Assessment of
socio-economic
aspects of spectrum
harmonisation
regarding wireless
microphones and
cordless videocameras (PMSE
equipment)
FINAL REPORT
A study prepared for the
European Commission DG
Communications Networks,
Content & Technology
Digital
Agenda for
Europe
This study was carried out for the European Commission by
Pierre Hausemer, Richard Womersley, Adam Parkinson, Andrew Burrage,
Pawel Janowski
Internal identification
Contract number: 30-CE-0521509/00-65
SMART number: 2012/0019
FINAL REPORT
A study prepared for the European Commission
DG Communications Networks, Content & Technology
DISCLAIMER
By the European Commission, Directorate-General of Communications Networks, Content & Technology.
The information and views set out in this publication are those of the author(s) and do not necessarily
reflect the official opinion of the Commission. The Commission does not guarantee the accuracy of the data
included in this study. Neither the Commission nor any person acting on the Commission’s behalf may be
held responsible for the use which may be made of the information contained therein.
ISBN 978-92-79-30563-4
DOI: 10.2759/18518
© European Union, 2013. All rights reserved. Certain parts are licensed under conditions to the EU.
Reproduction is authorised provided the source is acknowledged.
2
ABSTRACT
The objective of this study is to assess the socioeconomic impacts of different policy options
currently being considered by the European Commission to provide a long-term sustainable
solution to spectrum access for PMSE equipment.
The study focuses on wireless microphones/IEMs and cordless cameras. The scope of the
analysis is determined by the requirements of the European Commission’s Impact Assessment
process. For each type of equipment, the report sets out the baseline situation and spectrum
access challenges, including market fragmentation, lack of sufficient spectrum and uncertainty
regarding future availability of spectrum.
Regulatory initiatives to address these challenges include common tuning ranges and (for
microphones) harmonised frequencies defined at EU level. The study presents the impact of
each type of initiative on users, manufacturers and regulators.
The results show that the concept of common tuning ranges at EU level enjoys widespread
support among the PMSE community and that an intervention to adopt such tuning ranges
would be cost-beneficial. The study also highlights the need for further research to identify
suitable frequency ranges that could be made available for cordless cameras on a shared basis.
3
EXECUTIVE SUMMARY
The objective of this study is to assess the socioeconomic impacts of different policy options
currently being considered by the European Commission to provide a long-term sustainable
solution to spectrum access for PMSE equipment. The study focuses on wireless
microphones/IEMs and cordless cameras
In order to assess the impacts of different policy options proposed by the European
Commission, it is necessary to have a conceptual understanding of the socioeconomic value of
PMSE which the policy options may affect. There is a wide range of estimates regarding PMSE
use in Europe. First, estimates of the number of users of PMSE vary between approximately 5
million within Europe (CEPT, 2009) and about 10 million with 8 million daily users (APWPT,
2012). This compares with an estimate of about 2m wireless microphones currently in operation
in Europe (adapted from PAMA). Second, in terms of scope the report identifies three levels at
which PMSE creates socio-economic value. These include:



primary value of PMSE (i.e. economic value to manufacturers, users and regulators of
PMSE equipment);
secondary value of PMSE (i.e. economic and social value that accrues as a direct result
of different types of PMSE equipment use, such as the value of event quality and
frequency for audiences); and
tertiary value of PMSE (i.e. economic and social value experienced by stakeholders
who are not directly using PMSE equipment, e.g. hotels and restaurants next to
theatres, the societal “value of culture”, etc.)
The primary use of the broadest definition lies in setting out the broad types of impact that
PMSE can have and the diversity of stakeholders affected. The mid-level definition includes the
PMSE industry, users and regulators and consumers of programmes and events delivered
using PMSE applications (e.g. audiences). This level takes into account the value of PMSE as a
content catalyst. At the same time, it presents the problem of what share of the value of content
can be attributed exclusively to the use of PMSE equipment. The narrow scope is limited to
manufacturers who sell the technology, the users who purchase/use it, and regulators. This
narrow focus, though it does not capture the full value of PMSE, is the starting point for the
economic analysis in this report which focuses on defining the relative cost-benefits of different
EU level initiatives to feed into a European Commission Impact Assessment.
Total wireless microphone turnover in the EU in 2011 can be estimated at approx. €170m and
260,000 units/systems. Every year in the EU, approx. 13% of the 2 million units in operation
would be bought new and the remaining 87% would be old units. This in turn means that
wireless microphones would be exchanged approximately every 8 years. European companies
are very prominent among the key players on the wireless microphone market. User demand for
PMSE equipment is experiencing a continuous upwards trend with growth rates between 4 and
7% per year.
There is limited information on the total market size for cordless cameras but the EU market for
broadcast services is estimated to be approximately €64.4m. In addition to manufacturers, hire
firms are important market players in the cordless camera sector. The high costs of cordless
camera systems mean that users opt to hire such systems. Assuming an average price per
system of approx. €25,000 and using the working estimate of market size yields a figure of
4
approx. 1,300 units sold. Cordless camera receivers and transmitters are currently produced by
a small number of highly specialised companies but there is an expectation that the cordless
camera market will see substantial growth of around 4% per year.
From a European perspective, there are three key problems with respect to spectrum access for
PMSE equipment across the EU:
 Market fragmentation
 Lack of sufficient spectrum; and
 Uncertainty about future availability of spectrum
Lack of sufficient spectrum and uncertainty about future availability of spectrum are the key
issues from the perspective of users and manufacturers.
In response to these challenges, the study considers the following regulatory initiatives: do
nothing at EU level, specify a set of EU level common tuning ranges and (for microphones)
identify harmonised frequencies for wireless microphone use at EU level.
The tables below summarises the results of the analysis on the basis of a stakeholder survey,
consultation of existing literature and interviews with several stakeholder groups. Both tables
present the impact of each option compared with the default option (do nothing).
Table 1- Appraisal of options for wireless microphones
Option
Option 1
(do nothing)
Option 2
(common tuning
ranges)
Option 3
(harmonised
frequencies)
Impact
compared with
do-nothing
€ 75,562,000
Qualitative assessment (survey)




Majority of users would like to see some EU level intervention
Option 3 has highest regulator, manufacturer & user approval
Option 3 has stronger opposition than option 2
Option 2 is the least controversial option
€ 44,422,000
For wireless microphones, the results indicate that the aggregate impact on users is significantly
higher than impact on the other stakeholder groups and policy option 2 (tuning ranges)
represents the most cost-beneficial policy option on aggregate level.
Table 2 - Appraisal of options for cordless cameras
Option
Option 1
(do nothing)
Option 2
(common tuning
ranges)
Impact compared
with do nothing
€ 2,055,000
Additional qualitative assessment (survey)





Option 2 preferred by regulators
Insufficient information from manufacturers
Majority of users prefer option 2
Lack of clarity over the content of the option
40MHz not considered sufficient
The results indicate that option 2 is the preferred option on an aggregate level. However, to
yield maximum benefits, option 2 would need to be further specified in terms of the most
suitable frequency bands to be made available on a tuning range basis. This could be done
5
through a targeted consultation with stakeholders (primarily users) or through further research
regarding technical feasibility.
The concept of common tuning ranges at EU level that set a minimum amount of spectrum to
be made available for PMSE enjoys widespread support among the PMSE community.
An intervention to adopt such tuning ranges would be cost-beneficial for both cameras and
microphones. This conclusion is supported both by the quantitative analysis (i.e. option 2 is
most cost-beneficial for both types of equipment) and by the qualitative assessment (this option
is least controversial across different stakeholder groups). In the case of wireless microphones,
option 2 leaves greater flexibility in terms of the precise frequency bands to be made available
than option 3 (which specifies specific harmonised bands). This is particularly important for
professional users, for whom the quality of spectrum in the duplex gaps is insufficient.
In both cases additional research has been carried out to ensure that the common tuning
ranges that are specified correspond with technical feasibility requirements. For cordless
cameras, issues of technical feasibility are currently being investigated by CEPT. For wireless
microphones a technical assessment has been conducted and this should be taken into account
in any eventual initiative by the Commission. It is important to take into account stakeholder
comments not just on the amount of spectrum made available for PMSE but also its quality and
appropriateness for different types of uses.
At the same time, all stakeholder groups considered that the amount of spectrum for each of the
options in this study is insufficient and significant additional spectrum would need to be made
available at national or EU level to allow the industry to continue to operate. Rather than seeing
the options in this study as comprehensive solutions to the spectrum issues faced by the PMSE
industry, they should be seen as a strategic starting point in negotiating future changes from the
status quo. There is now a need to establish a process for refining the options in line with the
present cost-benefit analysis and stakeholder comments.
6
Table of Contents
1.0
Introduction and objectives
8
2.0
Conceptualising the value of PMSE
10
2.1
2.2
2.3
Challenges in determining the value of PMSE
Users of PMSE
Three perspectives on the scope of PMSE
10
10
11
Baseline and problem definition
16
3.0
3.1
3.2
4.0
4.1
4.2
5.0
Overview of the current market for wireless microphones & cameras 16
Spectrum access issues faced by PMSE
26
Definition of the policy options
35
Options for wireless microphones and in-ear monitors
Options for cordless cameras
35
37
Descriptive impact analysis
39
5.1
Description of literature
5.2
Survey results
5.2.1 Overview of user survey
39
41
42
5.2.2 Overview of manufacturer survey
5.2.3 Overview of regulator survey
49
52
6.0
Quantitative impact modelling
55
Wireless microphones
Cordless cameras
Sensitivity testing
55
63
66
Options appraisal and recommendations
68
7.1
Wireless microphones
68
7.2
7.3
Cordless cameras
Recommendations
68
69
6.1
6.2
6.3
7.0
Annex 1: Impact modelling methodology
70
Annex 2: Glossary of terms
76
Annex 3: Example of number of links by event
77
Annex 4 – Qualitative impact of excluding 700 MHz band
78
7
1.0
Introduction and objectives
This document is the final report of the assessment of socio-economic aspects of spectrum
harmonisation regarding wireless microphones and cordless video-cameras (PMSE equipment).
The objective of this study is to assess the socioeconomic impacts of different policy
options currently being considered by the European Commission to provide a long-term
sustainable solution to spectrum access for PMSE equipment. The study scope is limited to
wireless microphones/IEMs and cordless video cameras. The results of the study will feed into a
Commission impact assessment on policy options for PMSE spectrum access.
The figure below provides a high level summary of the tasks carried out under this contract.
Figure 1 – Overview of study tasks
Task 0
Task 1
Inception
Objectives & conceptual frameworks
Initial interviews & background research
Desk Research
Data collection on economic, social, environmental impact of PMSE
Baseline costs & benefits (status quo) microphones & video cameras
Socio-economic analysis
Tasks 2-4
T2: microphone
frequencies
Develop model
Populate model
T3: microphone
tuning
Develop model
Populate model
T4: cameras
frequencies
Develop model
Populate model
Primary data collection
Survey of manufacturers, users, regulators
Interviews with manufacturers, users, regulators
Task 5
Microphones: reports & recommendations
Interim report
Options Appraisal
Recommendations
Final report
Presentation
Cameras: reports &
recommendations
Interim report
Options Appraisal
Recommendations
Final report
Presentation
This report is structured as follows:


Section 2 describes three different perspectives on the social, economic and cultural
value of PMSE and it presents some of the challenges in defining the scope of this
study and the Impact Assessment.
Section 3 describes the baseline and defines the problem that the Commission is
aiming to address with the policy options.
8




Section 4 describes the Commission’s policy options and it outlines how they may
impact on different stakeholder groups.
Section 5 has a descriptive analysis of impacts based on the desk research, survey
and interviews.
Section 6 presents aggregate impacts based on the quantitative impact modelling.
Section 7 has the conclusions of the study including the options appraisal and
recommendations on which policy options to take forward.
The report also includes a set of annexes including further detail on the impact modelling
methodology, a glossary, further qualitative responses from the survey and a table providing
examples of the number of links required for different types of events.
9
2.0
Conceptualising the value of PMSE
This section highlights the challenges in determining the value of PMSE and it sets out our
approach to defining the scope of the current study.
2.1
Challenges in determining the value of PMSE
In order to assess the impacts of different policy options proposed by the European
Commission, it is necessary to have a conceptual understanding of the socioeconomic
value of PMSE which the policy options may affect. There are a number of challenges in
quantifying this value:





The technology is utilised by many different companies and organisations on a variety
of scales.
Non-professional use is not always recorded, and rarely has direct economic value (e.g.
PMSE use in churches).
Cultural value forms a significant part of the value provided by PMSE and this is very
difficult to quantify objectively.
The true value of PMSE goes beyond the industry itself. The value provided by PMSE
to secondary (e.g. quality of events and programmes) and tertiary markets (e.g. tourist
visits as a result of high quality cultural offer) could be considerably larger than the
PMSE industry itself.
Attribution of value in secondary and tertiary markets to PMSE is difficult. Indeed,
PMSE only forms a small part of the value of these markets.
While PMSE covers many types of hardware including; ‘wireless microphones, talkback, In Ear
Monitors (IEMs), cordless cameras, point–to-point audio, video and data links’ (Analysys Mason
Limited, 2009), this study is limited to wireless microphones/IEMs and cordless video cameras.
2.2
Users of PMSE
To understand the value of PMSE it is necessary have an overview of the different types
of users that demand PMSE equipment so that benefits to these user groups can be
identified. There are a number of typologies of PMSE user groups, reflecting different levels of
detail and different approaches to the industry. The table below presents several typologies
used in recent literature.
10
Table 1 - Overview of PMSE users
Source
Analysys
Reynolds, et al.
Mason Limited,
2006
2009
Large theatres
Amateur Opera
Broadcasters
Amateur Drama
Local theatres
Schools
Schools
Universities
Churches
Sports Clubs
Ministry of
Broadcasters
Defence
West End theatres
Regional theatres
Specified
Exhibition Sites
User
Concert Venues
Groups
Quotient
Associates, 2006
CEPT, 2009
Outside broadcasts
Newsgathering
Studio based
programme making
Local entertainment
and events
TV production
Radio production
Sport production
News gathering
National events
Actors on tour
Audio and video
distribution systems
Business installations
Conference installations
Church installations
Entertainment
production
Community Users
Industry trade shows
Musical production
Theatre
Schools
Movie production
Sources: Analysys Mason Limited, 2009. Opportunity cost and administrative incentive price (AIP) calculations for
spectrum proposed for award to a band manager with obligations to PMSE. OfCom. CEPT, 2009. Technical
considerations regarding harmonisation options for the digital dividend in the European Union. Quotient Associates,
2006. Supply and demand of spectrum for Program Making and Special Events in the UK. Reynolds, M., Mottram, N.,
McHardy, R. & Wooder, S., 2006. Use of the UHF Spectrum for Programme Making and Special Events in the UK.
From the above table we can see that existing typologies differ in two fundamental ways:


their scope (i.e. how comprehensive and detailed they are)
their perspective (i.e. distinguishing between different types of users, etc.)
Of course, uncertainty/inconsistency in the typology of users/uses, makes predicting the
number of users of PMSE very difficult, especially when attempting to assess the value on a
wider scale.
Notwithstanding such methodological difficulties, several reports have developed
estimates for the number of PMSE users. For instance, CEPT estimates that there are
approximately 5 million users of PMSE within Europe, with 70% of these using it for nonbroadcast applications (CEPT, 2009). The APWPT estimates that for microphones, “the total
number of channels being deployed is about 10 million and the number of daily users will be
about 8 million” (Association of Professional Wireless Production Technologies, 2012).
2.3
Three perspectives on the scope of PMSE
Given the above methodological difficulties and perspectives on users and uses of PMSE, the
study team have identified three possible approaches to defining the value of PMSE.
11
Broad scope (“core industry”, consumers + parallel sectors)
For this report, a broad scope refers to a definition of the value of PMSE that includes:



primary value of PMSE (i.e. economic value to manufacturers, users and regulators of
PMSE equipment);
secondary value of PMSE (i.e. economic and social value that accrues as a direct
result of different types of PMSE equipment use, such as the value of event quality and
frequency for audiences); and
tertiary value of PMSE (i.e. economic and social value experienced by stakeholders
who are not directly using PMSE equipment, e.g. hotels and restaurants next to
theatres, the societal “value of culture”, etc.)
The most prominent example of this broad approach to the PMSE industry is the “Study on
social and economic benefit of European, Austria and German Art, Culture and Creative
Industry” (2013). This set of statistics covers all activity directly or indirectly linked to PMSE. As
the authors make clear in their opening lines if a wireless microphone is used at a book
presentation, the value of the publishing sector, the number of employees, free lancers etc.
should be included. As a result, the study includes employment in all cultural and creative
industries, covering sectors with at most a very indirect link to PMSE, such as architecture and
advertising. The table below has some examples of the tertiary value of PMSE taken from
existing literature and reports in different economic, social and cultural domains.
Table 2 - Examples of value domains of PMSE under a broad definition
Domain
Description of value
Example of valuation
Tourism
Productions that depend on radio According to VisitBritain, “in 2012, 15.5 million
spectrum include TV, film, sport, visitors spent time in London, spending over
theatre,
circuses,
music, £10bn or 54% of all inbound visitor spending
1
newsgathering, political and corporate in Britain.”
events, and many others.” (British “London is the most important urban
Entertainment Industry Radio Group destination in Europe and second worldwide
(BEIRG), 2013)
after New York. Audience surveys indicate
that a large percentage of theatre goers in
London were overseas tourists” (Hughes,
1998)
Special
The Olympics relied heavily on PMSE, An “estimated 420 thousand of the total visits
events
in particular wireless microphones and to the UK were for an Olympics or
cordless cameras, for the opening and Paralympics-based purpose and a further 170
closing ceremonies, and coverage of thousand involved attendance at a ticketed
events.
event.” (Office for National Statistics, 2012). A
proportion of the value (£2.4B revenue,
excluding indirect value) of the event can be
attributed to PMSE
1
http://www.visitbritain.org/insightsandstatistics/inboundtourismfacts/
12
Education
Typically PMSE users in the education
domain
make
use
of
radio
microphones, although increasingly
cameras are being used, for the
purposes of remote learning. An
example use of PMSE would be radio
microphones in university lecturing.
As with tourism, the principal economic
benefit is a tertiary one, namely the results of
improved education and workforce.
Culture and
enhanced
social
environment
PMSE is used in “places of worship,
amateur dramatics, theatres, concerts,
touring shows, hospital radios, public
and
private
events”
(Quotient
Associates, 2006)
Where PMSE is used in these events,
improved quality of the event adds to the
cultural richness of Europe. In the UK,
creative industries are currently responsible
for 1.5 million jobs, and contribute £36 billion
annually to the UK economy” (British
Entertainment Industry Radio Group (BEIRG),
2013)
Parallel
technologies
Usage of wireless microphones and
cordless cameras, create and support
markets for supporting technologies
(Indepen and Aegis Systems, March
2004).
Examples include RF components, digital
signal processors, power supply, micromachine devices (e.g. noise cancelling),
optics, light sensors, acoustic to electric
transducers (e.g. piezoelectrics)
At this very broad level it is almost impossible to attribute an economic value to PMSE
(and even less so to PMSE spectrum access) because:




