EN 1  EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 28.10.2009 
SEC(2009) 1436 
COMMISSION STAFF WORKING DOCUMENT 
IMPACT ASSESSMENT  
 
 
Accompanying document to the 
 
COMMUNICATION FROM THE CO MMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMI TTEE OF THE REGIONS 
 
"Transforming the digital dividend into social benefits and economic growth" 
 
and the   
 
COMMISSION RECOMMENDATION 
 
Facilitating the release of the digi tal dividend in the European Union 
   
{COM(2009) 586 final} 
{C(2009) 8287 final} 
{SEC(2009) 1437} 
EN 2  EN TABLE OF CONTENTS 
 
Summary of changes in res ponse to the Opinion of the Impact Assessment Board.................. 5 
1. Background, context and consultation ......................................................................... 6 1.1 Background and context............................................................................................... 6 1.1.1 A significant amount of radio spectrum beco ming available concurrently in Europe. 6 
1.1.2  Main objectives of the initiative................................................................................... 6 1.1.3 A spectrum with exceptional qualities ......................................................................... 7 1.1.4 The potential social and economic  benefits are significant ......................................... 7 
1.1.5 Limited window of opportunity ................................................................................... 8 1.1.6 Longer term view to reap the full benefits................................................................... 8 1.1.7 Considerable political interest and support.................................................................. 9 1.1.8 Envisaged policy instruments ...................................................................................... 9 1.1.9 Main basis for this impact assessment ....................................................................... 11 1.2 Consultation and expertise ......................................................................................... 11 1.2.1 Overview of main ex ternal consultations................................................................... 11 
1.2.2 Internal consultations and consu ltation of other EU institutions ............................... 13 
1.2.3 Main conclusions from the consultative process ....................................................... 13 1.2.4 Summary of results of the consultations on the first topic:  Analogue Switch-Off ... 14 
1.2.5. Summary of results of the consultations  on the second and third topics:  the 790-862 
MHz sub-band and its technical harmonisation......................................................... 14 
1.2.6. Summary of results of the consultations on the fourth topic: further improvements in 
broadcasting transmission efficiency ......................................................................... 14 
2. Problem definition...................................................................................................... 15 2.1. Identified issues and their underlying drivers ............................................................ 15 
2.1.1. Lack of coherence of nati onal approaches will lower th e usability of the spectrum 
and hence the potential socio-economic impact of the digital dividend .................... 15 
2.1.2. Lack of EU coordination w ill prevent Member States to allocate the digital dividend 
to its best uses ............................................................................................................ 16 
2.1.3. Lack of economies of scale and pan-Eur opean coverage of services may hurt the 
European economy and deter investments................................................................. 16 
2.1.4. Optimising the digital dividend in the medium term (spectrum below 790 MHz).... 17 
EN 3  EN 2.1.5. Risk of disruption of important services  already making use of part of the UHF 
where the digital dividend spectrum is located.......................................................... 18 
2.1.6. A sizeable part of the benefits could be foreclosed in absence of proper coordination 
with third countries .................................................................................................... 18 
2.2. Likely outcome in the absence of action at the EU level........................................... 19 2.3. The advantages of EU intervention............................................................................ 21 3. Specific objectives pursued by this initiative............................................................. 22 4. Policy options............................................................................................................. 2 2 
4.1. Policy options regarding the time ly switch-off of analogue TV................................ 22 
4.1.1 No further EU action.................................................................................................. 23 4.1.2. Recommendation that Member States take all necessary steps to switch-off analogue 
signals by 1 January 2012 .......................................................................................... 23 
4.1.3 Mandating analogue switch-off by 1 January  2012 (a Community legal measure) .. 23 
4.2. Policy options regarding the achievement of the optimal use of spectrum in the UHF 
band (470-862 MHz).................................................................................................. 23 
4.2.1 No further EU action on coordination activities ........................................................ 24 4.2.2 Proposing further coordination activiti es in sub-bands below 790 MHz................... 24 
4.3. Policy options regarding the coordinati on of Member State action to ensure a 
coherent approach to the 790-862 MHz sub-band ..................................................... 26 
4.3.1. No further EU action.................................................................................................. 26  
4.3.2. Recommendation that Member States follo w a co-ordinated approach in the 790-862 
MHz sub-band............................................................................................................ 26 
4.4. Policy options regarding th e technical harmonisation of  the 790-862 MHz sub-band27 
4.4.1. Guidelines for the harmonisation (non  mandatory) of the 790–862 MHz sub-band . 27 
4.4.2. Commission Decision setting the techni cal parameters of the 790–862 MHz sub-
band........................................................................................................................... . 27 
4.4.3. Commission Decision setting th e technical parameters and setting a mandatory end-
date for clearing the 790- 862 MHz sub-band of broadcas ting (high-power) services27 
5. Assessment of impacts ............................................................................................... 28 5.1.  Impact of options regarding the timely analogue switch-off ..................................... 28 5.1.1. No further EU action.................................................................................................. 28  
5.1.2. Recommendation that Member States take all necessary steps to switch-off analogue 
signals by 1 January 2012 .......................................................................................... 28 
5.1.3 Mandating analogue switch-off by 1 January  2012 (a Community legal measure) .. 29 
EN 4  EN 5.2. Impact of options regardi ng the achievement of the optim al use of spectrum in the 
UHF band (470-862MHz).......................................................................................... 30 
5.2.1. No further EU action on coordination activities ........................................................ 30 5.2.2. Further coordination activities in sub-bands below 790 MHz................................... 30 5.2.3  Impact of mandatory requirements to improve spectrum efficiency linked to the 
digital dividend .......................................................................................................... 34 
5.3. Impact of options regarding the coordi nation of Member State actions in the 790-
862MHz sub-band...................................................................................................... 34 
5.3.1. No further EU action.................................................................................................. 34  
5.3.2. Recommendation that Member States take  no action that would interfere with the 
technical harmonisation measure being pla nned at EU level in the 790-862 MHz sub-
band........................................................................................................................... . 34 
5.4. Impact of options regarding the te chnical harmonisation of the 790–862MHz sub-
band........................................................................................................................... . 34 
5.4.1. Guidelines (non mandatory) for the harmonisation of the 790–862MHz sub-band .. 37 5.4.2.  Commission Decision setting the techni cal parameters of 790-862 MHz sub-band 37 
5.4.3.  Commission Decision setti ng the technical parameters and setting a mandatory end-
date for clearing the 790- 862 MHz sub-band of broadcas ting (high-power) services38 
6. Comparison of options ............................................................................................... 40 6.1. Comparison of options regarding the tim ely completion of analogue switch-off ..... 40 
6.2. Comparison of options regarding the achieve ment of the optimal use of spectrum in 
the UHF band (470-862 MHz)................................................................................... 41 
7. Evaluation and monitoring......................................................................................... 45 Annex A: Glossary of abbreviati ons used in the IA report...................................................... 47 
 
EN 5  EN SUMMARY OF CHANGES IN RESPONSE TO THE OPINION OF THE IMPACT ASSESSMENT BOARD  
In its opinion the Impact Assessment Board re quested improvements to the draft version of 
this Impact Assessment and issued the following main recommendations: 
• The report should be strengthened with regards to the social and distributional impacts of 
the proposed measures, in particular on aff ected groups of consumers. It should also 
address more explicitly the distributional impact  on individual Member States as well as on 
border regions and on third countries. It shoul d also provide a summary of the underlying 
economic analysis and methodology used to estima te the projected benefits and costs on all 
relevant points of the main proposals; 
• The report should integrate the main resu lts of the stakeholders' consultation; 
• The report should better explain what follo w-up measures are envisaged and how the 
impact of these measures will be assessed, in cluding in the case of the proposed technical 
harmonisation measure. 
This final version addresses the comments of the Board in the following manner:  
With respect to the first point, the revised Impact  Assessment clarifies the social benefits in 
the background section (1.1). It al so addresses distributional asp ects under relevant options in 
the policy options (5) and assessment section (6 ), mainly the impact on groups of consumers 
and specific Member States of earlier analogue  switch-off, the impact  on the broadcasting 
sector, individual Member States and third co untries of creating a sub-band for electronic 
communications services, and the impact of th e same measure on the existing users of the 
band, mainly the users of wireless microphones. 
Regarding analogue switch-off, one has to be aware that the current initiative could only 
affect the precise timing of the switch-off on 1 January 2012 but not the principle of switching 
off analogue TV by 2012, which was already agreed with Member States in the context of the 
Communication of 2005 on the switchover to di gital broadcasting a nd ensuing political 
discussions1. The other proposals regarding the achievement of the optimal use of spectrum in 
the UHF band (section 4.2) are presen ted to initiate a debate at EU  level. They are at an early 
stage of development and do not therefore in clude concrete action at Community level. 
Therefore, these proposals could not be assessed  with any great level of detail and further 
impact assessment may be required at a later stage. 
Regarding the need to clarify the methodology used  to assess benefits, the main text of the 
document is more explicit on the assumptions and the scope of the underlying analysis. In 
addition, the full version of the Commission study is made public. 
The results of the public consultation have been integrated in  the main text of the report as 
requested. The responses allowed a more nuanced  assessment to be made of a certain number 
of issues but did not reveal fundamentally new developments, or changes, regarding the 
position of the main stakeholders. 
With respect to the follow-up measures, these were addressed mainly by improving the 
section on the background (1) and problem defin ition (2) and by specific clarification in the 
sections on policy options (4) a nd assessment of impacts (5).  
                                                 
1  COM(2005) 204, Communicati on on “Accelerating the transiti on from analogue to digital 
broadcasting”, 24 May 2005 and Council Conclusi ons of Telecom Council of 1/5 December 2005. 
EN 6  EN 1. B ACKGROUND , CONTEXT AND CONSULTATION  
1.1 Background and context  
This Impact Assessment accompanies proposals for a co-ordinated approach to the use of the 
radio spectrum freed up by the switchover of terrestrial TV tr ansmission from analogue to 
digital format (Digital Terrestri al Television, or DTT) in orde r to maximise the social and 
economic benefits that can be reaped fr om this unique opportunity in the EU.  
1.1.1 A significant amount of radio spect rum becoming available concurrently in 
Europe 
This spectrum becoming available, located in the UHF (470–862 MHz) frequency band, is the 
result of the superior transmission efficiency  of digital broadcast technology which requires 
five or six times less freque ncy than the old analogue one in  order to transmit the same 
number of programme channels. It  is commonly referred to as the "digital dividend" . 
1.1.2  Main objectives of the initiative 
This initiative aims at taking advantage of the unique opportun ity of the digital dividend at 
EU level in order to ensure that: 
1. There will be sufficient spectr um available in Europe to address the issue of rural 
access to broadband services  (where a wireless infrastructure is often the only 
workable solution) as well as the issue of the "digital divide" . “Broadband for all” is 
a primary objective of the EU’s i2010 policy framework2 and is linked to the 
European Economic Recovery Plan. This obj ective includes bridging the ‘digital 
divide’ between areas that have limited or  no broadband coverage (typically in rural 
areas) and those that have access to high-sp eed broadband, as an important way of 
supporting social and economic co hesion. These objectives are al so an integral part of 
the Commission's broadband initiative which is in the process of  being adopted by the 
Commission. In addition, wire less broadband infrastructure s could also be used by 
public services such as for PPDR (Public Protection Disaster Recovery) applications. 
From a societal perspective, access to broadband communications can have a 
significant impact on the competitiveness of the EU economy in terms of productivity 
gains and social impact, for example by in creasing employment, reducing the need for 
mobility and providing more efficient health care and public administration services to 
the citizens. Finally, the digital dividend constitutes the most cost-effective spectrum to be allocated for the launch of the next  generation of high-speed mobile broadband 
communications (typically used for smar t phone and netbook PC connections).  
2. In addition to the spectrum used  for wireless broadband services,  there will also be 
sufficient transmission capacity for the future development of terrestrial 
broadcasting services  (e.g. High Definition Television) by increasing the average 
efficiency level of television transmission in frastructures. Terrest rial broadcasting has 
entered a period of intense transformation and innovation as it makes the transition to 
digital format. High Definition TV and mob ile TV are high on the agenda in some 
Member States. Increasingly, the number of  television programming channels creates 
                                                
 
2  Communication from the Commission “i2010 - A European Information Society for growth and 
employment” 
EN 7  EN the prospect of greater media pluralism,  growth in media c ontent production, and 
higher-quality, more interactive services. Spectrum is a rare public resource and it is important to ensure that there is an optimum use of this limited capacity by all users including by the main incumbent user (bro adcasters). This objective must also take 
into account the Member States' competencies  in the field of a udiovisual policy, in 
particular in relation to cultural diversit y and pluralism. Support for audiovisual and 
media policies is a priority goal for EU spectrum management. 
1.1.3 A spectrum with exceptional qualities 
The digital dividend is particularly suited to fa cilitate the achievement of the above objectives 
because the related frequencies are located in a very attractive part of the radio spectrum, 
offering ideal propagation characteristics: radio signals in these frequencies can travel over 
relatively long distances, reducing the number of costly transmitters, and can also penetrate buildings easily, meaning terminal equipment can  be easily used indoors. These frequencies 
can also carry a significant amount of data and allow the use of relatively small antenna, 
which is particularly suitable for mobile devices. 
1.1.4 The potential social and econo mic benefits are significant 
High potential value The digital dividend represents a rare opportunity in Europe when a significant amount of 
spectrum suitable for a variety of uses is beco ming available across all Member States in a 
relatively similar timeframe. It has therefore attracted a lot of interest from potential users, with demand from users likely to significantly  exceed supply. More generally, the digital 
dividend is truly a un ique opportunity for Europe to m eet the growing demand for radio 
spectrum, particularly for the wireless services  described above, and can  therefore contribute 
significantly to the Lisbon goals of competitiveness and economic growth and satisfy some of the most important emerging social, cultural an d economic needs for the benefit of European 
citizens. The digital dividend carries both high economic as well as high social and public 
value. It would be counterproductive to oppos e these two types of value as they often 
complement each other: it is clear that wire less access to broadband services creates public 
benefits such as "access for all" to the Intern et, and hence an increased access to educational 
and cultural information, while offering cost sa vings and revenue opportunities for operators. 
At the same time, broadcasting services bring high value content through a number of platforms including terrestrial transmission in the UHF-band, IPTV on broadband access, and 
other platforms. Many predict the convergence of both domains in the long term, especially 
when taking into account the blurring separa tion between types of content and types of 
distribution platforms. 
Social impact  
The expected social benefits of the initiative ar e considerable and they derive from two main 
services having crucial importance for societ y: broadband access for citizens in presently 
underserved areas and improved broadcas ting services. A number of studies
3 have 
demonstrated the direct and indirect social effects of those applications. The need for 
additional broadband capacity in pa rticular is at the core of the ongoing broadband initiative 
                                                 
