The Union Position for the World Radiocommunication Conference 2023

1. Introduction STARTICAL is pleased to offer comments to the European Commission aiming at helping to define the EU´s position on the Agenda Items in the context of the upcoming ITU-R World Radiocommunication Conference 2023.

Astroscale Ltd is a a European based company which is part of the Astroscale group. Astroscale's mission is to develop and implement technically viable space systems to provide various forms of In-Orbit-Services (IOS). In-orbit services (IOS) are those performed by a spacecraft to maintain, repair, upgrade, refuel or de-orbit a space asset while it is in orbit or to de-orbit or re-orbit a space debris object.

GSOA welcomes the opportunity to share its position on the different Agenda Items in the context of the forthcoming ITU-R World Radiocommunication Conference 2023. GSOA (the Global Satellite Operators Association), the global CEO-driven association representing global and regional satellite operators, provides a platform for collaboration between satellite operators globally and a unified voice for the sector.

Meta welcomes the opportunity to contribute to the Call for Evidence on the EU position for the World Radiocommunication Conference 2023. The World Radiocommunication Conference (WRC) 23 Agenda Item 1.2, specifically the question whether to identify the 6425-7025MHz in Region 1 and the 7025-7125MHz globally for International Mobile Telecommunications (IMT), can affect different European Union (EU) policies on…

The International Amateur Radio Union (IARU) welcomes the opportunity to provide feedback on a common EU position to be negotiated by Member States on behalf of the EU at WRC-23. The attached text provides our views on current and proposed future Agenda Items of concern.

The Association of European Radios – AER - is the Europe-wide trade body for commercial radio, representing the interests of companies operating over 5,000 commercial radio stations to the EU Institutions. AER promotes the development of commercially-funded radio broadcasting in Europe, by ensuring a fair and sustainable economic framework for radio so it can continue to thrive.

The Dynamic Spectrum Alliance (“DSA”), a leading global spectrum organization promoting and showcasing the value of spectrum sharing, and specifically the benefits of Wi-Fi connectivity in the 27 European Union countries, welcomes the opportunity to respond to the European Commission’s call for evidence to develop the EU’s position for the International Telecommunication Union (ITU) World Radiocommunication…

Broadcom welcomes the opportunity to respond to this “Call for Evidence” to help establish a common EU position for WRC-2023 Agenda Item 1.2 for the 6425-7125MHz band. Indoor wireless data demand has never been greater. As a result, Broadcom has now shipped over 1 billion of its most advanced Wi-Fi semiconductor solutions (Wi-Fi 6 and Wi-Fi 6E products).

ecta, the european competitive telecommunications association, welcomes the opportunity to provide feedback on the European Commission’s initiative to establish a common EU position to be negotiated by Member States on behalf of the EU at the World Radiocommunication Conference 2023.

The companies Apple Inc., Broadcom Inc., Cisco Systems Inc., Hewlett Packard Enterprise, Meta, and Microsoft welcome the opportunity to respond to the European Commission's Call for Evidence on the EU position during the World Radiocommunication Conference 2023.

2RN owns and operates broadcast network infrastructure in Ireland. It distributes and transmits TV and radio programme services for RTÉ (the Irish public service broadcaster and owner of 2RN) and other broadcasters. 2RN operates and broadcasts Ireland’s free to air digital terrestrial TV (DTT) platform Saorview, covering over 98% of Irish households.

EU position on agenda item 1.5: NO CHANGE The Bregenz Festival is a leading music festival in Europe and attracts almost 200 000 visitors to Lake Constance every summer. In order to carry out the numerous events, it is essential that the more than 80 radio channels in operation are operated in the frequency range between 470 and 694 MHz.

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DIGITALEUROPE appreciates the opportunity to provide feedback on the European Commission's call for evidence on the establishment a common EU position to be negotiated by Member States on behalf of the EU at the World Radiocommunication Conference 2023. Our views, along with their underlying justifications, are set out in the attached position paper.

Whilst the GÉANT Association as an organisation is not involved in radio spectrum specifically, but instead spectrum fibre, a number of its National Research and Education Network (NREN) Membership do operate radio linkages. As such, GÉANT therefore supports the initiative if it aims to ensure that EU Member States respect the principle of unity in external negotiations when EU action is required.