Capturing all variables falling within the broad scope is impossible;
Attribution is impossible because links with PMSE are only indirect (e.g. hotels
accommodating tourists who attend a show where PMSE is used);
Valuation of some of the concepts is highly subjective (e.g. the value of wireless
technology in a specific theatre production compared with the use of e.g. wired
microphones/cameras); and
No markets exist to provide a robust estimate (e.g. the value of culture)
The primary use of this broad definition therefore lies in setting out the broad types of
impact that PMSE can have and the diversity of stakeholders affected. The broad scope
assessment has not been taken further in this report, due to the added complexity, uncertainty
and questionable integrity of resulting valuations. Nevertheless, the cultural and social value of
PMSE should not be underestimated. As the Association of Professional Wireless Production
Technologies points out, “people experience through events the essential emotions that
everybody needs. These once in a lifetime experiences will be vastly inferior without PMSE.”
(2012).
13
Mid-level scope (“core industry” + consumers)
At a mid-level scope, the value of PMSE is linked to four groups: PMSE industry, users
and regulators (covered in the narrow definition described in more detail below) and
consumers of programmes and events delivered using PMSE applications (e.g.
audiences). An example of this approach was given by APWPT in their 2010 contribution to the
2
workshop on a “long term approach to radio spectrum for PMSE in Europe” which refers to the
benefits of a coordinated approach to PMSE spectrum access for:
1. manufacturers/technology (e.g. development costs, production costs, investment),
2. users (cheaper/easier equipment, use across the EU, pan-EU rental, cheaper frequency
management) and
3. EU citizens (event price, quality of events and social/cultural cohesion)
The value of PMSE to this last group (citizens) is broadly captured by changes to the
“quality of events”. Quality of events is a multi-dimensional concept, which we have
operationalised for this study as:
1. Improved quality of recordings
2. Recording of more and a greater variety of events
3. Time savings and ease of preparation
Improved quality of recordings
PMSE technology has led to increased quality of recording “at source” (i.e. during the
event). For instance, the ability to access a wider range of locations improves the overall quality
of recording and all future broadcasting/transmission of the recording. The quality of recording
of a live event determines how this event will be experienced by audiences in the future (e.g.
when a delayed broadcast, the evening news, etc.). The better the original recording, the closer
the experience of future audiences to the live event. If wireless equipment improves the quality
of live recording, it will affect all future experiences of the event.
Cordless cameras are typically used to provide coverage of events to audiences outside
the event venue. The 2012 London Olympics provides an extreme example, but undeniably
demonstrates the value which PMSE technology can deliver. “Almost 900 million people
watched part of the London Games' opening ceremony on television” (The Independent, 2012).
For some events, for example live concerts, wireless microphones and cordless cameras are a
critical part of the event bringing the stage show closer to the audience. Without the use of
wireless microphones and cordless cameras only a much smaller audience could experience a
close-up of their favourite stars.
Recording of more and greater variety of events
PMSE equipment enables artists to produce a greater variety of events (innovation) and it
enables producers/broadcasters to record more of these events. For cordless cameras,
2
https://ec.europa.eu/digital-agenda/sites/digital-agenda/files/pmse_present_0.pdf
14
wireless PMSE technology allows more varied locations to be accessed. This is particularly the
case for live news gathering and outside broadcasting (Quotient Associates, 2006), in which
reporters are filmed via cordless cameras which have a radio link to a news van and ultimately
their studio. Wireless microphones allow reporters to be as close as possible to a breaking
news event in question so that audiences can see and hear the event in the background during
the report. Similarly, wireless equipment facilitates innovation in events by e.g. allowing actors
to move about more freely on stage (e.g. in the musical Starlight Express all performers are on
roller skates).
Time saving and ease of use
As discussed above, wireless technology is used in PMSE for health and safety reasons (e.g. to
avoid tripping over cables). Additionally, it is easier to use than wired technology and it often
allows quicker setup and tear-down, due to less time physically manoeuvring components at an
event (this assumes that connectivity is easy to achieve and maintain, which is dependent on
the quality of technology and software).
Narrow scope (“core industry”)
On a narrow scope PMSE directly involves three groups of people: The manufacturers who sell
3
the technology, the users who purchase/use it, and regulators.
The narrow scope has a much more clearly defined economic scope which enables more
accurate economic estimates regarding market size and impacts of different policy
options on the market. By focussing on the core PMSE market, the number of market actors
can be estimated using the following data:




the number of manufacturers and users
the number of PMSE units sold
the cost of this equipment to producers (factory) and users (retail)
the frequency and type of events being held across Europe
The economic value of the core PMSE industry is the sales revenue of manufacturers,
the sales revenue of users (attributable to wireless technology), licensing revenues to
regulators, set against equipment costs for users and manufacturers and administrative
costs for regulators. This definition ignores upstream suppliers (e.g. suppliers of
camera/microphone parts) as well as downstream stakeholders (e.g. audiences).
As the discussion above shows, in choosing one of the above scopes for this study, it is
important to clearly bear in mind the objectives of the study. The objective here is not to
estimate the total value of PMSE (and/or compare it to other industries). Such a net present
value analysis would indeed require a comprehensive picture of all possible impacts of the
3
In addition to manufacturers, rental companies are important intermediaries, particularly in the market for cordless
cameras. These companies purchase equipment from manufacturers and then hire it out to (mostly) professional users.
Equipment purchases by rental companies are taken into account in estimates of market size based on manufacturer
sales, their customers are captured in the views of professional users.
15
industry. Instead, the objective here is to assess the relative socio-economic impact of a range
of possible EU level initiatives.
In the first instance, therefore, this study needs to determine which of the proposed
initiatives leads to the most positive impact. For this type of analysis, the narrow conception
of PMSE which maximises robustness, allows for a quantitative analysis and reduces attribution
challenges is most appropriate. The underlying assumption is that widening the scope of the
study to additional stakeholders (e.g. consumers of content disseminated through wireless
technology) would increase the impact of all of the proposed initiatives in equal measure (i.e.
without affecting the relative impact of the options vis-à-vis one another).
On this basis the quantitative analysis in this report will principally consider the core
PMSE industry, supplemented by qualitative information falling into the mid-level scope
where appropriate.
3.0
Baseline and problem definition
This section has an overview of the current state of the market for wireless microphones and
cordless cameras and a discussion of the problems faced by the market in relation to access to
spectrum now and in the future if no action is taken at EU or national levels.
3.1
Overview of the current market for wireless microphones & cameras
The report distinguishes between wireless microphones and cordless cameras throughout as
the markets for both of these PMSE applications are quite different both in terms of demand and
supply.
3.1.1 Wireless microphones
Size of the market
There is little systematic information concerning the total EU market for wireless
microphones and IEMs. The Professional Audio Manufacturers’ Alliance (PAMA), estimates
that the 2011 wireless microphone turnover in key European markets (Germany, UK, France,
Italy, Spain) was €106.8m at wholesale prices with 164,000 units or systems sold. The
breakdown in individual markets, according to PAMA is as follows:
Table 3 - Wireless microphone turnover in largest EU markets
Market
Turnover
Units/systems
Germany
€36m
61,000
UK
€41m
37,000
France
€15m
33,000
Italy
€8m
22,000
Spain
€6.8m
11,000
Total
€106.8m
164,000
Source: PAMA quoted in the Robert Bosch GmbH response to the European Commission public consultation on
options for the possible harmonisation of spectrum available for wireless microphones and cordless video-cameras
(PMSE equipment).
16
Extrapolating the above figures to the EU level using total population as a weighting
variable, the total wireless microphone turnover in the EU in 2011 can be estimated at
approx. €170m and 260,000 units/systems. It is however worth noting that the PAMA figures
are based on wholesale rather than retail prices and may not include data from all
manufacturers, which in turn means that these calculations may somewhat underestimate the
market size. In fact, some higher estimates are available: one, unverified estimate cited as a
4
secondary source by Analysys Mason puts the total number of wireless microphones sold in
2010 in the Netherlands alone at 250,000 units. This would mean that the total EU market could
be much larger than estimated above. At the same time, the estimate provided by one
5
manufacturer puts the total number of wireless microphones in use in Germany at 700,000 ,
while the APWPT study on the social and economic benefit of the art, culture, and creative
6
industry includes an estimate of at least two million wireless production devices on the
European market (although it is not clear whether this is based on information from all or a
selection of Member States). Both these figures suggest that the Dutch estimate is likely to be
an over-estimate and that the more conservative market size estimate based on the PAMA
figures may be more appropriate.
It is possible to combine the estimate of units on the market with the yearly unit sales to
arrive at the average life span of a wireless system. Every year in the EU, approx. 260,000
of the 2 million units in operation would be bought new and the remaining 1,740,000 would be
old units. This in turn means that wireless microphones would be exchanged approximately
every 8 years. Although this number appears high and demanding professional users are likely
to exchange their equipment much more frequently, this number also reflects smaller and nonprofessional users for whom older equipment is likely to deliver sufficient performance.
Nature of products
A wide range of products in different price ranges fall under the wireless microphones
and IEMs definition. The products include handheld microphone and body pack transmitters,
receivers, IEMs, and monitoring units. Retail prices can range from little over €100 for a simple
handheld transmitter and receiver set to over €5,000 for multi-channel systems. Higher cost
units generally provide increased flexibility by offering larger bandwidth. For instance a high-end
3000 series receiver from Sennheiser offers up to 184 MHz of bandwidth in each frequency
7
range, compared to 24MHz of bandwidth for an entry-level XS series wireless set . The above
estimates of market size and units sold yield an overall average cost of a system of €650 at
wholesale prices, although the average cost of professional-grade devices is likely to be closer
to the aforementioned €5,000 figure.
4
Analysys Mason, Consumer- and community-driven spectrum usage demand for commercial services – food for
thought, 15 February 2013.
5
Shure response to the European Commission public consultation on options for the possible harmonisation of
spectrum available for wireless microphones and cordless video-cameras (PMSE equipment).
6
APWPT (2013). Study on social and economic benefit of European, Austrian and German Art, Culture, and Creative
Industry
7
See http://en-de.sennheiser.com/
17
Assuming that the unit cost figures can be used to represent cost per link, it is possible
to arrive at an estimate of the maximum total cost of wireless microphone units used at
different types of events. The following figure uses the APWPT estimates of maximum
number of links required for different type of events and the upper-end €5,000 cost estimate,
since units used in such events are likely to be higher-cost professional-grade devices.
Table 4 - Cost of equipment used at different types of events
Production
Number of links
Typical studio production
Up to 24
Total cost of wireless
microphones used
Up to € 120,000
Typical event
Up to 50
Up to € 250,500
Large event
Up to 300
Up to € 1,500,000
Source: APWPT response to European Commission public consultation on options for the possible harmonisation of
spectrum available for wireless microphones and cordless video-cameras (PMSE equipment, own calculations)
It is important to note that these figures should not be interpreted as equipment cost per event,
since many users own equipment that can be used at multiple events over a number of years
(as noted above) or, alternatively, equipment could be rented at lower cost.
Market players
The key manufacturers of wireless microphones tend to be firms traditionally involved in
the production of wired microphones and other professional- and consumer-level audio
equipment. These include:








Sennheiser
Shure
Audio Technica
Robert Bosch (under the Bosch and Electro Voice brands)
Beyerdynamic
Harman (under the AKG brand)
Sony Europe
Panasonic
In addition, some manufacturers, such as MIPRO, Nady or Samson focused on wireless
systems from their inception. As this list shows, European companies are very prominent
among the key players on the wireless microphone market. For instance, 54% of Sennheiser’s
over 2,000 employees are based in Germany. European companies collectively hold a large
share of the market in the EU and many of them also operate globally.
Even for larger manufacturers, wireless microphones constitute a significant portion of
turnover. For instance, in 2011 sales of wireless microphones constituted 26.4% of Sennheiser
8
Group’s total global turnover of €531.4m, which amounts to €140m . Only a fraction of this
turnover figure relates to the EU market, however.
8
Sennheiser Electronic GmbH & Co KG. (2012). Financial Report 2011
18
The box below illustrates how spectrum access for wireless microphones currently works from a
user perspective in a sample of three countries: UK, France and Germany (some of the German
responses were provided separately and only cover a small sub-sample of the survey
questions). There are significant differences across Europe in the modality of spectrum access
for users and spectrum management. The box also has a list of bands that are typically
available for microphone use in each country (note that this list is different from the list of bands
that could potentially be available for PMSE (based on the ECC questionnaire).
Box 1 - Spectrum access for PMSE from a user perspective
9
UK
Under UK law (Wireless Telegraphy Act 2006), a licence is required for "Programme Making
and Special Events" (PMSE). This includes use of wireless microphones, talk back (walkietalkies) and production services in theatrical performances, radio and television programmes,
conferences, places of worship and so on, associated with a performance or event.
PMSE in the UK is regulated by Ofcom. However, licensing of PMSE has been outsourced
since 1997 to a specialist spectrum management company JFMG due to the high number of
licences (Approximately 80,000) and the fact there is significantly less unlicensed bandwidth in
the UK compared with other European countries.
Applications for PMSE spectrum can be made online, by fax email or post using an appropriate
form available on the JFMG website. A full list of the types of licence available, and the specific
frequencies
that
are
available
in
the
UK
is
available
at:
http://www.jfmg.co.uk/pages/apply/apply.htm
10
France
PMSE spectrum licencing within France is operated by ANFR (National Frequency Agency)
which was established in 1997. Its mission is to ensure the planning, management and
controlled use, including private and public sectors, of radio frequencies subject to the
application of France’s Article L. 41 of the Postal and Electronic Communications act, which
governs use of spectrum. Spectrum licence conditions are specified by the Electronic and
Communications and Postal Regulatory Authority (ARCEP).
The ANFR regulates and coordinates spectrum usage for multiple applications. Applications are
separated into three categories; marine radio, amateurs, and independent networks (covering
PMSE). ANFR also has a strong presence in international institutions. Frequencies are
available for licencing on a permanent or temporary basis, a temporary permit lasting 2 months.
Information on available frequencies and the application process is available on the ANFR
website. Applications can be made by post or electronically, forms for each of the above
categorise are available online.
11
Germany
9
http://www.jfmg.co.uk
www.anfr.fr
10
19
In Germany PMSE licences are sourced through BNetzA (Federal Network Agency). They are
responsible for the regulation all telecommunications within Germany.
Section 55(1) of the German telecommunications Act (TKG) states that anyone wishing to use a
radio frequency must first be assigned the frequency by the Federal Network Agency.
Frequencies are allocated according to their intended use and the national frequency usage
plan. Frequencies are assigned by administrative act either ex officio (general assignments
published in the Federal Network Agency's Official Gazette) or upon application (individual
assignments). Each assignment defines the particular purpose for which the frequency may be
used and the conditions to be met so that the spectrum may be used efficiently and with
minimum interference. No-one has the right to be assigned specific frequencies, this is the
process used to gain a licence for spectrum usage for any application, including PMSE.
Applications require 4 weeks for completion. Applications are to be made by post and a
standard application form is available on the website. There is also a flyer that can provide
additional information and support.
Indicative frequencies and costs
The regulations relating to the PMSE frequencies available and associated licence costs for
each country are complicated and varied. The table gives examples for the typical frequencies
and licence costs for microphones in the UK, France and Germany. The specific detailed
information can be found through the telecommunications regulator in each country.
Country
UK
Available spectrum for
microphones (MHz)
 Many PMSE frequency
bands are technology
and application neutral
however the following
are typically used for
microphones
o 175- 208 MHz
o 470-790 MHz
o 863-865 MHz
o 1785-1800 MHz

