While recognizing the value of considering a secondary mobile allocation in view of envisaging a compromise with the minority of Region 1 countries who insist on a change in regulations, the Wider Spectrum Group calls on the Council to support “No Change” and oppose a co-primary allocation to mobile in the international debate on the allocation of the UHF Band at WRC-23.

Regarding any possible agenda item at WRC-31 impacting the European cultural band 470-694 MHz band, the Wider Spectrum Group calls for a neutral wording that would not prejudge any specific regulatory action.

Read the full position below.

The Wider Spectrum Group asks the Council to preserve the current UHF Band allocation by defending No Change at WRC-23

5 June 2023

While recognizing the value of considering a secondary mobile allocation1 in view of envisaging a compromise with the minority of Region 1 countries who insist on a change in regulations, the Wider Spectrum Group calls on the Council to support “No Change” and oppose a co-primary allocation to mobile in the international debate on the allocation of the UHF Band at WRC-23.

Regarding any possible agenda item at WRC-31 impacting the European cultural band 470-694 MHz band, the Wider Spectrum Group calls for a neutral wording that would not prejudge any specific regulatory action.

Frequencies within the UHF band are essential to secure European content creation and delivery through broadcasting and PMSE, for the benefit of all users – viewers and listeners. Moreover, the current spectrum allocation supports a democratic and safer Europe. by ensuring quality news, pluralism and freedom of speech through trusted and regulated media, available free-to-air, and through local events and debates.

The balance found in Europe for the allocation of the UHF spectrum is at risk of being disrupted if the remaining spectrum for broadcasting and PMSE is open to the mobile service at the ITU level. Such a change in regulation would have immediate and damaging effects on sectorial investment and innovation, and wide-reaching ramifications for the longer term: no UHF spectrum means no terrestrial TV for universal service, the most energyefficient platform, currently serving 80 million EU households and sharing much infrastructure with radio, which would be put in danger too; it means no live events, e.g. concerts, and much less content creation and associated jobs.

For that reason, the Wider Spectrum Group has called for a firm EU position in favour of “No Change” in the allocation of the UHF band at WRC-23. This position is echoed by more than 100 organizations that joined the Call to Europe in May 2023.

As the Council is now preparing the EU position ahead of WRC-23, after the Opinion of the RSPG and the proposal from the Commission for a Council Decision on WRC-23, we respectfully ask that the following 4 points are duly considered:

1. The Council position must be compliant with EU law, in particular with the EU UHF Decision 2017/899 which is a strategic and balanced compromise found in Europe around the allocation of the UHF Band 470-790 MHz. The first part of that Decision has been delivered by making the 700 MHz band available for mobile broadband. It is only fair and respectful of the letter and intent of the law that the second part, i.e. guaranteed long-term access to the 470-694 MHz band for broadcasting and PMSE, is now enforced.
2. In that respect, the Council Decision should support No Change to the ITU Radio Regulations on Agenda item 1.5, which allows a peaceful continuation of the allocation chosen in Europe. The Council should oppose proposals for co-primary allocation to mobile at WRC-23, effective now or later, which would dramatically upset the balance reached in Europe.
3. To respect the period of regulatory certainty until at least 2030, the Council Decision should also exclude any new discussion before WRC-31. For the same reason, and to avoid an unbalanced entry point in future negotiations, the wording for an agenda item at WRC-31 or later should be as neutral as possible, like the one adopted at WRC-15 for WRC-23.
4. Finally, the possible introduction of mobile services on a secondary basis in some countries is very likely to have a negative impact on the PMSE sectors of those countries. While the Wider Spectrum Group respects that this could be a compromise way forward at WRC-23 to accommodate the national needs of some countries, it is crucial that the WRC-23 Council Decision is strong in preserving the current use of the 470-694 MHz band.

Download the PDF here

For more information, please contact the AER office in Brussels at francesca.fabbri(Replace this parenthesis with the @ sign)aereurope.org.

About the Wider Spectrum Group (widerspectrum.org): Created in 2015, the Wider Spectrum Group (WSG) brings together 10 European and 8 national organisations representing civil society as well as employee and employer representatives.

• Trade associations and companies in audio, audiovisual and film creation, production and distribution; in radio and tv (broadcasting); in live performance, programme making and special events;
• Viewers, listeners and consumer organisations;
• European trade union organisations representing journalists, creators, technicians and other works in the media, entertainment, and arts.

Those organisations share a common view on the need to ensure that European and national policies regarding frequency allocation preserve the potential for European growth, innovation and sustainable employment.

European organisations: AER, APWPT, BNE, CEPI, EBU, EFJ, EURALVA, PEARLE, SOS, UNI MEI

National Organisations : AUC, Everyone TV, ICMEDIA, SPIO, Television Abierta, UTECA, VAUNET, VLV

AER welcomes the opportunity to provide comments on the Draft Radio Spectrum Policy Group Opinion on ITU-R World Radiocommunication Conference 2023 and will provide feedback on the WRC-23 Agenda Item 1.5 (UHF Review) which is relevant for commercial radios, and more in general for all broadcasters.  

WRC-23 Agenda Item 1.5 (UHF Review)

Terrestrial TV and radio broadcasters deliver a broad range of public value 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, making an essential contribution to media quality and pluralism, safeguarding democratic discourse with their journalistic services. Terrestrial broadcasters 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). In so doing, terrestrial broadcasters make a key contribution to media diversity, pluralism, and democratic discourse.

Moreover, in the event of a natural disaster or an emergency situation, terrestrial broadcasting is often the only reliable source of information available to the affected population. In such situations, listeners and viewers normally tune-in to terrestrial TV and radio, given their strong track record of serving audiences with real-time reporting, universal coverage and a continuous flow of reliable information. For example, during the COVID pandemic, the popularity of terrestrial TV and radio surged as populations tuned-in for regular updates on the health crisis.

