Property rights in UHF and 2.6GHz spectrum

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1 . Final Report for the Greek Ministry of Transport, Infrastructure and Networks Property rights in UHF and 2.6GHz spectrum 23 February 2012 Version for Public Consultation Ref:

2 Contents 1 Executive summary 1 2 Introduction Background to the study Structure of report 9 3 Overview of the bands under study The UHF band The 2.6GHz band 12 4 Approach to quantifying the benefits of different uses of UHF spectrum Scenarios Overview of mobile and broadcast markets in Greece Calculating costs and benefits of different allocation options for UHF spectrum The mobile model The DTT model 36 5 Modelling results for the economic impact of UHF spectrum Mobile results DTT results Combined results Modelling sensitivities 43 6 Market value of 800MHz and 2.6GHz mobile licences Summary of factors affecting spectrum price Comparison of spectrum benchmarks between Greece and other European countries Market value of 800MHz licences Market value of 2.6GHz licences 53 7 Licensing approach for DTT Licensing approaches Frequency assignment, fees and subsidies Roll-out obligations DTT technology options 63 8 Conclusions from the study Conclusions from the study Market value of 800MHz and 2.6GHz spectrum Recommendations from the study 66 Annex A Allotment areas using DTT channels 61-66

3 Property rights in UHF and 2.6GHz spectrum Confidentiality Notice: This document and the information contained herein are strictly private and confidential, and are solely for the use of the Ministry of Infrastructure, Transport and Networks. Copyright The information contained herein is the property of Analysys Mason Limited and is provided on condition that it will not be reproduced, copied, lent or disclosed, directly or indirectly, nor used for any purpose other than that for which it was specifically furnished. Analysys Mason Limited Apex 3, 95 Haymarket Terrace Edinburgh EH12 5HD Scotland Tel: +44 (0) Fax +44 (0) Registered in England No

4 Property rights in UHF and 2.6GHz spectrum 1 1 Executive summary This is the final report prepared by Analysys Mason Limited (Analysys Mason) on behalf of the Greek Ministry of Infrastructure, Transport and Networks (YME), and considers the allocation of property rights in UHF ( MHz) and 2.6GHz spectrum in Greece, as part of a study conducted between October and December In particular, the study considers the potential value of the digital dividend from the release of UHF spectrum, and whether this spectrum should be allocated for mobile broadband use, or for digital terrestrial television (DTT). Background to the study Digital dividend refers to spectrum released from the switchover from analogue to digital terrestrial television. The European Commission Decision of 6 May 2010 on harmonised technical conditions of use in the MHz frequency band for terrestrial systems capable of providing electronic communications services in the European Union (2010/267/EU) 1 has sought to harmonise use of the digital dividend spectrum by recommending that Member States assign the upper part of the UHF band ( MHz), referred to as the 800MHz band for mobile broadband services. Possible future changes to UHF allocations (e.g. at a future International Telecommunications Union (ITU) World Radio Conference (WRC)) may result in further UHF spectrum being allocated to mobile use. If this were to happen in Europe, the industry may prefer this allocation to be in the 700MHz range (e.g MHz), since this would harmonise Europe s UHF mobile allocations with those of other ITU world regions. 2,3 In Greece, the digital switchover (DSO) has commenced, but has not been completed. The YME considers it to be technically and operationally feasible for the DSO to be completed in Greece by the end of However, the Greek Government has yet to formalise its decisions about the licensing of DTT services, and the assignment of UHF spectrum, including the digital dividend. Modelling approach In order to provide a an assessment of the impact of different assignments of UHF spectrum in the Greek market, we have undertaken modelling to assess the economic value, also referred to as welfare from the service, of assigning different amounts of UHF spectrum for different uses specifically for mobile broadband and DTT Commission Decision of 6 May 2010 on harmonised technical conditions of use in the MHz frequency band for terrestrial systems capable of providing electronic communications services in the European Union (notified under document C(2010) 2923). Available at ITU WRC-07 allocated MHz to mobile services in Europe, but allocated MHz to mobile services in other world regions. Further to this report being produced, the World Radio Conference 2012 (WRC-12) decided upon a mobile allocation in the 700MHz band in Europe and Africa to come into force from 2015.