France




Note final allocations to
be confirmed; awaiting
updates from Ofcom
following a
reorganisation of
spectrum within the UK
174-223
470-786
823-830
Note that 1785-1800 is
not yet used but will be
Cost
A mixture of light licensing and
individual licensing is used.
1 Year Shared Microphone light
licence from £75
Individual licence cost calculated
based on unit bandwidth and duration
of licence
Use of microphones operated under
general licence conditions specified by
ARCEP. However specific frequency
plans may be put in place for large
events.
11
http://www.bundesnetzagentur.de; http://www.apwpt.org/downloads/handoutfrequencies2013.pdf
20
authorised soon for
PMSE professional
users
Germany







32-38
174-216
470-606
614-790
823-832
863-865
1785-1805
Any required licence fees are based
on the frequency, bandwidth, and area
covered, with a minimum of €100 per
year
A mixture of individual and general
licensing used
Individual licences are typically for 10
years and incur both a one-time fee
and annual fees.
€130 for temporary operation of a
channel for up to 30 days and €50 for
each additional channel
Future market demand
12
According to Analysys Mason , there are a number of demand drivers which are likely
to lead to a growth in the wireless microphone market. These demand drivers include:



number of events;
increasing complexity of events; and
increasing adoption of equipment per event.
With regard to number of events, Analysys Mason provides an example of an increase in the
number of theatre performances with PMSE use in London from 17,923 to 18,615 (4% increase)
between 2009 and 2010, as well as an increase in the number of theatres from 45 to 46 in the
same time period. They estimate that these theatres used around 600 microphones or a total of
940MHz of spectrum in 2011. Similarly, the Sagenta report on the Use of UHF Spectrum for
Programme Making & Special Events in the UK estimated a steady growth in the number of
13
organisations requiring wireless microphones for both “special event” and “background” use . A
Quotient report on PMSE in the UK noted that the trend towards a larger number of events is
also present in broadcasting, particularly due to increased amount of local coverage and local
14
programming, as well as “long-tail” niche productions .
The table below has an overview of spectrum requirements for audio-PMSE by type of location,
based on an analysis in the Netherlands.
Table 5 – Amount of PMSE equipment used and spectrum requirements
PMSE
Number of systems
Spectrum requirement
Village countryside (<500 people/sqkm)
12
>12Mhz
Village countryside (<500 people/sqkm, 1 small event)
38
>40Mhz
12
Analysys Mason, Consumer- and community-driven spectrum usage demand for commercial services – food for
thought, 15 February 2013.
13
Sagenta (2006). Use of UHF Spectrum for Programme Making & Special Events in the UK.
14
Quotient (2006). Supply and Demand of Spectrum for Programme Making and Special Events in the UK
21
Town (500-1000 people/sqkm)
56
>80Mhz
City (1000-2500 people/sqkm)
>102
>100Mhz
Capital city (>2500 people / sqkm)
>200
>130Mhz
Source: Dutchview
The table below has an overview of spectrum requirements for different West End theatre
shows in London in 2013.
Table 6 - Microphone spectrum requirements for different West End productions in
London 2013
No of
No of
No of Comms Duplex Spot
Total
Show name
radio mics RR/IEM freqs
Pair
Frequencies MHz
We Will Rock You
36
1
17
2
58
60
Billy Elliot
40
0
9
1
51
51
Les Miserables
40
1
9
1
52
55
Jersey Boys
40
4
16
1
62
64
Chorus Line
41
4
0
1
47
51
Wicked
36
0
9
1
47
47
The Lion King
40
0
26
2
70
70
Matilda
34
2
14
1
52
54
Rock of Ages
26
5
9
1
42
45
BodyGuard
43
2
9
1
56
58
Warhorse
32
4
9
1
47
49
Singin' in the Rain
32
1
10
1
45
47
Viva Forever
Charlie and the
Chocolate Factory
48
0
9
1
59
59
64
10
27
1
120
95
Mamma Mia
32
0
10
1
44
44
One Man Two Guvs
16
4
9
1
31
33
Spamalot
16
0
0
1
18
18
Once
68
0
9
1
79
87
Book of Mormon
40
0
16
1
58
60
Trelawny of the Wells
8
2
0
0
10
12
Grandage Season
8
0
0
1
10
12
Curious Incident..
8
1
0
1
11
12
16
0
5
1
23
23
8
0
5
1
15
15
Stomp
16
0
5
1
27
27
39 Steps
16
0
5
1
23
23
Woman in Black
Phantom Of the
Opera
16
1
5
1
24
26
40
3
17
1
62
64
Thriller
40
1
13
1
56
58
Top Hat
King Lear
22
The Mousetrap
Let It Be
8
0
9
1
19
19
32
2
17
1
53
55
Source: Information on PMSE use in London West End Theatres, Brian Copsey, 2013
There is substantial evidence base pointing to an increase in the complexity of events as well
as the increasing adoption of equipment per event. For instance, the figure below outlines the
use of wireless microphones and in-ear-monitors (IEMs) in the Eurovision song contest,
showing the substantial increase in the number of wireless microphones and IEMs used by
performers and presenters.
Figure 2 - Use of wireless microphones in the Eurovision song contest over time
Source: Sennheiser Germany response to the European Commission public consultation on options for the possible
harmonisation of spectrum available for wireless microphones and cordless video-cameras (PMSE equipment).
The development in wireless microphone use in the Eurovision song contest represents
on average a 7% yearly increase during the 1998-2012 time period (noting that between
2002 and 2009 the use remained relatively stagnant). Although the Eurovision song contest is
of exceptional scale and cannot be used as a representative event, it does serve as a useful
indication of the trend in the adoption of wireless technology, given that it takes place annually
in the EU since the 1950s and the general format does not change substantially. Applying this
rate of increase to the entire market for wireless microphones, one would expect the total
market size to reach approx. 500,000 units and €325m by 2020.
Although a portion of the increase can be attributed to the adoption of new technology,
the large increases in the number of channels used in the 2010-2012 period suggest that
complexity of events also plays a role. The 2006 Quotient report on PMSE in the UK
identifies a set of drivers behind the increased adoption of wireless microphones IEMs and
rising complexity of events. These include:

larger number of “live” broadcasts and increased use of “walkie talkie” shots (with
reporters moving about and being part of closer to the action covered);
23





increased complexity of sports coverage (including the use of wireless microphones to
add ambience);
continued popularity of reality television requiring many microphone and camera links;
increased complexity of studio programmes, in particular increase in the size of cast;
migration of smaller theatre production to wireless microphones; and
15
more complex top theatre shows .
Finally, a number of respondents to the European Commission public consultation on options
for the possible harmonisation of spectrum available for wireless microphones and cordless
video-cameras (PMSE equipment) pointed to the adoption of formats such as HD Audio and 3D
Audio as important demand drivers.
3.1.2 Cordless cameras
Size of the market
Cordless cameras, contrary to wireless microphones, are a relatively newer technology
16
with the use of cordless camera growing substantially in the 2000s . The cordless camera
market is smaller than that for wireless microphones, but has a significantly higher cost per unit,
reflecting the increased complexity of the equipment.
There is limited information on the total market size for cordless cameras. Vislink, one of
the market leaders, estimates that the potential market for its broadcast services (which, in
addition to cordless camera systems, include also other satellite and microwave solutions) was
17
£230m (€263m) in 2011 . In 2011, Vislink reported a total broadcast revenue of £42.3m
(€49.6m), £10.1m (€11.6m) or 24% of which was revenue in the UK and the rest of Europe, out
18
of which only a portion relates to the sales of cordless camera products . Assuming that the
relationship between EU and global sales of Vislink products can be applied to the market as a
whole, and assuming that the global market size corresponds to the Vislink estimate of £230m
(€263m), the EU market for broadcast services would be approximately £54.9m (€64.4m).
Unfortunately there are no estimates to available to determine what portion of this figure would
relate to cordless camera systems falling within the scope of this study. For the purpose of this
research, the assumption is that half of this figure relates to cordless camera systems. This, in
turn, means that the estimate of the EU market size for cordless cameras would be €32.2m.
This figure will be used as a working estimate for the remainder study. In future research it will
be important to arrive at more accurate market size estimates. Nevertheless, even given the
assumptions, the above estimate is helpful in establishing the order of magnitude related to
market size estimates. The potential implications of the assumptions made are discussed in the
sensitivity testing section.
15
Quotient (2006). Supply and Demand of Spectrum for Programme Making and Special Events in the UK
Sagenta (2008). Examining the potential to use SHF and EHF spectrum to support Wireless Camera PMSE
applications.
17
Vislink (2012). Annual Report & Accounts 2011
18
Vislink (2012). Annual Report & Accounts 2011
16
24
In addition to manufacturers, hire firms are important market players in the cordless
camera sector. The high costs of cordless camera systems mean that users opt to hire such
systems. The daily rental costs of such systems range from approx. €300 for simple standard
19
definition (SD) systems to €1,700 for advanced High Definition (HD) ones .
Nature of products
Wireless broadcast cameras consist of three main elements:
 the camera body;
 the camera lens; and
20
 the wireless transmitter .
Generally, wireless camera systems refer to camera systems (form manufacturers such as
Sony or Thomson) equipped with a wireless transmitter, which is in turn coupled with a wireless
receiver. Therefore, wireless camera producers refer primarily to the producers of wireless
receivers and transmitters. Used almost exclusively for professional purposes, these are not
sold to customers through retail channels and are costly, with Standard Definition (SD)
21
transmitters costing over €10,000 and, according to an interview with a rental company
specialising in wireless equipment, the cost of a complete system exceeding €40,000.
According to the same interviewee, the life-cycle of such systems is usually three to five years.
Assuming an average price per system of approximately €25,000 and using the working
estimate of market size yields a figure of 1,300 units sold per annum. As in the case of wireless
microphones it is possible to arrive at an estimate of the cost of wireless camera equipment for
different types of events. The table below assumes the cost of €25,000 per channel and use
APWPT estimates of channel requirements.
Assuming an average price per system of approx. €25,000 and using the working estimate of
market size yields a figure of approx. 1,300 units sold. As in the case of wireless microphones it
is possible to arrive at an estimate of the cost of cordless camera equipment for different types
of events. The table below assume the cost of €25,000 per link and use APWPT estimates of
link requirements. Unlike in the case of wireless microphones, average cost can be used here,
since practically all cordless camera units on the market are professional-grade devices.
Table 7 - Cost of equipment used at different types of events
Total cost of cordless camera
Production
Number of links
systems used
Typical studio production
Up to 8
Up to € 200,000
Typical event
Up to 20
Up to € 500,000
Large event
Up to 30
Up to € 750,000
Source: APWPT response to European Commission public consultation on options for the possible harmonisation of
spectrum available for wireless microphones and cordless video-cameras (PMSE equipment, own calculations
19
See http://broadcastrf.com/rate-card/ for example hire costs
Sagenta (2008). Examining the potential to use SHF and EHF spectrum to support Wireless Camera PMSE
applications.
21
Sagenta (2008). Examining the potential to use SHF and EHF spectrum to support Wireless Camera PMSE
applications.
20
25
Market players
Cordless camera receivers and transmitters are currently produced by a small number of
highly specialised companies. These include Vislink, a market leader, which produces
cordless camera solutions under the Link and Gigawave brands, more recent market entrants
such as Cobham, and other companies such as IDX, Videosys, VTQ Videotronik GmbH or
Arnold and Richter Cine Technik.
Future market demand
22
There is an expectation that the cordless camera market will see substantial growth .
This is reflected also in the survey of PMSE users, majority of whom expect their use of wireless
cameras to increase. One of the drivers is likely to be the further maturing of cordless camera
technology, potentially pushing costs down and leading to wider adoption of the technology. In
addition, there are other identified demand drivers, including:
23
 increasingly widespread adoption of HD and 3D technologies ;
 larger number of “live” coverage events; and
24
 increasing complexity of sports coverage and studio programmes .
Vislink expects the total market for its services to grow from £230m to £270m by 2015, which
would imply an approx. 4% yearly growth rate in the market. Applying this number to the above
working estimate of market size, one would expect the cordless camera market to reach €46m
in value.
3.2
Spectrum access issues faced by PMSE
From a European perspective, there are three key problems with respect to spectrum
access for PMSE equipment across the EU:
 Market fragmentation
 Lack of sufficient spectrum; and
 Uncertainty about future availability of spectrum
3.2.1 Market fragmentation
Spectrum availability for wireless microphones and in-ear monitors in the EU is
fragmented. The table below has an overview of the availability of different bands for potential
wireless microphones use arranged by Member State and frequency band. The table is based
on the results of the 2012 CEPT ECC WG FM questionnaire on PMSE. It therefore shows only
the frequency bands addressed in the questionnaire and there may differences between this
table and the frequency ranges identified in ERC Recommendation 70-03. Where bands were
identified as being available for PMSE but without clear indication of intended equipment (i.e.
“technology neutral” bands), they were assumed to be potentially available for wireless
microphone use. The table therefore shows bands potentially available rather than bands
actually used.
22
See for instance Sagenta (2008). Examining the potential to use SHF and EHF spectrum to support Wireless Camera
PMSE applications.
23
Analysys Mason, Consumer- and community-driven spectrum usage demand for commercial services – food for
thought, 15 February 2013.
24
Quotient (2006). Supply and Demand of Spectrum for Programme Making and Special Events in the UK
26
Table 8 - Frequency ranges that are potentially available for wireless microphones across Member States
53-60 (7 MHz)
786-789 (3MHz)
823-826 (3MHz)
826-832 (6 MHz)
863-865 (2 MHz)
Source: adapted from CEPT ECC, Summary and preliminary analysis of the responses to the WG FM questionnaire on PMSE (Version 3), November 2012
27
As further spectrum is allocated to other applications, a lack of coordination among
regulators may increase fragmentation of spectrum availability for wireless microphones
and cordless cameras. Annex 10 of the ERC Recommendation 70-03 documents available
bands and conditions of use to provide some guidance to PMSE stakeholders. However, our
survey results show that regulators rarely coordinate with other EU countries. In some cases,
coordination only occurs on specific issues like border use of equipment, special coordination
for high power devices.
Similarly, cordless cameras currently do not operate on the same spectrum bands
across EU. The table below has an overview of the supply of frequency bands for cordless
cameras across Member States.
28
Table 9 - Frequency ranges that are potentially available for cordless cameras across Member States
2025-2110 (85 MHz)
Source: adapted from CEPT ECC, Summary and preliminary analysis of the responses to the WG FM questionnaire on PMSE (Version 3), November 2012
29
As the table shows, currently, the most available bands are:




2025 – 2110 MHz;
2200 – 2500 MHz (in part);
10-10.7GHz
21.2-24.5GHz
Fragmentation in access to spectrum for PMSE causes several problems for both users
and manufacturers of cordless cameras and wireless microphones. These include:



Lower usability of devices with users not able to simply switch on their equipment in any
Member State.
Lack of economies of scale, higher production and development costs. For instance,
one of the online survey respondents highlights that: “If there are no harmonized
frequency bands, we need to produce many different frequency versions, which
increases the costs”. Increased costs include production costs for different Member
States, but also indirect costs in R&D due to the need of providing the same quality for
a wide range of frequency range.
User preference for hiring rather than purchasing devices where cross-border use is
frequent, e.g. in ENG or cross-border tours, etc. Hiring of devices, though not an issue
itself, can replace purchasing and thereby reduce user investment in new equipment,
reduce overall market growth and increase costs for users over the longer term.
Responses to the online survey indicate that two thirds of users do not frequently need
to use their equipment in other Member States. In addition, the majority of users indicated
that their current wireless microphone equipment is tuneable to work across the EU already.
This suggests that manufacturers produce equipment that meets the current limited user
25
demand for cross country operability.
3.2.2
Lack of spectrum
Lack of spectrum availability is one of the key issues for PMSE stakeholders. While the
digital dividend has freed up spectrum in some bands that fall within the ranges used by PMSE,
the increasing demand of bandwidth by mobile networks has seen a reallocation of spectrum to
those services (e.g. 800 MHz). As one manufacturer points out: “The big fear is that even more
spectrum will be assigned to other services, which will have influence on the day to day use in
the future". After 2015, the industry association APWPT fears that PMSE may lose up to 52% of
UHF spectrum available until 2010.
The figure below illustrates the distribution of spectrum squeeze for PMSE applications
in the UHF band. In the 800MHz band, only the duplex gap remains for PMSE following
allocation to LTE services, there are ongoing discussions about a potential reallocation of the
700MHz band.
25
Wireless microphone manufacturers make different sets of equipment which in total can tune across the EU but each
individual device can only tune across a more limited range.
30
UHF spectrum
Figure 3 – Distribution of UHF spectrum for PMSE applications
470
500
600
700
800
862 MHz
470 – 862 MHz
Suitable UHF spectrum for terrestrial TV distribution and PMSE equipment. Due to the general assignment, the frequencies 790 - 862
MHz were mainly used for wireless microphones and other PMSE devices.
470 –
502 MHz
PSS
Public
Safety
and
Security
502 – 790 MHz
UHF band for TV distribution and productions using PMSE equipment
470 – 606 MHz and 614 – 710 MHz broadcasting/ 710 MHz – 790 MHz professional wireless
production
790 – 862 MHz*
694 – 790 MHz
700 MHz- Band
TV stations
Wireless microphones
*without duplex gap
Source: adapted from Sennheiser
The table below shows the number of microphones and IEMs that can operate on a given
bandwidth under normal conditions and without interference.
Table 11 - Spectrum requirement for interference-free operation of wireless microphones
and IEMs
Bandwidth
Microphones
IEMs (mono)
(MHz)
8
10
10
16
16
12
24
20
14
32
28
18
40
32
22
48
34
24
56
36
26
64
38
28
Source: Technische Universitaet Braunschweig, Untersuchung der zukünftigen Frequenzbedarfe des terrestrischen
Fernsehens und des Mobilfunkdienstes sowie weiterer Funknutzungen im Frequenzband 470-790 MHz sowie
Bewertung von Optionen zur Verteilung der Frequenznutzungen unter sozio-ökonomischen und frequenztechnischen
Gesichtspunkten insbesondere im Teilfrequenzband 694-790 MHz (2013)
One of the key issues for PMSE spectrum planning is the concentration of spectrum
needs among a small number of users and in a small number of locations. For instance
the following types of location should be distinguished:
 Areas with high demand such as the West End in London (see table 5 above)
31
 Areas where production facilities are located
 Areas of low demand (e.g. a rural area with a church using PMSE equipment)
 Exceptional demand in rural areas (e.g. natural disaster, unexpected event)
 Exceptional demand in urban areas (e.g. Olympics, sports, political events, etc.)
In addition, while there may be 5 million (or more) users of PMSE equipment in Europe,
the vast majority of spectrum demand in each location comes from a small number of
professional users and broadcasters. For instance, there are estimates that 13% of PMSE
spectrum use in the UK is due to the BBC alone and 50% of such use can be attributed to just
50 users. This compares with 64,000 PMSE frequency assignments per year to 1,300
26
organisations and individuals each year. Similarly it has been estimated that 50% of UK
27
assignment days take place in only 4% of locations.
This is particularly significant given PMSE market trends described in section 3.1 which
should lead to ever increasing demand or spectrum from the PMSE industry. As noted
28
above, market growth is currently estimated at around 4-7% . Applying the lower bound of that
growth range to estimates of current spectrum needs (e.g. the widely cited 96MHz figure based
29
on a study in Germany ) suggests that spectrum needs would double by 2029 and triple by
2040. Clearly, such a linear projection into the future cannot be accommodated under any
circumstance given spectrum scarcity. Alternatives therefore need to be found either in terms of
increase spectrum efficiency (including shared use with mobile broadband), technological
progress or use of bands that are not within the range of currently available equipment.
The figure below presents a forecast of spectrum demand by PMSE in the short, medium
and long term, broken down by demand driver. In the short term, all drivers (number of events,
event complexity, equipment per event, sophistication of equipment and HD/3D cameras) point
to increased spectrum requirements by the industry. This trend is likely to continue over the
medium term though in the longer term technological development may stabilise demand for
spectrum.
Figure 4 – Summary of spectrum demand drivers for PMSE and assessment of their
impact on spectrum usage demand
PMSE
Short term
Medium term
Long term
Type and number of events
+
+
+
Type of equipment and growth
+
+
+
Increase in the amount of equipment per event
+
+
++
Adoption of HD and 3D cameras
+
+
++
OVERALL ASSESSMENT
+
+
+/++
Source: Analysys Mason, 2013
26
Analysys Mason report on spectrum demand, 2013
Analysys Mason report on spectrum demand, 2013, citing Quotient research
28
Based on estimates of growth in theatre use of PMSE in the UK and Eurovision figures
29
Technische Universitaet Braunschweig, Untersuchung der zukünftigen Frequenzbedarfe des terrestrischen
Fernsehens und des Mobilfunkdienstes sowie weiterer Funknutzungen im Frequenzband 470-790 MHz sowie
Bewertung von Optionen zur Verteilung der Frequenznutzungen unter sozio-ökonomischen und frequenztechnischen
Gesichtspunkten insbesondere im Teilfrequenzband 694-790 MHz (2013).
27
32
Lack of spectrum does not only lead to a reduction of the quality and reliability of the
equipment in use (especially when the presence of several devices creates interference),
but also uncertainty regarding the development of new technologies: for example, new HD
cordless cameras require more bandwidth than prior generations, and in complex events, lack
of available spectrum combined with the presence of several cordless cameras may lead to
tuning problems for users.
Another issue with wireless cameras is that they require a significant amount of
spectrum when used but their usage is generally very sporadic both in terms of time and
location. Typically 10 MHz channels are required for digital cameras (20 MHz used to be
required for analogue cameras and the move to digital has largely been driven by the greater
spectral efficiency of digital). This may increase with the proliferation of HD and 3D material.
As such, current usage is generally on a secondary basis, requiring the agreement of the
primary user.
In addition, lack of spectrum availability may also cause a decrease in the use of both
cordless cameras and wireless microphones. Further reduction in spectrum availability may
force manufacturers to develop new technologies to exploit other frequency ranges, requiring
increased R&D without the certainty of achieving the same results in terms of quality and
reliability of the technology.
Among respondents to the user survey, concerns about lack of spectrum are confirmed
as well. Most users expect their use of wireless microphones to increase significantly over the
coming years with some suggesting increases by over 20%. Almost none of the respondents
thought their use of microphones was likely to decrease. At the same time most users did not
think that spectrum availability would be a major driver of their use of wireless microphones in
the future, suggesting that users do not expect spectrum availability to act as a constraint on
their use of PMSE equipment. Technological changes are, according to users, likely to lead to
increased used of microphones while licensing costs do not seem to have much impact on use
of microphones and IEMs.
3.2.3 Uncertainty about future availability of spectrum
Finally, the Commission’s public consultation identified uncertainty regarding future
availability and access to spectrum as one of the problems facing the PMSE industry and
its stakeholders. Indeed, market fragmentation, lack of sufficient spectrum and ever increasing
demand for spectrum for other applications are likely to lead individual Member State regulators
to adjust the frequency bands available for PMSE use in the future. For instance, discussions
are on-going in some Member states regarding reallocation of the 700MHz band which is
currently used by PMSE.
The absence of a clear understanding of which frequency bands will be available for
wireless microphones and cordless cameras in the future (and the conditions of access),
could affect the market for PMSE equipment negatively in that it:
33


reduces user investment in upgrading, replacing or purchasing additional equipment;
and
reduces manufacturer incentives to invest in R&D and develop new products
While the digital dividend is forcing some users to update older equipment, uncertainty about
future spectrum regulation induces some users to opt for hiring rather than purchasing devices
(which, in turn, may be more expensive for some companies).
In our survey, regulatory uncertainty was mentioned as the most worrisome concern for
users and manufacturers in relation to future spectrum availability. In particular, most
users consider this aspect as the main barrier to investment in both wireless microphones and
cordless cameras. Regulators also consider that regulatory uncertainty is one of the main
problems for the PMSE industry.
34
4.0
Definition of the policy options
This section has an outline of the policy options whose impact is of interest to the Commission
in order to tackle the above issues.
4.1
Options for wireless microphones and in-ear monitors
There are three policy options for wireless microphones and IEMs, ranging from do nothing to
common tuning ranges to the specification of harmonised bands.
Option 1: Do Nothing
This scenario consists of a continuation of the status quo at EU level and a projection of
the baseline into the future. Under this scenario, spectrum availability for PMSE will decrease
following further allocation of spectrum to mobile communications and other uses.
In response, it is likely that regulators in many Member States will carry out national level
interventions to address spectrum issues for wireless microphones. However, these
interventions may not be coordinated at a cross-country/European level.
In the absence of a European solution, Member States will implement different solutions,
which is likely to reinforce regulatory uncertainty in the short to medium term and market
fragmentation in the longer term.
Thus, in this scenario, the availability of spectrum for wireless microphones across the
EU will continue to be fragmented. The availability of bands will differ between MS, and the
method of access to spectrum will also differ. Some commonality (specifically with relation to
licence exempt usage) may be provided through the adoption of ERC Recommendation 70-03,
however this neither guarantees availability across EU MS, nor does it provide a harmonised
method for gaining access to this spectrum.
Option 2: Common Tuning Ranges
In this scenario, common tuning ranges for wireless microphone use across the EU
would be identified (on a shared-use basis). The amount of spectrum covered in a common
tuning range would need to be sufficient to accommodate all targeted users (e.g. nonprofessional/professional) and different types of events (small/large).
Specifically the option would recommend that Member States grant wireless
microphones secondary user status in at least 60MHz selected from among the following
bands:
 29.7 – 68 MHz;
 174 – 216 MHz;
 470 – 790 MHz;
 821 – 832 MHz;
 863 – 865 MHz (Licence Exempt);
 1785 – 1805 MHz,
35
Member States would be free to make additional spectrum available where needed (e.g. in
urban centres with a concentration of theatres or for special events). Information similar to ERC
Recommendation 70-03 could be provided (e.g. in form of a database) to show the availability
of bands in each MS, together with the licensing rules.
In terms of direct effects, this option would:







Improve regulatory clarity as to which bands to focus manufacturing and usage on
Reduce market fragmentation through a structuring of currently available spectrum and
a reduction in the number of bands in use across Member States
Encourage national regulators to make available at least 60MHz of spectrum within the
common tuning range
Provide information on licensing of PMSE spectrum use
NOT guarantee spectrum availability for PMSE in any one of the specified bands in any
particular MS
NOT preclude other bands from being made available for PMSE use
NOT impose significant opportunity costs on other spectrum users
This option would not impose binding measures on national regulators but it would
focus on providing information to regulators, manufacturers and users as to the
availability and use of spectrum for PMSE. In addition to specifying a 60MHz floor, the added
value of this option over the status quo and the do nothing option lies in:
1. formally recognising the PMSE industry as a key stakeholder in future spectrum
allocation decisions
2. encouraging all Member States to reflect on their PMSE spectrum needs and
actions required to ensure availability of sufficient spectrum in future in their Member
State.
3. serving as a starting point for the development of a Europe-wide coordinated
long term solution to PMSE spectrum needs based on common tuning ranges.
Option 3: Option 2 + Harmonised Spectrum Availability
In this scenario, in addition to the specification of common tuning ranges as set out in
option 2, EU legislation would be used to harmonise specific spectrum bands to be made
available for wireless microphones and IEMs across all countries. The following bands are
being considered as candidates for harmonisation:
 821 – 832 MHz;
 1785 – 1805 MHz;
Additionally, a recommendation would specify that at least 30MHz from the following
bands should be allocated to wireless microphone use:
 29.7 – 68 MHz;
 174 – 216 MHz;
 470 – 790 MHz,
 863 – 865 MHz (Licence Exempt).
36
Some countries may wish to use a licence based approach where as others may wish to make
the bands licence exempt. Information similar to ERC Recommendation 70-03 could be
provided (e.g. in form of a database) to show the availability of bands in each MS, together with
the licensing rules.
In addition to the direct effects set out in option 2 this option would also:



4.2
Guarantee spectrum availability for PMSE in the specified bands
Further reduce market fragmentation in these bands
Impose opportunity costs on previous users of the newly harmonised bands
Options for cordless cameras
There are two policy options for cordless cameras, ranging from do nothing to common tuning
ranges.
Option 1: Do Nothing
This scenario consists of a continuation of the status quo at EU level and a projection of
the baseline into the future. Under this scenario, spectrum availability for PMSE will decrease
following further allocation of spectrum to mobile communications and other uses.
In response, it is likely that regulators in many Member States will carry out national level
interventions to address spectrum issues for cordless cameras. However, these interventions
may not be coordinated at a cross-country/European level.
In the absence of a European solution, Member States will implement different solutions,
which is likely to reinforce regulatory uncertainty in the short to medium term and market
fragmentation in the longer term.
In this scenario, spectrum availability for cordless cameras will continue to be
fragmented and subject to relatively regular change. The licensing regimes for access to
spectrum will also be different in each MS, though commonly cordless cameras require
licensing rather than being licence exempt. Some commonality, through the bands identified in
ERC Recommendation 25/10 will be present but it will be very limited.
Option 2: Common Tuning Ranges
In this scenario, specific frequency bands for cordless camera use across the EU would
be identified. Unlike with wireless microphones, it is likely that the identification of common
tuning ranges would lead to a very reduced subset of frequencies requiring the lowest common
denominators to be selected to ensure some buy-in from national regulators. It may be feasible,
however, to identify some bands which would be common across the EU.
This option would recommend that Member States grant secondary user status to
cordless cameras in a minimum of four 10 MHz channels (probably licensed) in the range
2025-2500MHz across MS. Not all channels would be available in all MS. Information could be
37
provided (e.g. in form of a database) to show the availability of bands in each MS, together with
the licensing rules.
In terms of direct effects, this option would:




Improve regulatory certainty and reduce future need for migration
Reduce market fragmentation through a reduction in the number of bands in use
Clarify the legality of cross border use of equipment
Provide a focus for regulators, manufacturers and users in future discussion and put
“pressure” on national regulators to make available a certain amount of spectrum within
the common tuning range on a secondary basis
This option would not impose binding measures on national regulators but it would focus on
providing information to regulators, manufacturers and users as to the availability of
spectrum.
The figure below presents the conceptual framework of the initiatives the impacts of
which the Commission is currently considering. The empirical part of this study tests the
impact hypotheses presented this framework and it establishes the strength of the relationships
between the different initiatives presented in this section, shirt term effects and ultimate costs
and benefits.
Figure 5 – Simplified conceptual impact framework
38
5.0
Descriptive impact analysis
This section presents the results of the impact analysis carried out on the basis of survey
responses, desk research and interviews.
5.1
Description of literature
Although there is a wide range of existing grey literature on PMSE and the management
of PMSE spectrum, there is generally only a limited amount of information concerning
the impact of the potential harmonisation measures considered in this report. The key
data source is the European Commission public consultation on options for the possible
harmonisation of spectrum available for wireless microphones and cordless video-cameras
(PMSE equipment). The consultation responses are discussed below.
Public consultation responses
The public consultation carried out by the European Commission in 2012 focused in particular
on:




impact/added value of EU harmonisation of the frequency bands 821-832 MHz and
1785-1805 MHz for wireless microphones;
impact/added value of EU harmonisation of bands 1900-1920 MHz and 2010-2025 MHz
for cordless video-cameras;
impact of EU harmonisation on the efficient use of PMSE equipment; and
other measures excluding spectrum harmonisation.
The main stakeholder concern relating to the baseline scenario was the risk that after the
digital switchover (DSO), there may be insufficient spectrum available for large events. In
addition, one stakeholder organisation noted that equipment costs for touring theatre could
increase by a minimum of 100% as a result of increased fragmentation of available PMSE
30
spectrum . One equipment manufacturer also noted that consumer insecurity with regard to
spectrum availability, especially given the digital dividend, has actually led to lower sales
31
between 2008-2012 .
Consultation respondents were generally very supportive of harmonisation measures.
Although many stakeholders noted that the proposed harmonised bands are too narrow, even
32
for such small amount of spectrum, security is better than uncertainty . Specific impacts of
harmonisation identified by stakeholders include:


less uncertainty and optimal operation of equipment across the EU, which in turn can
33
bring performances and events to greater audiences ;
34
returns on investment for users and manufacturers ;
30
PLASA public consultation response
Audio Technica consultation response
32
French association for Picture Sound and Audio Technica consultation responses
33
BEIRG and French association for Picture Sound consultation responses
34
APWPT consultation response
31
39


possibility for manufacturers to develop equipment to be sold across a much wider
35
market, which in turn frees up resources for R&D and product development ; and
36
lower prices due to economies of scale effects .
Some of the respondents pointed out that harmonisation may not necessarily be that
beneficial to users. One broadcaster noted that the main benefit of harmonisation would be to
manufacturers who would be able to reduce tuning ranges of their models, but this would not
37
necessarily lead to a saving for consumers . In addition, harmonisation would mean that
38
broadcasters would need time and expenditure to renew their equipment .
Although, there was general support of harmonisation and an expectation that it would
generate some positive impacts, stakeholders had a number of reservations concerning
the frequency bands put forward by the Commission in the consultation.
The key criticism, as noted above, is that the proposed harmonised frequency bands are
too narrow. The 822-832 MHz band is seen as not large enough to satisfy the needs of
wireless microphone users, especially considering the fact that, as some stakeholders point out,
the 821-823 MHz band is needed as a guard and therefore would not be usable for PMSE
39
applications . Some stakeholders even believe that the band would not be suitable for
40
professional use . The harmonisation of the 1785-1805 MHz band is seen as a solution to
some capacity problems, but stakeholders note that few units operate in that range and
41
broadcasters generally do not have such equipment . Finally, one respondent noted that the
42
band would only be viable for short-distance and indoor use .
The consultation also provided some data points concerning the costs to users of updating
wireless equipment.