Securing broadcaster spectrum is indispensable to achieve these objectives of ensuring wide coverage as well as widespread availability of and accessibility to broadcaster’s content for the entire population.

Furthermore, broadcasters are an important economic source as they create and secure thousands of jobs. To safeguard the future of the radio and TV industry and its services, it is necessary to set a technological course that takes into account the changes in media consumption habits that accompany digitization.

The 470-694 MHz band is the only remaining frequency resource left to digital terrestrial television. If its allocation is changed to ‘co-primary’ use with mobile services, millions of terrestrial broadcast users will lose their ability to watch free-to-air television programmes.

Studies confirmed by experience in the field[1] have shown that broadcasting services and mobile services cannot operate on the same frequencies either in the same area or in adjacent areas without causing unavoidable harmful interference. Consequently, no European country can decide independently how to use the UHF band without conditioning the neighboring countries. For these reasons, any co-primary allocation would mean the allocation of the UHF band to mobile.

Mobile broadband, however, as it is not a native broadcast-technology, cannot become an adequate substitute for universal free-to-air terrestrial TV and radio distribution, since the roll-out of mobile networks, especially in rural areas with low population densities, is not economically viable and is very unlikely that it will provide universal and free of charge services. The allocation of the 470-694 MHz band to mobile services would harm many households and society due to its negative effects on quality media distribution, with little or no additional value at all in terms of mobile broadband quality or coverage.

Television and radio broadcasters frequently share large parts of the national terrestrial broadcast network infrastructure. If digital terrestrial television broadcasters are forced to cease their operations due to loss of the spectrum usage rights, radio broadcasters would have to finance the entire broadcast network on their own, which they could not afford to do, or cease their operations as well. This would threaten the existence of many radio broadcasters, and lead to unintended consequences such as a significant reduction in the volume and diversity of radio output.

On the other hand, it would be possible to deploy the 5G broadcasting standard, a promising broadcast distribution technology of the future, in the 470-694 MHz band without causing interference and without changing the current regulation. 5G Broadcast has already been successfully tested. With 5G broadcast a large variety of broadcast content, television and radio, including reliable information in the event of a disaster, will be viewed or listened to on all mobile devices, smart speakers and connected car systems, regardless of a SIM card, a mobile phone contract or the mobile network coverage. 5G broadcast will ensure that the reception of the broadcast content does not imply additional costs for users, since 5G broadcast does not rely on a mobile streaming connection. In the future, 5G broadcast will allow the users of any member state to receive high-quality TV and radio content free of charge, (basically) anywhere and on any devices.

For all these reasons, AER calls for preserving the existing exclusive primary allocation to broadcasting in the 470-694 MHz frequency band with secondary allocation to programme-making and special events (PMSE) and strongly supports a “No Change” to this frequency band at WRC-23.

AER agrees with the RSPG reasoning that the European Commission’s proposal for an EU position needs to be compliant with the Decision (EU) 2017/899 providing priority to broadcasting and PMSE usage until at least the end of 2030. Both options mentioned in the ‘Note’ – the No Change at WRC-23 and a co-primary allocation effective after 2030 – would indeed be formally compliant with Decision (EU) 2017/899.

The role of the RSPG, in AER’s understanding, is to come up with a sound analysis of the technical and economic issues of different allocation options, including forecast scenarios of future demand and technological developments. AER calls for an explanatory complement to the ‘Note’ clarifying the potential consequences of a co-primary allocation and strongly recommends to support the first option – suggested by the RSPG – of a No Change at WRC-23.

The second option of “a co-primary allocation to the mobile service which should become effective at a later stage (e.g. 31.12.2030)” would challenge the stability of the 470-694 MHz band used by broadcasters and PMSEs “at least until 2030” foreseen in the EU UHF Decision. A co-primary allocation of the reserved 470-694 MHz band for broadcasters is to be avoided as it would endanger the sustainability not only of terrestrial television but also of radio broadcasting due to its cost effects on radio networks. It would compromise the legal certainty of the broadcast model and disincentivise the further development of 5G Broadcast.

AER wants to point out, that there is in fact no need for any allocation decision to be made at WRC-23. Due to the binding Decision (EU) 2017/899, the allocation of the frequency band is fixed until the end of 2030. A ‘No Change’ at WRC-23 leaves open all options for the future.

AER believes that discussing a review “with a possible agenda item for WRC-27 or WRC-31” would threaten the legal certainty for the 470-694 MHz band and would in fact hamper investment in future broadcast technologies such as 5G broadcast. For this reason, the discussion on any possible review of the UHF band beyond 2030 should be postponed to at least end of 2030.

In conclusion, in view of the World Radiocommunication Conference 2023, defending the position of the EU UHF Decision is crucial: the results of WRC-23 will have a decisive impact on the future of broadcasting of media services and PMSE services for the production of audio-visual content, news and events in the EU, therefore should be carefully considered.

Securing the relevant spectrum range exclusively for broadcast services as well as PMSE to be used beyond 2030 by supporting a no change at WRC-23 should be the priority in order to ensure European broadcasters can continue to serve citizens and deliver a broad range of public value 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.

[1]Report ITU-R BT.2337 “Sharing and compatibility studies between digital terrestrial television broadcasting and terrestrial mobile broadband applications, including IMT, in the frequency band 470-694/698 MHz” 10;

Report ITU-R BT.2301 “National field reports on the introduction of IMT in the bands with co-primary allocation to the broadcasting and the mobile services”.

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[1] foresees, in its article 4, that the 470-694 MHz band shall be used by broadcasting organisations and PMSEs “at least until 2030”.[2] 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.