OIV (https://oiv.hr/en/home/) welcomes the opportunity to provide feedback on the call for evidence regarding the establishment of a common EU position at the World Radiocommunication Conference 2023 (WRC-23). OIV is a Croatian broadcast network operator for digital terrestrial television (DTT) operating four national, one regional and one local SFN multiplex, in Sub-700 MHz band (470-694 MHz) using the latest…

Ericsson welcomes the opportunity to provide input to the Commission in relation to a potential Council decision on WRC-23. WRC is a key opportunity for spectrum harmonization, including technical conditions. As stated by the Commission, decisions at WRC can affect EU policies and thus it is of high importance that a common EU position exists and that EU countries can defend it at WRC.

Cisco welcomes the opportunity to respond to the European Commission’s call for evidence to develop the EU’s position for the International Telecommunication Union (ITU) World Radiocommunication Conference 2023 (WRC-23). We believe it is an important opportunity to advance the future of connectivity in Europe in line with the Digital Decade Policy Programme.

České Radiokomunikace a.s. - the leading owner and operator of a wide portfolio of robust digital infrastructure providing nationwide digital television & radio distribution, DC & cloud computing, internet & telecommunication and IoT services in the Czech Republic.

The GSMA, which represents the interests of mobile operators worldwide, welcomes the European Commission’s work to establish common EU positions to be negotiated by Member States on behalf of the EU at the World Radiocommunication Conference in 2023 and the opportunity to provide input to this position in the context of the Commission’s call for evidence.

The Federal Agency for Digital Radio of the Authorities and Organisation with Security Tasks (BDBOS) has been operating the world’s largest digital radio network for digital radio communication by the emergency, security, rescue and armed forces since 2007. BDBOS welcomes the opportunity to respond to the European Commission’s invitation to comment on the EU position for WRC-23.

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We respectfully plead for the European Commission to adopt a “No Change” position on the WRC-23 Agenda Item 1.2 for the 6425-7125 MHz band to enable European citizens and business to enjoy the socio-economic benefits that Wi-Fi delivers. We explain this position in more detail in the attached document.

The Critical Communications Association (TCCA) leads the global development and promotion of standardised critical communications solutions for professional users. TCCA provides the forum for governments, regulators, manufacturers, operators, end-users – for any and every stakeholder in the critical communications sector – to discuss, debate, deliver and evolve the market for the benefit of all.

Executive Summary Apple Inc. (Apple) appreciates the opportunity to submit this filing in response to “World Radiocommunication Conference 2023 – EU position”. We agree that “WRC agenda items can affect different EU policies or EU law, particularly on harmonised technical conditions for spectrum use” with WRC-23 Agenda Item 1.2 on a possible IMT identification for 6425-7125 MHz being a case in point.

Digita is in favor of ‘No Change’ to the Radio Regulations under WRC-23 agenda item 1.5 with following grounds: Importance of linear TV to European media and culture to be supported Europe consists of many smaller language areas which form a unique and diverse cultural entity. TV companies acting in European countries and local markets offer local content for audiences in that area.

Hewlett Packard Enterprise (HPE) commends the Commission for its initiative to establish a common EU position to be negotiated by Member States on behalf of the EU at the World Radiocommunication Conference 2023 (WRC-23). We fully concur that the common EU position should enable an outcome of the WRC-23 negotiations that will yield the maximum benefits for EU citizens, businesses, and societies overall.

Electronics Industriale — MFE Group World Radiocommunication Conference 2023 — EU position WRC-23 Agenda Item 1.5 (UHF Review) Electronics Industriale SpA is the network operator of the MFE — Media For Europe group, one of the main activities is to offer transmission capacity on its digital multiplexes in Italy and to manage the traffic to and from the various production centres of its parent company R.T.I. S.p.A.