5 EUR (billion) Property rights in UHF and 2.6GHz spectrum 2 In calculating the costs and benefits of assigning UHF spectrum to different services, we have considered the private value, defined as the benefits that users gain from a service, minus what the service costs to produce, plus any externalities. 4 Our approach to modelling private value has been to split the calculation between consumer surplus (benefit to consumers minus the price they pay) and producer surplus (revenue of the producers minus the costs to provide the service), plus externalities. We have also assessed the potential market value of spectrum if the 800MHz and 2.6GHz bands were to be assigned for mobile broadband services in Greece, based on benchmarking the prices paid for similar spectrum in different European countries, and adapted per MHz per head of population in Greece. Finally, we have considered potential approaches to spectrum assignment both in terms of typical methods of assigning property rights for mobile broadband, and for DTT as well as providing a comparison of specific licensing approaches to DTT. We also summarise the key issues to be considered when taking the licensing of DTT services forward, and the frequencies needed to operate those services. Modelling results and conclusions Figure 1.1 below shows the combined results of our assessment of the economic impact of assigning UHF spectrum for difference uses, whereas Figure 1.2 and Figure 1.3 show the value created by assigning spectrum for mobile broadband and DTT, respectively. Figure 1.1: Total economic value of the 700MHz and 800MHz bands for mobile broadband and DTT services [Source: Analysys Mason, 2012] Base case: MHz is used for DTT Mobile uses the 800MHz subband 800MHz Mobile uses the 700MHz and sub-bands Base case Increment on base case 4 The economic value of using spectrum to provide a particular service is also referred to as welfare from the service, which is the sum of consumer and producer surplus, plus externalities (positive or negative).

6 EUR (billion) EUR (billion) Property rights in UHF and 2.6GHz spectrum 3 Figure 1.2: Total economic value of the 700MHz and 800MHz bands for mobile broadband services [Source: Analysys Mason, 2012] Base case: MHz is used for DTT Mobile uses the 800MHz subband 800MHz Mobile uses the 700MHz and sub-bands Base case Increment on base case Figure 1.3: Total economic value of the 700MHz and 800MHz bands for DTT services [Source: Analysys Mason, 2012] Base case: MHz is used for DTT Mobile uses the 800MHz subband 800MHz Mobile uses the 700MHz and sub-bands Base case Increment on base case From the modelling result, we have concluded that the greatest benefits come from assigning some of the spectrum in the UHF band to mobile broadband services and the rest to DTT. We have found that if the 800MHz band were to be awarded for mobile use in Greece, the economic value 5 5 I.e. the combined value of the switchover from analogue to digital terrestrial television in the MHz band and the introduction of mobile services in the 800MHz band

7 Property rights in UHF and 2.6GHz spectrum 4 of assigning UHF spectrum would be around EUR26.2 billion, over 20 years. 6 By contrast, if the entire UHF spectrum were assigned to DTT, the economic value would be EUR22.7 billion. This means that the incremental value of assigning the 800MHz sub-band from within the UHF band for mobile use is around EUR3.5 billion. We have also found that awarding both the 700MHz and the 800MHz band for mobile use in Greece would generate a further incremental benefit of EUR1.0 billion, with total benefits at around EUR27.3 billion, over 20 years. However, we note that awarding spectrum in the 700MHz, 800MHz and 2.6GHz bands for mobile use in Greece could result in supply of mobile spectrum exceeding demand, since only three mobile operators are present in the Greek market. Therefore, in our model we have assumed that the award of additional spectrum in the 700MHz band could enable a new player to enter the Greek market with a larger amount of sub-1ghz spectrum suitable for LTE services (e.g. 2 20MHz of UHF spectrum). Hence, the incremental value we have calculated if the 700MHz band is awarded for mobile use derives largely from the presence of a fourth operator in the Greek market. Notwithstanding this, we have not explicitly modelled the viability of a new market entrant in the Greek market. We have only assumed that, if viable, the entry of a new player in the Greek market would increase competition and thus lower the prices of mobile broadband services. We have also found that the additional network costs incurred by a new operator entering the market and building its own infrastructure reduces the producer surplus created by the scenario in which both the 700MHz and the 800MHz bands are assigned to mobile broadband use, compared to if just the 800MHz band is assigned. To compensate for the reduction in producer surplus, however, there is an increase in consumer surplus as a result of a new entrant being in the market, due to the lower ARPU resulting from increased competition and lower prices. We have also noted that the additional value of the 700MHz band over and above the 800MHz band for existing operators is marginal if 2.6GHz spectrum is also awarded, since existing operators are expected to have sufficient spectrum to accommodate their future mobile data requirements using a combination of their existing 900MHz and 1800MHz spectrum, and new 800MHz and 2.6GHz spectrum. By contrast, we have found that the allocation of 700MHz spectrum away from broadcasting resulting in a reduction in the number of multiplexes that can be provided over the DTT platform presents only a small decrease in the value generated from DTT services. This is because the majority of value from DTT comes from analogue services being able to be delivered digitally, whilst the value of incremental multiplexes over and above those required to accommodate existing analogue services for DSO is marginal. We have found that the economic value is slightly higher if DVB-T2 is used to accommodate high-definition (HD) programmes in one multiplex than if DVB-T is used. The value of DTT services also increases if we assume that multiplexes are used to provide both SD and HD services, rather than assuming all multiplexes are used just for SD. 6 The majority of this value around EUR15.9 billion is value generated from mobile services, whilst the remaining EUR10.3 billion is derived from the switchover from analogue to digital terrestrial television.

