Europe’s unique audiovisual model sustains its creative and cultural sector’s economy and jobs. It is a huge asset for Europe’s competitive position in the digital world, cultural diversity and media pluralism.

The creative and cultural sector, acknowledged as a leading employer and value driver in Europe, deserves a strong industrial strategy that reinforces the pillars it rests on. Spectrum allocation is one of those pillars. Free-to-air TV, live performance and radio make available to the general public local, diverse and plural European works and information.

The Lamy report[1], amongst others[2], made explicit the need for a change of mindset from platform convergence to co-existence[3]. This in order to meet different consumer expectations, support Europe’s cultural diversity, support original content creation, promote media pluralism and sustain the development of an inclusive audiovisual, radio and live performance sectors. The broadcasting and live performance sectors have co-existed for decades and can be taken as an example. European leaders have called for a fresh start for growth and jobs[4], resting on investments surpassing €300 billion and a priority on Digital.

The cultural, creative and media industries are an essential pillar of the digital economy and one of the key assets of Europe Digital Single Market Strategy, in every dimension: 

•    Accounting for 6.8% share of GDP (€860 billion) and 6.5% of Europe’s employment (approximately 14 million direct and indirect jobs)[5];
•    Combining the forces of flagship European-based companies competing in a global market alongside more than 1.4 million small and medium sized enterprises[6] (who generate over 80% of the total revenue for the sector); 
•    Employing a highly skilled, non-offshorable and well-educated workforce that is deeply rooted within local territories, economies and cultures;
•    Creating and investing in digital platforms in technological innovations; Europe's digital market for cultural products and services are providing more and more choice to consumers.


European enterprises and employees from the creative and cultural industry stand together at the forefront of Europe’s fresh start to provide more growth and jobs for Europeans. A fresh start based on:

  • A vision for its future digital economy and society that integrates all existing components to optimise opportunities and potential rather than drive fragmentation and conflict between sectors and players;

  • A strategy that embraces cultural diversity and pluralism as valuable assets in the EU;

  • A commitment to enshrine fair access and support for creation, innovation and finance.

EU policy-makers in close consultation with all stakeholders and civil society need to define a European industrial policy, which will recognise the cultural, creative and media industries as a growth enabler for Europe and as a key component of European construction. This means policies that:

  • Acknowledge the business, investment and funding[7] models for the works produced; including content creation, distribution and licensing models that ensure sustained levels of efforts and investments in content from employees and enterprises; and infrastructure investments to spark innovations that meet evolving EU audience expectations;

  • Uphold the importance of local/national works[8] as supporting European employment, diversity and plurality with a thorough consideration of the added value these industries, driven by broadcasting and live performance sectors, create through contextualising works[9] and investing[10] for citizens;

  • Enshrine guaranteed access to critical resources such as spectrum for services that enable and sustain Europe’s creative and cultural industry, to maintain free-to-air as a capacity for citizens to participate in the public discourse, have choice and preserve their local identity.

 Europe’s preference - Low cost, accessible, local, reliable, regulated, plural

250 million Europeans choose television via the digital terrestrial television (DTT) broadcasting platforms as one of their preferred means of media consumption. 80% of the EU population listens to the radio for 2 to 3 hours a day, mostly through broadcasting (analogue and digital). Traditionally and increasingly PMSE[11] equipment  such as wireless microphones, in-ear monitors and cordless cameras – is used to create this content for broadcast and in live performance.

Television and radio are the most intimate, most trusted and most economic rational means to address the reality of national identities and to uphold Europe’s unique, comprehensive and virtuous model. This model spreads the production base across Europe creating jobs and growth. Broadcasting platforms, and in particular DTT and radio platforms, will continue to play a crucial role in delivering linear broadcast content to European citizens.  

This diversity of supply ensures a diversity of choice to Europeans allowing for platform competition, innovation and investment over the long-term. Reducing spectrum for content creation and terrestrial broadcasting has far-reaching consequences beyond just arbitrating between broadcasting and mobile. Moving away from DTT would result in a loss of €38.5 billion to the EU economy[12] before any account of losses to the creative sector.