3  See for instance Plum Consulting, Restructuring Europe's economic and social progress: unleashing 
the potential of ICT (January 2006); Ovum, Bridging the Digital divide – less technology, more 
understanding  (23 March 2009). 
EN 8  EN and has also been elaborated in this context4 and reiterated recently by the Radio Spectrum 
Policy Group (RSPG) in its position paper of 14 May 20095. A sizeable part of these benefits 
can be triggered at local and na tional level but this Impact Assessment looks at the significant 
incremental social value that can be genera ted by this specific Community initiative. The 
Impact Assessment also considers some negative impact of specific measures on selected communities of users (e.g. cost of upgrading e quipment to continue receiving television 
programmes after the transition to  digital format for consumers who can not afford to replace 
their old analogue TV set
6) and in some cases, on specific Me mber States (e.g. Member States 
exposed to interference from third countries preventing the deployment of new services). 
1.1.5 Limited window of opportunity 
There is an urgent need to give access to the digital dividend spectrum to contribute to 
economic recovery 
The current economic crisis clearly underlin es the urgency of ma king sufficient radio 
spectrum available for wireless communications, which currently represent the most vibrant 
link in the technological innovati on chain. They are essential to  creating further efficiency 
gains and cost savings in the broader econo my and are thus a key driver for economic 
recovery. The timeliness of this action is thus important so as to ensure that the digital dividend can contribute to the EU efforts for economic recovery.  
Several Member States are going ahead 
Recognising this urgency, a number of Member States have recently stepped up their efforts 
to develop full broadband access. As part of these efforts, several Member States have already expressed their intention to open up very soon the 790-862 MHz su b-band located in the 
upper part of the UHF-band, to deliver wireless  broadband access. This means, however, that 
there is a risk of fragmentation if these Me mber States were to proceed on the basis of 
different conditions of use for the same spectrum, and thus there is an urgent need to ensure 
that there will be consistency at EU level in order to allow all Member States to take full 
advantage of this opportunity. While five EU  Member States have completed analogue 
switch-off, the United States was the first non-E uropean country to do so (in June 2009). The 
700 MHz band, which forms part of the US digi tal dividend, was auctioned at the beginning 
of 2008. The auctions raised the si zeable amount of US$ 19 billion
7. 
1.1.6 Longer term view to reap the full benefits 
The recent acceleration of the developments  concerning the 790-862 MHz sub-band has put 
the emphasis on the need to address EU coordi nation for this particul ar sub-band. One should 
                                                 
4  See for instance Connecting Europe at High Speed : National Broadband Strategies {SEC(2004) 599}, 
COM(2009) 36 final of 28 January 2009 – Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the 
Regions “Investing today for tomorrow's Europe” and the Presidency Conclusions, Council of the 
European Union, Brussels, 12 December 2008 17271/08, http://ec.europa.eu/sport/information-
center/doc/timeline/european_council_12-12-  2008_conclusions_en.pdf. 
5  RSPG09-284 Final  
6  These issues are now well known as several Member  States have already switched off analogue TV. A 
particularly publicised case was the approach used by the first region to switch-off, the Berlin-
Brandenburg region, which included state subsidies to consumers for the purchase of digital decoders 
which were approved by the Co mmission under certain conditions. 
7  US auction of the 700 MHz band in February 2008. FCC website, auctions: 
http://wireless.fcc.gov/auctions/def ault.htm?job=auction_summary&id=73  
EN 9  EN keep in mind, however, that the digital divi dend can be wider and offer other attractive 
possibilities in other parts of the UHF spectrum.  A coordinated approach to the use of the 
overall digital dividend would si gnificantly increase its capacity and impact – and hence the 
potential social and economic benefits – throug h increased efficiency in the use of spectrum 
via technical coordination and acceleration of th e transition to new technologies, increased 
economies of scale in the single market, greater po tential for interoperability of services, more 
stability and predictability for investors,  increased innovation and competitiveness for 
European industry, more efficient spect rum negotiations with third countries. 
1.1.7 Considerable political interest and support 
The importance of a coordinated approach was also recognised by the European Parliament 
and by the Council in their res ponses to the earlier Commis sion Communication on "Reaping 
the full benefits of the digi tal dividend in Europe: A common approach to the use of the 
spectrum released by the digital switchover"8. The European Parliament adopted a 
Resolution9 which called on the Commission to submit proposals for better coordination of 
the digital dividend at Co mmunity level. The Council10 adopted specific conclusions in 
response to the previous Comm unication calling on the Commission to initiate the studies and 
consultations necessary to define a coherent basis for the coordinated usage of spectrum and 
to support and assist Member States in this pr ocess. Efficient use of radio spectrum was an 
important topic in the Review of the telecoms regulatory fram ework. The new rules about to 
be adopted foresee the estab lishment of a Radio Spectrum Po licy Programme for important 
political decisions on radio spectrum matters to  be adopted by the European Parliament and 
the Council. 
The Radio Spectrum Policy Group (RSPG), a high-level group of experts from Member 
States that assists and advi ses the Commission on strategic aspects of spectrum policy, 
provided advisory input on the digital dividend  issue (see section 1.2.1) and invited the 
Commission to act at EU level. This shows th at Member States understand the added-value of 
acting at EU level and support de veloping a coordinated approach. 
1.1.8 Envisaged policy instruments 
Three main policy instruments are envisaged at the start of this initiative: 
1. A Commission  Recommendation  to address two specific pre-requisites to the availability 
of a digital dividend, and which need to be fu lfilled by Member States without any further 
delay. There is already a high de gree of consensus in Europe  on these preliminary actions: 
– Member States to fulfil the political commitme nt for timely analogue switch-off in order to 
ensure that the target date of 1 Janu ary 2012 identified by th e Commission in 200511 is 
adhered to; 
                                                 
8 COM(2007) 700 
9  European Parliament Resolution of 24 September 2008 on reaping the full benefits of the digital 
dividend in Europe: a common approach to the use of the spectrum released by the digital switchover 
[2008/2099(INI)]. 
10  Council Conclusions on "Reaping the full benefits of the digital dividend in Europe: A common 
approach to the use of the spectrum released by the digital switchover" 2877th Council meeting, 
Luxembourg, 12 June 2008. 
11  COM(2005) 204, Communicati on on “Accelerating the transiti on from analogue to digital 
broadcasting”, 24 May 2005 and Council Conclusi ons of Telecom Council of 1/5 December 2005. 
EN 10  EN – Member States to support regu latory efforts towards the ha rmonised use in the Community 
of the 790-862 MHz sub-band for electronic comm unications services other than, and in 
addition to, broadcasting servi ces, and refrain from any acti on that might hinder or impede 
the deployment of such communication services in that band. 
2. A Commission  Communication  that will identify the key policy issues for a common EU 
roadmap (a "blueprint" for further EU-level coor dination of the digital dividend). To this end 
it will: 
– explain the need to ensure an appropriate le vel of coordination in the European Union to 
reap the full social and economic benefits  of access to this spectrum in Europe; 
– outline the initial steps to be taken in order to ensure that the roadmap can be established 
and effectively implemented – by avoidi ng delay of the analogue switch-off and by 
preventing situations where a Member Stat e takes individual decisions on the digital 
dividend that would seriously hinder a co -ordinated approach and undermine the 
contribution that the digital dividend can make to the EU efforts for economic recovery; 
– call on Member States to consider the a dvantages of allocating the 790-862 MHz for 
electronic communications services on a t echnology and service neutral basis, and 
consequently signal the Commission's in tention to propose harmonised technical 
conditions under which the 790-862 MHz sub-band – the upper part of the UHF band – can 
be made available for wireless broadband when a Member State decides to allow services other than broadcasting into those frequencies (see also Commission Decision in point 3 
below); 
– call on the European Parliament and the Council to give a political impetus on key 
strategic objectives, including the possibility of a deadline for the full availability of the 
790-862 MHz sub-band for electronic communicat ions in all Member States, or the 
adoption of a common EU position on the dig ital dividend in international spectrum 
negotiations (bilateral as well as in ITU). 
– identify further measures to increase efficien t use of spectrum and to enhance the digital 
dividend, which will be fed into the Co mmission proposal for a Radio Spectrum Policy 
Programme (established under th e Review of the telecoms regulatory framework in order 
to establish strategic orientat ions on radio spectrum matters).  This could include measures 
on the migration to more efficient and more versatile terrestrial broadcasting systems, 
which in turn would allow more programmes to  be transmitted and improve the consumers' 
viewing experience, as well as the setting of  a date for clearing the 790-862 MHz sub-band 
in parallel with the development of thes e more efficient broadcasting systems. 
3. A Commission Decision on the technical harmonisation of the 790-862 MHz sub-band 
In line with the above, the Commission would adopt a technical harmonisation decision (EC 
Decision) to set the te chnical parameters for use of th e 790-862 MHz sub-band. The setting of 
these parameters is vital since high power networks, such as t hose used for fixed broadcasting 
services, and low power networks such as those used for fixed and mobile wireless 
broadband, cannot co-exist in an un-coordinated manner wit hout considerable costs or 
spectrum inefficiencies being incurred. This re inforced coordination would facilitate EU-wide 
interoperability and would re duce distortions of competiti on in the single market.  The 
envisaged Decision is to be implemen ted by Member States if and when  they decide to 
change the designation of the sub-band, but a possible deadline for the implementation  of 
EN 11  EN the Decision (mentioned in 2.) would be left to a separate discussion with the European 
Parliament and Council, under the Radio Spectrum Policy Programme , because of its 
political  importance12.  
1.1.9 Main basis for this impact assessment 
This impact assessment builds upon work  undertaken by the Commission since 2007, in 
particular the previous Communication on the digital dividend mentioned above which clearly 
identified the potential for synergies at EU leve l. This Communication in itiated a consultation 
and "consensus-building" process with a view  to identifying the best possible approach, 
quantifying the potential cost and benefits  of each option, and stimulating the dialogue 
between interested sectors. 
These efforts were supported by several technical studies13, as well as by the in-depth study of 
the socio-economic impact14. This study, conducted on behalf of the Commission by a 
consortium of external experts, allowed to ev aluate both in quantita tive and in qualitative 
terms the various approaches and options to create optimal value from the digital dividend 
spectrum, and provided therefore an impor tant input to this impact assessment. 
1.2 Consultation and expertise  
1.2.1 Overview of main external consultations 
The consultation process was an integral part of each stage of policy development as a large 
part of the policy work consisted in creating awareness on the unique opp ortunities created by 
the emergence of a digital dividend. As we ll as the Commission's own efforts to raise 
awareness, notable through the Communication of  November 2007, further attention was paid 
to this issue when a relatively limited part of the digital dividend was awarded in the US 
through auctions that raised the sizeable amount of US$ 19 billion in February 2008.  
Interested parties were given several oppo rtunities to provide th eir input through the 
following activities and meetings. Each of these events contributed to the overall consultation 
process conducted by the Commission on the topic of the digital dividend: 
- Stakeholders' Hearings  15 . 
- Two Member States' workshops  16 . 
- Public consultation on the draft RSPG Opinion  on the Digital Dividend17 . 
                                                 
12  A firm deadline for implementa tion would mean the obligation for Member States to vacate the 790-
862 MHz sub-band from any existing high power broadcasting transmitters. This may affect the cost 
and/or the extent of terrestrial television serv ices and has therefore a clear political dimension. 
13  These studies were conducted by the CEPT under the Commission mandate on technical considerations 
regarding harmonisation options for the digital dividend in the EU. The reports are available at: 
http://ec.europa.eu/information_society/policy/ecomm /radio_spectrum/manage/eu/rsc/rsc_subsite/mand
ates/index_en.htm 
14  Commission study on Study on "Exploiting the Digital Dividend, a European Approach!. Full 
information including fina l report accessible at:  
http://ec.europa.eu/information_society/policy/ecomm/radio_spectrum/documents/studies/index_en.htm
#digitaldividend2009 . 
15  http://www.analysysmason.com/PageFiles/11730/ Stakeholders%20hearings%20-%20Summary.pdf  
16  http://www.analysysmason.com/Global/Consulting/ Digital%20Dividend/First%20Member%20States%
20workshop%20-%20Summary%20-%2020090505%20REVISED.pdf  
17 http://rspg.ec.europa.eu/consultations/respons es_digitaldividend_090515_0630/index_en.htm  
EN 12  EN - Public consultation on the technical aspect s of the digital dividend conducted by the 
CEPT , in response to the mandates from the Commission18. 
- Public consultation on the draft proposals set out in a consultation document entitled 
"Transforming the digital dividend opportunity into social benefits and economic growth 
in Europe"; this closed on 4 Septem ber 2009 and generated 122 contributions. 
The general position of the main interested sector s, as identified during th e successive steps of 
consultations, are summarised below: 
- The broadcasting sector  broadly supports the principle an d objectives of the draft policy 
proposals, including, in most cases, the neces sity to open up the 790-862 MHz sub-band 
for new services. However, the sector re quests the Commission to exercise caution 
regarding future implementation, in particular  concerning the risk of  harmful interference 
to TV transmissions and to receivers and the cost of reorganising the broadcasting 
networks to clear up the 790-862 MHz sub-band  from high power TV transmitters. While 
accepting that broadcasting services will be able to develop under the envisaged proposals, broadcasters warned against ta king a purely economic approach. The sector 
also warns against further policy changes that could affect spectrum below 790 MHz. 
There were some notable differences of view s among contributions from the broadcasting 
sector, in particular concerning the timing of  the availability of spectrum above 790 MHz 
and the prospects of upgrading networks to  achieve higher spectrum efficiency. The 
proposal to upgrade DTT
19 receivers seems to be generally welcome by broadcasters as it 
would facilitate future enhancem ents in broadcasting services. 
- Telecommunications operators  express their wide-rangi ng support on virtually all 
topics. The contributions part icularly welcome the opening of the 790-862 MHz sub-band 
for mobile and fixed wireless communicatio ns. Some mobile operators are somewhat 
sceptical about the possible use of white spaces  (the gaps between spectrum blocks used 
by broadcasters) but do not oppose the draft pr oposal on this matter. Many contributions 
from telecommunications players call for ensuri ng the availability of further spectrum of 
the digital dividend on a service and tec hnology neutral basis in the future. Several 
prominent telecommunications associations stress the need to address potential 
competitive issues as the available spectrum is likely to satisfy a fraction of the demand, 
and request that this issue be added to the Commission's work (this request emanates 
particularly from associations that include fixed operators). 
- Cable operators  fully support the underlying objectives in relation to the re-use of the 
790-862 MHz sub-band and recognise the benef its that could be av ailable to a large 
number of citizens. However, they are equall y concerned that custom ers/ viewers could be 
negatively impacted by interference to their existing television and broadcast services, arising from the introduction of certain f ourth generation mobile systems. The tests 
commissioned by this industry to provide broader validations  and conclusions are still 
ongoing. Some criticism is targeted by cable op erators at the CEPT, which allegedly did 
not consider all technical issues in sufficient depth. 
                                                