one large broadcaster estimated the cost of replacing its entire wireless equipment pool
43
to be between €750,000 and €1m ;
a Swedish opera house stated that total investment to operate in a different band
44
amounted to €225,000 ;
an operator of a 160-seat theatre in Norway noted that the cost of replacing its wireless
45
system in order to be able to operate in the proposed bands would be €16,000 ’; and
a Danish Theatre noted that the cost of ensuring that equipment can function across the
46
EU would amount to approx. €3,000 per channel .
35
BEIRG consultation response
Copsey Communications and EBU consultation responses
37
ITN consultation response
38
ARD/ZDF consultation response
39
FICORA consultation response
40
BEIRG consultation response
41
ARD/ZDF consultation response
42
Audio Technica consultation response
43
Canal+ consultation response
44
GöteborgsOperan consultation response
45
Hordaland Theater consultation response
46
Odense Theater consultation response
36
40
With regard to spectrum for cordless cameras, stakeholder comments were similar. The
bands 1900-1920 MHz and 2010-2025 MHz bands are seen as insufficient for video camera
47
use, offering capacity for only one or two HDTV links . One stakeholder noted that these bands
48
could only be seen as a temporary solution to spectrum availability issues .
Other literature
In addition to the stakeholder consultation, other studies have explored the costs and
benefits of harmonising PMSE spectrum. The Indepen/Aegis Systems report on the costs
and benefits of relaxing the international frequency harmonisation and radio standards
considers the scenario of a more harmonised PMSE spectrum and its implications in the UK.
The identified impacts include:




reduction of instances where regulators would engage in interference
management. The authors of the study assume that this would only lead to a saving of
a fraction of UK regulator’s spectrum management cost, equalling to half person-year
per major event. Assuming five major events annually, this figure is estimated to be
£125,000 (€145,000);
potentially lower equipment cost due to economies of scale, although the authors
argue that the market demand is the main driver of equipment development, so such
savings would be minimal;
ability of touring shows to use same spectrum across Europe, although also here
the authors believe that the saving will be minimal, since existing equipment normally
allows touring shows to find spectrum also in a non-harmonised environment; and
potential cost of replacing equipment by users and the cost of moving existing users
49
to other parts of the spectrum within same bands .
Overall, the Indepen/Aegis Systems study finds that there would be little benefit to
harmonisation of spectrum for PMSE users, since it would likely reduce available PMSE
50
spectrum without bringing substantial mobility benefits or lowering equipment costs .
5.2
Survey results
The current analysis is based on 561 survey responses received until the survey closing
date on 21st April 2013 (additional responses were received from German users but these did
not cover all questions in the original survey). Most of the responses are from users (505
responses). In addition, we received 23 responses from manufacturers and 33 responses by
national regulators. It is important to note that for the purpose of this impact analysis a valid
response has been defined as one where the respondent entered their details into the survey
software (obvious duplicates and “test” responses were discarded). Therefore many of these
responses are incomplete: Average response rate to each survey question was 17% for
47
ARD/ZDF and EBU consultation responses
BnetzA consultation response
Indepen and Aegis Systems (2004). Costs and Benefits of Relaxing International frequency Harmonisation and Radio
Standards
50
Indepen and Aegis Systems (2004). Costs and Benefits of Relaxing International frequency Harmonisation and Radio
Standards
48
49
41
manufacturers, 28% for users and 29% for regulators. This means that survey findings related in
the report are generally based on data from 20%-30% of all respondents.
Despite overall good response rate, there are a few limitations:



Only one partially complete response was received from a manufacturer of cordless
cameras.
Although 32 responses to the regulator questionnaire were received, a number of these
were from multiple bodies in a single Member State. The responses to the regulator
questionnaire therefore cover 22 relevant countries.
The majority of users who responded to the questionnaire are based in either France,
the UK or Germany. Fewer user responses were received from other large Member
States.
5.2.1 Overview of user survey
Overall, the participants in the user survey came from 23 different countries. However, the
vast majority were based in the UK (120) and France (108). Most of the participants in the
survey use only wireless microphones and or in-ear monitors (73%). 24% of respondents
indicated that they use both wireless microphones and cordless cameras while a small minority
(2%) claimed to use only cordless cameras.
Almost all respondents to the survey are professional users (>95%) which is not surprising
given that this group has a strong incentive to feed into the development of PME spectrum
policy. In addition, the non-professional user category is less relevant for cordless cameras
which are used almost exclusively by professionals.
Consistent with the professional nature of the sample, most respondents use wireless
microphones very frequently with 63% indicating that they use such devices on a daily or
weekly basis and 25% indicating that they do so monthly, annually or irregularly.
Furthermore, 32% of respondents use wireless microphones and IEMs in “typical events”
in more than one EU Member State compared with 68% who only work in one country. To
bridge differences in spectrum regulations for microphones, users either purchase tuneable
devices (57%) or they hire the needed equipment in situ (about half of respondents 49% hire
equipment).
Finally, demand is expected to increase with 75% of users planning to invest in wireless
51
microphones in the next 5 years. More than three quarters of users expect an increase in
usage compared with only 20% who expect usage to remain stable. Furthermore, more than
one fifth of respondents believe the increase in use of wireless microphones to exceed 20%.
51
A share of this investment will relate to replacement of existing equipment.
42
Figure 6 - Expected usage of wireless microphones in the next 5 years
60%
51%
50%
40%
30%
22%
21%
20%
10%
4%
3%
decrease up to
20%
decrease over
20%
0%
increase over
20%
increase up to
20%
no change
It is interesting to notice that among the possible drivers of the usage of wireless devices
in the future, spectrum availability is the main factor perceived to lead to a reduction in
usage. On the other hand, major events and technological changes are likely to lead to
increases in usage. Equipment and licencing costs are not considered as important in
52
determining change in usage of wireless microphones.
Figure 7 – Factors driving change in use of wireless microphones and IEMs
Major events
64%
Licensing costs
65%
Technological
improvements
21%
32%
49%
Equipment Costs
Spectrum availability
When asked to indicate barriers to investment in wireless microphones, users expressed
a lack of confidence that currently available equipment would continue to work in the
future, a concern that can be directly traced back to uncertainty about which frequency bands
52
Note that not all countries charge licensing fees.
43
will continue to be available for PMSE. Similarly some users were unsure about the amount of
available spectrum in the future, with fewer users expressing concern about differences in
spectrum regulations across the EU.
Figure 8 – Importance of barriers to investment in wireless microphones (1=not important,
5=very important)
Option 1 - Do nothing
Several questions in the user survey assessed the impact of no EU intervention (option
1) on PMSE users. This refers to a case where no specific action is taken at EU level to secure
a long-term solution for PMSE spectrum access.
Please note that this option is different from a simple continuation of the status quo (i.e.
the current situation). For instance, the do nothing option may include initiatives at Member
State level that alter the way in which PMSE users access spectrum in some countries or
national and international level frequency reallocations. The precise nature of these initiatives is
not known at present and this study focuses solely on the value added of an EU initiative to find
53
a long term solution for PMSE spectrum access.
Generally, users thought that a lack of EU intervention would not have a large impact on
their business including the number of microphones per event (about 50% expect no change
with the remainder split equally between those who expect an increase and those who expect a
decrease), overall cost per event (about 40% expect no change, about 60% expect an increase)
and licensing costs per event (>60% expect no change).
When asked about expected development of the overall business over the next 5-10 years
(number and quality of events, etc.) in the absence of EU intervention, typical answers included
53
See Appendix 1 for a more detailed description of the assumptions underlying the different options and rationale for
these assumptions.
44
the following: “business as usual”, “grow steadily”, “carry on hopefully as I am” or “I doubt there
will be much change”. Other users thought spectrum demand would continue increasing thus
posing a problem in the future and yet others expect costs to increase in the absence of
intervention. Finally, a number of users referred to the impact on cultural output and enjoyment
across Europe if spectrum access for PMSE equipment is further reduced. On the whole, the
picture emerging from the user survey suggests an overall perception that there would be no
great impacts, coupled with a concern that there could be significant negative impacts if a
longer-term solution is not found.
Option 2 - Common tuning ranges
When asked about the impact of adopting common tuning ranges (option 2), a large number of
respondents claim they would be incentivised to purchase more devices and increase usage of
wireless microphones. However, the overall perception is that EU intervention would also
require them to update their equipment, thus incurring additional costs. In particular, UK users
are worried about losing access to CH38, which has required users to invest in new equipment
relatively recently.
Figure 9 – Key impacts of adopting common tuning ranges
60%
50%
40%
30%
52%
43%
20%
32%
22%
10%
25%
0%
More use of wireless Require different
microphones
wireless
microphones
More likely to
Reduce costs of Consider working in
purchase than rent spectrum licensing more EU countries
wireless
than now
microphones
If the 700Mhz band was excluded from option 2, most users predicted significant issues
for the use of current equipment and significant replacement costs (see Annex 3 for an overview
of responses to this question). Where negative impacts were identified these related to:



the need to purchase new equipment
the lack of available spectrum for larger scale productions
the need to move again after recent displacement from other frequency ranges
45
Nevertheless, this was not a unanimous position with very divided opinions ranging from
“no impact” to “devastating”. In the UK, more generally, the impact was seen as less severe
because of the use of Channel 38 in that country.
Finally in terms of the business impact of the common tuning range option, about 40% of
users expect increased use of wireless microphones, compared with about 50% who
expect no change. About 45% of respondents expect no change in the cost of wireless
microphones for a typical event and about an equal share expect an increase. At the same time,
more than two thirds of respondents expect no change in licensing costs.
Option 3 - Harmonised spectrum
When asked about the impact of adopting harmonised spectrum in the duplex gap in addition to
the tuning ranges in option 2, again most respondents claim this would require new equipment,
with a few stating that this option would lead to greater usage of microphones. One third of
users suggested that this option would entice them to purchase rather than rent PMSE
equipment. There does not seem to be much impact on cross-border or on the costs of
spectrum.
Figure 10 – Key impacts of adopting harmonised bands
Finally, the survey asked respondents to rank the different options available for wireless
microphones. The table below shows the share of respondents who considered each option to
rank first second or third.
46
Table 12 - Ranking of the three policy options from the users’ perspective
Best ranked
Second rank
Third ranked
Aggregate
preference54
Option 1: do nothing
32%
18%
50%
37%
Option 2: tuning
ranges
27%
60%
13%
45%
Option 3:
harmonised bands
41%
22%
36%
48%
41% of respondents rank Option 3: Common Tuning Ranges and Harmonised Spectrum
Availability as their preferred option, compared with 27% who prefer common tuning ranges
only. However, almost one in three users ranked doing nothing at EU level first which suggests
that for these users there is little added value in EU intervention compared with national level
intervention. From a different perspective, half (50%) of users consider doing nothing the worst
of the three options, followed by option 3 which is considered the worst by 36% of users. Option
2 does not elicit nearly as much opposition with only 13% of users considering this option the
worst. There are two key conclusions from this table:


