RD427 - ETNO position on the proposal for an EU decision on the 470-790 MHz band

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ETNO welcomes the European Commission's proposal for a Decision of the Parliament and the Council on the use of the whole 470-790 MHz frequency band in the Union.

The UHF band (470-790 MHz) is considered as a very important band for mobile broadband. A strategic policy is needed considering the future convergence between broadcasting and mobile platforms, as well as the rapidly increasing use of audiovisual media services in mobile devices.

ETNO generally supports the part of the proposal which addresses short or medium-term issues related to the upper part of the band, the so-called "700 MHz band" (i.e. 694-790 MHz), whereas it has some reservations on the part addressing the lower part, the so-called "sub-700 MHz bandh (i.e. 470-694 MHz).

700 MHz band

ETNO supports article 1 of the EC proposal concerning a coordinated and timely release of the 700 MHz band across the European Union by:

• Setting a fixed date (30 June 2020)¹ for Member States to allow the use of the 694-790 MHz frequency band for terrestrial systems capable of providing electronic communications services, with no derogation allowable, except for cross-border frequency coordination with non-Union countries. In cases where frequency coordination with non-EU countries remains unresolved and therefore the aforementioned date is not applied to these respective Member States, their neighbouring Union countries shall not be prevented to use the 700 MHz band for electronic communications services.
• Setting a fixed date (30 June 2017)¹ for the publication of the national plans for the roadmap.
• Setting a fixed date (31 December 2017) for the finalisation of cross-border frequency coordination agreements within the Union.

Regarding coverage obligations, article 3 provides Member States with the flexibility to choose the obligations that are most appropriate, based on their specific needs and existing national coverage. Member States shall assess and consult on the need to attach conditions to the rights of use for frequencies within the 694-790 MHz frequency band. This type of flexibility should be retained.

Sub-700 MHz band

Article 4 offers flexibility to Member States, within todays regulatory framework, to identify all or parts of 470-694 MHz band for granting Supplemental Downlink (SDL) spectrum resources to mobile services on a non-interference basis both at national and cross border level. This is considered positive in principle. The reason is that such a measure may fulfil the short-term needs of some countries where DTT is not the main means to get access to TV services.

However, ETNO considers that the aforementioned flexibility does not balance the negative implications for the following reasons:

• Although SDL is a reasonable approach in terms of coexistence with the broadcasting service, it imposes a technical limitation regarding the possible future usage of the sub-700 MHz band for two-way mobile communication. This may hinder the development towards a technological optimum to fulfil medium/longterm mobile servicesf needs, including 5G.
• Additionally, Member States interested in implementing SDL option would designate different blocks for SDL, due to different national constraints. This would consequently lead to a non-harmonized landscape in Europe, and prevent a harmonized approach for the future use of these frequencies for mobile broadband services.

Therefore, ETNO supports the deletion of article 4.2.

Concerning article 6, the idea of conducting a review of the usage of the sub-700 MHz band and the related customer demand is a valuable approach as a basis to decide on the future usage of this frequency range. However, the proposed deadline of 1/1/2025 for such review does not fit with relevant international developments in particular with the already agreed agenda item for WRC-23. It is essential that Europe develops a common position in preparation of WRC-23 to be able to act accordingly.

Therefore, ETNO believes that the envisaged review should be completed in a timely manner ahead of WRC-23. To achieve this, ETNO invites the European Commission to produce a mandate to CEPT. Furthermore, the CEPT mandate should be complemented by a Radio Spectrum Committee Decision harmonizing the 600 MHz band-plan for the Member States that want to use this band for electronic communications services in accordance with article 4.

Therefore, concerning article 6, ETNO supports to amend it, replacing the date 1 January 2025 with the date 1 January 2023.

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1 This paper fully reflects the ETNO members’ view with the exception of Portugal Telecom who is in favour of Member States having flexibility regarding the 700MHz release date for mobile services.

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