8 Property rights in UHF and 2.6GHz spectrum 5 Recommendations On the basis of our modelling results, we recommend that the Hellenic Government proceeds with allocating the 800MHz sub-band for mobile use, but do not recommend that it allocates the 700MHz band for either mobile use or DTT at the present time. We suggest that the Hellenic Government awaits a decision at a European level on the harmonised use of the 700MHz band in order to make a decision on whether the 700MHz band should be used for mobile services in future. This is particularly required because the European Allocation Table does not contain a primary mobile allocation in the 700MHz band (although this might change as a result of future WRCs). Since there is no common allocation, there is also no harmonised band plan for 700MHz mobile use in Europe and hence equipment manufacturers are not developing mobile products for this band in Europe. By contrast, LTE800 equipment (for use in the 800MHz band in Europe) is becoming increasingly widely available. We strongly recommend that, to maximise value from the allocation of 800MHz UHF spectrum for mobile use, the Greek government assigns spectrum in the 800MHz band in accordance with the harmonised European band plan defined by EC Decision 2010/267/EU 7. This will require migration of military systems in Greece from the upper part of the 800MHz band to an alternative band. We note that one possibility to release 800MHz spectrum for mobile use might be to migrate military systems to the 700MHz band. However, this may preclude the 700MHz band from being used for mobile services in the future. We estimate that the impact of the 700MHz band not being available for mobile use (i.e. the loss of value from the entire 700MHz band not being available for mobile services as a result of military systems occupying part of this band) is around EUR1.6 billion 8. The reduction in value from the DTT model if the 700MHz band is not available (e.g. if 700MHz is used for military or other systems) is smaller, at around EUR326 million, or 1.2% of the total value already shown in Scenario 2b (EUR26.3 billion). We have also estimated the market value of an 800MHz licence in Greece based upon benchmarks of 800MHz auction prices in different European countries. Taking a conservative view, a 2 10MHz licence might have a market value of up to EUR97.8 million, suggesting a total value (for the entire 800MHz band) of EUR million. Assuming a 15-year licence duration, this would be equivalent to EUR6.5 million per annum per a 10MHz paired licence. In terms of the 2.6GHz band, we have estimated using benchmarks of the prices paid for 2.6GHz spectrum in other European countries that the total revenue that the Greek Government might expect to obtain from each 20MHz paired licence would be up to EUR20.8 million, if all of the available spectrum were to be assigned, but could be only EUR11.3 million if a more conservative benchmark price is used. This is equivalent to an annual value of EUR0.7 million per 20MHz paired licence (assuming a 15-year licence duration). It is also noted that there might not be sufficient demand for 7 8 Commission Decision of 6 May 2010 on harmonised technical conditions of use in the frequency band MHz frequency band for terrestrial systems capable of providing electronic communications services in the European Union: This is the difference in economic impact between scenarios 3a and 3b, as described in Section 5.1.

