RD188 - ETNO Reflection Document in response to RSPG's public consultation on secondary trading of rights to use radio spectrum

ETNO believes that the current spectrum management regime already allows the orderly introduction of necessary adaptations with regard to radio spectrum user needs. However, the introduction of spectrum trading could offer additional incentives, in particular concerning the flexible use of radio spectrum.

From ETNO’s point of view, spectrum trading entails serious challenges from both technical and market structure point of view and should be introduced step by step. Special care has to be taken when treating possible harmful interference in particular in the case of change of use. Another important aspect in this regard is the introduction of possible difficulties concerning harmonisation of frequency bands. Any frequency trading initiative should be thoroughly considered from a competition point of view, and should avoid introducing market distortions. In this regard, the transfer of rights to use radio spectrum has to be linked to the associated obligations. ETNO is of the opinion that benefits and drawbacks have to be considered carefully and sufficient experience need to be gained before spectrum trading is mature for a broad harmonised introduction.