
Read full responseMeeting with Gerasimos Sofianatos (Head of Unit Communications Networks, Content and Technology)
27 Jun 2025 · General overview of EUTC businesses and their interests in the radio spectrum
Response to How to master Europe’s digital infrastructure needs?
28 Jun 2024
Dear all, please find attached as a pdf document the comments from EUTC on the white paper "How to master Europe's digital infrastructure needs"? Best regards, Dr. Jürgen Tusch CTO juergen.tusch@eutc.org European Utilities Telecom Council AISBL Avenue de la Toison dOr 22 B1 1050 Brussels, Belgium
Read full responseResponse to Cyber Resilience Act
14 Apr 2022
EUTC Input to the Public Consultation on an EU Cyber Resilience Act.
The European Utilities Telecom Council (EUTC) is pleased to provide an input to the above legislation. EUTC represents European electricity generation, transmission and distribution companies and associated vendors plus equivalent operations in public gas and water utilities.
The telecommunications monitoring and controlling these real-time operational networks have stringent security requirements appropriate for critical national infrastructures supporting services essential to life and the functioning of an advanced economy. However, as these telecommunications networks become ever more complex and intelligent, they present greater attack surfaces for malicious intrusion.
EUTC encourages the Commission to enact option 5 as presented in the Cyber Resilience Act (“horizontal regulatory intervention introducing cybersecurity requirements“). So far, the lack of regulatory intervention has not delivered a ubiquitous cybersecure rich ecosystem. Extremely cybersecure technology is therefore considered a niche market with prices and supply options correspondingly high. By intervening in the market as proposed in option 5, the Commission would be encouraging higher cybersecurity standards across the board whilst also normalising the pricing from a niche to a commodity product or service. The result would almost certainly be increased innovation and greater vendor choice. In the absence of such a mandate, lower cost devices and services will dominate the market place and there will generally be lower cybersecurity capabilities. Mandating cybersecurity standards will benefit European industry and every citizen and consumer.
The Directive on the security of Network and Information Systems (NIS) was introduced to improve cybersecurity capabilities nationally, across borders and for supervision of critical sectors (including energy). Energy utilities therefore have to meet mandatory cybersecurity standards. Energy utilities can only meet the NIS Directive’s requirement cost effectively for the benefit of those having to pay for the energy supplied if there is an effective market for cybersecure technology and devices. In the absence of regulatory intervention, highly secure cybersecure technology will continue to be a niche product or service and may only be available in the market if volume demands are encouraged.
There is a further benefit from mandating stringent cyber security requirements as it will help to avoid scenarios where malicious agents subvert third party devices and applications to cause catastrophic failures of the energy networks. Malicious events may involve, for example, subverting third party devices controlling access to telecommunications networks such that the telecoms networks collapse in a way which makes restoration extremely lengthy, sometimes requiring every site to be visited to manually reset or replace devices.
EUTC therefore urges the Commission to mandate cybersecurity requirements as a means of enabling critical sectors to deliver effectively obligations imposed by the NIS Directive.
The European Utilities Telecom Council (EUTC) is the leading European Utilities trade association dedicated to informing its members and influencing policies on how telecommunication solutions and associated challenges can support the future smart infrastructures and the related policy objectives through the use of innovative technologies, processes, business insights and professional people.
This is combined with sharing best practices and learning from across the EUTC and the UTC global organization of telecommunication professionals within the field of utilities and other critical infrastructure environments and associated stakeholders.
Read full responseResponse to Amendment to the Regulation (EU) No 1025/2012 European standardisation
1 Apr 2022
Please see our input on the attached file. It is repeated below
EUTC is pleased to provide feedback on the above proposal.
Whilst we can identify with the objectives of the proposal, we fear that the result will be an even greater delay in the introduction of new harmonised European Standards as a result of the increased complexity of the process.
Technology is developing so quickly that the standards process struggles to develop the necessary harmonised standards on a suitable time frame. This increasing complexity and internationalisation of standards making is tending to exclude all but the largest global players.
Although at first sight, the proposed Commission changes might appear to enable SMEs to contribute through their own national standards bodies, the increase in time and complexity of the process will mitigate against their involvement. Indeed, not only will this affect SMEs and Trade Bodies such as EUTC, but we have noted that fewer and fewer national administrations have the financial or technical resources to participate in standards making, leaving the field open to only the largest and most powerful countries.
Thus, although well intentioned, we fear that the proposal will not achieve its objective in that the delay in production of harmonised international standards will provide more opportunities for proprietary standards to gain a dominant position in the absence of international standards, to the detriment of European consumers and industry.
The European Utilities Telecom Council (EUTC)
The European Utilities Telecom Council (EUTC) is the leading European Utilities trade association dedicated to informing its members and influencing policies on how telecommunication solutions and associated challenges can support the future smart infrastructures and the related policy objectives through the use of innovative technologies, processes, business insights and professional people.
This is combined with sharing best practices and learning from across the EUTC and the UTC global organization of telecommunication professionals within the field of utilities and other critical infrastructure environments and associated stakeholders.
Read full responseMeeting with Thierry Breton (Commissioner)
5 May 2020 · Connectivity - contact tracing app