9 Property rights in UHF and 2.6GHz spectrum 6 mobile spectrum within the current Greek mobile market for the entire 2.6GHz band to be sold. This is because of the relatively limited competition in the Greek market and the fact that, with a total of 2 70MHz of paired spectrum is available in the 2.6GHz band, all of the spectrum would be sold only if individual operators demand more than 2 20MHz of spectrum each. Based upon demand exhibited in other European auctions, this is very unlikely. In terms of award options, we recommend that 800MHz and 2.6GHz spectrum is assigned in Greece for mobile services through a market-based process such as an auction. We also recommend that the Hellenic Government should proceed as soon as is practically possible with the award of rights to access and use spectrum in the MHz band for DTT, to accelerate the migration from analogue to digital terrestrial television and analogue switch-off (ASO). In terms of the approach to licensing DTT, our analysis shows that assigning frequencies by multiplex is the method most commonly used, rather than assigning frequencies by individual DTT programming channel, or by DTT transmitter. The former approach enables multiplex operators to plan the DTT network within the available frequencies assigned to the multiplex, in accordance with the agreed co-ordination parameters (i.e. as defined within the ITU-R GE-06 Agreement and Plan 9 and the associated bilateral agreements with neighbouring countries). 9 Results of the ITU Regional Radio Conference 2006:

10 Property rights in UHF and 2.6GHz spectrum 7 2 Introduction Analysys Mason Limited (Analysys Mason) has been commissioned to provide advisory support to the Greek Ministry of Infrastructure, Transport and Networks (YME) in the assessment of the best-available options for the management of the rights on selected bands in the national frequency spectrum. This document is the final report of a series of deliverables produced by Analysys Mason for the YME in the context of this project, in order to inform YME s policy decisions on the award of property rights in the UHF and 2.6GHz bands in Greece. The purpose of the study has been to assess the benefits to Greece s economy of assigning UHF spectrum for different candidate uses, namely to mobile broadband systems, or digital terrestrial television (DTT) systems. The study has also considered the possible proceeds to the Government from assigning 2.6GHz spectrum for mobile broadband systems, and how spectrum in each bands might be licensed, based upon benchmarks of similar spectrum awards in other European countries. The estimation of the economic value or welfare of UHF spectrum is based upon a model that considers a range of scenarios for assignment of different amounts of spectrum for mobile broadband and for DTT, in order to identify the scenario that achieves maximum benefits. The estimation of the likely proceeds from sale of 2.6GHz spectrum is based upon benchmarks of auctions for similar spectrum obtained in other European countries, adapted to give a comparable price per MHz per capita of population in Greece. We have also considered the suitability of different assignment methods for both UHF and 2.6GHz spectrum for mobile broadband (in both bands) and for DTT (in the UHF band), and contrasts methods used for both bands in selected other countries in Europe, based upon a series of case studies. 2.1 Background to the study Until 2007, it was assumed that spectrum in the UHF Bands IV and V would be used for digital TV services in line with the International Telecommunications Union (ITU-R) GE-06 agreement or, potentially, mobile TV (using technologies such as DVB-H). However, in 2007, the ITU World Radio Conference (WRC-07) allocated the MHz band (or parts of it in some countries) to mobile services on a primary basis in a number of countries within ITU Region 1, including all European Union countries. This is in accordance with footnote number 5.316A of the ITU Radio Regulations. The EC subsequently put forward a decision 2010/267/EC to harmonise use of the MHz band for electronic communications systems such as mobile broadband. Consequently, many European countries have now renegotiated or are in the process of renegotiating DTT/mobile TV multiplex plans with neighbouring countries (i.e. based upon the frequency plan provided by the ITU-R GE-06 agreement). This will allow the release of the MHz band for use by mobile services. This would mean that DTT services

