We appreciate the opportunity to comment on the draft RSPG opinion on a 6G spectrum roadmap, which addresses the prospect for 6G in the band 470-694 MHz band in point 10.
The first and most recent RSPG report listed in the draft opinion is the RSPG 25-033 report “Assessment of future usage of the frequency band 470-694 MHz within the EU”, published end 2025. The UHF report highlights important facts
“The data clearly show that use of the 470–694 MHz band in the EU is currently dominated by DTTB and PMSE, and most of the regulators do not anticipate any significant change to this situation.” (page 10)
“The majority of EU countries currently have no plans to refarm the UHF band.” (page 11)
“The majority of the regulators who replied are not currently considering the possibility to introduce additional services in the 470-694 MHz band” (page 10).
“A majority of MS indicate a requirement to use the entire 470-694 MHz band for audio PMSE over the course of the next decade.” (page 4)
The Wider Spectrum Group is surprised that none of those facts, which reflect the views of countries, administrations and regulators, are mentioned in the draft 6G opinion. This gives the impression that point 10 reflects only the viewpoint of some stakeholders, while prejudging the outcome of a complex process regarding specific discussions on the 470-694 MHz band and ignoring any impact on the incumbents of that essential band. This disrupts the balance of the draft 6G opinion in that respect.
The asks of the Wider Spectrum Group are the following:
- For fairness, balance and consistency, the final opinion should acknowledge the limitations to be expected in the majority of EU Member States for 6G use of the 470-694 MHz band, as outlined in the RSPG Report on UHF.
- In light of these findings, the final opinion should clarify that the 470-694 MHz band is not a suitable option for 6G in Europe, at least for the foreseeable future, because it cannot be implemented in a harmonized way in the majority of EU Member States.