the majority of users would like to see EU level intervention.
while option 3 sees the highest approval overall it also faces stronger opposition than
option 2
From the user perspective, option 2 could therefore be seen as a starting point for
negotiating a long-term solution for PMSE spectrum access for wireless microphones
User responses regarding cordless cameras
For cameras, a smaller number of users responded to the survey and the proposed
harmonisation initiative was less detailed than for microphones. Nevertheless some
interesting results can be obtained from the survey regarding current use of cordless cameras
and the impact of a limited spectrum harmonisation initiative at EU level.
46% of users who responded indicated that they frequently hold events in more than one
country. In addition 64% of users indicated their equipment is tuneable to work across most EU
countries. This is not surprising since users of cordless cameras tend to be professionals
including major broadcasters and news organisations that operate internationally. At the same
time,
In terms of future plans, 61% of respondents indicated that they would invest in cordless
cameras over the next 5-10 years. Reasons included equipment upgrades (e.g. HD) and
replacement. In addition 70% of users expected increased use of cordless cameras in the future
irrespective of any EU action. In terms of the drivers of this increase 70% suggested that this
increased use was due to the nature and number of major events and a full 87% suggested that
technology was one of the key drivers behind increased use. At the same time about half of
54
The aggregate is equal to the share of users who rank the option first plus 0.3* the share of users who ran the option
second.
47
respondents suggested that lack of spectrum could be a constraint on future use of cordless
cameras. Generally, equipment costs and licensing costs were seen as less important drivers of
change.
In terms of barriers to the current use of cordless cameras, 37% identified differences in the
frequency bands used in different EU countries, 50% suggested uncertainty over future
availability of spectrum and 40% cited a lack of confidence in their ability to use their current
equipment in the future.
Regarding the proposed harmonisation initiative (option 2: communion tuning ranges),
few users thought that this would require them to acquire different cameras. 42% of
thought that this option would enable them to make greater use of cordless cameras, 45% of
users indicated that they would be more likely to purchase rather than rent equipment and 47%
indicated that they would be likely to operate in additional EU countries
In terms of a ranking of the two harmonisation options 58% of users thought option 2
was the best way forward compared with 42% who preferred the do nothing option. By
way of qualitative feedback there were a number of common reactions among users, in
particular referring to lack of clarity in the definition of the options and the focus of the options
on harmonisation rather than the amount of spectrum available. Below two typical qualitative
comments provided by camera users:
“The proposed options are not clearly defined. The impact depends highly on the
amount of identified spectrum. Option 1 is not clear whether the current situation is
kept or further spectrum decisions may have an adverse effect on PMSE spectrum.
This survey doesn't reflect on our many concerns about the future of PMSE usage,
i.e. to supply sufficient spectrum for PMSE. The survey rather focuses on
harmonization on a national or European level.”
Another user provided the following comments:
“Our support for option 2 only applies if the current total quantity of available
channels in the 2GHz band does not decrease. Availability of quantity of spectrum
is more important than availability of a small harmonised spectrum. We are already
struggling to provide our current level of business demand now we have lost
access to 2GHz spectrum above 2500MHz in the UK. This is likely to have a
continued negative impact on our business.”
For option 2 in particular users noted that “4 channels for cordless cameras are not
sufficient to meet our demands of a "Typical Event" therefore we assume that sufficient
additional spectrum on a national basis is available.”
48
5.2.2 Overview of manufacturer survey
There are not many manufacturers of wireless microphones or cameras in Europe and
only a small number of responses to the survey were received (23). Despite the small
number of respondents, the survey has achieved a comprehensive coverage of the market with
submissions from a large number of key market players including Sennheiser, AKG, Audio
Technica, Robert Bosch, Shure and Sony Europe. Although market share information is not
available, these companies are likely to cover well above 50% of the EU market for wireless
microphones.
In terms of cross-border operability of equipment, 10 manufacturers indicated that their
equipment was tuneable across most or all of the European Union. However, uncertainty
about availability of spectrum and lack of consumer confidence are seen as key barriers to
growth. As one manufacturer states,
“there is enough spectrum for normal day to day use, however not enough
spectrum for big events. The big fear is that even more spectrum will be
assigned to other services, which will have influence on the day to day use
in the future.”
There were quite diverse opinions on the evolution of the market if no EU level action is
undertaken. This may be partly due to the fact that national solutions to a growing problem of
spectrum availability will differ. Some manufacturers indicated for instance that their production
costs would decrease (perhaps as a result of reduced investment in product development under
this option) whereas others thought they would increase due to lack of economies of scale. In
terms of R&D, the do nothing option could lead to increased investment as manufacturers have
to grapple with lower availability of spectrum. At the same time, most manufacturers thought
their sales would decrease significantly (more than 10%) if no action is undertaken at EU level.
Under option 2 (common tuning ranges), manufacturers presented again a divided
picture. Four respondents thought this option might require changes to their production line,
and require more investment in R&D, whereas 5 respondents thought this option would
increase customer investment in wireless microphones. Manufacturers did not expect this
option to affect their entering of new EU markets or leading to falling production costs. Indeed,
most respondents already operate in several EU countries.
On the crucial question of the impact of this option if the 700MHz band was not included,
those manufacturers who provided a response, thought that the impact would be severe.
The table below shows a sample of the most relevant responses:
49
Table 13 - Impact of removing the 700MHz band from option 2
Including 698 - 790 would be in line with the US/FCC market
We would lose sales. Big problems for big setups and unsafe operations
This would have a strong impact for the majority of users, as in many countries this band is
assigned for wireless microphones and IEM's by national regulation.
more investment in R&D
Large events may not be feasible. All specified spectrum (60MHz) should be inside 470790MHz for professional use
The impact will be terrible for users and productions. Very expensive to change frequencies
on units.
As the UHF TV band is the core band for our industry the market potential because of
available spectrum would collapse
Regarding option 3 (harmonised spectrum), manufacturers did not expect the impacts of
this option to differ significantly from option 2. However, a number of qualitative comments
were made which are reported in the table below.
Table 14 - Qualitative input from manufacturers regarding option 3
Option 3 is not attractive [name of organisation removed]: 470 - 790 is the important frequency
range/market also due to physical characteristics
This tuning range is used by many professional users today. Future access need to be
provided to support the ability to produce cultural events with high social impact for the EU.
Big events not feasible. All specified spectrum (30MHz) should be inside 470-790MHz for
professional use
We believe that 30MHz of spectrum is way too little to accommodate daily event productions.
100 MHz of interference free spectrum in the UHF TV band is needed. The bands 821-832MHz
suffer from interference from 4G user equipment Out Of Band emissions. Measurements show
that just a small part of these bands usable. This would require users to switch of their cell
phones before production starts. 4G standards have to amended in order to get better 4G
filtering. Any further erosion of the UHF TV band is a danger to our industry
New frequency bands need to be produced.
We will need to study heavily on very sophisticated equipment to deal with more hostile
environments and less available spectrum. The proposed harmonised bands have too much
noise and the other 30MHz tuning ranges are too little.
We will receive more customer complaints.
Sales increase is envisaged due to market expansion and not due to common tuning ranges.
821 - 832 MHz and 1785-1805 MHz are duplex center frequencies of LTE services. Actual
studies show that these bands can be only used for specific PMSE applications and not usable
for high professional users due to interference generated by LTE services.
All specified spectrum (30MHz) should be inside 470-790MHz for professional use.
Harmonised spectrum not usable for professional applications.
These bands are already available in most other European countries. The band 470-790 MHz
is very difficult to access in Spain and Belgium and the European Union should do all they can
to have this band available for wireless microphones.
The band 29.7 till 98 MHz is unusable due to long antennas and a too high noise floor and
interferences from e.g. computers.
Measurements show the band 821-832 MHZ will suffer from Out Of Band (OOB) emissions
from 4G cell phones used in the venue. To secure the quality of service of productions these
cell phones must be switched off in the venue to enable the use of radio microphones in the
band.
Same is applicable to the band 863-865MHz. 4G cell phones must be switched of in the venue
in order not to interfere on radio microphones.
50
The band 1785 till 1805MHz is still a GSM band with no interference probability on radio
microphones. When this band would be turned into 4G the same interferences from 4G cell
phones on radio microphones will occur. Due to the propagation characteristics of frequencies
above 1 GHz the band 1785-1805MHz can only be used in “line of sight” between transmitter
and receiver.
Finally, when asked to rank the three options, manufacturers generally agree that option
3 would be most beneficial, followed by option 2. Option 1 (do nothing) is seen as the worst
course of action by most respondents. Additional comments on the options for wireless
microphones included the following
Table 15 - Additional qualitative assessment of options
the most positive impact on our business would be if PMSE in the EU became more aligned
with US/FCC bandwidth rules
470 - 790 MHz is the key spectrum and needed as common tuning range; the suggested
harmonized frequency bands are needed for specific PMSE applications on a license free
basis. In addition the band at 1.5 GHz, which is currently under discussion within CEPT, shall
be harmonized as we need replacement for the DD1 (790 - 862 MHz).
No option is perfect. EU comission should specify the spectrum inside 470-790MHz for
professional use. All the other spectrum suffers from other services or man made noise and is
not usable for professional applications.
We highly welcome this initiative of the European Union to get acquainted with our industry!
100MHz of interference free UHF-TV band spectrum is needed to accommodate the daily
productions and should preferably be Europe wide harmonised. EU should also harmonise
licensing regime, preferably license exempt with the least administrative burdens and costs.
European Union has to understand that our industry is not that organised and well financed to
do lot of lobby activity. The Union should not follow that much the IMT (International
Telecommunications Industry) lobbyists but should try to understand and defend the interest of
our industry and take care of its needs. Our industry needs a secured, reliable and stable long
term spectrum availability globally.
In addition, a representative of the PMSE association in the Netherlands suggested that
“because of changing frequency allocations and developing new technologies a lot of
equipment will become redundant. The 1st DD will make 30-50% of the current used
equipment redundant. Demand for wireless channels will grow in the future so investments will
be needed.”
It should be noted that only one full response was received from a camera manufacturer.
This company considered the key issue to be competition from outside the EU rather than
spectrum availability. They advocated that the EU should adopt a ‘do nothing’ approach
regarding spectrum access, as the proposed option would require them to re-design their
products.
51
5.2.3 Overview of regulator survey
The survey results include responses from national regulators covering 23 European countries.
One key result of the survey is an overall lack of coordination among European countries
for what concerns PMSE spectrum. While some countries (i.e. Germany and Belgium) follow
ERC Recommendation 70-03, others have specific agreements on border usage of wireless
devices (similar responses were given for both wireless microphones and cordless cameras).
Regarding licencing revenues, all regulators provide very low figures mainly because
licencing is free in most countries and usually spectrum (such as the 470-790 MHz band) can
be used by PMSE on a secondary basis.
The figure below shows the key barriers to growth for wireless microphones from the
perspective of regulators. Lack of spectrum is seen as the key concern, followed by
uncertainty about future regulation. Licensing costs, market fragmentation and information
regarding demand for spectrum are seen as less important barriers to the industry.
Figure 11 - Number of regulators who consider each driver as a major barrier to PMSE
From a qualitative point of view several regulators provided additional insights into the
key barriers to the market, including mentions of a lack of harmonisation in conditions of use,
and a focus on the decrease not just of spectrum but of white space spectrum in particular.
Demand for spectrum from non-PMSE applications (in particular, mobile services) and
technological change in the wireless microphones market are the two major drivers for
change, from the perspective of national regulators. In contrast, increasing demand from PMSE
applications themselves are seen as less significant market drivers. A revision of licencing
52
conditions (often to introduce a form of light licensing) is currently ongoing in a number of
countries.
When asked about the potential impact of policy option 2 (common tuning ranges) most
regulators recognize that this solution would favour the cross-border portability of
equipment and more importantly, it would allow for a more efficient use of available
spectrum. Regarding the possibility of not including the 698-790MHz in the common tuning
ranges, some regulators express a strong preference to leave such spectrum portion to mobile
services while others recognize that without this spectrum, the usability of PMSE would
decrease dramatically. The majority of regulators do not however foresee any change from their
perspective in terms of the relative desirability of each option.
Some respondents point out that currently they refer to ERC Recommendation 70-03 and
for this reason there would be no particular need for further non-binding intervention. As
one respondent points out: “In general, common tuning ranges could, to some extent, reduce
the level of uncertainty for audio-PMSE users and manufacturers. However, common tuning
ranges are already recommended by ERC Recommendations 25-10 and 70-03 within CEPT.
The implementation of these recommendations on national level is a well-established method.”
Regulators seem to agree that option 2 would not lead to greater coordination across
Member States, it would not increase registration/licensing of PMSE applications or lead
to more accurate monitoring of demand and supply. In addition, most regulators do not
foresee any particular change in terms of licencing revenues or regulatory costs. Typical
comments included queries about how the EU recommendation would relate to ERC
Recommendation 70-03 and what the difference between this option and the current situation
would be from the regulator’s perspective. Generally, regulators did not perceive much added
value from this option compared with the status quo and further clarification would be required
to set out those differences in greater detail. Furthermore one regulator suggested that:
“An EU harmonisation measure including the bands 29.7-68MHz and 174216MHz would need another legal base [..]parts of the band 29.7-68MHz are
under shared civil-military use, partly under military use only. This has to be
taken into account, if an EU harmonisation measure (including a non-binding
EU recommendation) would be considered. Currently, the band 470 - 790
MHz is the core band for professional wireless microphones and IEMs due to
physical and technical reasons. It is expected that in the foreseeable future a
certain amount of spectrum in this range will still be required. With the
proposed Option 2 it would be possible to completely realise the
recommended “at least 60 MHz” outside this core band. In particular for large
events the recommended total amount of “at least 60 MHz” might be not
sufficient to fulfil the demand. We do not see the need of the proposal in the
sentence explaining Option 2 (“A document showing availability of bands in
each EU country together with licensing rules will be made available.”) These
information are already gathered and electronically available in the ECO
Frequency Information System (www.efis.dk). To draft (and maintain) an
53
additional “document” produces additional effort and the risk of obsolete or
diverging information.”
There were no large differences in regulator responses to option 3 compared with option
2. If anything, regulators seem to consider that this option would lead to less efficient spectrum
allocation (probably due to the binding assignment of the duplex gap to PMSE). Option 3 would
not dramatically change licencing revenues, while some regulators commented that this solution
would reduce their regulatory costs and have a positive impact on PMSE use.
In their overall ranking, regulators again had similar preferences to users. Option 3 is
preferred by 9 respondents but it is also the least preferred option for 9 respondents. Option 1
(do nothing) is clearly seen as the least preferred with 12 regulators indicating this option in rank
3. Option 2 is the least controversial, with only one regulator ranking this option the worst of the
three and 15 respondents considering this the best option.
Regarding cameras, regulators provided very similar answers to the questions on
wireless microphones. Whilst the common tuning ranges specified in the option are not seen
as a long term answer to spectrum needs, a majority of regulators prefers option 2 to the do
nothing approach. Typical qualitative responses to the policy options included the following:
Table 16 - Qualitative input from regulators on cordless camera options
Wider tuning range approach / two tuning ranges would be proposed: 2 - 2.5 GHz & 3.2 - 3.4
GHz.
The questions raised above do not completely cover the issue. From our point of view, it is
key to find additional/new spectrum resources.
The issue is as a whole insignificant in our work.
In our view the tuning range of wireless cameras could be extended up to 6 GHz.
These proposals do not result in improvements to the current situation for wireless cameras.
54
6.0
Quantitative impact modelling
This section presents the results of the quantitative impact modelling for each of the options and
for each type of PMSE equipment covered in the study.
6.1
Wireless microphones
The tables below show the monetary impact of the policy options for wireless
microphones for the three stakeholder groups (manufacturers, users, and regulators). This
analysis is based on the narrow definition of PMSE covering the direct market for PMSE
equipment and its use.
The tables show the impact of each option for different stakeholders groups after a
period of 5-10 years. Figures compare the situation under each option to the current scenario
(status quo). Option 1 refers to a situation where no EU level intervention takes place with each
Member State addressing spectrum access for PMSE equipment through national level
intervention, option 2 refers to an EU recommendation of at least 60MHz of common tuning
ranges (as described in section 4) and option 3 refers to the development of 30MHz of binding
harmonised PMSE spectrum in addition to 30 MHz in common tuning ranges.
Costs and benefits for manufacturers refer to changes in production costs or revenue
(e.g. market size) that manufacturers think would materialise under each scenario. To
illustrate how the impacts would affect market players, we have modelled the impacts on a
hypothetical company holding 5% of market share.
The results indicate that:



Under option 1 (no EU intervention), manufacturers stand to lose between EUR
9.4 and 13.5m overall across the EU market over the next 5-10 years. While
production costs would decrease under this option, total sales would also fall reflecting
user concern with availability of spectrum in different Member States. For a company
holding 5% of market share this translates into a loss of EUR 470,000-675,000
compared with the current situation.
Under option 2 (tuning ranges), manufacturers would stand to gain EUR 11m
compared with option 1. While this option is still not favourable compared to the status
quo, in the event that the status quo cannot be maintained, option 2 represents a
significant improvement for manufacturers. Specifically, manufacturers expect a
combination of rising production costs (presumably to invest in equipment that operates
in the tuning ranges) and rising sales (as users invest in new equipment). Under this
option, a hypothetical company holding 5% market share in wireless microphones
would stand to gain about EUR 547,000 compared with the do nothing option.
Option 3 represents an absolute improvement of EUR 13.5 compared with option
1. Option 3 is therefore an absolute improvement over the current situation as well as
over options 1 and 2, mainly due to a rise in sales compared with option 2 and
compared with the status quo. The availability of harmonised spectrum would generate
benefits of about EUR 13.5m for manufacturers compared with option 1, which
55
corresponds to about EUR 675,000 for a hypothetical manufacturer holding about 5
percent of the overall market.
On the basis of the analysis and under the model assumptions, option 3 (30Mhz of
harmonised spectrum combined with 30Mhz of common tuning ranges) represents the
most cost-beneficial outcome for manufacturers, generating about EUR 13.5 million in
net benefits compared with option 1 over 5-10 years.
However, it should be noted that the economic impacts across all options are quite
limited. A total net benefit of EUR 13.5m over 5-10 years across the entire EU 27 market is
unlikely to make a significant difference to the industry as a whole.
56
Table 17 - Impact on manufacturers
Aggregate
Hypothetical
company
Total additional costs
compared with today
Total additional benefits
compared with today
Overall impact compared with today
Min
Max
Min
Max
Low impact
High impact
Average
Overall impact
compared with
do-nothing
Average
Option 1
€ 10,913,522
€ 15,763,977
€ 1,503,641
€ 2,255,461
-€ 9,409,882
-€ 13,508,516
-€ 11,459,199
€-
Option 2
€ 2,255,461
€ 3,007,282
€ 1,414,716
€ 2,829,432
-€ 840,745
-€ 177,850
-€ 509,298
€ 10,949,901
Option 3
€ 1,754,248
€ 2,631,372
€ 2,829,432
€ 5,658,863
€ 1,075,184
€ 3,027,492
€ 2,051,338
€ 13,510,537
Option 1
€ 545,676
€ 788,199
€ 75,182
€ 112,773
-€ 470,494
-€ 675,426
-€ 572,960
€-
Option 2
€ 112,773
€ 150,364
€ 70,736
€ 141,472
-€ 42,037
-€ 8,892
-€ 25,465
€ 547,495
Option 3
€ 87,712
€ 131,569
€ 141,472
€ 282,943
€ 53,759
€ 151,375
€ 102,567
€ 675,527
57
For users, costs and benefits refer to changes in licensing and equipment costs under
each scenario. These are calculated on the basis of three hypothetical events based on survey
findings, where event 1 is a large event (10 or more links used) taking place daily, event 2: is a
large event taking place monthly, and event 3 is a small event (fewer than 10 links used) taking
place daily. The method for arriving at these event types is described in more detail in the
Annex.
According to the user survey, neither licensing nor equipment costs are likely to reduce
as a result of any of the proposed policy options, compared with the status quo. On
average PMSE users believe that costs will increase. This does not necessarily mean that
options 2 and 3 would lead to higher costs, but rather implies that they are unlikely to address
the underlying trend of rising costs as perceived by PMSE users.
It is important to note, however, that cost increases as a result of equipment and
licensing will differ under each option. To illustrate how the impacts would affect market
players, we have modelled the impacts on users putting on three types of events of different
sizes (described above). The results indicate that:


Taking only licensing and equipment costs into account, options 2 and 3 are both
marginally less costly than option 1, with option 2 resulting in the lowest costs to users
overall.
For all event types, the difference between the net impact of each option is however
quite limited.
Table 18 – Impact on users (per event)
Low impact
High impact
Average
Overall impact
compared with donothing
Average
Option 1
-€ 682.16
-€ 1,188.71
-€ 935.43
€-
Option 2
-€ 584.96
-€ 1,038.37
-€ 811.66
€ 123.77
Option 3
-€ 641.95
-€ 1,106.80
-€ 874.37
€ 61.06
Option 1
-€ 185.94
-€ 324.45
-€ 255.20
€-
Option 2
-€ 161.29
-€ 286.41
-€ 223.85
€ 31.35
Option 3
Option 1
Option 2
-€ 177.64
-€ 85.17
-€ 73.27
-€ 306.52
-€ 148.47
-€ 130.08
-€ 242.08
-€ 116.82
-€ 101.68
€ 13.12
€€ 15.14
Option 3
-€ 80.49
-€ 138.81
-€ 109.65
€ 7.16
Overall impact compared with today
Event 1
Event 2
Event 3
The key challenge is to estimate the aggregate impact on users. Arriving at such an
estimate requires information on the total number of events of different types taking place in the
EU in a given year. APWPT estimates that for microphones, “the total number of channels being
55
deployed is about 10 million” . Assuming that this represents the total number of channels used
55
Association of Professional Wireless Production Technologies, 2012
58
for wireless microphones in a given year, this information can be combined with information on
impact on users per channel to yield an aggregate impact figure for users.
In order to obtain an estimate of impact per channel, one can use an average number of
wireless microphones used for these events (assuming a microphone per channel) collected
through the survey. This is outlined in the table below.
Table 19 - Impact on users per channel
Option 1
-€ 935.43
Average
number of
channels
12
Option 2
-€ 811.66
12
-€ 67.64
Option 3
-€ 874.37
12
-€ 72.86
Option 1
-€ 255.20
12
-€ 21.27
Option 2
-€ 223.85
12
-€ 18.65
Option 3
Option 1
Option 2
-€ 242.08
-€ 116.82
-€ 101.68
12
4
4
-€ 20.17
-€ 29.20
-€ 25.42
Option 3
-€ 109.65
4
-€ 27.41
Average impact
Event 1
Event 2
Event 3
Impact per
channel
-€ 77.95
The impact estimate range can in turn be combined with the estimate of 10 million channels
used in the EU to arrive at an aggregate impact estimate, as shown in the table below.
59
Table 20 - Aggregate impact on users
Cost per channel
Min
Max
Option 1
-€ 21.27
-€ 77.95
Option 2
-€ 18.65
Option 3
-€ 20.17
Total number
of channels
Overall impact
compared with
do-nothing
Aggregate impact
Min
Max
Average
10 million
-€ 212,664,768
-€ 779,525,873
-€ 496,095,321
-€ 67.64
10 million
-€ 186,543,388
-€ 676,386,471
-€ 431,464,929
€ 64,630,392
-€ 72.86
10 million
-€ 201,732,360
-€ 728,644,618
-€ 465,188,489
€ 30,906,832
60
On the basis of the analysis and under the model assumptions, option 2 (tuning ranges)
represents the most cost-beneficial outcome for users.
For regulators, costs and benefits refer to changes in licensing revenue and regulatory
costs under each scenario. The results indicate that:



