Survey on the Generic Inventory of Candidate Applications for the 1452-1492MHz Band

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,

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 ECC WG FM PT45’s “survey on the generic inventory of candidate applications for the 1452-1492MHz band” (herein after “ECC survey on 1452-1492MHz band”). Considering its representativity, AER will focus its remarks on the pros of digital radio’s presence in the band 1452-1492MHz.

On-air broadcasting radios reach massive audience on a daily basis in all EU Member States: between 60 and 85% 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 the most intimate medium, and has been so for the past 50 years at least: it is indeed ubiquitous, mobile, simple-to-use and free-to-air. All these features enable our audience to cultivate a personal relationship with our programmes, our DJs, our hosts, and our brands. Our listeners thereby access programming they enjoy, useful / crucial information.

AER would like to underline that it is highly unlikely that internet transmission can efficiently replace broadcasting. Therefore, radios’ activities do and will require use of spectrum, as a primary user.

This element is of utmost importance and entails two main consequences: 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 urges the ECC WG FM PT45 to consider the following:
– no universal switch-off date for analogue 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 markets
– decision on the adequate time-frame should be left to each national industry: as a matter of principle, transition to any improved digital broadcasting system should benefit from a long time-frame, unless there is industry agreement to move at a faster rate
– access to bands II, III and L for radio broadcasting will remain necessary for an harmonious development of digital radio across Europe
– maintaining exceptions to market-based approaches to spectrum management in bands II, III and L is equally essential

FM on band II remains an efficient, simple-to-use and free-to-air technology for the vast majority of radio stations across Europe. This efficiency relates to the business-model: it is actually an essential part of the main business model for commercially-funded radio. Free-to-air FM broadcasting on band II only represents 20,5 MHz. Across Europe, nearly every single frequency is used in this bandwidth. Thanks to the broad receiver penetration and the very high usage by the listeners this small bandwidth is very efficiently used. Furthermore, by its free-to-air, free-to-online, widely-spread, mobile, simple and direct model, commercially-funded radio plays a general interest role for citizen information, cultural diversity, media pluralism, access to creativity, and social inclusion. It is fundamental not to forget that radio also plays another central general interest role. When there are catastrophes or other emergency situations, citizens naturally switch on their FM radio to be informed, advised or warned, and governments explicitly ask them to do so: FM radio is, for the time being, the most immediate, most efficient and technically most reliable means of mass communication; furthermore, it will still reach its audience even in the event of a power failure, as many receiver devices are powered by batteries. Therefore, one cannot consider a complete migration to digital terrestrial broadcasting – and certainly not an analogue broadcasting switch-off date – before every car and every household can receive a digital signal, and are equipped by a sufficient number of digital receivers.

However, across Europe, plans to migrate from a satisfying analogue technology to digital technology are being actively discussed and tested: digitization is the future of radio broadcasting, and digital terrestrial radio broadcasting will mainly use band III (174-230 MHz), channel 13 (230-240 MHz) or L-band (1452-1492 MHz) in Europe. Markets will decide what is the best suited technology for digital radio broadcasting in Europe: a choice endorsed by consumers. A smooth transition from analogue to digital technology broadcasting is a significant challenge. There are indeed currently millions of FM-sets in the EU. Switching from analogue to digital broadcasting will represent an important cost and will take time for consumers: there is in Europe on average 6 FM-receivers per households. Consumers will also need to be made aware of the existence of digital radio programmes, via information campaigns. Finally, and basically: interesting content, produced by broadcasters, should also be offered to consumers. The latter will simply not make use of digital radio otherwise. Yet again, this requires time and money: extremely large investments are required in new networks for digital broadcasting. The most significant investments are nonetheless related to simulcasting of programmes at the same time via analogue and digital technologies.

As the situation stands now, the most likely scenario for the development of digital radio in Europe will take the form of a hybrid scenario: on-air commercially-funded (and publicly-funded) digital radio and internet-based radio will be part of the patchwork of transmission techniques for commercially-funded radios in the future, but it is not easy to provide a reliable timescale. But, to be very clear: broadcasting is the only conceivable transmission technique enabling radio with a sustainable / efficient business-model. Therefore, as planned in previous ITU / CEPT negotiations, band II, band III and L-band should be preserved for radio broadcasting. One should note that some of these bands are somehow currently not free for radios in certain European countries: for example, in Italy, band III is still being used by TV services. In those countries where the access to band III is restricted or currently blocked for digital radio services, the L-band constitutes the most viable alternative for the development of digital radio services. It is therefore paramount to preserve radio’s primary access to these bands.

Finally, and as most of commercially-funded radios are SMEs, they are in no position to compete for access to spectrum with other market players. In addition, one of the main reasons supporting digital radio’s development is the necessity to enable a more diverse radio landscape. So, now and for a foreseeable future, commercially-funded radios need guaranteed access to spectrum, in all bands described above: regulation must be tailored to local, regional or national needs in order to allow the best possible development of radio. In these bands, market-based approaches to spectrum management (such as auctions, service neutrality or secondary trading) should not be enforced.

AER remains available to explain this position in further details.


Contact details:

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