 
18  The Electronic Communications Committee (ECC) of the European Conference of Postal and 
Telecommunications Administrations (CEPT) adopted on 1 July 2009 a draft ECC Decision on harmonised conditions for Mobile/Fixed Communications Networks operating in the band 790-862 
MHz (ECC/DEC/(09)EE) , for which a public consultation has been launched. The text of the draft 
ECC Decision on the 800 MHz band can be found on the ECO web site www.ero.dk
, under ECC 
Activities/Public consultations on ECC Decisions/Recommendations and Reports. 
19  Digital Terrestrial TV 
EN 13  EN - Existing users of white spaces  for wireless microphone  services stress the great 
difficulty that they would face if  they would be limited to us ing only one dedicated part of 
the UHF, and if new systems based on cognitive radio technologies20 start making use of 
the same spectrum. They however support efforts by the Commission to discuss at EU level the issue of future relocation. 
- The constituency interested in using the digital dividend for PPDR  (public protection 
disaster recovery) services  reiterated the need for spectrum below 1 GHz for their future 
high speed data services but di d not present argument s to indicate if the use of the digital 
dividend would be a preferred option. 
1.2.2 Internal consultations and consultation of other EU institutions 
Regarding internal consultations, other services  of the Commission with a policy interest in 
the subjects involved have been associated with  the above consultative activities. There was 
also an Inter-Service Group meeting on spect rum policy on 18 June 2009 where the broad 
lines of the proposed Commission's proposals,  which are the subject of this impact 
assessment, were presented to the participan ts. As a follow-up, the draft impact assessment 
document, as communicated to the secretaria t of the Impact Assessment Board, was also 
transmitted to this group in the middle  of Au gust. Finally, an Impact Assessment Steering 
Group including all relevant services was es tablished. This Group met on 18 September 2009 
to discuss this impact assessment. 
As far as other EU institutions are concerne d, as indicated above the European Parliament 
responded to the invitation in the 2007 Commission Communi cation and adopted an own 
initiative resolution which has been taken in to account in the proposal. The Council adopted 
specific conclusions in response to the pr evious Communication. The Communication was 
also addressed to the Committee of the Regions  and the Economic and Social Committee. The 
Committee of Regions adopted its opinion
21 on 19 June 2008.  
1.2.3 Main conclusions from the consultative process 
At the end of this process, there were four main topics which were identified as requiring 
concrete actions and which underpin the main proposals subject to this impact assessment: 
(1) The importance of a timely analogue switch-o ff, i.e. the end of analogue broadcasting 
by 2012 in Europe, as a pre-requisite to tri gger investments in new infrastructures and 
unleash the expected social and economic benefits. 
(2) Requirement upon Member States to refrain fr om any action that would contradict or 
complicate the application of a co-ordinat ed EU approach in  the 790-862 MHz sub-
band. 
(3) The setting of technical parameters fo r the 790-862 MHz sub-band (so-called 800 
MHz band) to allow access to the UHF sp ectrum for new uses such as wireless 
broadband access in rural areas, for example. 
                                                 
20  Cognitive radio technologies allow radio equipment to identify frequencies which are not occupied by a 
primary user at a given moment, and to exploit them temporarily. 
21  Opinion of the Committee of Re gions on "Telecommunications refo rm package" (2 008/C 257/10), 
http://eur-lex.europa.eu/LexUriServ/LexUri Serv.do?uri=OJ:C:2008:257:0051:0069:EN:PDF  
EN 14  EN (4) The potential for further increases in transmission efficiency by adopting the most 
recent digital compression technologies, wit hout affecting negatively the capacity for 
current services. 
1.2.4 Summary of results of the consultations  on the first topic:  Analogue Switch-Off 
The stakeholders from the telecoms sector cl early asked the Commission to ensure that the 
analogue switch-off be completed at the latest  by 1 January 2012, in accordance with the time 
table proposed in the Communication on the digital switchover in 2005. The broadcasting 
sector was more cautious on this point, howev er, and while not questioning the importance of 
the switch-off date, it drew atte ntion to the substantial invest ments that, although unavoidable, 
do require careful planning in order to ensure both  the continuity of service and that specific 
groups of viewers will not be  negatively affected. The tel ecommunications industry also 
expressed the fact that certai nty on switch-off in 2012 was more  important that the precise 
date of 1 January 2012. A few Memb er States having plans to sw itch-off during the course of 
2012 indicated that advancing their planning  by a few months could be unworkable or 
counterproductive. 
1.2.5. Summary of results of the consultations  on the second and third topics:  the 790-862 
MHz sub-band and its technical harmonisation 
At the Hearings, there was a broad consensus be tween stakeholders that  the harmonisation of 
the 790-862 MHz sub-band22 for fixed and mobile wireless  communications should not be 
mandatory. Instead voluntary harmonisation was de sirable for political reasons. The telecoms 
sector expressed the wish that the Commission should make itself availa ble to assist cross-
border co-ordination, especially  with non-EU countries. The s ector finally stressed that 
opportunities for use of spectrum below 790 MH z should be explored. The broadcasting 
sector, although not generally in  favour, did not oppose the prin ciple of gradually opening up 
the 790-862 MHz sub-band to othe r services on a neutral basis. The stakeholders from 
services ancillary to broadcasting and programme making (mainly the wireless microphone 
industry) wanted to be recognized as existing users and expressed strong concerns about the 
availability of their service following th e harmonisation of the 790-862 MHz sub-band for 
mobile services. 
In the Member States workshops, the majority  of respondents were in favour of opening the 
790-862  MHz band, but were opposed to a fixed e nd date for opening the band. Most of them 
agreed with allowing electroni c communications services in this band on a technology and 
service neutral basis. It was noticeable that opi nions evolved positively from the first to the 
second workshop. The respondents to the RSPG consultation expressed generally a positive 
opinion, or at least a neutra l attitude, towards a timetab le for making the 800 MHz band 
available to new uses but there were few to favour making it mandatory at this stage. The 
compensation for the cost of clearing out th e 790-862 MHz sub-band was a priority for many 
respondents in the broadcasting sector.  
1.2.6. Summary of results of the consultations on the fourth topic: further improvements in 
broadcasting transmission efficiency 
The Hearings showed differences of opinion amo ng stakeholders from the broadcasting sector 
on whether action is required at a European level regarding MPEG-4/DVB-T2. The majority 
of stakeholders recognised th e benefits of new compression techniques but were concerned 
                                                 
22  Often referred to as the "800 MHz band". 
EN 15  EN about mandating MPEG-4 transmission standards and a date for transition from MPEG-2 to 
MPEG-4 due to the costs involved for their indu stry. Broadcasters were widely supportive of 
minimum quality in the rejection of interferen ce on all DTT receivers (interference immunity) 
as it is recognised that the poor quality of so me receivers is already a worrying consumer 
issue. 
At the Member States workshops, a number  of Member States fully supported the 
recommendation to define minimum interferen ce rejection standards for DTT receivers. 
However, Member States had mixed views regard ing the idea of a binding EU-level action on 
the full adoption of MPEG-4, or equivalent sta ndard, compatible receivers. Some of them 
stressed that most DTT receivers currently pr oduced are MPEG-4 compatible and that market 
forces are already leading to the full adoption of MPEG-4 compatible receivers. 
2. P ROBLEM DEFINITION  
2.1. Identified issues and their underlying drivers 
The issues underlying the initiatives presen ted in the Communication and Recommendation 
are also documented in the Commission’s 2007 Communication “Reaping the full benefits of 
the digital dividend in Europe: A common approach to the use of the spectrum released by the 
digital switchover”.23 
2.1.1. Lack of coherence of national approaches wi ll lower the usability of the spectrum 
and hence the potential socio-economi c impact of the digital dividend  
For interference management reason, it is technically  impossible, or very in efficient, to mix in 
the same spectrum various wireless services ha ving fundamentally different types of technical 
characteristics. To illustrate this point, e xperts have estimated that mixing together high 
power and low power services in the UHF band (the band linked to the digital dividend) 
without at least proper cha nnelling/guard band arrangements would reduce the overall 
theoretical transmission capacity of the band by as much as two thirds. 
There is also a cross-border effect as the t ype of use of the UHF band in one Member State 
has an impact on the type of use that can be made by neighbours:  e.g. if DTT is broadcast at 
high power levels throughout the band, it will significantly re duce the scope for neighbouring 
countries to make use the spectrum for other se rvices. This would be particularly acute in 
smaller Member States or in Member States  where a large proportion of the population lives 
within reach of signal transm issions from neighbouring countri es including th ird countries 
(which create interference typically up to 100 kilometres from borders). 
The current cross-border coor dination of the UHF band between  Member Sates is achieved on 
the basis of the Internationa l Telecommunications Union (ITU ) Radio Regulations and, in 
particular, the Geneva 2006 Regional Agreem ent (GE-06) ruling the coordination of 
broadcasting frequencies. Some Member States anticipated the use of the UHF band also for 
other services than broadcasting and obtaine d at the last World Radio Conference (WRC) 
2007 the possibility to allocat e a part of the band (790-862 MHz) band for mobile 
communications24. However, the ITU frequency planni ng remains based on the use of the 
                                                 
23  Op. cit. COM(2007) 700. 
24  By undersigning footnote 5.316 of the ITU Radio Regulations, which allocates the band 790–862 MHz 
to the mobile service on a co-primary basis (except aeronautical mobile). 
EN 16  EN band for high power DTT and is therefore inade quate for the coordinati on of others services 
than broadcasting. 
In the absence of EU regulations dealing with the 470–862 MHz band, there is currently a 
range of possible technical approaches to the digital dividend in order to cope with the 
interference issue. There is a risk that Member  States would proceed to implement changes to 
the conditions of use of the spectrum at va rying paces and with fundamentally different 
objectives. Some Member States have yet to develop plans for the digital dividend while 
others have specific proposals fo r future use. Such plans range  from continuing to use the 
whole digital dividend for broadcast TV services, to allowing market forces to determine the 
future use of the spectrum. 
In conclusion, the digital divide nd will produce much better effect s if coordinated at EU-level 
despite the fact that some of the expected benef its from the digital dividend can be realised at 
national level alone. In particular, coordination will allow much more efficient technical co-
existence of networks supporting services ot her than existing broadcasting services.  
2.1.2. Lack of EU coordination will prevent Member States to allocate th e digital dividend to 
its best uses 
The interference issue raised by the cross-border propagation of high-power DTT signals, and 
the resulting lack of coordinated clearance of part of the band, also im pact on the ability of 
Member States and their Spectrum Management Authorities to discha rge their duty under the 
Framework Directive. 
The EU regulatory framework specifies that Memb er States must manage spectrum in a way 
that fosters efficiency and innovation. Cross-border interfer ence permitted under the current 
agreements, however, places a great constraint on their ability to do so. In the absence of 
cross-border interference, the optimal allocat ion may be very different from what is 
practically achievable under current circumstances. 
Consequently, national spectrum management au thorities, in the absence of a consistent 
coordination mechanism to minimise the negative impact of interference in the EU, may be 
forced to conclude that the best  use of the spectrum is still DTT, whereas if coordination was 
implemented it would be a different use. Th is creates further interdependence between 
Member States and their neighbours. 
2.1.3. Lack of economies of scale and pan-European coverage of services may hurt the 
European economy and deter investments 
Virtually all of the expected potential uses of the digital dividend (whether these are new 
broadcasting or wireless broadba nd services) rely on the possibili ty to achieve critical mass 
and economies of scale. It is also essential to underline th e importance of a coordinated 
approach to ensuring that these economies of scale throughout the EU are maximised, and that 
internal market objectives are achieved as much as possible by enabling interoperability and 
roaming between Member States. Both of th ese can best be furthered through a common 
frequency allocation and common adoption of  technical conditions. Typically, it is 
significantly more cost-efficient for equi pment manufacturers to produce network and 
consumer equipment to a single set of techni cal conditions, than to have multiple, smaller-
scale production lines for different markets.  For example, the Commission study found that 
manufacturers of mobile communi cations equipment expect a potential market of at least 100 
million inhabitants before investing in new production lines for the 4th generation mobile 
EN 17  EN communications equipment. The reduced developm ent times and greater certainty associated 
with harmonised choice of technology and fre quencies also enables manufacturers to bring 
equipment to market faster. 
In the stakeholders' hearings and in the public  consultation, it was made  clear, by equipment 
suppliers and telecommunications operators in particular, that EU coordination would play a 
major role to create confidence and acceler ate investments in new infrastructures. 
2.1.4. Optimising the digital di vidend in the medium term (spectrum below 790 MHz) 
There is now a general consensus that the 790 -862 MHz sub-band should be made available 
for the deployment of wireless  broadband. However, the effects of further measures in the 
other sub-bands (spectrum below 790 MHz) need  to be explored more carefully in the 
medium to long-term as they offer a potential fo r additional capacity to be progressively made 
available (independently from the precise use th at could be made of it in the future). In 
particular, in the majority of Member States , DTT networks can be upgraded, including with 
existing technology, to become more spectrally effi cient in the future. These upgrades vary in 
efficiency gains, the investment required to implement them, and the degree to which they are 
governed by well-established standards.  
Upgrading is possible in three ways: 
• Compression technology : Currently, most Member States use the so-called MPEG-2 
standard for DTT signal compression, but a move to a more advanced compression technology such as the widely-available MPEG-4 H.264/AVC (MPEG-4) standard would 
almost double the capacity, and valu e, of the digital dividend. 
• Modulation and radio technology : DTT in the EU uses the Digital Video Broadcasting – 
Terrestrial (DVB-T) standard. Improvement s to the techniques used by DVB-T are 
brought by the DVB-T2 standard.25 This standard is likely to enable a 30% increase in the 
capacity of a DTT multiplex compared to DVB-T. 
• Network topology : Most DTT networks in the EU are mostly multi-frequency networks 
(MFNs).26 This means that a given multiplex (a set of television programming channels 
broadcast in a given geographi c location over an 8MHz freque ncy channel) uses different 
frequencies in different geogra phic locations to avoid self-interference. In the future, the 
increased use of single-frequency networks (S FNs), where all frequenc y channels are used 
at all sites, could substantia lly reduce the need for spectrum (but limit the possibility for 
regional programming). 
It is therefore possible for DTT networks to be nefit from significant efficiency improvements, 
should demand for large numbers of television programming channels and/or high-definition 
programming warrant it.27 In the short term however, the most  realistic, and most beneficial, 
upgrade option is for broadcasters using MPEG-2 to move to a better compression technology 
such as MPEG-4. One very significant issue, however, is that existing MPEG-2 decoders 
would not be able to decode MPEG-4 transm issions. MPEG-4 compatible terminals, which 
                                                 