On average, all options generate primarily costs to regulators in terms of regulatory
coordination,
Taking only licensing revenue and administrative costs into account, option 3
represents the least costly option under the assumptions of the model
For all options, the absolute net impact of each option is very limited.
On the basis of the analysis and under the model assumptions, option 3 (harmonised
bands) represents the most cost-beneficial outcome for regulators.
61
Table 21 - Impact on regulators (EU28 aggregate)
Total additional
Total additional
costs compared with benefits compared
today
with today
Min
Max
Min
Max
Option
€
EU28
€ 23,635
€ 8,960
€ 17,919
1
13,131
Option
€
€ 39,684
€ 5,973
€ 11,946
2
24,802
Option
€
€ 22,322
€ 13,539
€ 23,693
3
15,944
Min
Max
Average
Overall impact
compared with donothing
Average
-€ 4,171
-€ 5,716
-€ 4,943
€-
-€ 18,829
-€ 27,738
-€ 23,284
-€ 18,340
-€ 2,405
€ 1,371
-€ 517
€ 4,426
Overall impact compared with today
62
Box 2 - Impact of removing the 698-790 MHz band (“700 band”) from the list of common
tuning ranges under option 2
The analysis undertaken as part of the study treated options as packages of measures rather
than individual measures focusing on specific frequency bands. For option 2 (‘common tuning
ranges’) this means that the cost benefit analysis reflects the potential impact of designating a
number of tuning ranges already used for PMSE (including the 700 band) as common tuning
ranges rather than the sum of impacts associated with each single tuning range being
designated as a common tuning range. This simplifies the analysis and ensures that the
analysis focuses of broad EU policy directions rather than relative merits of individual frequency
bands.
This approach however means that it is not possible to isolate the monetary impact of removing
the 700 band from the policy options. However, the survey respondents were asked for their
views regarding the possibility of this band not being included in the common tuning ranges.
Overall, respondents generally identified the band as a key band for PMSE use and noted that
not being able to use the band would imply, potentially substantial, additional equipment costs,
in case of users, and additional investment or loss of sales in case of manufacturers. At the
same time, it is important to note that the Impact of not including the band in the set of common
tuning ranges will only materialise if the band becomes allocated to non-PMSE uses across a
selection of Member States, since this would reduce the amount of available PMSE spectrum
and increase fragmentation. Since the band is already widely used for PMSE across the EU, if
such reallocation does not take place, it is unlikely that not including the band in a set of
common tuning ranges will have immediate material consequences other than increasing
uncertainty about this key PMSE band.
6.2
Cordless cameras
The tables in this section show the monetary impact of the policy options for cordless cameras
for the three stakeholder groups (manufacturers, users, and regulators). This analysis is based
on the narrow definition of PMSE covering the direct market for PMSE equipment and its use.
The tables show the impact of each option for different stakeholders groups after a
period of 5-10 years. In each case, similar to the analysis for wireless microphones, the
estimates first compare each option to the status quo (i.e. the present situation) and then to
option 1 (do nothing at EU level). This allows for an analysis of the overall impact of each option
compared with the situation today and a relative assessment of the options against one another.
Costs and benefits for manufacturers refer to changes in production costs or revenue
(e.g. market size) that manufacturers think would materialise under each scenario. To
illustrate how the impacts would affect market players, we have modelled the impacts on a
hypothetical company holding 5% of market share.
63
For manufacturers, option 2 (tuning ranges) imposes significantly less costs than option
56
1 (do nothing), resulting in an overall positive impact of EUR 2 million. For a hypothetical
company holding 5% market share the cordless camera/transmitter market, this translates into a
total positive impact of about EUR 100,000 per company. On the basis of the analysis and
under the model assumptions, option 2 represents the most cost-beneficial outcome for
manufacturers.
Users showed no particular preference for either option 1 (do nothing) or option 2
(common tuning ranges) with regard to costs of a hypothetical event (described in more
57
detail in the Annex). The average user expects a small additional net cost of about EUR 330
per event under both options. On the basis of the analysis, there is no difference to users
regarding the two proposed options.
For regulators, costs and benefits refer to changes in licensing revenue and
administrative costs under each scenario. Under option 1, regulators expect additional
licensing revenue to be generated and they also expect regulatory costs to increase. On
balance, option 1 (do nothing at EU level) would have a significant positive impact on regulators
compared with the status quo. Under option 2 regulators expect additional regulatory costs
compared with option 1 (presumably due to the required coordination at EU level) but a lower
increase in licensing revenues. As a result, option 2 (tuning ranges) as it is specified now, is not
seen as cost-effective for regulators. However, it should be noted that difference between the
net impact of each option is very limited and further research will be required once the tuning
ranges have been specified more precisely. On the basis of the analysis and under the model
assumptions, option 1 (do nothing) represents the most cost-beneficial outcome for regulators.
56
It should be noted that manufacturers expect the future under any scenario, with or without EU level intervention to be
worse than their current situation (status quo). Under option 1 (no EU level action) the loss compared with the status
quo can be attributed primarily to expected fall in sales (due to worsening spectrum availability, fragmentation and
continued regulatory uncertainty) and under option 2 (EU level tuning ranges) to rising costs (presumably as a result of
adaptations required).
57
As for manufacturers, users also expect a deterioration compared with the status quo with or without EU intervention.
64
Table 22 – Impact on manufacturers
Aggregate
Option
1
Option
2
Total additional costs
compared with today
Total additional benefits
compared with today
Min
Max
Min
Max
€ 2,070,613
€ 2,990,885
€ 285,284
€ 427,927
€ 427,927
€ 570,569
€ 268,413
€ 536,826
Table 23 - Impact on regulators (EU28 aggregate)
Total additional
Total additional
costs compared
benefits compared
with today
with today
Min
Max
Min
Max
Option
€
EU28
€ 5,252
€ 7,878
€ 29,866
1
14,933
Option
€
€ 20,834 € 6,346
€ 12,693
2
11,905
Overall impact compared with today
Low
impact
-€
1,785,329
-€ 159,514
Overall impact
compared with
do-nothing
High impact
Average
Average
-€ 2,562,959
-€ 2,174,144
€-
-€ 33,743
-€ 96,629
€ 2,077,515
Overall impact compared with
today
Overall impact compared with
option 1
Min
Max
Average
Average
€ 9,681
€ 21,987
€ 15,834
€-
-€ 5,559
-€ 8,141
-€ 6,850
-€ 22,684
65
6.3
Sensitivity testing
Sensitivity testing allows us to investigate how changes in the assumptions underlying the
modelling process influence the final outcome of the analysis. In the above tables, the key
assumptions involve:


the effect data coding; and
baseline data where it is not obtained from survey results.
In the following sections we perform two separate sensitivity tests focusing on the above assumptions.
Sensitivity test 1: Data coding
With regard to the effect data coding, explained in more detail in the Annex, changing the
mapping of questionnaire response options to quantitative estimates will have an impact on
the final impact estimates. The table below outlines the effect of using wider coding ranges (10%
and 20% instead of 5% and 10%) on the overall average impact estimates for wireless microphones.
Table 24 - Sensitivity testing - effect data coding
Original coding
Revised coding
Manufacturers
(Aggregate)
Users
(Event 1)
Regulators
(Aggregate)
Manufacturers
(Aggregate)
Users
(Event 1)
Regulators
(Aggregate)
Option 1
-€ 11,459,199
-€ 935
-€ 4,943
-€ 14,721,129
-€ 858
-€ 6,797
Option 2
-€ 509,298
-€ 812
-€ 23,284
-€ 2,344,386
-€ 717
-€ 27,510
Option 3
€ 2,051,338
-€ 874
-€ 517
€ 198,060
-€ 819
-€ 8,587
As the above table shows, for manufacturers and users the average impact estimates do
change, but the ranking of options remains the same (option 3 for manufacturers and option 2
for users remain most cost-effective). The main change occurs in the case of regulators, where the
average impact of all options remains negative (i.e. costs of regulation offset increase in licensing
revenues), but option 3 is no longer the preferred option. Although this is a significant change, the
actual impact figures are relatively small and are unlikely to change the result of the analysis once all
the impacts are aggregated.
Sensitivity test 2: Baseline assumptions
The other set of assumptions that has an effect on impact estimates are baseline data
assumptions. These are relevant to manufacturer baseline data, since unlike in the case of users and
regulators, these were not obtained from the survey. Although the assumptions used to arrive at
market size estimates (especially in the case of cordless cameras where less information is available)
will have an impact on the total magnitude of the impacts, they will not affect the ranking of the options
in terms of cost-effectiveness. This ranking can only be influenced by the estimate of manufacturer
costs as a proportion of value sales. The figure below shows the relationship between cost estimates
(expressed as a % of sales) and the average impact of each option for wireless microphones.
Digital
Agenda for
Europe
Figure 12 - Sensitivity testing - Impact of different cost estimates
As the above figure shows, option 3 remains the preferred option for manufacturers regardless of the
cost estimate used. This does not mean that option 3 remains the preferred option overall, since
impact on users and regulators also needs to be taken into account. The aggregation of impacts
across the three stakeholder groups is discussed in the next section
67
7.0
Options appraisal and recommendations
The previous section has presented the results of the quantitative analysis for each option and for
different stakeholder groups. This section aggregates these impacts to develop an overall options
appraisal for wireless microphones and for cordless cameras including the key qualitative comments
provided by stakeholders.
7.1
Wireless microphones
The final element of the impact analysis is to combine the impact estimates for the three
stakeholder groups to select the most cost-effective policy option on EU level. Combining the
aggregate impact estimates for manufacturers, regulators and users presented in the previous section
yields the following aggregate impact figures.
Table 25 - Aggregate impact
Aggregate
impact:
Manufacturers
Aggregate
impact:
Regulators
Aggregate
impact: Users
Total impact
Option 1
-€ 11,459,000
-€ 5,000
-€ 496,095,500
-€ 507,559,500
Option 2
-€ 509,500
-€ 23,000
-€ 431,465,000
-€ 431,997,500
Impact
compared
with donothing
Additional qualitative
assessment (survey)

€ 75,562,000

€ 2,051,500
Option 3
-€ 500
-€ 465,188,500
-€ 463,137,500
€ 44,422,000


Option 3 has
highest regulator,
manufacturer &
user approval
Majority of users
would like to see
some EU level
intervention
Option 3 has
highest user
approval overall but
also stronger
opposition than
option 2
Option 2 is the least
controversial option
Note: figures rounded to nearest EUR 500, subject to sensitivity analysis
The results indicate that the aggregate impact on users is significantly higher than impact on
the other stakeholder groups and policy option 2 (tuning ranges) represents the most costbeneficial policy option on aggregate level. This corresponds with the preference of stakeholders
expressed in the survey.
7.2
Cordless cameras
The table below shows the aggregate impact for manufacturers and regulators for the cordless
camera policy options.
Table 26 - Aggregate impact: Manufacturers and regulators
Aggregate
impact:
Manufacturers
Aggregate
impact:
Regulators
Option 1
-€ 2,174,000
€ 16,000
Option 2
-€ 96,500
-€ 7,000
Aggregate
impact:
Users
No
quantitative
data
available
No
Combined
impact
Impact
compared
with do
nothing
Additional qualitative
assessment (survey)

-€ 2,158,500
-€ 103,500

€ 2,055,000

Option 2 preferred by
regulators
Insufficient information from
manufacturers
Majority of users prefer
68
quantitative
data
available


option 2
Lack of clarity over the
content of the option
40MHz not considered
sufficient
Note: figures rounded to nearest EUR 500, subject to sensitivity analysis
There is no secondary information available on the aggregate use of cordless cameras in the EU,
which means that estimating the aggregate impact on users would require considerably more
assumptions than in the case of wireless microphones. This would in turn mean that the final impact
estimates are likely to be highly unreliable. Nevertheless, it is possible to draw conclusions about the
individual policy options without arriving at the aggregate figures. In particular, by looking at the user
impact data it is possible to conclude that:


7.3
Option 1 is likely to remain the most costly option also when aggregate user impact figures are
included, since the impact on users is practically identical for both policy options. Therefore,
option 2 would be the preferred option on aggregate level.
However, it should be noted that, in order to yield maximum benefits, option 2 would need
to be further specified in terms of the most suitable frequency bands to be made
available on a tuning range basis.
Recommendations
The impact analysis has produced results regarding the relative impact of the different options
considered in this study. The following recommendations emerge from the study:
1. For both wireless microphones and cordless cameras, the analysis suggests that
option 2 (common tuning ranges) should be taken forward. This conclusion is supported
both by the quantitative analysis (i.e. option 2 is most cost-beneficial for both types of
equipment) and by the qualitative assessment (this option is least controversial across
different stakeholder groups). Finally, in the case of wireless microphones, option 2 leaves
greater flexibility in terms of the precise frequency bands to be made available than option 3
(which specifies specific harmonised bands). This is particularly important for professional
users, for whom the quality of spectrum in the duplex gaps is insufficient.
2. In both cases additional research has been carried out to ensure that the common
tuning ranges that are specified correspond with technical feasibility requirements. For
cordless cameras, issues of technical feasibility are currently being investigated by CEPT. For
wireless microphones a technical assessment has been conducted and this should be taken
into account in any eventual initiative by the Commission. It is important to take into account
stakeholder comments not just on the amount of spectrum made available for PMSE but also
its quality and appropriateness for different types of uses.
3. Rather than seeing the options covered in this study as comprehensive solutions to the
spectrum issues faced by the PMSE industry, they should be seen as a strategic
starting point in negotiating future changes from the status quo. There is a need to
establish a process for refining the options in line with the present cost-benefit analysis and
stakeholder comments.
69
Annex 1: Impact modelling methodology
This annex presents our approach and key assumptions of the impact analysis model.
A.1.1 Scope, objectives and assumptions of the model
Scope
The quantitative analysis of impacts focuses on the primary effects of the policy options proposed in
section 4.1 and 4.2. In accordance with the description in section 2.3 this includes:



PMSE manufacturers;
PMSE users; and
regulators.
In other words, the quantitative analysis focuses on a “narrow” definition of the value of PMSE.
Secondary effects are analysed qualitatively.
Objective
This study will feed into a European Commission impact assessment. The objective of the study is not
to analyse the impact of spectrum scarcity on the PMSE industry. Rather, the analysis aims to
assess the added value of EU action as set out in the policy options described above.
Assumptions
Given the above objective, an assumption has to be made about what would happen at Member State
level in the absence of EU action.
The “status quo” scenario refers to the current situation in terms of availability and access to
spectrum for the PMSE industry across Europe. As discussed above, this status quo, though a
useful comparator to assess the absolute impact of each option on the industry, is not a long-term
solution, given competing demands for spectrum from different types of applications and strategic
priorities at EU and national levels (e.g. implementation of the first digital dividend or the current
discussion on the 700MHz band).
The “do nothing” scenario assumes that actions will be taken at national level to ensure
sufficient PMSE spectrum availability in each Member State, though different solutions would
likely be found in each country in the absence of EU coordination. It is reasonable to assume that
most Member States (especially those with a significant PMSE industry) would take steps even in the
absence of EU intervention, to grant continued spectrum access to PMSE equipment to allow the
cultural and creative industries to continue to function. However, in the absence of a coordinated EU
response, there is a risk that some Member States might not realise the impact of planned spectrum
reallocation on the PMSE industry or that they might simply not be able to find a solution that provides
a minimum of spectrum to PMSE users. Similarly, some Members states might opt for a succession of
short term “fixes” that provide a temporary spectrum home for PMSE but which require the industry to
move frequently to different bands.
This means that, by definition, the added value of any EU initiative does not lie in making
sufficient spectrum available to the PMSE industry. This is, in fact the task of national regulators.
58
Rather, the value of EU action (as laid down in the RSPP , articles 8.5 and 6.6) in this case lies in:
58
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:081:0007:0017:EN:PDF
70


seeking to ensure the necessary frequency bands for PMSE, in accordance with the Union’s
objectives to improve the integration of the internal market and access to culture
ensuring that the freeing of the 800 MHz band does not adversely affect programme making
and special events (PMSE) users.
It should be noted that these assumptions were adopted on purpose to set the bar for the
Impact Assessment as high as possible. A policy option passes the cost-benefit test only
if it leads to a more beneficial outcome than individual Member State actions to ensure
spectrum availability in their jurisdictions. This conception of the impact analysis is
squarely within the spirit of the subsidiarity requirement and it ensure that EU
intervention only takes place if it presents real added value over national action.
A.1.2 Overall impact modelling approach
The quantitative analysis focuses on the impacts on the costs and revenues of the three main
stakeholder groups as a result of each of the policy options. This analysis is based primarily on
the data collected through the stakeholder survey. It is complemented by secondary sources, such as
available grey literature, responses to the public consultation undertaken by the European
Commission, published corporate information, or information on the usage and licensing of PMSE
equipment provided by stakeholders.
The analysis approach has the following limitations:


It is difficult for survey respondents to isolate the impact of the policy options from
underlying trends in the PMSE sector (i.e. changes in technology, underlying changes in
demand, etc.). These trends are effectively included in the impact figures. These changes are
not modelled separately but they are implicit in the stakeholder estimates of the impact of
each option.
The analysis does not attempt to quantify second-order impacts beyond the costs and
revenues for individual stakeholder groups, such as for instance the impact on the
quality of events or performances. Although this means that broader impacts will not be
quantified, such quantification would require a set of assumptions about the choices
stakeholders would make given the changes in their costs and revenues (i.e. the trade-off
between costs of using wireless microphones and the inconvenience of wired systems).
Instead, the implications of changes in costs and revenues will be discussed qualitatively on
the basis of survey responses and stakeholder input.
The analysis consists of two elements:


