Future Use of UHF TV Broadcasting Band: The Lamy Report


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,

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.


Contact details:

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