[1] 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

[2] 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. »

Radio’s experience today is hybrid, with radio programs being accessible terrestrially via FM and DAB/DAB+ or via fixed or mobile broadband networks using IP streaming.

5G broadcast could enable unprecedented radio and TV consumption on mobile devices: high quality access to the full range of radio programs, anywhere, on any mobile device, at no access or broadband costs. For this to happen, the sub 700 MHz band (470-694 MHz) must continue to be exclusively allocated to broadcast transmissions.

In times of crisis as well as increasing disinformation, radio and TV being a source of trusted information is of vital importance. Broadcasters play a significant public value role, providing reliable news and curated quality content, making a vital contribution to media plurality. 5G broadcast will enable radio and TV to improve its significant public value role of delivering trusted, culturally diverse and, in case of manmade or natural disasters, lifesaving safety information to the public.

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What is 5G for radio and why is it important for radio?

5G broadcast combines the advantages of 5G (mobile communications standard) and broadcasting (radio and TV), enabling very high efficiency in terms of spectrum usage, network costs, network coverage and energy consumption. With 5G broadband, inefficient (one-to-one) IP-streaming is replaced by a broadcast transmission (one-to-many). Moreover, this mode of transmission is much more energy efficient than one to one transmission, and will therefore contribute to a significant reduction in CO₂ emissions.

In addition, 5G broadcast offers significant customer benefits: linear radio (and television) services could be received on all 5G-capable mobile devices and at no additional mobile broadband costs, at home and on the move without unnecessarily burdening users’ mobile data limits. While currently it is necessary to set up a streaming connection whenever one wants to consume radio or TV via smartphone, with 5G broadcast a smartphone operates like a portable radio or TV set.

Taken together, the technical possibilities, energy efficiency gains and expected customer benefits create significant additional benefits for society. For example, in case of manmade or natural disasters as well as emergency situations, in which the population can mainly be reached via classic radio receivers, 5G broadcast provides a technology to effectively inform citizens via smartphone or other mobile and connected devices, wherever they are, at no additional cost.

Finally, thanks to 5G transmission, radio will be able to continue to innovate and provide listeners with access to news and entertainment content via their smartphones, tablets, smart speakers and connected car systems. Radio will continue to provide diversity of content and pluralism of opinion. This is, in times of crisis and increasing disinformation, especially important. Radio is a vital source of trustworthy information.

Broadcasters play an important public value role in providing reliable news and curated quality content.

Background

Licensed broadcasters make a critical contribution to media pluralism and diversity. With their news services, they make a crucial contribution to safeguarding democratic discourse. In the event of a disaster or an emergency situation, radio is the first – and often the only remaining – medium for informing the public. The COVID pandemic makes it very clear how important quality media, especially radio, are in disaster situations to inform the population.

Furthermore, broadcasters are an important economic input as they create and secure thousands of jobs. To safeguard the future of the radio and TV industry and its services, it is necessary to set a technological course that takes into account the changes in media consumption habits that accompany digitisation.

Securing spectrum in the future

Spectrum is needed for the terrestrial distribution of broadcast content. Traditional radio broadcasting, e.g., uses the 87.5 to 108 MHz frequency band for FM transmission and the 174 to 230 MHz frequency band for DAB+. Terrestrial television broadcasting currently uses the 470 to 694 MHz frequency band for DVB-T and DVB-T2 transmission. 5G Broadcast, as the future mobile broadcast transmission standard for linear radio and television content, should also use the 470 to 694 MHz frequency band. No other frequencies would be available for audiovisual broadcasting, and a significant risk of harmful technical interference would arise in the event that this band was allocated on a co-primary basis to mobile telephony (or any other non-broadcast related use not already permitted within this sub-band). For this reason, the so- called ‘sub 700 Mhz band’ needs to be preserved exclusively for broadcast use also in the long-term.

In this context, the next International Telecommunications Union’s World Radiocommunication Conference in 2023 (WRC-23) will be the forum where the decision on the future use of spectrum will be made at international level. The next WRC will take place in 2023 and will consider possible regulatory interventions in the 470 – 694 MHz band based inter alia, on the results of spectrum use and studies conducted by ITU-R. A ‘no change’ to the existing allocations will mean that broadcasting remains the exclusive primary service in 470-694 MHz, with programme-making and special events (PMSE) as secondary service, and will in fact be able to continue on its path of transformation and innovation, e.g. by introducing 5G broadcast or future broadcast related technologies and thus opening up smart devices for one-to-many broadcast reception.

For the highly adaptive and innovative broadcasting industry “change” is a central paradigm of their work, as regards the direct and effective reaction to changing market requirements or media consumption habits. In order to do so, however, broadcasters need the required frequency spectrum, which is why “No Change” is indispensable with regard to frequency assignment. It is essential to preserve the ‘sub 700 band’ exclusively for broadcasting and PMSE, and to secure it well beyond 2030 so that broadcasters can provide reliable news content, entertainment and companionship to all mobile users and ensure democratic discourse. A co-allocation, or loss, of these broadcasting frequencies would completely end terrestrial TV broadcasting and also pose an existential threat to terrestrial radio broadcasting via FM and DAB+ in the medium term as the broadcasting costs of transmitters and tower rents for radio would suddenly rise.

Download the document here.

For more information, please contact Francesca Fabbri at the AER office in Brussels at  francesca.fabbri(Replace this parenthesis with the @ sign)aereurope.org

About Us

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. The AER’s mission is to promote the development of commercially-funded radio broadcasting in Europe, by advocating for a fair and sustainable economic regulatory framework for radio, which will, in turn, allow commercial radio to continue to deliver significant public value and, beyond that, support media plurality, improve social cohesion and promote European culture.