25  See http://www.dvb.org/technology/fact_sheets/DVB-T2-Fact-Sheet.0409.pdf . 
26  Or regional single frequency networks (SFNs). 
27  High-definition programming channels typically re quire twice the spectrum resources as a standard-
definition channel. 
EN 18  EN must be backward compatible with MPEG-2, are also significantly more expensive than 
MPEG-2-only decoders, and this raises important  considerations of consumer policy and cost. 
A further potential obstacle is that due to the absence of minimum interference rejection 
standards in the current generation of DTT r eceivers, a significant proportion of these would 
be impaired by uses other than DTT in the 470–862 MHz band. In pr actice, where these 
receivers are in use, the signal from the DTT transmitter would conflict with the signal received from, for instance, wireless broadband transmitters in the adjacent frequency channel or in channels located nine channels apart (known as n+9). 
In conclusion, enabling existing uses such as DTT to become more spectrally efficient can 
lead to the possible extension of  the digital dividend (spectrum below 790 MHz) in the future. 
If it is possible to use less spectrum for a gi ven number of televisi on programming channels, 
more DTT programming channels can be offered or  new uses can be introduced into the band. 
The consultations showed that EU  action could play a significant role to create the necessary 
momentum to address the above issues. 
2.1.5. Risk of disruption of important services already making use of part of the UHF where 
the digital dividend spectrum is located 
The main category of legacy services in the UHF spectrum, and therefore potentially 
interfering with the use of the digital dividend, is commonly referred to as wireless 
microphones and services ancillary to  broadcasting and programme making 
28. 
Wireless microphone and similar ancillary servi ces can use these particular frequencies 
(known as ‘interleaved spectrum’ or ‘white spaces’). They are essential to  a number of sectors 
of the economy, particularly broadcasting, conten t production and events organising (such as 
concerts and public speaking for instance). Any changes to the band should carefully consider 
the ability of these users to offer continuity of service. 
2.1.6. A sizeable part of the benefits could be foreclosed in absence of proper coordination 
with third countries  
As mentioned in 2.1.1, broadcasting transmission s can travel across border up to typically 100 
kilometres and can prevent other services than  broadcasting to operate in these geographical 
areas. In turn, this may prevent nation-wide serv ices to be deployed since all regions can not 
be covered. There is therefore a clear advant age, and sometimes a necessity, to coordinate 
with third countries.  
The current ITU rules foresee that, under the GE -06 agreement, uses other than DTT are not 
guaranteed protection  from high-power DTT transmissions from neighbouring countries. The 
consultations also revealed that early bi-lat eral negotiations between a Member States and 
third countries were often disappointing. 
In this context, a common EU approach would allow to establish an EU-wide platform for 
negotiation with third countries. This was gene rally very welcomed by stakeholders and 
Member States concerned. One additional issue concern the incompatibility of existing 
                                                 
28  In technical jargon, this is part of SAB/SAP re spectively for Services Ancillary to Broadcasting (SAB) 
which support the activities of broadcast service companies carried out in the production of their 
programme material and Services Ancillary to Programme making (SAP) which support the activities carried out in the making of "pro grammes", such as film making, advertisements, corporate videos, 
concerts, theatre and similar activities not initially meant for broadcasting to general public. 
EN 19  EN Aeronautical Radio Navigation Systems opera ting in the Russian Federation, Belarus and 
Ukraine with future wireless broadband system s that are envisaged in the Member States 
bordering these third countries. There is a strong support to ensure this issue can be dealt with 
the interested countries at EU level.  
2.2. Likely outcome in the absen ce of action at the EU level 
A number of Member States have  clearly stated their intention to designate, clear, and award 
the 790–862 MHz sub-band either directly for, or in a format that will enable, electronic communications services (e.g. wireless broadband) . The situation is evolving rapidly, but at 
the time of writing these Member  States included: Denmark,
29 Finland,30 France,31 
Germany,32 the Netherlands,33 Spain,34 Sweden35 and the UK.36 Other Member States have 
also indicated that they were contemplati ng creating such a sub- band after analogue is 
switched off both domestically and in neighbou ring countries (this includes some countries 
outside the EU and therefore not subject to the Commission’ s recommendation to complete 
digital switchover by early 2012). 
In the absence of action at the EU level to c oordinate the adoption of the sub-band, it is likely 
that this momentum will nevertheless continue, and that those Member States bordered by countries where the sub-band has been identif ied, but currently undecided about the sub-band 
will also adopt it. Conversely, Member States  that are surrounded by countries that are not 
likely to adopt the sub-band would be more likely to retain their GE-06 plans. This 
particularly affects Member States at the easte rn and south-eastern borders of the EU, where 
the decisions of large neighbouring non-EU countri es, such as Belarus, Russia, Turkey and 
the Ukraine, will have a significant impact. 
This may result in two categories of Member States: 
• Those that will coordinate the use of the 790–862 MHz sub-band according to the 
technical parameters that are set  (i.e. for low-power services such as wireless broadband). 
For the purposes of this impact assessment and the related economic modelling, and based 
on information provided by Member  States, these Member States are assumed to be, in the 
end: Austria, Belgium, the Czech Republic, Denmark, Finland, France, Germany, Ireland, Italy, Luxembourg, the Netherlands, Portugal,  Slovenia, Spain, Sweden and the UK. 
• Those that will retain high-power DTT in the whole band . For the purposes of the 
economic modelling these Member States are assumed to be: Bulgar ia, Cyprus, Estonia, 
Greece, Hungary, Latvia, Lithuania, Malta, Po land, Romania, and Slovakia. The acuteness 
of the issue would be even more serious if Italy would have been included in this list37. 
                                                 
29  http://vtu.dk/nyhed er/pressemeddelelser/2009/frekvense r-til-fremtidens-mobile-bredbaand/ . 
30  http://www.lvm.fi/web/fi/p uheet/puhe/view/904813 . 
31  http://francenumerique2012.fr/html/france_2012.html . 
32  http://www.bundesrat.de/cln_090/nn_8538/DE/presse/pm/2009/117-2009.html?__nnn=true  and 
http://www.bundesrat.de/cln_090/Share dDocs/Drucksachen/2009/0201-300/204-
09,templateId=raw,property=publicationFile.pdf/204-09.pdf . 
33http://www.ez.nl/Onderwerpen/Betrouw bare_telecom/Frequentiebeleid/Consultaties_en_informatieve_papers/
Consultatie_beleidsvoornemen_inzake_de_verdeling_van_het_resterende_Digitale_Dividend_in_de_U
HF_frequentieband/Consultation_document_Digital_Dividend_in_the_UHF_frequency_band_470_862
_MHz.  
34  http://www.mityc.es/es-ES/GabinetePrensa/Not asPrensa/Paginas/dividendodigital020609.aspx . 
35  http://www.sweden.gov.se/sb/d/9760/a/94782 . 
36  http://www.ofcom.org.uk/consult/condocs/800mhz/statement/ . 
37  There is still great uncertainty on the direc tion to be adopted in Italy at this moment. 
EN 20  EN As shown in Figure 2.1 below, assuming cross-border propagation of up to 100km in 
distance, large parts of the Czech Republic, Au stria and Slovenia would be unable to benefit 
from new services deployed in the sub-band. This illustrates the potentially negative impact of one Member State’s decision on another. 
 
Countries that are too far from EU27 to cause interferenceAreas affected by high pow er DTT interference100km radius of interference from countries with high power DTT 
Austria
Slov eniaLithuaniaEstoniaNorwaySweden
Finland
Italy BulgariaUkraineRussia
AlbaniaBelarus
Belgium
Croatia
CyprusCzech RepublicDenmark
FranceGermany
GreeceHungaryIrelandLatvia
Malta
MoroccoNetherlandsPoland
PortugalSlovakia
SpainSwitzerland
TurkeyUnited Kingdom
RomaniaCountries that are too far from EU27 to cause interferenceAreas affected by high pow er DTT interference100km radius of interference from countries with high power DTT 
Austria
Slov eniaLithuaniaEstoniaNorwaySweden
Finland
Italy BulgariaUkraineRussia
AlbaniaBelarus
Belgium
Croatia
CyprusCzech RepublicDenmark
FranceGermany
GreeceHungaryIrelandLatvia
Malta
MoroccoNetherlandsPoland
PortugalSlovakia
SpainSwitzerland
TurkeyUnited Kingdom
Romania
 
Figure: Assumption of regions in which harmful interferen ce is caused by Member Stat es using the 790–862MHz sub-band 
for high-power DTT [Source: Analysys Ma son, DotEcon, Hogan & Hartson, 2009] 
For the purpose of the economic analysis perfor med in the context of the Commission study, a 
sensitivity analysis was conducted in which be tween 5 and 13 Member States would not adopt 
the 790–862 MHz sub-band without intervention at  EU level. Member States in which the 
sub-band is not adopted will remain outside any single market that may emerge, limiting economies of scale in the EU as well as other benefits, such as pan-EU roaming. 
In addition, there is a high proba bility that there will be some  differences between technical 
conditions for the use of spectrum imposed by the Member Sates having adopted the 790-862 
MHz sub-band for electronic communications se rvices. This would result in a risk of 
EN 21  EN fragmentation of the internal market as the equipment operating in this band could not be 
completely technically compatible in all cases. 
Finally, the absence of EU acti on would allow current uncertainty  to persist until all Member 
States have formally adopted an approach to the sub-band. The economic analysis conducted 
by the Commission and the consortium (see final Commission study report38), which is 
referred to throughout this impact assessment show s that this is likely to result in very 
substantial social and economic va lue remaining unrealised (for de tails, see more particularly 
sections 13.2 and 13.3 of the Commission study). 
2.3. The advantages of EU intervention  
Section 2.1 above outlines that a major issue for current use of the digital dividend spectrum 
is the cross-border interferen ce, where DTT is used througho ut the 470–862 MHz band. In the 
‘no action’ scenarios described in the previous  section, this problem would continue for a 
large proportion of Member States, which w ould in turn limit other benefits such as 
economies of scale, interoperabili ty and roaming throughout the EU.  
This illustrates that if Member States act al one, an optimal outcome across the EU may not 
emerge. This is because if neighbouring countr ies maintain high-power DTT transmission in 
the 790–862 MHz sub-band, the valu e they can realise from adopting that sub-band for 
alternative uses may be reduced. Through such an  effect, actions by Member States alone are 
likely to significantly damage the interests of other Member States. 
Intervention at the EU level is therefore justified on seve ral counts as it can generate 
significant benefits compared to uncoordinated action by indivi dual Member States. The main 
areas for potential additiona l value for the EU are:  
• Technical efficiency and interoperability : a common frequency allocation would also 
create greater scope for roaming/interoperabi lity for consumers. The cost-efficiency and 
feasibility of providing ro aming services, particularly for wireless broadband, which 
enhances the value of the service to citizens,  are greatly improved compared to a situation 
in which consumer equipment requires multi-band operation. In addition, EU-level action to incentivise or secure the improved effici ency of current uses of the spectrum would 
help create value at the EU level. For instance encouragin g the adoption of advanced DTT 
compression technologies may help release di gital dividend spectrum for other valuable 
uses, such as improved broad casting and/or wireless broadband. 
• Economies of scale and innovation : a common frequency allocation and common 
adoption of technical conditions would resu lt in economies of scale for equipment 
manufacturing. A harmonised choice of technology and freque ncies would reduce 
development times, costs, create greater ce rtainty and enable manufacturers to bring 
equipment to market faster. 
• Securing investment and estab lishing international leadership : an early decision on a 
coordinated approach to the use of the digital dividend spectrum  at the EU level is likely 
to have two major impacts. Firstly, it will provide increased certainty to investors and 
                                                 