11 Property rights in UHF and 2.6GHz spectrum 8 will be constrained to the remainder of the UHF spectrum ( MHz), with the MHz band (referred to as the 800MHz band) being re-allocated for mobile use. This release of spectrum is often referred to as the digital dividend. This decision has not been formalised in Greece; one of the key objectives of this study is therefore to confirm the future use of the UHF bands IV and V in Greece. This consideration includes whether the 800MHz band should be used for broadcasting or for mobile services. We have also been asked to consider whether the adjacent spectrum ( MHz, referred to as the 700MHz band) should be retained for DTT use, or released for other uses such as electronic communication systems (e.g. 3G/4G mobile services). Finally, we have been asked to identify award options for the 2.6GHz band ( MHz), which is a band also intended for mobile broadband use according to EC Decision 2008/4776/EC. A number of studies (including a number by Analysys Mason) have been conducted into the relative benefits to Europe s economy of different allocation options for the UHF spectrum released from switchover from analogue to digital TV. These options have tended to consider a variety of possible configurations of spectrum allocated to mobile and DTT networks. In each of these studies, the objective has been to identify the appropriate apportioning of spectrum between mobile and DTT in the UHF band in order to maximise overall welfare 10. For mobile network operators, the main benefit of having access to more UHF spectrum is that it would allow the deployment of new mobile broadband technologies over a wider area, with better quality and to more consumers than would be possible using higher-frequency spectrum. Specifically, UHF spectrum would allow the deployment of networks using Long-Term Evolution (LTE) technology, the successor to the UMTS standard for 3G services. For the broadcasting sector, the benefits of having access to UHF spectrum lie in the potential to provide viewers with new high-definition (HD) channels over DTT, as well as to increasing the take-up of DTT platforms compared to other methods of viewing digital TV, such as via satellite or fibre-based networks 11. Identifying the appropriate balance of UHF spectrum assignment between mobile and DTT requires modelling of the costs and benefits of deploying mobile broadband and DTT networks, in order to identify the net benefits of different amounts of spectrum between the two services, and the impact of various sensitivities within the model upon the net benefits predicted In other words, economic benefits that can be expected to be generated by increased availability and use of mobile broadband networks and/or DTT For example, via IP-TV

12 Property rights in UHF and 2.6GHz spectrum Structure of report The remainder of this document is laid out as follows: Section 3 provides an overview of the bands under study in this project Section 4 describes the approach to modelling economic benefits of assigning different amounts of UHF spectrum for mobile and DTT systems Section 5 summarises the results generated by the mobile and DTT models in relation to the economic benefits of both services Section 6 considers the value of 2.6GHz spectrum for mobile broadband use in Greece Section 7 considers licensing approaches for DTT Section 8 presents the conclusions and recommendations from this study, relevant to the YME s consideration of assignment of property rights in both bands. The report the following annex containing supplementary material: Annex A illustrates Greece s allotments in the GE-06 plan in the 800MHz sub-band (DTT channels 61 to 69).

13 Property rights in UHF and 2.6GHz spectrum 10 3 Overview of the bands under study This section provides a brief overview of the two frequency bands under study namely the UHF band ( MHz) and the 2.6GHz band ( MHz) 3.1 The UHF band Historically, the UHF band has been allocated entirely to the broadcasting service, for use by terrestrial TV broadcasting services. In many European countries, UHF spectrum is also used on a secondary basis by services ancillary to broadcasting, often referred to as programme making and special events (PMSE). To reflect the development of technology to broadcast terrestrial TV digitally, the UHF band was subsequently re-planned for DTT as a result of the ITU Regional Radio Conference held in 2006 (RRC-06). The output of this conference, referred to as the Geneva-06 Agreement (GE-06), sets out coordination principles and a frequency plan for digital terrestrial broadcasting (including DVT-T, DVB- H and T-DAB) across ITU Region 1, of which Europe is a part. It is still possible for PMSE systems to use spectrum within the GE-06 frequency plan, on a co-ordinated basis with DTT. Subsequent to this, the ITU WRC held in 2007 (WRC-2007) considered a number of issues relating to the identification of spectrum for future mobile services. 12 As a result, it decided to allocate parts of UHF Bands IV and V for mobile services on a co-primary basis with broadcasting services, to provide further opportunities for the growth of mobile broadband services. The following allocations were made to mobile services: MHz in Regions 1 and MHz in Region 2 and parts of Region 3. The decision to allocate some spectrum for mobile services in UHF Bands IV and V reflects two key market developments: DTT broadcasting is more efficient than analogue TV broadcasting. Digital networks can therefore provide an equivalent number of channels using less spectrum than an analogue network. The lower spectrum requirement of DTT broadcasting allows the release of surplus spectrum when networks are migrated from analogue to digital, which is referred to as the digital dividend. Spectrum below 1GHz has particularly good propagation characteristics and is generally considered highly desirable not just for broadcasting, but also for electronic communications services. In mobile networks, spectrum below 1GHz is particularly useful for achieving wide-area coverage in less densely populated areas and also for achieving indoor coverage in urban areas. 12 Referred to within the ITU as International Mobile Telecommunications, or IMT.