The current debate has pitched mobile services against terrestrial broadcasting when in reality these services should be seen as complementary and supporting different needs.

Mobile services ensure one-to-one communications (phone calls, mobile internet...). Terrestrial broadcasting is indispensable for spectrum-efficient one-to-many transmissions (free-to-air TV and radio, coverage of major live events, emergency communications...). The latter makes the platform more cost effective and self-sustaining due to the economies of scale involved with equal quality.

While the European Creative sector is a leader in creating and distributing contents in linear and non-linear modes to a variety of devices, the concept of convergence of network is not supported by a compelling business case   and innovation for LTE-Broadcast can be experimented at European scale in the already harmonized telecommunication bands  without stifling innovation for terrestrial broadcasting and threatening the existence of special events and live performance.

Europe’s broadcast industry has scale and can invest to deliver high impact / quality cultural and creative works.

Scale is manifested in reach, coverage of the service, which enables low cost delivery of media works on consumer devices affordable to all. Scale raises advertising income enabling more money to be re-invested in cultural oriented creation and national / local distribution.

The benefits of terrestrial broadcasting are recognised in European law as an integral part of the general interest.

More specifically as promoting “social, regional or territorial cohesion” and “cultural and linguistic diversity and media pluralism”[13]. For many European countries, no terrestrial broadcasting would equate to significantly weakening this general interest objective with the loss of the national media industry and no production of local works and hence jobs.

The 2015 World Radio Conference in Geneva, and the overwhelming majority of nations who expressed their support to maintain the present UHF allocation to broadcasting, has shown that Europe can have its own way to express leadership.  WRC15 can be a milestone for European policy-makers to bring about an industrial policy that will:
1.    Position creative and cultural industries at the heart of Europe’s Digital Single Market objectives
2.    Guide new and sustain existing investments to increase certainty for employers, employees and the public alike as well as to maintain innovation, plurality and cultural diversity
3.    Take decisions on critical resources such as spectrum allocation on the basis of a comprehensive examination of the impact on cultural and creative sector growth and jobs, particularly the context of the ongoing discussion regarding use of the UHF band in the EU and regarding the upcoming Telecom Package review.

It is urgent to adopt a wider vision, an industrial strategy, and a fresh start for Europe!

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1 Pascal Lamy, Report to the European Commission, Results of the work of the high level group on the future use of the UHF band (470-790 MHz), September 2014

2 See recent RSPG opinion and ECC report 224

3 Co-existence' in the sense of simultaneous deployments of terrestrial broadcasting and mobile broadband platforms.   

4 Jean-Claude Juncker, My priorities, Priority 1 “put policies that create growth and jobs at the centre of the policy agenda of the next Commission”

5 Laurent Benzoni and Philippe Hardouin, The economic contribution of the creative industries to EU GDP and employment - Evolution 2008-2011, Paris, September 2014

6 Idem

7 For example, recognising public contributions as well as advertising revenues’ key role in funding content in Europe, especially for media; e.g., almost 100% of commercial radio revenues come from advertising, and up to 90% for commercial free-to-air TV

8 Dr Alice Enders, The value of territorial licensing to the EU, October 2013

9 Pr Olivier Bomsel, Why territories matter, October 2013, “’contextualisation’ [...] is a complementary good that enhances the meaning value of the copyrighted expression”

10 Enders on conclusions of AVMS 2011- Final Study Report - 13 December 2011, “every euro of net broadcaster revenue funds 54 cents of investment, of which about 29 cents to mainly national works”

11 Programme Making and Special Events / SAP/SAB (radio microphones, wireless “in ear” monitor system, and wireless communication systems)

12 Aetha study, Future use of the 470–694MHz band, October 2014

13 Electronic Communications Framework Directive, 2009/140/EC, 2009

14 The Radio Spectrum Policy Program (RSPP) defines common policies within the European Union