38  The full text, as well as the executive summary, of the Commission study "A European approach to the 
digital dividend" conducted by Analysys Mason, Dotecon and Hogan & Hartson is available on-line at: http://ec.europa.eu/information_society/policy/ecomm/radio_spectrum/activities/index_en.htm
 [pending 
activation]. 
EN 22  EN companies over the future availability of spectrum for uses other than DTT. This 
increased certainty is likely to foster substa ntial investment in research and development 
sooner than might otherwise have been the case. Secondly, it may influence neighbouring 
non-EU countries, increasing the potential bene fits from adopting the sub-band. Benefits 
would be realised principally because of reduced interference from neighbouring 
countries. If a common use of the band emerged beyond the EU’s borders because of this early leadership, economies of scale would al so be enhanced. Both these impacts would 
benefit the EU by stimulating economic  activity and providing opportunities for 
innovation within the EU which could be exported. 
3. S
PECIFIC OBJECTIVES PURS UED BY THIS INITIATIVE  
The first specific objective is to maximise be nefits from the digital dividend and to act 
sufficiently rapidly to avoid fr agmented national legacy situa tions, which would hamper the 
establishment of a single market with rega rds to future services and equipment. 
Secondly, this initiative seeks to ensure sufficient consistenc y between national approaches 
and foster convergence over time, with a vi ew of supporting innovation and long-term 
benefits for consumers, streng thening the single market, and in creasing EU competitiveness. 
These initiatives aim to further increase the av ailability of digital dividend spectrum by 
adopting common approaches to various technical and deployme nt issues, and providing more 
predictable and stable spect rum planning for investors. 
Thirdly, the Commission's acti on should aim at faci litating the early e fforts by several 
Member States to open up the 800 MHz band to ne w services such as wireless broadband and 
help avoiding unnecessary fragmentation (i.e. different Member States imposing different 
levels of technical or functional restrictions). 
4. P OLICY OPTIONS  
The proposals under development include four main  areas where direct actions are considered 
in order to achieve: 
- Timely analogue switch-off of analogue terr estrial TV in the EU  by 1 January 2012, as 
a pre-requisite to estab lish a digital dividend; 
- Optimal use of spectrum in the UHF band (470-862 MHz); 
- Avoiding un-coordinated acti on by Member States in the 790-862 MHz sub-band; 
- Technical harmonisation of  the 790-862 MHz sub-band. 
The four proposals involving direct action result from an analysis  of a range of options, which 
are summarised below.  
4.1. Policy options regarding the ti mely switch-off of analogue TV 
In its Communication on the switchover to digi tal broadcasting in 2005, the Commission set a 
target EU date for analogue switch-off of be ginning 2012. This time frame has been further 
endorsed by the European Parliament and Coun cil in their response to this Communication 
but this does not commit Member States legall y. The Council has however referred to end of 
2012 in its conclusions on this matter. 
EN 23  EN A number of Member States have now already switched off39 or have announced plans to 
switch off analogue signals by 2012 (though not necessarily by the beginning  of 2012) while 
at the same time several Member States have no t yet adopted final plans. There is even the 
possibility that at least one large Member State delays anal ogue switch-off up to July 2013. 
In this context, the situation of Member States  located at the Eastern and Southern borders of 
the EU may remain partially constrained in wh at spectrum they can use because of cross-
border interference from neighbouring non-EU count ries which will not have yet switched off 
analogue television as the end da te specified at international level (during GE-06) for the 
protection of analogue broadcasting is 2015. 
4.1.1 No further EU action 
This option would result in each Member State completing analogue switch-off according to 
its own timetable. On the basis of information ava ilable at the time of writing, it is expected 
that up to 11 Member States may switch o ff analogue signals after 1 January 2012, which 
poses a serious risk to efforts to exploit th e digital dividend for ec onomic recovery, although 
at least ten of these Member States are exp ected to complete switch-off by the end of 201240. 
4.1.2. Recommendation that Member States take al l necessary steps to switch-off analogue 
signals by 1 January 2012  
This policy option will seek to ensure that th ere is no residual analogue transmission in the 
470–862 MHz band by the start of 2012. This will he lp securing a critical mass towards a co-
ordinated EU approach to the digital dividend  and enable most Memb er States to take 
advantage of the spectrum that will be fr eed by the stopping of analogue terrestrial 
transmissions, while creating greater certainty for industry. 
4.1.3 Mandating analogue switch-off by 1 Januar y 2012 (a Community legal measure) 
This option would ensure, by applying a legally  binding Community measure, that analogue 
switch-off is completed across the EU by 1 Ja nuary 2012. Such a legislative measure would 
carry significant political weight, as well as ensuring that the way was open for a fully co-
ordinated approach to the digital dividend. However, it may cause difficulties for those 
Member States that have not been able to  prepare sufficiently for the implementation 
deadline, and would also create difficulties of  co-ordination with third countries, where the 
shift to new transmission configurations ha s yet to be co-ordinated with neighbouring 
countries to avoid interference wi th existing broadcasting services. 
4.2. Policy options regarding the achievement of the optimal use of  spectrum in the 
UHF band (470-862 MHz) 
There are a number of policies and instruments that could usefully be employed in order to 
obtain an optimal use of the digital dividend spectrum. Apart from immediate action in the 
790-862 MHz sub-band (dealt with under sections 4.3 and 4.4 below), the effects of further 
measures in the other sub-bands (spectrum below 790 MHz) need to be explored in more 
                                                 
39  Member States that have already switched off anal ogue terrestrial TV (and are therefore in a fully 
digital format): Germany, Finland, Luxembourg, Sweden, the Netherlands. Belgium has partially 
switched (Flanders) and major areas in Austria. 
40  During the consultation process, Poland informed the Commission that it now plans to switch off 
analogue terrestrial TV by July 2013. 
EN 24  EN detail in the medium to long-term. These invol ve measures and orientations to ensure an 
efficient use of spectrum freed by analogue switc h-off to be set out by the Commission and, 
ultimately, to serve as input to the Radio Spectrum Policy Programme to be proposed to 
the EP and Council after adoption  of the new telecoms package .  
4.2.1 No further EU action on coordination activities 
Under this option, the EU would not adopt any m easure, formal or informal, to increase the 
optimal use of spectrum below 790 MHz. There would be no specific action  such as 
promoting interference resistant DTT receive rs or better compression and transmission 
technologies beyond the guidelines currently in pl ace. This would leave the issues raised in 
Section 2.1.4, such as potential interference to D TT receivers from other uses and the need for 
broadcasters to migrate transmission to mo re efficient technologies  without prejudice to 
consumers, to the responsibility of Member States.  
4.2.2 Proposing further coordination activities in sub-bands below 790 MHz 
The Commission could i ssue a Communication outlining the benefits of further coordination 
action which could also feed into the proposals for a Radio Spectrum Policy Programme. The 
following issues could be covered by such an orientation: 
(a) Coordination for t he possible migration of DTT netw orks to more advanced transmission 
technologies (e.g. MPEG-4, DVB-T2) and interference resistant DTT receivers 
A recommended timeline for the migration to MP EG-4 and/or DVB-T2 t echnologies could be 
produced at the EU level. While this woul d not be obligatory, it could gain momentum, 
leading to an accelerated adoption of these technologies.  
(b) The possibility of implementing national Single Frequency Networks 
A recommended timeline for wider deployment of national SFNs could increase the scope for 
a coordinated re-planning of the 470–862 MHz ba nd across several Member  States with the 
resulting benefits and costs.  
(c) The use of more frequency-agile wire less broadband networks (e.g. variable duplex 
technology) 
The Commission could encourage ma nufacturers to invest in a nd adopt more frequency-agile 
technologies, such as FDD systems that  could operate with  a variable duplex.  
(d) Cooperate at EU level over examining the future use of interleaved spectrum  
Wireless microphones rely on the availability of  interleaved spectrum (spectrum shared by 
DTT on a geographic basis); a number of Member States dedicate freq uencies nationally to 
this use. In the short-term the availability of interleaved spectrum will decrease due to the 
introduction of low/medium-power  use into the 790–862 MHz sub-band. 
Member States will therefore n eed to relocate wireless microphone  use in order to adopt the 
sub-band. Benefits from economies of scale, as well as roaming, could pot entially be created 
in future systems if the frequency location of dedicated channels were  coordinated across the 
EU. In this option, guidelines would be produced  regarding which frequencies Member States 
should dedicate. 
In the medium to long term, th e availability of sufficient spectrum in the 470–862 MHz band 
for wireless microphones and assimilated is less clea r, and it would therefore be warranted to 
EN 25  EN consider measures to encourage users to either  migrate to more spectrally efficient digital 
equipment or to migrate to spectrum outside  the 470–862 MHz band, in a coordinated fashion 
across the EU. 
Under this option, Member States would be also  invited to cooperate with the Commission in 
examining the technical and re gulatory conditions for using interleaved spectrum (white 
spaces) for applications that use cognitive technologies. Cognitiv e technologies will have the 
ability to detect dynamically whether frequencies are being used in a pa rticular location, and 
if not, transmit over those frequencies. The introduction of cognitive technologies will be 
discussed at the next World Radiocommuni cation Conference (WRC-12) under agenda item 
1.19. Decisions need to be made regarding whic h technical approaches may be permitted, as 
well as the technical specification required of the chosen approach. This option may ultimately result in a CEPT/ECC Common Po sition on the technical parameters and 
regulatory conditions under which cognitiv e technologies should be introduced. 
(e) Increased involvement of EU-level institu tions in cross-border spectrum coordination 
The adoption of the 790–862 MHz sub-band acro ss Europe may require  significant re-
planning of DTT between Member States. As discussed above, there may be doubts about the ability of Member States to make the necessa ry agreements, particularly with neighbouring 
non-EU countries, within desirable timescales without some EU-level  coordination. This 
option would see EU-level institutions take a mo re active role in organising or facilitating 
those negotiations. 
 
The strategic relevance and implications of th ese proposals should be first discussed with the 
European Parliament and Council as part of  the future Radio Spectrum Policy Programme 
before taking more concrete steps towards their implementation (including the detailed impact 
assessment mentioned above). 
4.2.3 Mandatory requirements to improve spect rum efficiency linked to the digital  dividend  
In order to ensure a co-ordinated appro ach, the Commission coul d propose a number of 
individual mandatory measures regarding the e fficient use of the digital dividend spectrum 
and which could possibly be considered in th e context of a future Radio Spectrum Policy 
Programme: 
a) Accompanying measure for  the migration of DTT networks to more advanced transmission 
technologies (e.g. MPEG-4, DVB-T2) and interference resistant DTT receivers 
A legally binding Community m easure could be to specify minimum performance 
characteristics  for DTT transmission technologies. Th ese could be the bit rate of each 
multiplex (set to be equivalent to DVB-T2) or parameters that define the performance 
characteristics of compression technologies (p erhaps equivalent to H.264/MPEG-4 AVC as 
this is a mature standard and the variant that appears to be gaining momentum across the industry). As an intermediate measure, the minimum performance level could be imposed 
only on DTT receivers as a pre-requisite to f acilitate the upgrading of the networks at a later 
stage. 
A legally binding Community m easure could also specify minimum interference rejection 
standards  for DTT receivers which would include detailed specifications for the minimum 
EN 26  EN interference tolerance/rejection pe rformance of the receivers, in cluding the rejection of signals 
received in the adjacent cha nnel and image channel (n+9).  
A legally binding Community measure could also  require that all Member States adopt 
transmission technologies that meet technology-neutral specifications.  
b) Implementation of national Si ngle Frequency Networks  
 
Under this option, Member States would be  required to adopt th e use of national Single 
Frequency Networks  (SFNs) within a specific timeline by applying a legally binding 
Community measure. This could either be for all DTT multiplexes or (more realistically) for a 
subset of multiplexes, allowing the remaining multiplexes to continue to be deployed using multiple frequency networks (MFNs) in order to provide regional content.   
c) Cooperate at EU level to examine th e future use of interleaved spectrum  
Under this option, Member States would be requi red to provide information on a regular basis 
to a central EU database regarding the availability and use of the so-called "white spaces" or interleaved spectrum , to provide a mapping for providers of equipment and services that 
may wish to exploit the internal market po tential for operating betw een existing broadcast 
frequencies. 
4.3. Policy options regarding the coordinati on of Member State action to ensure a 
coherent approach for the 790-862 MHz sub-band  
The EU has so far facilitated the public debate on the digita l dividend through a series of 
Communications and CEPT mandates, but has not directly intervened to recommend or 
require that Member States follow a ny particular approach to the band. 
4.3.1. No further EU action 
This option would result in each Member State being able to a dopt regulatory measures at the 
national level including moving new high-pow er services into  the sub-band.  
4.3.2. Recommendation that Member States follow a co-ordinated approach  in the 790-862  
MHz sub-band  
This policy option will ensure that Member  States refrain from  any regulatory action 
regarding the use of the 790-862 MHz sub-band that woul d contradict or jeopardise the 
application of the technical ha rmonisation measure which is pla nned at EU level, for example 
the designation of new (not yet planned) dig ital broadcasting servic es in the 790-862 MHz 
sub-band that would undermine the internal market and create problems for neighbouring 
Member States seeking to roll-out wireless br oadband services in the sub-band. Furthermore, 
action at the EU level will be consistent and wi ll ensure that all Member States can reap the 
benefits of the digital dividen. 
EN 27  EN 4.4. Policy options regarding the technica l harmonisation of the 790-862 MHz sub-
band 
4.4.1. Guidelines for the harmonisation (non  mandatory) of the 790–862 MHz sub-band 
This policy option would see the EU limiting its action to facilitating th e harmonisation of the 
790–862 MHz sub-band, without any obligatory acti on. This could include, for instance, a 
role in centralising and disseminating informati on on the management of the sub-band in all 
Member States, by encouraging or obliging Member  States to share their plans with sufficient 
notice. Under this policy option, the core action at EU level would cons ist of the preparation 
of non-obligatory guidelines for the t echnical harmonisation of the sub-band. 
4.4.2. Commission Decision setting the tec hnical parameters of the 790–862 MHz sub-
band  
Under this option, Member States would be  required to make the 790–862 MHz sub-band 
available for electronic communications. This  option introduces a binding requirement only 
for Member States that chose to designate the sub-band for any services other than 
broadcasting (i.e. when a Member State chan ges the current allocation for broadcasting 
services), and could therefore prevent the intr oduction of new services  that do not correspond 
to the harmonised technical parameters. It w ould not, however, guarantee that the sub-band 
will effectively be available across the EU by a certain date (cf. 4.1.1. above). Awarding of 
the band could be conducted on a t echnology and service-neutral basis41 with common 
technological conditions and a common band plan. 
4.4.3. Commission Decision setting the technical parameters an d setting a mandatory end-
date for clearing the 790-862 MHz sub-ban d of broadcasting (high-power) services 
Under this option the Commissi on would introduce a harmonisa tion measure with the same 
technical parameters  as that  under 4.4.2, but which would also set a binding date for Member 
States to clear the 790- 862 MHz sub-band of othe r services, notably br oadcasting that uses 
high power transmitters that would not be compatible with the Decision.  
 
