24 August, 2023

ETNO comments to the RSPG Draft Opinion on Strategy on the future use of the frequency band 470-694 MHz beyond 2030 in the EU

The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Radio Spectrum Policy Group (RSPG) Draft Opinion on the “Strategy on the future use of the frequency band 470-694 MHz beyond 2030 in the EU”.

In this document we provide first general remarks on the content of the Draft Opinion, then more specific comments related to existing flexibility, scenarios beyond 2030, and finally on the recommendations.

General remarks:

We welcome that the RSPG recognised the diverging situations in the European Union (EU) markets and acknowledged the need for flexibility to serve the needs of all countries including those not having Digital terrestrial television (DTT) anymore (at least after 2030). However, in general, ETNO believes the Draft Opinion is taking a conservative stance on the strategy of the future use of the UHF band beyond 2030, as elaborated below.

The demand for mobile broadband services is increasing also in sparsely populated areas and other areas which are difficult to reach with higher frequency bands. Additional availability of spectrum in the UHF band would support delivering these demands and would support targets for digital inclusion and equal digital opportunities, and provide better access to digital healthcare, education and media services in remote areas.

Having in mind that the topic addressed by this Draft Opinion was to be treated separately from the WRC-23, ETNO believes that considerations on a “Strategy on the future use of the frequency band 470-694 MHz beyond 2030 in the EU” for the benefit of the European society should be more forward-looking instead of only recognising that a single scenario might not be applicable. In addition, we consider the draft Opinion provides quite limited analysis to support EC responding to its reporting obligation under Article 7 of the Decision (EU) 2017/899. It mainly focuses on technical developments and challenges.

Article 7: The Commission shall, in cooperation with the Member States, report to the European Parliament and to the Council on developments in the use of the sub-700 MHz frequency band, with a view to ensuring efficient use of spectrum, pursuant to the applicable Union law. The Commission shall take into account the social, economic, cultural and international aspects affecting the use of the sub-700 MHz frequency band pursuant to Articles 1 and 4, further technological developments, changes in consumer behaviour and the requirements in connectivity to foster growth and innovation in the Union.

ETNO also thinks that the consideration of EU spectrum strategies for the future should be driven by the broader EU policy contexts. The European Union has agreed on Digital Decade targets for 2030 including gigabit connectivity in order to provide sufficient capacity to all end users. It would also serve TV content distribution and reception.

ETNO acknowledges the diverging situation between the different Member States regarding the role of DTT for TV distribution and agrees that it is challenging to satisfy the different requirements for a harmonised approach. However, future scenarios provided in the Draft Opinion are not fully recognising the availability of other TV distribution platforms and the changes of user behavior with respect to media consumption. It is assumed that terrestrial broadcasting continues and is allowed to continue as today in countries with expected high DTT demand. This creates priority for one future scenario over the others and creates limitations to the other scenarios. We also note that the future scenarios provided in the Draft Opinion focus on the technical feasibility of possible future use in single countries, but there is no scenario considering possible steps towards harmonised future use in Europe.

We urge the RSPG to use this opportunity to include a more detailed analysis and summary on the development of how the band is used for terrestrial provision of TV broadcasting services in different Member States, and similar analysis of the other means to distribute TV content. As there are already today several parallel platforms in use to distribute and receive TV content (linear and non-linear), it would be appropriate to analyse the different means, their current availability, popularity, and expected development towards 2030. In addition, the Opinion could include analyses on whether the national media policies are neutral towards different distribution means, and if not, whether the obligations/priorities are still justified. Such additional analyses are essential when considering the future of the TV content distribution, and the use of the UHF band both from efficient spectrum use of perspective and efficient socio-economic perspective.

ETNO recognises the need for a harmonised European approach and recognises the difficulties to achieve that. However, we would like to invite the RSPG to be more future looking and to think more out-of-the-box when further discussing this issue.

We elaborate on our recommendations in the attached document. For further questions, please contact Xhoana Shehu, Policy Manager, ETNO (shehu@etno.eu).



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