]]> 2452 https://www.aereurope.org/aer-response-to-the-public-consultation-on-the-radio-spectrum-policy-group-draft-work-programme-for-2022-and-beyond/ Thu, 06 Jan 2022 18:30:25 +0000 https://www.aereurope.org/?p=2372  

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 provide comments on the Radio Spectrum Policy Group Draft Work Programme for 2022 and beyond and will provide feedback only on relevant points for commercial radios:

WRC-23

Radio broadcasters play a very strong public value role, providing free-to-air reliable news and curated quality content, making an essential contribution to media quality and pluralism, safeguarding democratic discourse with their journalistic services.

In the event of a disaster or an emergency situation, radio is the first – and often the only remaining – medium for keeping the public informed. The COVID pandemic made it even clearer how important and unique radio broadcasters are in disaster situations to reach and deliver emergency messages to all citizens.

Securing radio spectrum is indispensable to achieve these objectives of ensuring wide coverage as well as widespread availability of and accessibility to commercial radio’s content for the entire population.

For this reason, AER supports the position to maintain the existing exclusive primary allocation to broadcasting in the frequency band 470-694 MHz (the so-called ‘sub 700 band’) with secondary allocation to PMSE without further changes at WRC-23. 

AER calls for preserving the sub 700 band and securing it beyond 2030, and at least until 2050, so that commercial broadcasters can continue to provide trusted journalistic content, entertainment and companionship to the EU population.

Furthermore, the reserved 470-694 MHz band for broadcasting and PSME beyond 2030 will enable innovation as this band will be used for the development of 5G for broadcasting, an important distribution perspective for radios which allows a broadcast element in the mobile reception. Thanks to 5G broadcast, radio will be able to continue to provide listeners with access to entertainment programming content and trustworthy information through smartphones, tablets, smart speakers and connected car systems, which, in times of crisis and increasing disinformation, is especially important.

Strategy on the future use of the frequency band 470-694 MHz beyond 2030 in the EU

The EU UHF Decision[1] foresees, in its article 4, stability of the sub-700 MHz band used by broadcasting organisations and PMSEs “at least until 2030”.

However, the RSPG in its draft Work Programme 2022, challenges the EU UHF Decision stating that, “Building on the 2015 RSPG opinion”, “will investigate the latest development, as underlined in Article 7 of the EU decision 2017/899, relating to the band 470-694 MHz and develop a strategic vision for sub-700 MHz spectrum use beyond 2030” including “A review of the background and recommendations of its first opinion”.

AER believes discussing a review threatens the certainty of the EU UHF Decision that secures access to the sub-700 MHz band for broadcasting services until at least 2030. 

Moreover, the regulators have not foreseen the use of the 470-694 MHz band later than 2030, which should be the focus instead. Securing the relevant spectrum range exclusively for radio and TV broadcasting as well as PMSE to be used beyond 2030 should be the priority to ensure commercial radio (and television) will be able to continue serving the population with trusted quality information, entertainment and companionship, as well as granting democratic discourse. 

In view of WRC-23, defending the position of the EU UHF Decision is crucial: WRC-23 will be the forum where the decision on the future use of spectrum will be made at international level, involving the review of the broadcasting frequencies 470-694 MHz for their primary and co-primary use, including a potential co-primary mobile-broadcasting allocation, which would mean that other services (i.e. International Mobile Telecommunications (IMT) for broadband Public Protection and Disaster Relief (PPDR) applications) would also be able to operate on a primary basis. It is key that a no change to the existing allocations, keeping broadcasting as the exclusive primary service in 470-694 MHz, with PMSE as secondary service, is ensured beyond 2030.

In conclusion, the results of WRC-23 will have a decisive impact on the future of broadcasting of media services and PMSE services for the production of audio-visual content, news and events in the EU, therefore should be carefully considered.

The loss of the reserved sub 700 band for broadcasters would endanger the sustainability of radio broadcasting and compromise the legal certainty of its broadcaster’s nature.

For this reason, AER finds it imperative to maintain the existing exclusive primary allocation to broadcasting in the frequency band 470-694 MHz (the so-called ‘sub 700 band’) with secondary allocation to PMSE without further changes at WRC-23.  

For more information, please contact the AER office aer(Replace this parenthesis with the @ sign)aereurope.org.

[1] 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: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32017D0899&from=en

ABOUT US

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.

CONTEXT

The Radio Spectrum Policy Group (RSPG) published on 15 February 2021 its Opinion on a Radio Spectrum Policy Programme (RSPP). AER welcomes the work presented by the RSPG and the mention of Audio-Visual (including radio) Media, as being identified among the sectors for which sufficient spectrum availability is a priority. We call for an Opinion that would not endanger the future viability of commercial radio.

Radio provides significant social and public value, reaching large and diverse audiences across Europe. Its mix of music, news, entertainment and speech is highly valued by listeners who constantly identify radio as the most trusted medium in Europe. The multitude of commercial radio stations present on the European scene bring cultural diversity and media pluralism: radio must remain free-to-air to offer listeners quality content. 

As radio remains a broadcast medium, relying on free-to-air analogue and digital broadcasting to reach listeners, it is key that the sub 700 MHz (UHF 470-960 MHz) band remains reserved to broadcasters. This will ultimately benefit Europe and Europeans, as stressed by EU Legislators in article 45 of Directive EU 2018/1972: radio broadcasting, alongside television, is described as promoting “cultural and linguistic diversity and media pluralism”. The termination of the reserved sub 700 MHz band for broadcasters would jeopardise the sustainability of radio broadcasting and the legal certainty surrounding its nature of broadcaster. Furthermore, radio must be present on all platforms; 5G broadcast is an important distribution perspective for radio broadcasters that would bring broadcast-radio to mobile devices.