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Response on the EUROPEAN COMMISSION Call for Evidence on the World Radiocommunication Conference 2023 EU position from Broadcast Networks Europe (BNE) Broadcast Networks Europe (BNE) welcomes the opportunity to share its views on the Call for Evidence on the World Radiocommunication Conference 2023 EU position and wants to express its full availability to collaborate and discuss with the European Commission on all…

Wi-Fi Alliance commends the European Commission on its efforts to establish common EU positions for the World Radiocommunication Conference 2023. As explaine in the attached, Wi-Fi Alliance calls on the Commission to recognize that IMT operations in the upper 6 GHz band are not feasible, while delaying needed spectrum capacity for Wi-Fi undermines the benefits this technology is ready to deliver to the European…

It is believed that 6425-7125 MHz frequency band should be able to be used equally by both fixed and mobile operators and FWA use case should be explicitly allowed. In any case, the protection of existing and future fixed links should be ensured.

At AIIP (Associazione Italiana Internet Provider) we are very, very concerned about the future of landlines and the de-facto radio "extension" of the landline Internet services (for both residential and business), the Wi-Fi and it's future.

Huawei welcomes the opportunity to provide feedback on a common EU position to be negotiated by Member States on behalf of the EU at WRC-23. We encourage efforts towards the future Council Decision on WRC-23 for those issues that could have an impact on EU policies. The common European position will be extremely valuable in facilitating a positive WRC-23 outcome for the Union.

The United Stage Vienna advocates the long-term preservation of radio spectrum between 470 and 694 MHz for broadcasters and cultural operators. In the music theatre sector in particular, microphones are used in the UHF spectrum, which are essential for modern musical productions.

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In view of the activity carried out, Persidera considers it crucial to maintain scarce television frequencies in the 470-694 MHz band as exclusively dedicated to digital terrestrial broadcasting broadcasting services for at least the next decade.

Filed in Italian · English published by the European Commission

The Vienna State Opera is an internationally important opera house and a major Austrian cultural institution. The daily views of 2500 viewers, as well as the numerous broadcasts and productions for radio, television and the internet, use more than 60 radio channels. High quality and direct transmission of audio and video is basic and non-alternative for our work.

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Policy Impact Partners welcomes the European Commission's invitation to provide a written response to public inquiry on the EU position during the World Radiocommunication Conference 2023 (WRC-23). We respectfully present our request and justification in the attached document.

EU position on agenda item 1.5: NO CHANGE The ‘Mörbisch Sea Festival’ runs one of the largest open-air theatrical platforms. We can welcome around 6,000 visitors every evening in our ideas during the season. Operette was played in Mörbisch until 2021 — with the 2022 season we will specialise in the Genre Musical.

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WRC-23 Agenda Item 1.5 (UHF Review) Confindustria Radio Televisioni (CRTV) is the Italian television and radio media trade association and represents all the main components of the television radio sector: public and private, national and local broadcasters. It is a sector with a combined revenue of around EUR 9,8 billion and a workforce of over 90.000, of which more than 25.000 are direct.

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WRC 23 — EU position on agenda item 1.5: No CHANGE in sub-700 MHz For the following reasons: Terrestrik offers free-to-air television Currently, some 470,000 Austrian households use digital terrestrial television (DVB-T2) for in-patient reception.

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Innovation Lambda welcomes the European Commission's invitation to provide a written response to public inquiry on the EU position during the World Radiocommunication Conference 2023 (WRC-23). Innovation Lambda respectfully asks the European Commission to adopt a “No Change” position on the WRC-23 Agenda Item 1.2 for the upper 6 GHz band (6425-7125 MHz).

The Wider Spectrum Group is a coalition of 10 European and 8 national organisations representing civil society as well as employee and employer representatives, and described below. The Wider Spectrum Group welcomes the opportunity to provide feedback to this call of evidence regarding the preparation by the Commission of an EU position to be adopted by the Council for WRC-23.

Globalstar is a long-established Mobile Satellite Service (MSS) operator and service provider with ongoing operations in many EU countries, and currently operates a global constellation of non-geostationary Low Earth Orbit (LEO) satellites. The Globalstar system includes the satellites, user equipment, and earth station “gateways,” which interconnect with terrestrial networks and communicate with the satellites.

