Summary of BNE’s views on the RSPG’s recommendation on WRC-23 Agenda Item 1.5:
• The first option considered by RSPG is No Change at WRC-23 with a possible new agenda item at WRC-27 or WRC-31:
o BNE welcomes a ‘No Change’ decision, as this option would avoid serious impacts on the European audiovisual industry and the significant social and cultural benefits it delivers for citizens. See our general comments below for a deeper substantiation of such impacts.
o Also, BNE considers that discussing the Region 1 allocation of 470-694 MHz band again at WRC-27 would not provide enough certainty for industry to foster investment and innovation in DTT networks over the next five years. In contrast, revisiting this agenda item in 2031 or later, would be more compatible with investment plans and innovation agenda.
o BNE notes that since 2016, 24 new countries in Region 1 have launched DTT networks, and in many other countries broadcasters and terrestrial network operators are investing in the development of new technologies such as 5G Broadcast, higher quality standards with UHD and the introduction of new services, such as Hybrid TV. Like all industries, broadcast needs a period of stability and certainty to allow development and innovation. Having to deal with regulatory changes every 5 to 7 years limits investment, development and innovation.
• The second option considered by the RSPG is a co-primary decision taken at WRC-23 but effective at a later stage:
o BNE strongly opposes this proposal. In the attached position paper (Annex II), BNE argues that a change to co-primary would create an existential threat to the remaining spectrum available to deliver terrestrial broadcasting services and Programme Making and Special Events (PMSE). The recent Call to Europe on 30 June (see Annex I) shows that this concern is shared across a wide range of companies, associations, and NGOs in the broadcasting, cultural and creative industries sectors including workers and end users trade associations.
o Whether the timing of that threat is differed, or not, does not change the nature of the threat. Indeed, if speaking of long-term certainty, a differed decision will have the same impact on the terrestrial broadcasting services, PMSE and the whole European Audiovisual industry; the investment plans and innovation agenda will suffer from an uncertain environment.
o Moreover, once a co-primary decision would be applicable to all countries in Region 1, it would supersede the part of the Article 4 in the UHF Decision, stating that new services can be introduced solely on a secondary basis with respect to broadcasting.
o BNE thinks this would in practice end the coordinated approach in the EU on the use of the 470-694 MHz band, which is a key tenet agreed in the UHF Decision.
Considering the above, the best way to secure European interests is to establish ‘NO CHANGE’ as a European Common Position regarding the AI 1.5 at WRC23 and onwards.
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