Baseline data – this includes information on the current costs and revenues for the relevant
stakeholder groups based on the stakeholder survey and other secondary information; and
Effect data – this includes information on potential changes to costs and revenues as a result
of the policy options and is based on the survey results.
The following figure outlines the structure for the quantitative analysis.
71
Figure 1 - Quantitative analysis approach
As mentioned above, qualitative analysis will be used to supplement the quantitative analysis.
It will be based on the stakeholder survey, literature, and interviews and will, on one hand, allow to
analyse the impacts which are not quantified, and, on the other, help further qualify and interpret the
quantitative findings.
Baseline data
The following sections outline the methodological choices made with regard to baseline data for each
of the three key stakeholder groups: manufacturers, users and regulators.
1. PMSE manufacturers
In order to arrive at impact estimates for PMSE manufacturers, it is important to establish:


existing cost figures for PMSE manufacturers; and
existing sales figures for PMSE manufacturers.
Although the survey asked for these estimates, the responses received were not sufficiently
complete to use the survey results as a source of the baseline data. Instead, the EU market size
estimates presented in Section 3 along with an estimate of costs as a percentage of turnover based
59
on publically available accounts of one PMSE manufacturer were used to arrive at these figures. The
implications of using different baseline data estimates are explored in the sensitivity testing section.
2. PMSE users
The baseline data necessary for arriving at impact estimates for PMSE users includes:


equipment costs for different types of events; and
license costs for different types of events.
In this case the survey results included sufficient number of equipment and licensing cost estimates to
serve as the basis for the impact estimates. For wireless microphones, this involved the following
steps:
59
Sennheiser
72
1. survey responses that provided data on cost of equipment and licensing costs were grouped
together;
2. a typology was developed based on event size (measured by the number of wireless
microphones used) and event frequency;
3. average equipment and license costs were calculated for event types with sufficient number
of observations and where both equipment and licensing cost data are available;
4. this yielded baseline data for three types of events:
o Event 1: Large event (10 or more links used) taking place daily;
o Event 2: Large event (10 or more links used) taking place monthly; and
o Event 3: Small event (fewer than 10 links used) taking place daily.
It is important to note that the above events are ones for which there was sufficient data to construct
average cost estimates. In the case of a small event (event 3), the dataset was most complete for
small event taking place monthly. However, since small daily events are likely to be more common for
professional users, this type of event was selected despite more limited dataset. This in turn means
that findings for this event type are potentially subject to higher uncertainty levels.
Since fewer responses were received from cordless camera users, the hypothetical camera event is a
single average event based on the survey responses. As a result, it is predominantly based on events
using fewer than five camera links and occurring on a daily or weekly basis, which corresponds to the
majority of survey responses. It is important to note that broadcasters are likely to use more camera
links on a regular basis. However, they are likely to also own their equipment, meaning that equipment
costs per event are more difficult to determine.
The baseline figures for users can be estimated in alternative ways. Whereas the baseline data
(equipment and licensing costs) currently comes from the survey, the hypothetical events can also be
constructed using secondary information on the number of wireless microphone or camera links for
different type of events, information on the costs of purchasing or hiring units (available from retailers
or hire companies), and information on the costs of obtaining licenses for such events (available from
regulators). Another alternative approach to baseline data would be to estimate equipment costs per
event by using the total cost of equipment used. A number of users stated in survey responses that
equipment costs per event are negligible, since they already own the equipment. Such costs, for
example those outlined in Section 3, could then be converted to per-event costs using average
lifespan of equipment and information on the frequency of events.
Both these approaches allow for more precisely defined event types, which in turn would make it
easier to aggregate the impacts for the EU as a whole. At the same time, this approach requires
additional assumptions and, as a result, risks not reflecting the practical experiences of individual
users that responded to the survey. Given the number of assumptions already needed to generate the
impact figures, the approach chosen in the next sections uses the survey data.
3. Regulators
The baseline data needed for impact estimates for regulators includes:


cost of regulating PMSE spectrum; and
licensing revenue.
Since only few of the regulators who responded to the survey were able to provide estimates of these
costs and revenues, it was not possible to arrive at estimates for each individual Member State. As a
73
result, average costs and revenues were calculated and extrapolated to the EU28 level to arrive at an
aggregate figure.
Effect data
In this analysis effect sizes, or the percentage changes in costs and benefits expected by stakeholders
as a result of the policy options, were obtained by calculating the average effect for each of the
stakeholder groups. In order to make it easier for stakeholders to respond to the survey, the response
options were expressed as percentage ranges. These have been coded for analysis as shown in the
table below.
Table 1 - Effect data coding
Response option
Relevant stakeholder group
No change
Decrease by over 20%
Decrease by up to 20%
Decrease by over 10%
Decrease by up to 10%
Increase by over 20%
Increase by up to 20%
Increase by over 10%
Increase by up to 10%
Manufacturers, users, regulators
Users, regulators
Users, regulators
Manufacturers
Manufacturers
Users, regulators
Users, regulators
Manufacturers
Manufacturers
Low impact
estimate
coding
0%
-20%
-10%
-10%
-5%
20%
10%
10%
5%
High impact
estimate
coding
0%
-30%
-20%
-15%
-10%
30%
20%
15%
10%
The impact of alternative coding approaches is discussed in the section on sensitivity analysis.
As noted previously, insufficient data was received from cordless camera manufacturers, hence no
effect estimates were obtained for cordless cameras. For the purpose of this analysis it was assumed
that the effect on wireless microphone manufacturers would also apply to cordless cameras and effect
data for wireless microphones was applied to cordless camera baseline figures.
There are potential alternative approaches to using effect data. Whereas the current impact estimates
are based on average percentage changes in costs for all respondents, an alternative approach would
be to obtain these estimates for the distinctive respondent groups. This would however only be
possible for users, where sufficient number of observations is available. Therefore to ensure
consistency the average percentage change approach is used.
Impact calculation approach
As noted in the previous sections, the impacts are calculated by combining baseline and effect
data. It should be noted that the impact estimates in this report focus on the smaller market size
estimates (i.e. about EUR 170m) rather than the larger APWPT figure. As for the assumptions
underlying the do nothing scenario, this approach was chosen in line with good impact assessment
practice to provide conservative estimates of the impacts of the policy options and to avoid overstating
expected benefits for the PMSE industry. The table below illustrates, step by step, how impacts are
calculated for wireless microphones.
Table 2 – Illustration of determining impact for wireless microphones
Step Step description
Figure
Source
1
Baseline data: Total
€ 169,765,904
Extrapolation of the
turnover figure EU
PAMA/Robert Bosch 2011
market size estimate
provided in response to
the European Commission
Calculation
A
74
Baseline data: Costs of
PMSE production as
percentage of turnover.
Baseline data: Total
costs in EU 27
Effect data: Change in
annual costs Option 1 –
low estimate
62%
5
Effect data: Change in
annual costs Option 1 –
high estimate
-2.14%
6
Effect data: Change in
annual sales Option 1 –
low estimate
-6.43%
7
Effect data: Change in
annual sales Option 1 –
high estimate
-9.29%
8
Change in annual costs
under Option 1 – low
estimate
Change in annual costs
under Option 1 – high
estimate
Change in annual sales
under Option 1 – low
estimate
Change in annual sales
under Option 1 – high
estimate
Impact: Benefits minus
costs under Option 1 low estimates
Impact: Benefits minus
costs under Option high estimates
-€ 1,503,641
(benefit)
2012 consultation (See
Section 3.1.1)
Sennheiser cost structure
provided in 2011 Annual
Report
Calculation based on
figures A and B
Average of the coded
responses to the online
survey (See Section 5.3.2
for coding approach)
Average of the coded
responses to the online
survey (See Section 5.3.2
for the coding approach)
Average of the coded
responses to the online
survey (See Section 5.3.2
for the coding approach)
Average of the coded
responses to the online
survey (See Section 5.3.2
for the coding approach)
Calculation based on
figures C and D
-€ 2,255,461
(benefit)
Calculation based on
figures C and E
I=C*E
-€ 10,913,522
(cost)
Calculation based on
figures A and F
J=A*F
-€ 15,763,977
(cost)
Calculation based on
figures A and G
K=A*G
-€ 9,409,882
Calculation based on
figures H and J
|H|-|J|
-€ 13,508,516
Calculation based on
figures I and K
|I|-|K|
2
3
4
9
10
11
12
13
€ 105,254,860
-1.43%
B
C=A*B
D
E
F
G
H=C*D
75
Annex 2: Glossary of terms
Term
PMSE
SAB
Channel
Link
Transmitter
Receiver
Frequency
Band
Tuning
Range
Radio
Microphone
Wireless
Camera
In-Ear
Monitor
Primary
Status
Secondary
Status
Non
Interference
Basis
Definition
Programme Making and Special Events
Services Ancillary to Broadcasting (synonym for PMSE)
A slice of radio spectrum, whose size is defined by the technology using it (a
television channel represents a slice of 7 or 8 MHz, whereas the channel for a
radio microphone is typically only 400 kHz).
A point-to-point connection carrying either audio or video.
A device which converts audio or video into a radio frequency signal.
A device which converts radio frequency signals into audio or video.
A range of frequencies, typically one whose usage is common (e.g. UHF
television band, or 3G band).
The range of frequencies over which a radio microphone can operate without the
need for physical modification.
(also Wireless Microphone) A low power transmitter for audio signals generated
in a microphone. Usually either hand-held or body-worn.
(also Cordless Camera) A transmitter for video signals. Usually mounted on the
camera.
A receiver for audio signals, which feeds an earpiece worn by a performer.
A user of the radio spectrum who has ‘first refusal’ over its use. A primary service
cannot claim protection from harmful interference from another primary service
which shares the same allocation.
A user of the radio spectrum who can use spectrum as long as they do not cause
harmful interference to a primary service. Secondary users cannot claim
protection from harmful interference from a primary service.
(also Licence Exempt) Use of the radio spectrum with no protection from harmful
interference from any user. Users must also not cause harmful interference to
primary or secondary users.
76
Annex 3: Example of number of links by event
77
78
Annex 4 – Qualitative impact of excluding 700 MHz band
It would have a severe impact as this band is one of the core bands of wireless productions.
We would have to change our entire range of wireless mics
Not enough space for existing equipment. We would have to purchase new kit. Don't like this.
we couldn't use abroad part of our present systems
lack of available channels
It would have a severe impact as this band is one of the core bands of wireless productions.
strong impact, because most of users use this range
It would have a severe impact as this band is one of the core bands of wireless productions.
problem
It would have a severe impact as the band 470-790 MHz is one of the core bands of wireless
productions.
devastating
Very big difficulties in making important TV show or event, Serious problem in area where many
frequencies are used like TV studio
It would have a severe impact as this band is one of the core bands of wireless productions.
Expensive
We would lose the ability to use our mics and intercom bays... We would lose our material.
we lose more than an half of our equipment
Very large impact. It would ruin the usefulness of the plan.
Since we use that spectrum, costs will be higher to buy new equipment. We use about 40 channels in
that spectrum today.
It would render many units bought recently as unusable. forcing another re-investment after just being
removed from the 800MHz band forced increased re-stocking into the 600-790MHz bands
Limiting large events.
none for us at this time
broadly similar
Less spectrum
What would be bad would be not including Ch38
Obsolescence of some existing stock
We would have to hire radio systems when working in mainland Europe
The issue raised by WRC 2012 Digital Dividend 2 would take away even more usable spectrum for
wireless microphone technology. Especially for us, that means that then 16 high quality channels
should no longer be used and thus an aftermarket in the order of approximately EUR 120,000 - would
hesitate.
A lot of recently bought equipment will be useless
again a loss of expensive gear
NIL
Damage to all rental/owner operators as personal kit would be of limited use.
Spectrum would be squeezed further and would make it harder for us to find clear frequencies to use
We would have equipment sat on our shelves that has been forced into being obsolete, which we will
no longer be able to use.
Less spectrum equals less channels can be used.
it would not affect me
None
To me, nothing, this range is not usable for radio mics in the UK
big problem - buy new equipment!
Not much impact to me personally
More hired equipment
worse, I think
As a channel 38 user, none.
No Impact.
79
None for me
None
We would not be able to do the events we do now so we would go out of business
This would not affect me at present
For us no change
We would have to invest in more equipment to replace existing site specific kit.
none, as the major IEM / wireless mic ranges between 470 and 698
change the gear.....again
none
Planning and equipment purchase would become more complicated and expensive.
A lot of locations and events do not have enough spectrum for large events
it becomes more difficult to produce with wireless equipment
None
Disastrous
ANY spectrum not available between 470-790 will severely impact the type of equipment we own and
the number of channels we can provide to one job
Serious impact. Most of the ranges listed above are useless, only 470-790MHz is relevant to us.
It would require a major refit of our studio operations
We would have to replace our equipment completely
destruction of capital
our nowfays hf mikes would be useless
buying new handhelds
cost for wireless equipment go up due to new investments
Great trouble for the number of frequencies we could use simultaneously
maybe interference with others
higher costs
then we have to buy new stuff
All critical wireless microphones will need to move to whatever UHF spectrum is leftover due to
physical propagation issues. The leftover UHF spectrum will become very crowded.
then we can't use our mics no more.
For us none since we are in the 800 band.
depends of the range that we will be given instead
We would have to invest in new equipment as our current setup would be excluded!
a lot of costs
We don’t use range 698-790
I have to replace my microphones
change of all our material.. not good..
none
no impact
None for us
no change for us
36000€ de remplacement de materiel!!!!!!!!!!!!!!!
ces fréquences ont déjà été supprimées, une partie de notre parc ne nous sert déjà plus à rien
less activity, less events
80% of the current used equipment will become (partly) redundant.
No impact for our company
Changement de matériel
That would be a pity
we are now working between 838 - 862
50% of equipment will be useless
new purchase not desirable
We need the current available frequencies (470-790 MHz) Otherwise the re-investment costs are too
high and so will be the costs for renting equipment.
Heavy!
80
Reduced flexibility in "white space"
Our mics (the ones we have at the moment) are in the 863-865 MHz range, so no impact.
some of our mics would become useless
It would limit the spectrum availability and make it more difficult to operate in Europe.
it will be hard to get all the equipment running
none
it would be impossible to use our micro for most of them
We would need to buy all new equipment.
Mieux
Changement du materiel ou adaptation
more crowded "airspace"
less possible usage of wireless
please read the various CEPT-ETSI reports on spectrum, in brief: 29-68 is unusable by radio
microphones due to man-made noise ,PLT and antenna length. 174-216 very limited spectrum
available due to DAB allocation and noise floor, 470-790, as stated if MFCN at 694-790 is introduced
plus WSD and the TV channels compacted plus losing at least 4MHz as a guard band there will be
very little left. 821-832, almost useless for professional use due to LTE out of band energy , Please see
AWPT reports which show some 3-6 channels may be usable in some places when mobile equipment
is not present. 863-865 has been shown in many reports including the joint CENELEC ETSI group to
be almost unusable when mobile lte equipment present (not a professional use band) 1785-1805,
again subject to LTE interference from their excessive out of band energy. Limited access to L band for
indoor use will help but not much. In brief the tuning ranges show "in theory" a large amount of
spectrum but in practice there is very little of practical use, suggest new bands around 1200 MHz must
be explored for any useful contiguous useful spectrum
none
The loss of this range would we a disaster. Think on DVBT 2 .
a. 80% of the current used equipment will become (partly) redundant .b. 50% of the spectrum capacity
gone. c. Enormous investments for new equipment, extra costs are then imposed to us, the users!
Users will pay for the benefit of another industry, ridiculous?
big loss of equipment
We need this frequencies, because we have a lot equipment in this range.
replacement appliances using these frequencies
New equipment, bought today becomes useless. Decent communication is needed at least 5 years in
advance. When you buy a product that will be useless in 5 years, the seller has to provide this
information to the customer.
We would be forced to buy new equipment.
The financial cost of the equipment for different frequency
For Belgian users, not much...
change a part of our rental park of wireless
changement de matériel
receiver and transmitter to trash
Neutral
None
It would cost a lot of money to change my system again
je serai obligé de changer tout mon matériel
high expenses for purchase
174-223 and 470-698 bands difficulties
We should have to purchase equipment with lower frequencies
I think it would not be a problem
No impact for us, we changed 2 years ago all of our wireless system to agree the 4G 's gsm protocol.
Organisations with old equipment need to purchase new.
we are going for 400-500 and if it´s not working where we tour, then that is problem
bad impact
Dramatique
That would be a big problem for us because all of our wireless microphones use these frequencies.
81
we would have to renew our gear
un investissement pour ceux qui l'utilisent
None.
It would require us to use different wireless microphone products to those we use now
A disaster !!
None
no change - currently everything has moved into Channel 39
It would have a severe impact as this band is one of the core bands of wireless production
More problems. Increase cost
82
European Commission
Assessment of socio-economic aspects of spectrum harmonisation
regarding wireless microphones and cordless video-cameras
(PMSE equipment)
Luxembourg, Publications Office of the European Union
2013 – 84 number of pages
ISBN 978-92-79-30563-4
DOI: 10.2759/18518
83
KK-03-13-217-EN-N
DOI: 10.2759/18518
ISBN 978-92-79-30563-4
84