GSMA对RSPG关于UHF频段未来使用的咨询的回应

TheGSMA, Connect Europeandtheirmembersthank the RSPGfor the opportunity to contribute tothis importantconsultationon thefutureuse of the UHFband.The belowresponseincludespolicyrecommendations,analyses,and a more detailed background on the evolving role of the UHF bandfor mobile services. 1.Introduction andConsumptionContext The UHF band’s use byterrestrialpublic service broadcasting across Europe,has ensuredaccessto news, cultural content, and emergency informationfor many yearsthrough analogue and digitalTV.WhileDTTusecontinues today,the emergence of gigabit fixed broadband and advancedmobilebroadbandnetworksmeans thatthe underlying technology for delivering these services isevolving rapidly. Today, GSMAand Connect Europemembers deliver a wide range of services,including mobile and fixed broadband, IPTV, and cable television–with linear and non-linearsolutions. Some operators still manage DTT networks or provide content via terrestrialTVplatforms, while others have shifted towardsbroadbanddelivery.Financing these networks isdriven by consumer demand, and market dynamics vary significantly between Member States. Despite DTT’s legacy role, consumerpatternsnowshow a clear shifton the means ofconsumingcontent, includingIPTV, OTTapplications, and satellite.Examples from Switzerland, Belgium,theNetherlands,Sweden, and Finland demonstrate a reduction ordecommissionof DTT. The UK isalsoconsidering scenariosfor the next decadein response to a lowerDTT usage, withlinearviewing declining,andon-demand streaminggrowing. This trend, accelerated by youngerdemographics and technological advances, challenges the long-term justification for dedicatingthe same amount of valuable low-band spectrum to DTT. 2.Technical Modernisation, Public / Local Content,and Limitations Technologies such as DVB-T2, HEVC/VVC, and HbbTV improve efficiency,but do not impact theability to slow downthe transition towardson-demand content. Improved image quality enhancesthe experience for current users but does notnecessarilymaintain orincrease overallterrestrial TVadoption.Additionally, local broadcastcontent is alreadyincreasinglyavailable throughonlineplatformsin the EU,guaranteeing thelong-termavailability of national productions, local culturalcontent, local news, and emergency informationin high-definitionwithoutthe need for a separatebroadcast network. TV broadband delivery not only replicates DTT’s public service role but enhances it with interactiveservices, accessibility options, and content personalisation. This transition aligns with the EU’sDigital Decade 2030 targets for gigabit connectivity, ensuring equitable access to both linear andnon-linear content via broadband rather thanabroadcast-specific infrastructure. Replacing DVB-T/T2 with 5G Broadcast for national linear TV deliverymaylack commercial viability.Suchatransition would duplicate existing services atahighercost, yielding no new revenue. While5G Broadcast could serve specific localised scenarios (e.g., stadiumsorlarge events), IMTnetworks already support similar functionalities.Cooperative models for spectrum sharingbetween broadcast and mobile have shown technical and economic limitations in past trials,making dedicated spectrum repurposingamore practical approach. 3.GrowingMobileData Demand and Future Connectivity Needs Data usage is growing onEurope’s mobile networks, mostlycoming from video streaming inresponse to the trend of on-demand content.By the end of the decade, the GSMA expectsthreetimes more traffic in European cellular networks than today1. Ericsson’s Mobility Report2estimates that data traffic per active smartphone in Western Europewill grow, on average, at a compound annual growth rate (CAGR) of 13%, rising from22GB in 2024to 47GB in 2030per month. This represents growth by a factor of 2.1by the end of the decade, andexcludes traffic generated by Fixed-Wireless Access (FWA) whichisexpected to contribute to35%oftraffic in cellular networksby 2030. Arthur D. Little’s3report estimates a CAGR of 25% on average for mobile uses (excluding FWA butincluding mobile-only homes), resulting in a growth factor of 4.75 on average for the EU.Traffic isexpected to continue to grow in MFCN networks beyond 2030, while 6G and the new use cases itenables increase the annual growth rate.FWAand IoT will further add to network demands. Newuse casesbeyond 2030, potentially driven by 6G technologies,willalsointensify pressure onexisting spectrumassignments,leading totheneed foraclearlong-termroadmapwithadditionalspectrumforMFCNin the EU.Thisdemandaffects both urban and rural areas.Additional UHFspectrum will enable capacity provision in places where higher frequencies cannot reach, such asdeep inside buildings. Rural regions,particularly,require low-band spectrum to ensure cost-effective coverage. Without additional spectrum below 700 MHz, bridging the digital divide willnecessitate expensive and less sustainable network densification. Expanding mobile access toparts of