                                                 
41  Technology neutrality means no re striction to one or more techno logies such as GSM, LTE, UMTS, 
WiMAX, but applying technological conditions such as power limit, duplex spacing, channel width.  
EN 28  EN 5. A SSESSMENT OF IMPACTS  
5.1.  Impact of options regarding the timely analogue switch-off  
The information currently available suggests that analogue switch-off will take place at 
varying times across the EU, despite th e EU target date of beginning of 2012. 
• Five (5) Member States have already sw itched off analogue transmissions: Finland, 
Germany, Luxemburg, the Netherlands and Sw eden. In addition, large regions have 
already switched-off in Belgium (Flanders) and Austria. 
• A further eleven (11) member States have o fficial plans to comple te analogue switch-off 
by the end of 2011: Austria, Belgium, Cy prus, Denmark, Estonia, France, Greece, 
Hungary, Latvia, Malta and Spain. 
• Another nine (9) member Stat es have plans to switch off during 2012: Bulgaria, the Czech 
Republic, Italy, Lithuania, Portugal, Roma nia, Slovakia, Slovenia and the UK. 
• Ireland has announced intentions to comply  with the Commission’s recommendation and 
Poland's latest objective is to switch-off in July 2013 but no firm plans are yet in place in 
these two Member States. 
5.1.1. No further EU action 
Without EU intervention, it is likely that 11 Member States will still retain some analogue 
broadcasting by 1 January 2012. Analogue switch-off in those Member States may take place 
throughout 2012, but in some cases may be de layed beyond 2012. Two Member States seem 
unlikely to switch-off any time before the e nd of 2012, and this would affect neighbouring 
Member States since parts of their spectru m would be unusable for low power use. The 
affected Member States would themselves  loose the benefits  of new services. 
5.1.2. Recommendation that Member States take all necessary steps to switch-off analogue 
signals by 1 January 2012  
Recommending that Member States ensure that digital switch-off is accelerated in order to 
ensure that the analogue switch -off date of 1 January 2012 is adhered to, would have a 
number of benefits: 
• There would be significantly increased pressu re on Member States to comply with the 
2012 deadline. Those Member States that have announced plans for analogue switch-off to 
take place before 2012 may miss their in itial, self-imposed deadline because of 
implementation issues, and a recommendation to accelerate switch off by 1 January 2012 is likely to focus the effo rts of all stakeholders. 
• Another benefit is that there would be more certainty that digital dividend spectrum would 
be available from 1 January 2012 in most Memb er States, hence more certainty for market 
players and all interested parties. 
• A widely applied analogue switch-off date  of 1 January 2012 woul d also increase the 
probability that some Member States w ill award the 790–862MHz sub-band earlier than 
would otherwise have been the case. The Commission study by the consortium of consulting firms estimated that, even on the basis of the most c onservative scenario 
EN 29  EN (modest demand for broadband services), avoidi ng a one-year delay in the availability of 
the sub-band 790-862 MHz across the EU could generate a collective benefit of several 
billion Euros in net present value (minim um EUR 1 billion in consumer and supplier 
surplus only, accumulated over 15 years). This figure is based on the cumulative effect of 
advancing the estimated overall economic benef its of the digital divi dend by one year over 
a period of 15 years (social benefits are not included but are assumed to be positive as the social advantages of access to broadband services are clearly established
42). For the sake 
of comparison, the UK regulator (Ofcom) has estim ated the impact of a one year delay to 
the availability of a part of the digita l dividend (790-9862 MHz) to reduce the potential 
net benefits from GBP 100 million to GBP 400 million in the UK alone. 
There are social costs , in particular due to the moving fo rward of the purchase of digital-to-
analogue converters by consumers who will continue to use an existing analogue TV. This cost, estimated at approximatel y 50 EUR per converter per anal ogue TV set to continue to 
receive terrestrial TV via an antenna, is however  low when compared to the aggregated total 
benefits mentioned above
43. The experience of switch-off in the five Member States which 
have already done so, as well as in the USA, indicates that this soci al impact is limited and 
can be mitigated through specific subsidies targeted to disadvantaged groups. 
In conclusion, as all Member States are planning to switch- over to digital technology, the 
timing of the switch-off does not influence signifi cantly the overall costs of the transition. To 
some extent, earlier investments could have  a positive effect on economic recovery. Some 
constituencies may face costs earlier than expe cted and this should be taken into account by 
authorities but the overall benefit is clearly po sitive as illustrated a bove. The distributional 
effect of these costs on disadva ntaged populations can be compen sated by state subsidies (the 
Commission has approved such state subsidies as  long as the choice of converter solution is 
technology-neutral)44. 
5.1.3 Mandating analogue switch-off by 1 Ja nuary 2012 (a Community legal measure) 
The impact of this option would be that ther e is no residual analogue transmission in the 470-
862 MHz band after 1 January 2012, legall y enforced by a Community measure . Member 
States who are unable to meet the analogue sw itch-off deadline of 1 January 2012 would tend 
to oppose the adoption of this Community measur e citing major issues of public interest, as 
certain among them would be faced with the st ark choice of significant and immediate extra 
switchover costs allied with the th reat of cutting-off television viewers that could not be re-
equipped in advance of the switch-off date. 
                                                 
42  See for instance Plum Consulting, Restructuring Europe's economic and social progress: unleashing the 
potential of ICT (January 2006); Ovum, Bridging the Digital divide – less technology, more 
understanding (23 March 2009). 
43  As a conservative estimate, socially-weak gro ups of populations representing up to 10% of the 
population could be affected in the potentially 11 co ncerned Member States (a mong those, there would 
be up to 2 or 3 million households, relying signi ficantly on terrestrial reception, which could not be 
eligible to subsidies, or for which Member States  would not have specific compensation measures in 
place). In this extreme cas e, the total expense to be moved fo rward could be EUR 150 million. The 
actual cost of the Community measure would actually be the interests on this amount accrued during 1 year on average, or appr oximately EUR 10 million
. Only the advancement of the expense is taken into 
account since the switchover to DTT is an agreed po licy, hence unavoidable, and already endorsed by 
all 27 Member States in 2005.  
44  See Commission Decision 2006/513/EC of 9 November 2005 on State aid C 25/2004: Financing of the 
introduction of DVB-T in Berlin-Brandenburg, Germany (OJ L 200, 22.7.2006). 
EN 30  EN Delaying the analogue switch-off in some Memb er States would have the following direct 
impacts: 
- the 790-862 MHz sub-band cannot be a dopted in those Member States; 
- the continued high-power analogue tr ansmissions in the 790–862 MHz sub-band 
would restrict the ab ility of neighbouring  Member States to use the sub-band for uses 
other than high-power DTT (issue of cross-border coordination). 
The social impact and impact on individual Member States would be similar as 5.1.2. 
5.2. Impact of options regarding the achievem ent of the optimal use of spectrum in 
the UHF band (470-862MHz)  
The impact analysis in this section examines which other actions could be taken in order to 
facilitate freeing-up of additional spectrum capacity, principally but not exclusively, below 790MHz
45 thereby enhancing the digita l dividend. This additional ca pacity could be used to 
allow satisfying later demand for more broadcasting services , more electronic 
communications services, or both. The impact of  these additional coordination possibilities 
have not been fully assessed in term of quantitative impact as they are only at the stage of 
proposal for discussion at EU level . They will be subject to a further impact assessment  
when precise actions, and their timing, will be considered as part of a possible future 
Community action. The following provides however  an estimate of thei r potential impact. 
5.2.1. No further EU action on coordination activities 
Under this option, there would be no EU-lev el intervention on DTT receivers or MPEG-
4/DVB-T2, beyond the obligations and guidelines alr eady in force. The main benefit of this 
option is the absence of compulsory  additional costs to upgrade receivers or transmission 
networks.  
5.2.2. Further coordination activities in sub-bands below 790 MHz 
(a) Preparation for a possible coordinated migr ation of DTT networks to more advanced 
transmission technologie s (e.g. MPEG-4, DVB-T2)  and ensuring more interference 
resistant DTT receivers  
This could potentially result in large efficiency  gains, illustrated for the DTT platform in the 
figure below. 
                                                 
45  This assumes that the proposed policy option to require that Member States make available the 790–
862MHz sub-band is first pursued (see 5.4. below). 
EN 31  EN Type of improvement S pecific improvement Gains compared to legacy situation (number of TV 
programming channels) 
Compression technology  MPEG-4 or better 
(instead of MPEG-2) Up to 100% (twice as many TV programming 
channels) 
Transmission standard DVB-T2 or better 
(instead of DVB-T) At least 30% 
Network topology National SFN 
(instead of MFN) Up to 300% (using two frequency channels per 
multiplex rather than the typical six). The benefits 
depend however strongly on the type of SFN and on the topology of t he Member State 
Figure 5.1: Illustration of potential im provement in DTT spectrum efficiency 
Over the next three to five years, the Commissi on could initiate research and analysis into the 
possibility of making uses of the 470–862MHz band more spectrum-efficient, and consider 
some of the following initiatives, listed below.  
► Inclusion of compression technology at le ast efficient as MPEG-4 in DTT receivers  
Recommending the inclusion of compression technology at least as efficient as MPEG-446 in 
all sold receivers (minimum efficiency standard ), in addition to the old standards ensuring 
backward compatibility47, would have two benefits compar ed to the “no further EU action 
option”: it would act as an incentive for Member States to migrate network earlier to these 
better transmission technologies, an d it could reduce the total cost  of a transition by reducing 
the number of MPEG-2 only receivers th at would need to be replaced.  
The Commission study has estimate the net benef it to be between EUR 3.6 and 8.8 billion in 
net present value over 15 years (net privat e value, or consumer and producer surplus)48. 
                                                 
46  The minimum efficiency standard is expressed by  reference to a specific existing standard only by 
default of a generic measurement scale that co uld define such a level in absolute value. 
47  In practice, virtually all MPEG-4 decoders curren tly on the market can also decode MPEG-2 signals. 
48  See detail in Commission study on "Exploiting the digital dividend – A European Approach", p. 309 to 
314. 
EN 32  EN -600-400-20002004006008001000
Increased cost for
consumers who
would have bought
MPEG-2 receiversBenefit for
consumers who
would have bought
MPEG-4 receiversReduction in costs
to replace MPEG-2
receivers during a
MPEG-4 migrationPotential benefit of
avoiding a 1 year
delay to 790-
862MHz sub-bandNPV of benefit over 15 years (EUR million)Estimated benefit 
EUR3.6-8.8 billion
-600-400-20002004006008001000
Increased cost for
consumers who
would have bought
MPEG-2 receiversBenefit for
consumers who
would have bought
MPEG-4 receiversReduction in costs
to replace MPEG-2
receivers during a
MPEG-4 migrationPotential benefit of
avoiding a 1 year
delay to 790-
862MHz sub-bandNPV of benefit over 15 years (EUR million)Estimated benefit 
EUR3.6-8.8 billion
 
Diagram of costs and benefits of including MPEG-4 in all sold DTT receivers. Source: Commission study conducted by Analysys 
Mason, DotEcon and Hogan & Hartson. 
The risk of negative social impact on consum ers who have not access to the new technology 
would be compensated by a period of so-calle d "simulcast", or a peri od during which both the 
signals in the old and new standard would be broadcast as to allow the continuation of the 
reception by those consumers with their old TV se t or set-top boxes. It is expected that, the 
future timing for a switch-off of the transmission in the older digital format would take into 
account the number of remaining older DTT receiv ers as well as the affordability of the new 
ones, and possibly of signal down-grading converter boxes.  
There would be a positive distributional effect  on Member States a dopting the MPEG-4, or 
better standard, from the introduction of DTT as  they would benefit from the lower prices 
stemming from larger economies of scale49. 
► Specification of minimum in terference rejection standards  
Specifying minimum interference rejection sta ndards for DTT receivers would improve the 
quality of TV reception and reduce the cost of other equipment operating near the TV 
frequencies since those latter could use less ex pensive interference f iltering components. The 
public consultation showed that this measur e would be almost unanimously welcomed. 
Although this may increase the cost of producing rece ivers, it is expected th at this cost will be 
largely offset by gains in economies of scale, es pecially if this action is combined with the 
inclusion of minimum compression standards. 
► The possibility of implementing na tional Single Frequency Networks   
The public consultation and other sources have indicated that the advantages and costs of 
SFNs, which vary widely under various scenario s (e.g. high power or "cellular" SFNs), are 
                                                 
49  France is a Member State that has adopted this approach as MPEG-4 will become compulsory on all 
DTT receives sold after 1 January 2010  and relative to TVs with screens larger than 51 cm in diagonal. 
EN 33  EN largely untested, and should therefore be a ssessed in more details based on practical 
experience. 
► The use of more frequency-agile wireless broadband networks 
The use of more frequency-agile systems (e.g. variable duplex technolo gy) would improve the 
efficient use of spectrum. Since there is limited incentive for individual users and/or 
equipment manufacturers to invest in research  to achieve substantial improvements in this 
domain, collective action such as research  (possibly funded by Community programmes) 
could be recommended. 
b) Cooperate at EU level over examini ng the future use of interleaved spectrum  
There is a large group of existing users of interleaved spectrum50, which mainly operate 
wireless microphones as explained before. The rearrangement of the UHF band will have a 
particular distributional impact on this commun ity, and this needs to be addressed. It is 
considered that Member States are best placed to provide the alternative capacity needed to 
ensure the continuity  of these services. 
However, in the medium to long term, furt her clearance of DTT from the 470–862 MHz band, 
would mean that wireless microphones may not have access to sufficient interleaved spectrum 
to meet demand. Exploring possibl e short-term options to migrat e these services to either 
more efficient digital technologi es or to common spectrum ba nds would enable these longer-
term issues to be addressed most effectively (more certainty for investors, new possibility for cross-border interoperability), for a limited cost  (economies of scale). There are more benefits 
to having a cooperation concerning the future use of interleaved spectrum, more particularly 
to assist in reaching a Common Position in preparation for WRC-12. 
In addition, Member States may soon consider allowing cognitive technologies to operate in 
the interleaved spectrum, following a recent decision in the US
51. If this would happen, there 
could be benefits to envisage  harmonisation at EU level as it would provide confidence to 
manufacturers and application developers. The potential value of such use of interleaved 
spectrum in the 470–862 MHz band to the EU could be EUR 20–30 billion, according to the 
study52 (mainly based on a critical review of previous studies by sectors and technology 
suppliers). 
c) Increased involvement of EU-level instit utions in cross-border spectrum coordination 
The increased involvement of EU -level institutions in cro ss-border spectrum management 
and, in particular, in negotiati ons over changes in DTT assignm ents, would have the benefit 
of reducing the risk of delays in ma king the 790–862 MHz sub-band available for new 
services. The need for EU coordination betwee n Member States may however be limited as 
bilateral and multilatera l negotiations seem to make good progress.  
Negotiations with non-EU countries  (third countries), however, may be significantly more 
difficult. Further coordination is required with several Member States to facilitate the timely 
realisation of the sub-band, as the EU coul d not impose binding measures on those non-EU 
countries. An increased involvement by EU-level  institutions in such  difficult negotiations 
would certainly be beneficial to those Memb er States who have several or large non-EU 
                                                 
