The Association of European Radios – AER – is the Europe-wide trade body for commercial radio, representing the interests of companies operating over 5,000 commercial radio stations to the EU Institutions. AER promotes the development of commercially-funded radio broadcasting in Europe, by ensuring a fair and sustainable economic framework for radio so it can continue to thrive.
AER welcomes the opportunity to respond to the Commission’s call for evidence aimed at establishing a common EU position to be negotiated by Member States on behalf of the EU and to be adopted by the Council at the World Radiocommunication Conference 2023. WRC-23 will be the forum where the decision on the future use of 470-694 MHz band will be made at international level. More specifically, the AER would like to give its views on the WRC-23 Agenda Item 1.5 regarding the review of the use of the 470-960 MHz band and possible regulatory actions in the 470-694 MHz band.
The EU UHF Decision foresees, in its article 4, that the 470-694 MHz band shall be used by broadcasting organisations and PMSEs “at least until 2030”. AER considers that a review of how the UHF band is used is both premature, and uncalled for, as such a review would put into question the long term availability of the UHF band for terrestrial broadcasting, which in term would threaten service continuity for terrestrial TV and radio audiences across Europe, and the broad range of public value that terrestrial broadcasters deliver to society. Such public value includes the provision of trusted local and national news bulletins, at a time when fake news is rife on social media networks. Terrestrial TV and radio are also a source of companionship (for example supporting people who may be lonely or feel isolated), entertainment and music discovery (providing cultural enrichment), and an amplifier of charitable causes and issues of major importance to society (such as the under-representation of young people from minority ethnic backgrounds in the creative industries).
Given the above, defending the position of the EU UHF Decision at WRC-23 is crucial: the UHF band must continue to be allocated on existing primary basis to terrestrial broadcasting and with a secondary allocation to PMSEs without any changes.
AER therefore urges the Commission, the Council and Member States’ representatives to strongly oppose a co-primary allocation to mobile services and support a position of ‘No change’ to the Radio Regulations under WRC-23 agenda item 1.5 in order to preserve European broadcasters and the public value contribution we make to society, incentivise high levels of investment in quality and trusted content over the longer term, and support Europe’s creative sector and global soft power.
For more information, please contact the AER office francesca.fabbri(Replace this parenthesis with the @ sign)aereurope.org.
 Decision (EU) 2017/899 of the European Parliament and of the Council of 17 May 2017 on the use of the 470-790 MHz frequency band in the Union
 Article 4:” Member States shall ensure availability at least until 2030 of the 470-694 MHz (‘sub-700 MHz’) frequency band for the terrestrial provision of broadcasting services, including free television, and for use by wireless audio PMSE on the basis of national needs, while taking into account the principle of technological neutrality. Member States shall ensure that any other use of the sub-700 MHz frequency band on their territory is compatible with the national broadcasting needs in the relevant Member State and does not cause harmful interference to, or claim protection from, the terrestrial provision of broadcasting services in a neighbouring Member State. Such use shall be without prejudice to obligations resulting from international agreements, such as cross-border frequency-coordination agreements. »