SAFEGUARD ACCESS TO SPECTRUM FOR RADIO

Commercial radio listening in Europe is still mainly done through analogue and digital broadcasting, and operators continue to rely on a licensing model as a right of use of spectrum. Thanks to its broadcasting nature, commercial radio maintained its strong presence during the COVID-19 pandemic and played a unique and important role in times of emergency.

Although analogue radio (FM) operates on a different spectrum band, FM transmitters are often installed on the transmission masts for DVB-T. The removal of such locations and mast would substantially limit access to FM by commercial radio operators, as fewer radio services distribution could afford increased fixed costs allocated to individual services.

Equipment and application used for radio broadcasting purposes depend on programme making and special events (PMSE), covering off-air events with real-time presentation of audiovisual information, which includes the transmission of audio, video and data signals. In that sense, it is paramount that the reserved sub 700 MHz band benefits to broadcasters and their activities as a whole, embracing PMSE as well as live audiovisual production and contribution.

AER therefore welcomes the RSPG’s Opinion’s mention at point 3.4. (Broadcasting and PMSE) outlining that “the future of broadcasting and PMSE in regard of the UHF Band 470-694 MHz shall not be subject of a new RSPP” as reserving the sub 700 MHz band to broadcasters. Furthermore, we are in favour of similar recommendations from the RSPG to the European Commission on an EU position to the upcoming WRC23 conference, that would go beyond the 2030 limit foreseen by article 4 of Decision (EU) 2017/899.

SUPPORT THE AUDIO REVOLUTION WITH A MULTI-PLATFORM FUTURE

As a small but growing proportion of radio listening is now online, the future of commercial radio is multi-standard and multiplatform. To remain accessible to all, radio must be present on all platforms and 5G broadcast represents an important distribution perspective for radio operators, bringing broadcast radio to mobile devices.

AER fully supports the European Commission’s ambitious plans towards 5G, and Broadcaster are taking fully advantage of the audio revolution with 5G broadcast trials are underway in several European States[1] (e.g. Germany, Italy, Austria and the United Kingdom). Standards for 5G broadcast, in particular for commercial radio, would include the following points:

• Free-to-access at the point of use of radio, via all mobile devices to linear programmes;
• An efficient use of spectrum, especially in comparison to streaming;
• Supporting overall reduced energy consumption;
• Robust medium in times of crisis with strong and better coverage via high-power-high-tower distribution.

AER acknowledges that some European countries have decided, in cooperation with industry actors, to switch off radio transmission on a given technology in favour of another. We firmly support any decision taken at national level, that is the result of a consensus with all radio providers, but caution against provoking a premature transition to new technologies and convergence of services. To this end, AER agrees with the RSPG’s assessment to “strike a balance to the benefit of consumers/users in all Member States”, while “ensuring the EU population free access to linear broadcasting content over different platforms, where appropriate and based on national decisions”.

For more information, please contact the AER office in Brussels at aer(Replace this parenthesis with the @ sign)aereurope.org

[1] European 5G Observatory, 5G Trials publicly announced in EU27, UK, Norway, Russia, Switzerland and Turkey, March 2021.

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AER continues to support a multi-platform future for radio: ensuring reception of terrestrial free to air analogue and digital broadcasting, complemented by IP, is crucial to maintain a healthy radio market in Europe. Multi-standard solutions – which allows the listener to access radio via all possible devices throughout the continent – are a positive signal for future developments.

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AER supports multi-standard solutions for devices as part of a multi-platform future for radio
New personal devices (e.g. smartphones, car integrated systems, smart speakers, etc.) should integrate analogue and digital broadcast standards with internet radio. The future of radio is multi-standard and multi-platform, including via 5G for broadcasting. Even if the latter might only be commercially useable for radios as from 2030 onwards, action is necessary now to secure the right conditions for radio.

5G for broadcasting – a combination of one-to-one and one-to-many
Broadcasting is the transmission of the same information from one transmitter to many receivers (one-to-many). Mobile connections are usually enabling bidirectional contacts between a device and a server therefore ensuring each person receives tailored information (one-to-one). 5G for broadcasting would combine both as it should enable a one-to-one connection (5G) to switch to a very localised broadcast signal if enough requests for the same programme are sent by devices located in the same vicinity. The main feature of 5G for broadcast must be the “the broadcast privilege” as on terrestrial FM/DAB+ broadcast (such as Free to Air, No SIM, no third-party Gatekeeping, mandatory interactivity/addressability).

5G for broadcasting – enabling flexibility for broadcasters
Broadcasters should have the possibility to create and operate their own 5G for broadcasting infrastructure or via commissioned third parties.

5G for broadcasting – legal guarantees in case of network slicing
Where radios would have to buy a fixed bandwidth from an existing mobile network operator and then manage and operate this “slice” under its control and conditions (with / without subscription, no SIM, but return channel for interactivity), regulation must ensure that radios are reserved enough capacities, and legal conditions are set to allow radios to use sliced spectrum such as ex ante price control, access regulation, no network neutrality risks, integrity and secured network conditions.

5G for broadcasting – spectrum needs
To ensure uninterrupted transmission of programmes anywhere, it is necessary to be able to use frequencies as low as possible (from 470MHz to 700 MHz) – also in order to enable larger and more economically efficient broadcast cells. It is therefore essential to secure at the International Telecommunications Union’s World Radio Conference 2023 spectrum capacity for broadcasting (TV and radio) in Band IV (470-582 MHz) and Band V (582 to 694 MHz) with to be able to serve the population with information, culture and entertainment and grant democratic discourse.