APWPT wants to ensure that the European Union / European Commission are aware that the discussion on the future of the UHF band 470 - 694 MHz is highly critical for the future for all kind of audio-visual media content creation. WRC Agenda Item 1.5 The band 470–694 MHz is the core band for audio PMSE applications and an essential frequency resource.

The Swedish-Dutch owned Genexis Sweden AB (Genexis) respectfully ask the European Commission to adopt a “No Change” position on the WRC-23 Agenda Item 1.2 for the 6425-7125 MHz band. The justification for this request can be found in the attached document.

Nokia welcomes the opportunity to provide inputs to the European Commission’s Call for evidence related to the initiative to propose a Council decision regarding the EU position towards the World Radiocommunication Conference 2023 (WRC-23).

Open TV comments (Spain) Open TV is a group made up of the main players of Digital Terrestrial Television in Spain, reflecting a global and pluralistic impulse from all those who contribute to universal, free and free television.

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The European Broadcasting Union (EBU) is the world’s leading alliance of public service media (PSM). The EBU welcomes the opportunity to take part in this call for comments related to the forming of the EU position on the 2023 World Radiocommunication Conference (WRC-23).

Volksoper Wien is one of the largest theatres in Vienna and is played by Oper, Operette, Musical and Ballett. In Volksoper Wien, over 75 channels operate wireless transmission between 470 and 694 MHz. These are essential for the operation of games. A technical alternative is currently not in sight, and other spectrum bands are also not useful.

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Sky Group is a leading media company in Europe and a connectivity provider in the UK, Ireland and Italy, serving in total more than 23 million customers across all our services and employing 35.000 people. We welcome the opportunity to respond to the European Commission’s Call for Evidence regarding the EU position for World Radiocommunication Conference 2023. We have expressed our views in the attached document.

EU position on agenda item 1.5: NO CHANGE On behalf of its members, the Association of Commercial Broadcasting Organisations in Austria (VÖP) is in favour of the use of the 470-694 MHz frequency band after 2030, i.e. ‘NO CHANGE’! There are the following reasons for maintaining ‘no change’: 1. Broadcasting as a media class needs to be safeguarded and promoted as a whole.

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World Radiocommunication Conference 2023 — EU position on agenda item 1.5: NO CHANGE Terrestrial offers free-to-air TV and low-threshold access By disseminating high-quality information from licensed radio and television broadcasters via the autonomous terrestrial broadcasting network, broadcasting as a whole makes an indispensable contribution to the diversity of opinions and media serving the public.

Filed in German · English published by the European Commission

World Radiocommunication Conference 2023 — EU position on agenda item 1.5: NO CHANGE Terrestrial offers free-to-air TV and low-threshold access By disseminating high-quality information from licensed radio and television broadcasters via the autonomous terrestrial broadcasting network, broadcasting as a whole makes an indispensable contribution to the diversity of opinions and media serving the public.

Filed in German · English published by the European Commission

‘The lower UHF band (470-694 MHz) shall be used for broadcasting and wireless production (PMSE: Programmes Making and Special Events). Our many media and event technology members in particular depend on these frequencies in their daily work. We therefore support a policy of safeguarding broadcasting frequencies for media and culture from the outset.

Filed in German · English published by the European Commission

World Radiocommunication Conference 2023 — EU position on agenda item 1.5: NO CHANGE In this point 1.5, WRC23 deals with the sub-700 MHZ band. ORF is committed to maintaining primary use for broadcasting and to maintaining PMSE equipment such as radio microphones as a secondary use. Co-primary use with telecoms and mobile networks is not meaningful or technically feasible.

Filed in German · English published by the European Commission

World Radiocommunication Conference 2023 – EU position zu agenda item 1.5: NO CHANGE! Broadcasting and culture need frequencies for their work. These frequencies between 470 and 694 MHz are in danger. Europe must act and secure these frequencies! Broadcasting needs UHF spectrum for easy, low-cost and therefore accessible terrestrial television transmission.

As subsidiarity is a basic requirement for a healthy community, I am arguing against an increasing dominant role of the EU with its EC and the EU parliament. The rules of the WRC thus must not change! Only individual sovereign nations can have a voice and vote at WRC.