50  Also called "white spaces" 
51             http://hraunfoss.fcc .gov/edocs_public/attach match/FCC-08-260A1.doc 
52  Commission study on "Exploiting the digital dividend – A European Approach", p. 77 to 80, and p.158 
EN 34  EN neighbours. The public consultation confirmed th e high interest of both Member States and 
stakeholders for such EU involve ment to accelerate negotiations. 
The cost of such a measure appears very lim ited, beyond the required staffing resources that 
must be made available. 
5.2.3  Impact of mandatory requirements to imp rove spectrum effici ency linked to the 
digital dividend 
The impact of mandatory requirements versus th e impact of "further coordination activities", 
as described in 5.2.2., varies generally in an incremental  way for each of the specific 
measures. At this moment in time, none of the measures can show a clear advantage for a 
compulsory approach at EU level. There is a need for more discus sions on the political 
relevance and feasibility of so me of the measures, for iden tifying possible Community action 
in more detail (form and scope) as well as for additional impact assessment. 
5.3. Impact of options regarding the coordina tion of Member State actions in the 790-
862MHz sub-band 
5.3.1. No further EU action 
This option would result in each Member State be ing able to adopt regulatory measures at the 
national level which can be contradictory w ith each other and which would jeopardise the 
application of the technical harmonisation meas ure that the Commission is planning to adopt 
in early 2010 with the assistance of the Radi o Spectrum Committee (RSC) and on the basis of 
the preparatory work done by the CEPT. 
5.3.2. Recommendation that Member States take no action that  would interfere with the 
technical harmonisation measure being pl anned at EU level in the 790-862 MHz 
sub-band 
Under this option, Member States will refrain fr om regulatory measure that would prevent or 
complicate low and medium-power bidirecti onal networks to use the 790-862 MHz sub-band. 
A regulatory measure at the national level could potentially complicate the application of the 
technical harmonisation measure the Commission is  planning to adopt with the assistance of 
the Radio Spectrum Committee (RSC) and on the basis of the preparatory work done by the 
CEPT. 
In addition, the Recommendation would aim at preventing the further build-up of legacy 
infrastructure in the sub-band, by requiring Memb er States to avoid th e installation of new 
(not yet planned) high power DTT transmitters in this spectrum. By doing so, the cost of 
vacating this band in the future (if decided at political level) would be significantly lower 
(reduced negative legacy). 
5.4. Impact of options regarding the tec hnical harmonisation of the 790–862MHz sub-
band 
It must be emphasised that a timely switch-off of  analogue terrestrial TV is a prerequisite for 
the use of medium/low power applic ations in the 790-862 MHz sub-band. 
EN 35  EN An important part of the Commission study cons isted in assessing the magnitude of economic 
benefits that could be derived from the digi tal dividend across the EU  over the next 15 years 
under different scenarios. These scenarios in cluded a combination of spectrum supply and 
demand situations53 ranging from: 
- Supply side : a small part of the UHF open to new services (790-862 MHz, or 18%) up 
to the entire UHF band open to new services  (470-862 MHz), and an intermediate step 
(694-862 MHz, or 42%).  
470 862 790 MHz X
Uses other than high-power DTTUses other than high-power DTT High-power DTTHigh-power DTT Uses other than 
high-power DTT
Scenario 3Scenario 1
Scenario 2
 
- Demand side : low demand for main expected se rvices (broadcasting and wireless 
broadband) to high demand for those services , with the possibility  of new unexpected 
broadband uses. 
Scenario A Scenario B Scenario C
Scenario D Scenario E Scenario FWireless broadband 
Low HighHigh with 
new use
Low
HighDTT
 Demand scenarios for 
the  
470–862MHz band [Source: Analysys 
Mason, DotEcon, Hogan 
& Hartson, 2009] 
Spectrum supply scenarios for the 470–862MHz band [Source : Analysys Mason, DotEcon, Hogan & Hartson, 2009] 
The underlying economic impact modelling used in the study was top- down (i.e. individual 
Member States are not analysed in detail) and based on (a) the evidence from previous studies on the incremental private value (i.e. consumer and producer surplus) of  the services that 
could be provided assuming the level of spect rum supply specified in each of the supply 
scenarios, coupled with (b) esti mates of the costs of network alterations or deployments and 
consumer equipment upgrades that might be re quired. This information was then used to 
quantify how differing divisions of the band am ong potential uses might translate into an 
economic value of the digita l dividend across the EU.  
The final economic benefits were  expressed in terms of incremental private value (consumer 
and producer surplus combined) for the various types of possible EU-level scenarios when 
compared to a reference scenario corresponding to be no EU coordina tion (as described in 
                                                
 
53  Commission study on "Exploiting the digital dividend – A European Approach", chapter 12 
EN 36  EN section 2.2.). These results were quantified in Net Present Value accrued over a period of 15 
years. 
The two policy options introduced in Section 4.4 above represen t progressive degrees of EU-
level intervention. 
The main conclusion of the study is that the priv ate value that could be created by all Member 
States adopting the 790-862 MHz sub-band for el ectronic communications services would be 
between EUR17 billion and EUR44 billion de pending on the assumed level of demand for 
different services as outlined above54. A conservative mean estimat e is EUR 30 to 40 billion 
(corresponding to modest DTT capacity increas e due to better compression technology and 
sustained demand for mobile and fixed wire less broadband). National studies announced even 
higher benefits 55 
This significant incremental private value of opening up the 790-862 MHz sub-band to new 
services under an EU-coordinated approach, over and above the “no further EU action” 
scenario, would accrue in the following ways: 
• cross-border interference from DTT would not occur in the 790–862MHz sub-band, 
enabling alternative services such as wire less broadband to be effectively deployed 
throughout the EU; 
• there would be benefits arising from th e single market dimension: pan-European 
interoperability and roaming, pa rticularly in terms of economie s of scale for end-user and 
network equipment. Based on Normalised Price of equipment, the Commission study 
estimated these economies at 40% of retail prices for the first 50 million users, and with additional 5% for the next 50 millions, and fina lly 1.5% more if the remaining parts of the 
EU can be subject to the same harmonised conditions of use.  
• there would be increased certainty provided to equipment manufacturers, which would 
accelerate research and development and enable services to be launched faster. During the 
stakeholders' workshop, manufacturers mentioned a minimum market of 100 million 
inhabitants as being the crit ical mass to start investing. 
There will be also significant, and positively corr elated social value, generated by the fact that 
the extent of access to broadband services will be  greater and occur ear lier than without this 
action, and through the possibility to create pa n-European interoperabi lity of services..  
The net benefits take account of the costs that will inevitably occur during the necessary 
changes to broadcasting networks. Thes e costs would primarily consist of: 
• the reorganisation of frequency assignments , which could require both changes to the 
networks as well as bilate ral negotiations with neighbour ing countries, and possibly 
equipment costs in the case of  Member States  which are likely to decide to migrate to 
more efficient DTT standards in order to mainta in  the same level of development of DTT; 
                                                 
54  Commission study on "Exploiting the digital dividend – A European Approach", details in chapter 13, 
summary results in 13.3.1  
55  For example, the study by ARCEP for the French g overnment in 2008 indicated  that a scenario that 
would ‘share’ the digital dividend between both electronic communications and audiovisual industries would add over EUR25 billion more to the French ec onomy between 2012 and 2024 than allocating the 
digital dividend exclusively to the digital TV industry. 
EN 37  EN • in specific case, broadcast networks may re quire the replacement or reorientation of 
aerials (mainly a potential issue in the UK)56.  
According to the analysis performed by the consultants, there should be no overall negative 
distributional impact on the broadcasting serv ices since any loss of broadcasting capacity in 
the 790-862 MHz sub-band should be compensa ted by network re-planning and/or improved 
transmission technology. In some case, financia l compensation of broad casters to cover these 
costs could be considered as well.  
Regarding the distributive effect on  some Member States , it is clear that costs will be 
depend on the amount of DTT transmitters located in the sub-band for each Member States. However, in all cases, Community action shoul d have a positive impact as compared to no 
action since it is likely to facilitate the reor ganisation of broadcasting networks (and lower the 
costs) as well as accelerate the realisation of the benefits in those affected Member Sates. 
Community action would also ha ve a positive impact on the speed  of the negotiations with 
third countries. As an example, as Community  action is in development, one can see a 
growing interest of third countri es in adopting a similar appro ach to the EU (e.g. Switzerland, 
Russia announcing analogue switch-off in 2015, North African countries considering the 
same sub-band for wireless communications). 
5.4.1. Guidelines (non mandatory) for the harmonisation of the 790–862MHz sub-band  
Implementing guidelines for the harmonisatio n of the 790–862MHz su b-band would provide 
a strong signal from the Commi ssion of what it considers to be the most effective way to reap 
maximum benefits from the 790–862MHz sub- band. These guidelines would be aimed at 
persuading undecided Member States to adopt the measures presented in the Communication 
and Recommendation without formal obligations. The public consultation has also made clear 
that this action is largely anticipated by stake holders and any failure to follow-up on the side 
of the Commission would create a de gree of uncertainty  in the market. 
More generally, this option is  likely to support maintaining the momentum which has been 
forming over the past few months, with De nmark, the Netherlands, Spain and the UK 
recently
57 announcing plans to clear and awar d the 790–862 MHz sub-band. This would 
unlock economic and social benefits in a larger  proportion of the EU an d increase benefits 
such as economies of scale, interoperability and roaming and increased certainty to industry, 
particularly for equipment manufact urers. As a result, parts of the identified benefit of EUR17 
billion to EUR44 billion may be realis ed (see introduction to section 5.4). 
Member States have expresse d a preference for non-obligato ry action to encourage the 
adoption of the sub-band. This is also the vi ew put forward in the RSPG Opinion on the 
digital dividend.58 Nevertheless, mere guidelines cannot  guarantee the EU-wide adoption of 
the sub-band. 
5.4.2.  Commission Decision setting the techni cal parameters of 790-862 MHz sub-band  
This policy option will reassure Member States  facing difficulties to relocate high power 
broadcasting transmitters outside of this band, and therefore increase overall acceptance to build support for the sub-band for use by electron ic communications in the foreseeable future. 
                                                