No auctions (of 5G spectrum for radio)
Radio is the most intimate and most trusted medium (Eurobarometer Survey of November 2018 (EB90)). Radios inform, entertain and educate the audience. During manmade or natural disasters, radio is the first – and often the only remaining – tool to inform the public. Most commercially funded radios are SMEs. In their role to deliver trusted, lifesaving and culturally diverse content, radios bare burdensome public value obligations and are therefore in no position to compete with other market players for spectrum.

Complementing the 2017 AER position on radio’s access to infrastructure[1], AER calls on the RSPG, BEREC, European Commission, European Parliament and Member States to secure the UHF band for broadcasting beyond 2030 and provide legal and economic certainty for radios in case of network slicing.

[1] http://www.aereurope.org/digital-single-market-radios-access-to-infrastructure-the-future-of-radio-is-multi-platform-2015/

AER continues to support a multi-platform future for radio. As well as analogue broadcast streams and digital broadcast signals the inclusion of other digital means of transmission in radio receivers, such as internet reception, will help to ensure a continuing healthy radio market in Europe. Multi-standard solutions – which would allow all devices to listen to radio throughout the continent – is a positive signal for future developments.

AER supports multi-standard solutions for devices as part of a multi-platform future for radio

In order to fully develop radio on all platforms new radio receivers should also embrace internet radio. New devices such as mobile phones or tablets should be encouraged to integrate and enable analogue and digital broadcast standards with internet radio. The future of radio is multi-standard and multi-platform, leaving flexibility for new business models enabled by actors such as RadioDNS.

1. Radio’s future is multiplatform

• Radio remains primarily a broadcast medium – it is still unclear how transmission of radio via internet will develop. From this perspective, in most of Europe, currently and for the foreseeable future, the main viable business model for the majority of existing radios is free-to-air FM broadcasting on band II (87.5-108 MHz). In some EU Member States, listening is still performed by AM. There are approximately 4 to 5 radio receivers in every household in Europe. Besides, during manmade or natural disasters, radio is the first – and possibly the only remaining – tool to inform the public.

• Radio needs to be on every platform: radio’s future is a mix of broadcasting and internet transmissions – as it has been for the past 50 years, radio is everywhere, mobile, simple-to use, interactive and free-to-air. These features make it the most intimate and most trusted medium (Standard Eurobarometer Survey of Autumn 2014 (EB82)). Listeners need to rely on the ability to receive radio on these same terms in the future, by analogue and digital broadcasting as well as internet transmissions. These means of transmission will all be part of the patchwork of transmission techniques for commercially funded radio in the future. It is therefore essential that any integrated device (phone, tablet, etc.) contains a chip that enables listening to the radio by analogue and digital broadcast as well as online means. When these chips are set on devices, they should be activated.

2. Radio’s best regulatory conditions ensuring access to infrastructure

• Radio is local, regional or national: regulatory decisions should continue to be taken at the same level – national radio frequency landscapes and national radio broadcasting markets are different, with divergent plans for digitisation, diverse social, cultural and historical characteristics and with distinct market structures and needs. Consequently, further coordination at EU level of spectrum management on the bands used by radio does not seem necessary, or appropriate.

• Radio’s access to bands II and III as a primary and unique user is paramount to ensure a healthy future for radio – as broadcasting is and will remain the backbone for all radio transmissions, it is essential that radios’ access to the bands mentioned above is preserved. Most commercially funded radios are SMEs. They are in no position to compete with other market players for spectrum. There should be no market-based approaches for spectrum management of radio bands.

• No EU switch-off date for analogue radio broadcasting services should be envisaged – across the EU, plans to migrate from analogue technology to digital broadcast technology are being actively discussed and tested. Decisions on whether to proceed and the appropriate time-frame should be left to each national industry.

• The open internet must remain open – when radio is listened to online, the quality of services provided should be at least equal to broadcasting on-air: uninterrupted transmission of programmes. However, commercial radios are, in their vast majority, SMEs: they are in no position to financially compete for access to the internet with other market players. There should be no restriction created by introducing new categories within the open internet and as a consequence set obstacles to “best effort” and media pluralism in the long term.

• Radios must be found online – it must be easy to find radios in an online environment: a must-be-found principle could be applied for radio online. At least, and given the fact that search engines constitute essential facilities online, search results should objectively reflect the search request, without undue (commercial) influence on these results. Search results should equally not end up privileging services owned, administered or controlled, in whole or in part, by search engines.

Contact: Vincent Sneed, AER Director Regulatory Affairs / vincent.sneed @ aereurope.org

The Association of European Radios (AER) is a Europe-wide trade body representing the interests of over 4,500 commercially-funded radio stations across the EU28 and in Switzerland.

AER is located at:
Association Européenne des Radios
76, av. d’Auderghem,
B-1040 Brussels,
Belgium

AER’s EU Interest Representative Register ID Number is 6822083232-32.

AER’s main objective is to develop and improve the most suitable framework for private commercial radio activity. AER constantly follows EU actions in the fields of media, telecommunications and private radio transmission, in order to contribute, enrich and develop the radio sector.

AER therefore would like to present the commercially funded radios’ point of view on the European Commission public consultation on the future use of the UHF TV broadcasting band: the Lamy Report. Representing commercial radios to the EU institutions, AER will make comments on points relevant for radio – hence without making use of the online public consultation tool.

First, AER would like to recall that radio is a mixture of audio content which is well-edited and well-produced. Content is Free-To-Air / Free-To-Access, transmitted via wired or wireless means – such as, first and foremost, broadcast, but also cable, satellite or online – and typically consists of talk, stories, entertainment, news, music and surprises.

Second, as explained in this document, radio is part of an ecosystem together with other media and creative industries. So AER attaches to this consultation a document adopted with the “Wider Spectrum Group”, and hopes it will prove useful to the European Commission.

However, AER will address the following points of the European Commission public consultation:
1. Reallocation of the UHF Band
– Potential repurposing of the 694-790 (‘700’) MHz band
– Ensuring regulatory certainty for current users of spectrum
– Flexibility of use of sub-700 MHz (470-694 MHz) spectrum
– Market review of the state-of-play of broadcasting and wireless broadband services
2. Harmonisation of use of sub-700 MHz (470-694 MHz) spectrum in the long-term, the European approach and the International Telecommunication Union (ITU) context

1.    Reallocation of the UHF Band

AER would have two main remarks regarding possible re-purposing of the UHF Band:

On the one hand, in many countries, radio and TV share the towers used for broadcasting. As most commercially-funded radios across Europe are SMEs, migrating TV broadcasting from the current towers they are using may have an unsustainable cost for radio.

On the other hand, a potential reallocation of band 470-694MHz to other services than those currently using it, although not used by radio, could have indirect dire effects on radio: TV services may have to migrate to other frequencies and could end up using frequencies planned for radio, especially digital broadcast radio. Band III (174-230MHz) is indeed the main band used in Europe to develop digital broadcast radio. However, once Band L (1452-1495MHz) is allocated to wireless broadband, Band III will be the only band allowing digital broadcast development of radio, and cannot, under no circumstance, be devoted to other services.

On-air broadcast radios reach massive audience on a daily basis in all EU Member States: approximately 80% of the EU population on average listens to radio for at least 2 or 3 hours per day, as shown by national audience measurement. Besides, it is still unclear how transmission of radio via the Internet can efficiently replace radio broadcasting . Therefore, radios’ activities do and will require use of spectrum, as a primary user.

This element is of utmost importance and entails that while terrestrial digital radio broadcasting most likely constitutes radio’s future main means of transmission, it is very difficult today to say when or how. In other words, AER would like to recall that:
– no universal switch-off date for analogue radio broadcasting services should be envisaged at EU level and decisions on standards to be used for digital radio broadcasting should be left to the national industry
– decision on whether to proceed and the appropriate time-frame to migrate from analogue to digital radio broadcast technology should be left to each national industry
– further coordination at EU level of spectrum management of the bands used by radio does not seem necessary or appropriate
– access to bands II and III for radio broadcasting will remain necessary for a harmonious development of digital radio across Europe
– maintaining exceptions to market-based approaches to spectrum management in bands II and III is equally essential

AER continues to support a multi-platform future for radio. As well as analogue broadcast streams and digital broadcast signals the inclusion of other digital means of transmission in radio receivers, such as internet reception, will help to ensure a continuing healthy radio market in Europe. Multi-standard solutions – which would allow all devices to listen to radio throughout the continent – is a positive signal for future developments.

2.    Harmonisation of use of sub-700 MHz (470-694 MHz) spectrum in the long-term, the European approach and the International Telecommunication Union (ITU) context

There are merits in the European Commission (EC) proposing Common Policy Objectives to offer guidance to Member States in developing European Common Proposals (ECPs) with the European Conference of Postal and Telecommunications Administrations (CEPT). In other words, a potential coordination of policy approaches with regard to the particular radio spectrum policy issues addressed in the agenda for the next World Radiocommunication Conference (WRC) to be held from November 2nd to 27th, 2015, may be positive. However, regarding the UHF Band, the points mentioned under 1 are of utmost importance.

Commercially funded radios indeed constitute a unique network of small and medium-sized enterprises (SMEs), contributing to cultural diversity, media pluralism, access to creativity, social inclusion. They also offer free-to-air services of general interest:
– they evolve in highly competitive environments
– their programmes encompass, broadly speaking, all possible formats, from debates to music-only
– as for the music broadcast, within one market, as soon as there is demand expressed, it has to be fulfilled; so, most of the musical expressions are represented
– most of them are non-politically affiliated, and certainly keep the freedom to express their opinion or to participate to the public expression of the opinions of their listeners
– their audiences are local, regional, or national
– they strive to develop on all possible platforms
– during natural, major or minor disasters, radio is the first – and possibly the only remaining –  tool to inform the public

Radio is, and has been for the past 50 years at least, ubiquitous, mobile, simple-to-use, interactive and free-to-air. These features make it the most intimate medium and the most trusted medium.

AER remains available to explain this position in further details.

ENDS
10/04/2015

Contact details:

Julia Maier-Hauff
AER Secretary General
76, av. d’Auderghem,
B-1040 Brussels,
Belgium
Tel: +32 2 736 9131
Fax: +32 2 732 8990
www.aereurope.org

The Association of European Radios (AER) is a Europe-wide trade body representing the interests of over 4,500 commercially-funded radio stations across the EU27 and in Switzerland.

AER is located at:
Association Européenne des Radios
76, av. d’Auderghem,
B-1040 Brussels,
Belgium

AER’s EU Interest Representative Register ID Number is 6822083232-32.

AER’s main objective is to develop and improve the most suitable framework for private commercial radio activity. AER constantly follows EU actions in the fields of media, telecommunications and private radio transmission, in order to contribute, enrich and develop the radio sector.

AER therefore would like to present the commercially funded radios’ point of view on the Radio Spectrum Policy Group (RSPG) Draft Opinion on Common Policy Objectives for WRC-15 (RSPG Draft Opinion). This RSPG, with this Opinion, intends to assist the European Commission (EC) in proposing Common Policy Objectives in an EC Communication and offer guidance to Member States in developing European Common Proposals (ECPs) with the European Conference of Postal and Telecommunications Administrations (CEPT). In other words, this RSPG Draft Opinion’s main aim is to advise the EC and EU Member States on potential coordination of policy approaches with regard to the particular radio spectrum policy issues addressed in the agenda for the next World Radiocommunication Conference (WRC) to be held from November 2nd to 27th, 2015. AER will comment on the points related to agenda items 1.1, 1.2 and 10.