 
56  The UK is facing a particular s ituation where the operative frequency ra nge of aerials vary from region 
to region. 
57  June 2009. 
58  RSPG Opinion on the digital dividend adopted on 19 September 2009. 
EN 38  EN This will avoid fragmentation and lead to an optimal use of  the spectrum. The technical 
conditions set in the Decision will prevent the us e of high-power applications that make the 
coexistence very costly and have  a substantial cross- border impact.  However, within these 
technical conditions, any servi ce could be allowed and tec hnology and service neutrality 
principles shall apply. 
Furthermore, a common frequenc y allocation would also create greater scope for roaming for 
consumers. The cost-efficiency of providing ro aming services, particularly for wireless 
broadband is greatly improved compared to a si tuation in which consumer equipment requires 
multi-band operation. 
This policy option is likely to result in the vast majority of the calculated benefits to be 
realised (between EUR17 billion and EUR44 b illion in net present value as explained in 
introduction to section 5. 4 and detailed the study). 
The Commission expects mobile broadband servi ces to be deployed in this band. The ITU 
gave a co-primary allocation to mobile serv ices in this sub-band. The CEPT measure (ECC 
Decision) on the 790-862 MHz sub-band is also ad apted to mobile servi ces. The availability 
of mobile broadband is a key cond ition to achieve the EU social  objectives, incl. bridging the 
digital divide. All recent studies predict that  UMTS or LTE are expected to be the most 
valuable uses of the sub-band. The sub-ba nd 790-862 MHz should be also open to other 
services that meet th e technical conditions set in the Decision. 
If the sub-band was to be awarded under common technological conditions and a common 
band plan, this would remove the uncertain ty on channelling arrangements, and hence on 
detailed spectrum planning for coping with inte rference, but at the expense of service and 
technology neutrality. It woul d require that all Member States award the 790–862 MHz sub-
band exclusively for wireless broadband serv ice, following common technological conditions 
and a common band plan (channelling arrangement).  This would be the surest way to secure 
the full benefits calculated by the study conducted by the consortium for the Commission. 
5.4.3.  Commission Decision setting the tec hnical parameters and setting a mandatory 
end-date for clearing th e 790-862 MHz sub-band of broadcasting (high-power) 
services 
While the absence of an end-date for clea ring the 790-862 MHz sub-band in the above 
measure could lead to an uncertainty in the EU single market due to different speeds of 
implementation in different Member States, it is important to take into account the 
sensitivities of Member States on this issue, mainly due to different switch off speeds and 
different legacy situations  regarding broadcasting.  
Seeking to set that date in th e current situation c ould be counter-produc tive and could give 
rise to greater uncertain ty. If the Commission were to set an end-date, it is not sure whether 
all Member States would support su ch a measure. Furthermore, it is likely that a number of 
Member States would apply long transitional peri ods. Economies of scale could not be reaped 
and spectrum could not be used  in the most efficient way. 
Therefore, while it will be necessary at so me point to fix a date beyond which the 790-862 
MHz sub-band should be used excl usively by medium- to low-power  services, in view of the 
importance of the matter and the politic al sensitivities outlined above, the European 
Parliament and the Council could discuss the matter and propose an end-date in the 
context of a Commission proposal under the Radio Spectrum Policy Programme in due 
EN 39  EN course. This would allow due account to be take n of the development of broadcasting services 
and would carry greater  political support. 
EN 40  EN 6. C OMPARISON OF OPTIONS  
6.1. Comparison of options regarding the ti mely completion of  analogue switch-off 
Figure 6.1. below summarises the benefits, costs a nd risks of requiring all Member States to 
switch off analogue broadcasting before 1 Ja nuary 2012, compared to the “no further EU 
action” baseline.  
Option Benefits compared to the “no 
further EU action” option Costs compared to the “no 
further EU action” option Risks 
1. No further EU 
action Not relevant NA. There are however 
some costs associated with the prolongation of simulcast (the parallel transmission of the same TV programmes in analogue and digital format) and an opportunity cost (see risks). There is an indirect opportunity 
cost due to the delay in allowing the 800 MHz band to be used by electronic communications services. This cost of delaying potential benefits is estimated at min. EUR 1 billion in net present value over 15 years for any one year of delay of the switch-off date. 
2. Recommendation that Member States take all necessary steps to switch-off analogue signals by 1 January 2012 (except those that have already switched-off) Increased pressure on some 
Member States to comply with the 2012 deadline ("momentum" effect on all stakeholders). 
Increased certainty as to the 
availability of the digital 
dividend by 1 January 2012. 
Increased probability that 
some Member States will award the 790–862MHz sub-band earlier than would otherwise have been the case. case (which has a potential benefit of between EUR1 billion and EUR10 billion in net present value over 15 years, in conjunction with other measures that aim to avoid delays in the availability of the sub-band). Additional implementation 
costs for Member States that have planned analogue switch-off for after 1 January 2012. 
Spectrum may remain 
unused before 2015 
(because of neighbouring countries outside the EU). Some consumers in vulnerable 
groups may not be adequately prepared for analogue switch-off by 1 January 2012 if the initial deadline was initially set for a later date. This risk can however be mitigated by considering adequately the special cases occu rring only in 
a limited number of Member Sates, including the possibility of state subsidies aimed at these socially-weak groups (the conditions for such subsidies have been clarified by the Commission). 
3. Mandating analogue switch-off by 1 January 2012 (a Community legal measure). No residual analogue 
transmission after 1 January 2012, legally enforced by a Community measure. Additional implementation 
costs for Member States that have planned analogue switch-off for after 1 January 2012. 
Spectrum may remain 
unused before 2015 (because of neighbouring countries outside the EU). Threat of cutting-off analogue 
TV viewers that had not been re-equipped in appropriate time. 
Figure 6.1: Comparison of options regardi ng advancing the analogue switch-off deadline 
EN 41  EN Although the costs mentioned above are limited to those maximum11 Member States for 
which analogue switch-off would have taken pl ace after 2012, the benefits  would actually be 
realised across the EU, partic ularly in neighbouring Member  States. The options 2 and 3 
could help accelerating the adoption of the 790–862 MHz sub-band by a few months across 
the EU, thereby creating significa nt value (see Section 1.1), this compared with estimates for 
the cost of a one-year delay of EUR 1 to EUR 10 billion as explained in section 5. 
6.2. Comparison of options regarding the ac hievement of the optimal use of spectrum 
in the UHF band (470-862 MHz) 
Figure 6.2 below summarises the benefits, costs and risks of possible further measures to 
increase spectrum efficiency. 
Option Benefits compared to the “no 
further EU action” option Costs compared to the 
“no further EU action” 
option Risks 
1. No further EU 
action on 
coordination activities NA NA Additional spectrum can 
not be made available to 
new uses. The digital dividend is minimised. 
2. Further 
coordination activities 
in sub-bands below 790MHz  EU able to react if additional 
spectrum is needed for new 
uses. High level of certainty to market players. Acceleration of the creation of a further digital dividend. 
Reduced costs for realising 
additional spectrum efficiency.  Additional regulatory 
burden to upgrade 
receivers. Cost of progressively replacing MPEG-2 receivers in the 15 Member States that currently use only MPEG-2 (The costs of replacing old DTT receivers should however be more than compensated by preventing more legacy devices from a certain date, and by lower costs due to economies of scale). Detriment to some 
suppliers and consumers 
who would incur those costs sooner than anticipated. 
3. Mandatory 
requirement to 
improve spectrum efficiency linked to the digital dividend Strong EU action to improve 
spectrum efficiency. 
Technology-neutral   specifications allow for flexibility in technology choice. 
Possible competitive 
advantage for the EU as a result of innovation in media industry (not assessed). Costs of migrating to 
mandated specifications. 
Costs of replacing old 
DTT receivers. Detriment to some 
suppliers and consumers 
who would incur those costs sooner than anticipated. Risk of picking specifications that are overtaken by further technological advances. 
Figure 6.2:  Comparison of options regarding ot her measures to increase spectrum efficiency 
Option 2, further coordination activities, and es pecially the collaboration between Member 
States to share future broadcasting network de ployment plans (e.g. migration to MPEG-4 or 
DVB-T2) and possibly the deployment of more Si ngle Frequency Networks  (SFNs) will lead 
to an increased efficiency of the use of spectrum below 790 MH z. This option will pave the 
way for a further digital dividend, while providi ng sufficient flexibility for Member States. 
Option 3, the mandating of minimum technology-ne utral specifications in  all DTT receivers 
EN 42  EN would provide more certainty to manufacturers and increased economies of scale over time, 
but still run the risk of being too closely associated with a cu rrent set of technologies that 
become outdated or are overtaken by  further technological developments. 
6.3. Comparison of options regarding the co-o rdination of Member St ate action in the 
790-862 MHz sub-band 
Figure 6.3 below summarises the benefits, cost s and risks of each of  the policy options 
compared to the baseline that can be achie ved by implementing the pr eferred option for the 
ensuring that Member States do not take acti on that would interfere with a co-ordinated 
approach in the 790–862 MHz s ub-band throughout the EU.  
Option Benefits compared to the 
“No further EU action” 
option Costs compared to the 
“No further EU action” 
option Risks 
1. No further EU action NA  NA The application of the 
technical harmonisation measure on the 790-862 MHz sub-band would be jeopardised. 
2. Recommendation that Member States apply a co-ordinated approach in the 790-862MHz sub-band  Eased harmonisation at the 
EU level of technical conditions for the use of the sub-band. 
Creation of an EU 
momentum increasing the 
chances of more Member States adopting the sub-band, and hence accelerating the availability of the band in some Member States that are already considering moving in this direction. 
It would also allow more  
Member States to unlock the benefits of the expected services. High-power networks 
would not be allowed in the 790-862 MHz sub-band from a certain date (to be approved at political level). 
Costs (if any) for Member 
States not being able to 
deploy high-power networks in the 790-862 MHz sub-band. Some Member States 
might not respect the recommendation, undermining the overall impact of the initiative. 
Figure 6.3: comparison of options regarding the preserva tion of a co-ordinated approach in the 790-862 MHz sub-band  
The application of the technical harmoni sation measure on the 790-862 MHz could be 
jeopardised in the absence of EU action ensuring  that Member States respect a co-ordinated 
approach. The major benefit of this option is that high-power networks  would not be allowed 
in the 790-862 MHz sub-band which would f acilitate the technical harmonisation. 
6.4. Comparison of options regarding the technical harmonisation of the 790-862 
MHz sub-band 
Figure 6.4 below summarises the benefits, cost s and risks of each of  the policy options 
compared to the “no further EU action” baseline. 
EN 43  EN Option Benefits compared to the 
“No further EU action” 
baseline Costs compared to the 
“No further EU action” 
baseline Risks 
1. Guidelines for the 
harmonisation of the 790-862MHz band Increased probability that 
more Member States adopt the sub-band. Negligible Negligible. See comments 
in section 1. 
2. Commission Decision setting the technical conditions for use of the 790-862MHz band Increased probability that 
more Member States adopt the sub-band. 
Certainty of release of 
spectrum in the 790–862MHz sub-band on the longer term. 
Highly increased probability 
of realising benefits of 
EUR19 to 46 billion in net present value over 15 years. Increased potential for 
legal action against NRAs’ decisions. 
Costs of increasing the 
efficiency of broadcast networks and reorganising transmission, of between EUR2 and EUR4 billion in net present value over 15 years. Negligible for most EU 
Member States. See comments in section 1. 
It must be however noted 
that the outcome in Member States at the edge of the EU is dependent on their non-EU neighbours adopting a similar approach. 
3. Commission 
Decision setting the 
technical conditions and setting a mandatory end-date for clearing the 790-862 MHz sub-band of broadcasting (high-power) services Removing uncertainty in the 
EU single market due to a 
fragmented situation in a number of Member States. 
Further likelihood of 
realising the benefits outlined under option 2. Additional costs for 
Member States that have 
not initially planned to use the band for other services than broadcasting. Implementation delays by 
Member States due to 
different switch off speeds and broadcasting situations. 
Difficulties in coordinating 
an EU-wide plan for clearance of the sub-band with neighbouring third countries. 
Figure 6.4: Comparison of options regarding the te chnical harmonisation of the 790-862 MHz sub-band  
The costs of implementing non-obligatory guidelines  in option 1 are likely  to be very modest, 
but would not significantly increase the li kelihood of achieving the major benefits of 
harmonisation. There would be a risk of a long term, difficult to reverse, fragmentation if 
early movers would adopt (even sligh tly) different technical specifications. 
Requiring Member States to make the 790–862 MHz sub-band available, is likely to increase 
the probability of achieving the benefits of ha rmonisation. The major bene fit from setting an 
end-date at the EU level for clearing the 790-862 MHz sub-band woul d be the removal of 
uncertainty in the single market caused by a frag mented situation in many Member States. As 
mentioned under 6.1, Member States that have not already carried out analogue switch-off 
might incur some costs, but such costs would be  offset by economies of scale and by efficient 
use of spectrum.  
Seeking to set a mandatory end-date immediatel y could be counter-produ ctive and could give 
rise to uncertainty. If the Co mmission were to set an end-date , it is not sure whether all 
Member States would support such a measure. Furthermore, it is likel y that a number of 
Member States would apply long transitional peri ods. Economies of scale could not be reaped 
and spectrum could not be used in the most  efficient way. Therefore, while it will be 
necessary at some point to fix a date be yond which the 790-862 MHz sub-band should be 
used exclusively by medium- to low-power servi ces, in view of the importance of the matter 
and the political sensit ivities outlined above, the European Parliament and the Council could 
EN 44  EN discuss the matter and propose an end-date in the context of a Commission proposal under the 
Radio Spectrum Policy Programme in due course.  
In summary, the more beneficial option at this point in time, and which satisfies 
proportionality requirements appears to be option 2, i.e. to require that  all Member States 
apply the same technical conditions when ch anging the designation of the 790-862 MHz sub-
band from the current designation for broad casting, recommending that awards be conducted 
on a technology and service-neutral basis w ith common technological conditions and a 
common band plan. 
Any later proposal by the Commission to introd uce a common deadline for implementation of 
the technical harmonisation decision of th e 790-862 MHz sub-band will be subject to a 
specific and more detailed evalua tion of impact of that specifi c measure, in particular its 
possible distributional impact on business sectors, groups of ci tizens or specific regions. 
 
EN 45  EN 7. E VALUATION AND MONITORING  
The link between the use of the digital dividend in Member States and its social and economic 
impact across the economy, either in specific app lication areas, or in structural change is too 
complex for aggregate measures of impact to be used as indicators of the effectiveness of the measures considered. It  is therefore proposed to base the evaluation and monitoring on the 
operational objectives  in the specific areas of focus. 
Special attention will be paid to assessing progress in the thre e main areas addressed i.e.:  
• The timeliness of measures taken in Member States for ensuring the complete switch-off 
of analogue TV by 1 January 2012; 
• The progress in making th e 790-862 MHz sub-band av ailable for electronic 
communications under harmonised techni cal condition in Member Sates; 
• Progress in migrating to "best in class" t echnologies for the transm ission of terrestrial 
broadcasting signals. 
Specific indicators which will be updated regularly will include the following: 
• Percentage of EU territory and/or population where the di gital broadcasting switchover 
has been completed; 
• Coverage of rural areas by mobile broadband; 
• Availability of new services pr ovided in the 790-862 MHz sub-band; 
• Percentage of sold DTT rece ivers ready to process transmission compression standards at 
least as efficient as MPEG-4 AVC/H.264; 
• Availability of minimum common standards for interference rejection on DTT receivers; 
• Number of Member States having implemented  the harmonised technical conditions of 
use for the 800 MHz band and the evolution of the prospect for an EU-wide implementation in the future; 
• Percentage of broadcasting networks us ing the first generation of DVB-T/MPEG2 
standards versus those using a next generation of more efficient transmission standards (at 
least as efficient as MPEG4 AVC/H.264); 
• Progress on a common position on the possi ble use of "white spaces" in Europe; 
• Availability of clear plans at Member Stat e level and/or at EU level to ensure the 
continuity of legacy services such as wireless microphones.  
From a more fundamental viewpoi nt, dealing with the evolving na ture of the di gital dividend 
issue will be a "dynamic" process: developmen ts in technology, services, market demand and 
societal requirements will require that the ac tions established under the roadmap evolve in 
parallel. Particularly relevant factors of uncertainty  which will have to be monitored are: 
• the extent of consumer take -up of HDTV on the terrestrial platform in the future, 
compared to the take-up on other platforms such as satellite and IPTV on broadband 
networks (in particular in an NGA context); 
EN 46  EN • a higher growth of broadband wireless usage leading to a spectrum bottleneck59; 
• the emergence of unforeseen additional broa dband uses which would require access to 
more spectrum below 1 GHz, for example public service uses such as Public Protection and Disaster Recovery (PPDR) or public security; 
• the pace of introduction of new technologi es: new transmission compression standards, 
new frequency agile technologies and their abi lity to take advantage of the white spaces; 
• the possibility to create synergies with othe r regions of the world in the light of not 
foregoing the chance to benefit from poten tially world-wide economies of scale. 
To address these evolutions, the Commission will propose to establish a mechanism to 
monitor external developments affecting the roadmap, using where possible existing 
structures and contact networks. The collection of data for that purpose should be performed 
through access to sector-specific statistics, data collected in the context of the work in 
relevant EU policy areas (e.g. broadband penetr ation, broadcasting serv ice take-up) and other 
appropriate sources. In additi on, the Commission may launch addi tional studies and/or task 
the Communications Broadcast Issues Sub- group (CBISS) of the Communication Committee 
(COCOM) and/or the Radio Spectrum Policy Group (RSPG) to assess progress if required. 
The Commission further proposes to report on any need to review elements of the roadmap to 
the European Parliament and Council at least once every two to three years. This reporting 
would include changes in forecasts for spectru m demand and identify any future need for 
making further spectrum availa ble on a co-ordinated basis. 
                                                 
59  This has also been identified by the RSPG in its Position Paper on wireless broadband (Document 
RSPG09-284 adopted on 13 May 2009). 
EN 47  EN  
Annex A:  Glossary of abbreviations used in the IA report 
 
CEPT  European Conference of Postal a nd Telecommunications Administrations  
DTT  Digital Terrestrial TV DVB-T Digital Video Broadcasting - Terrestrial ECC  Electronic Communications Committee ECO  European Communications Office FCC  Federal Communications Commission FDD  Frequency Division Duplex 
GE-06  Geneva 2006 frequency plan   
HDTV  High-Definition TV ITU  International Telecomunication Union MFN  Multi Frequency Networks MPEG Moving Picture Experts Group (ISO st andard for audio and video compression 
and transmission) 
RSPG  Radio Spectrum Policy Group SAB/SAP Services Ancillary to Broadcasti ng/Services Ancillary to Programme making 
SFN  Single Frequency Networks PMSE  Programme Making and Special Events  PPDR  Public Protection and Disaster Relief TDD  Time Division Duplex UHF  Ultra High Frequency (band) UMTS  Universal Mobile Telecommunications System   
WAPECS Wireless Access Policy for Electronic Communications Services WRC  World Radiocommunication Conference