Agenda items 1.1 + 1.2 – additional spectrum allocations to the mobile service on a primary basis, identification of additional frequency bands for International Mobile Telecommunications (IMT) and related regulatory provisions + use of frequency band 694-790MHz

The RSPG Draft Opinion recalls that agenda item 1.1 is the “result of proposals including from Europe demonstrating broad consensus on the need to harmonise additional spectrum for the mobile service to facilitate further development of mobile broadband applications in line with the objectives of the Radio Spectrum Policy Programme […]. However preparatory discussions of potential frequency bands to meet the additional spectrum requirements have proved to be controversial and action at WRC-15 could impact a range of other EU policy areas […]”. From this perspective, AER would like to recall that a potential reallocation of band 470-694MHz to other services than those currently using it, although not used by radio, could have indirect effects on radio: TV services may have to migrate to other frequencies and could end up using frequencies planned for radio, especially digital broadcast radio.

The RSPG Draft Opinion recalls that agenda item 1.2 “follows the decision taken at WRC-12 to allocate the band 694-790MHz also to the mobile, […] immediately after WRC-15 and to identify the band for IMT […]. The purpose of the Agenda Item is to determine the technical and regulatory conditions applicable to this mobile allocation, including a possible refinement of the lower band edge”.

AER welcomes the recommendations set by the RSPG to
– “support no mobile allocation in the band 470-694MHz”
– “support 694MHz as the lower edge for the allocation to the mobile service on a co-primary basis with the broadcasting service and identification for IMT in the 700MHz band, while ensuring protection of the broadcasting service below 694MHz”
– “ensure that no regulatory provisions in the radio regulations relevant to coexistence with broadcasting […] in addition to GE-06 agreement is adopted”

Besides, AER would like to recall, as mentioned in the RSPG Opinion on “Strategic challenges facing Europe in addressing the growing demand for wireless broadband”, that Band L’s usage was allocated to radio in the context of the ITU and of the CEPT. At national level, and according to information received, it appears that some EU Member States were making use or were planning to make use of Band L for digital radio:
– In Czech Republic, Band L is used for digital radio broadcasting. Private and public radios hold 10 years licences running until 2020-2021.
– In Italy, the National Regulatory Authority (AGCOM) adopted a regulation in November 2009, planning the development of digital radio broadcasting in both Band III and Band L.
– In France, the National Regulatory Authority (CSA) delivered in 2013Q1 an authorisation for satellite radio services in Band L

AER would like to recall that, once Band L (1452-1495MHz) is allocated to IMT, Band III (174-230MHz) will be the only band allowing digital broadcast development of radio, and cannot, under no circumstance, be devoted to other services.

Agenda item 10 – items for inclusion in the agenda for the next WRC, and views on the preliminary agenda for the subsequent conference and on possible agenda items for future conferences

For future WRC agenda, it is essential to ensure radio’s continued health that current rules and allocation related to Bands II and III are maintained as they currently are. AER would thereby like to stress some important points regarding radio’s current and future development.

On-air broadcast radios reach massive audience on a daily basis in all EU Member States: approximately 80% of the EU population on average listens to radio for at least 2 or 3 hours per day, as shown by national audience measurement.

Commercially funded radios indeed constitute a unique network of small and medium-sized enterprises (SMEs), contributing to cultural diversity, media pluralism, access to creativity, social inclusion. They also offer free-to-air services of general interest:
– they evolve in highly competitive environments
– their programmes encompass, broadly speaking, all possible formats, from debates to music-only
– as for the music broadcast, within one market, as soon as there is demand expressed, it has to be fulfilled; so, most of the musical expressions are represented
– most of them are non-politically affiliated, and certainly keep the freedom to express their opinion or to participate to the public expression of the opinions of their listeners
– their audiences are local, regional, or national
– they strive to develop on all possible platforms
– during natural, major or minor disasters, radio is the first – and possibly the only remaining –  tool to inform the public

Radio is, and has been for the past 50 years at least, ubiquitous, mobile, simple-to-use, interactive and free-to-air. These features make it the most intimate medium and the most trusted medium.

AER would then like to highlight that it is still unclear how transmission of radio via the Internet can efficiently replace radio broadcasting. Therefore, radios’ activities do and will require use of spectrum, as a primary user.

This element is of utmost importance and entails that while terrestrial digital radio broadcasting most likely constitutes radio’s future main means of transmission, it is very difficult today to say when or how. In other words, AER would like to recall that:
– no universal switch-off date for analogue radio broadcasting services should be envisaged at EU level and decisions on standards to be used for digital radio broadcasting should be left to the industry
– decision on whether to proceed and the appropriate time-frame to migrate from analogue to digital radio broadcast technology should be left to each national industry
– further coordination at EU level of spectrum management of the bands used by radio does not seem necessary or appropriate
– access to bands II and III for radio broadcasting will remain necessary for a harmonious development of digital radio across Europe
– maintaining exceptions to market-based approaches to spectrum management in bands II and III is equally essential

AER continues to support a multi-platform future for radio. As well as analogue broadcast streams and digital broadcast signals the inclusion of other digital means of transmission in radio receivers, such as internet reception, will help to ensure a continuing healthy radio market in Europe. Multi-standard solutions – which would allow all devices to listen to radio throughout the continent – is a positive signal for future developments.

AER remains available to explain this position in further details.

ENDS
12/01/2015

Contact details:        Julia Maier-Hauff
AER Secretary General
76, av. d’Auderghem,
B-1040 Brussels,
Belgium
Tel: +32 2 736 9131
Fax: +32 2 732 8990
www.aereurope.org