14 Property rights in UHF and 2.6GHz spectrum 11 The identified spectrum for mobile services within ITU Region 1, from MHz, comprises the top eight channels of the UHF band, as illustrated below. Figure 3.1: UHF Bands IV and V 800MHz band [Source: Analysys Mason, 2012] MHz MHz MHz MHz MHz 69 Following the WRC-07, the EC conducted a study on a co-ordinated approach to the digital dividend, to consider the benefits of European countries re-planning their digital TV services to allow the release of channels 61 to Thereafter, the EC published a decision (2010/267/EU) 14 recommending that EU Member States make the sub-band of channels from 61 to 69 at the top of the UHF band (i.e. from MHz, hereafter referred to as the 800MHz band) available for electronic communications services. The EC s decision recommends that the 800MHz band is allocated to mobile services in a harmonised band plan, comprising 60MHz of spectrum divided into two 30MHz paired block, as illustrated below. Figure 3.2: Harmonised European band plan for the 800MHz band [Source: Analysys Mason, 2012] FDD downlink FDD uplink MHz It is possible that a future WRC might make further changes to allocations in UHF spectrum. In particular, there is a possibility that a decision might be taken to align the mobile allocation in ITU Region 1 with the rest of the world, which would result in a wider sub-band, from MHz band, being allocated for mobile use. This would introduce the possibility of a further sub-band for mobile use: the 700MHz band, from MHz. However, since this decision has not been Available at European Commission Decision of 6 May 2010 on harmonised technical conditions of use in the MHz frequency band for terrestrial systems capable of providing electronic communication services in the European Union.

15 Property rights in UHF and 2.6GHz spectrum 12 taken yet, there is no 700MHz mobile allocation within the European frequency allocation table at present, and no harmonised European band plan for mobile use of the 700MHz band. Note that decisions to allocate spectrum in the 700MHz and 800MHz bands for mobile services will preclude those parts of the UHF band being used by PMSE. However, within our model, we have not considered the economic impact of PMSE not having access to the full amount of spectrum to which it has access currently. It is expected that, if a decision is taken at a future WRC to create a 700MHz sub-band for mobile use in Europe, further detailed study will follow in CEPT to develop a suitable harmonised band plan. In the absence of this, and for the purposes of this study in order to estimate the value of 700MHz spectrum, we have needed to make assumptions on how much paired bandwidth might be available in the 700MHz band. The assumption we have therefore made is it might be configured in a similar way to the 800MHz band i.e. two blocks paired spectrum with an 11MHz duplex gap. Whilst not confirmed at this stage, a possible configuration might be: Uplink and downlink MHz Duplex gap MHz Guard band MHz 3.2 The 2.6GHz band The 2.6GHz band comprises 190MHz of spectrum between 2500MHz and 2690MHz. At an international level, the band is allocated to mobile services in all three ITU regions, and was identified for use by IMT systems the ITU s definition of 3G/4G technologies at the WRC in 2000 (WRC-2000). The band sits alongside the 2.4GHz Industrial, Scientific and Medical (ISM) spectrum, used extensively around the world for licence-exempt wireless systems such as WiFi; at 2690MHz, it is adjacent to an international radio astronomy band. At a European level, CEPT and EC decisions on the harmonised utilisation of spectrum within the band MHz have been published as ECC Decision (05)05 and EC Decision 2008/477/EC, 15 respectively. EC Decision 2008/477/EC recommends that Member States issue licences in the 2.6GHz band in accordance with the harmonised band plan described in ECC Decision (05)05. This band plan divides the spectrum into 14 paired blocks of 5MHz, separated by 120MHz, with the sub-band MHz divided into ten 5MHz blocks of unpaired spectrum. This is illustrated below. 15 Commission Decision of 13 June 2008 on the harmonisation of the MHz frequency band for terrestrial systems capable of providing electronic communications services in the Community ((2008/477/EC). Available at

16 Property rights in UHF and 2.6GHz spectrum 13 Figure 3.3: Harmonised European band plan for allocation of the 2.6GHz band [Source: Analysys Mason, 2012] FDD uplink TDD FDD downlink MHz In accordance with the European band plan, the 2.6GHz band is suitable for both FDD and TDD technologies, since the band plan comprises of combination of paired and unpaired spectrum. Although spectrum is nominally divided as paired and unpaired 5MHz blocks, the EC Decision allows regulators to award spectrum in lots of 5MHz multiples, which has resulted in some regulators in Europe deciding to offer 2.6GHz spectrum in 10MHz, or larger, blocks.

17 Property rights in UHF and 2.6GHz spectrum 14 4 Approach to quantifying the benefits of different uses of UHF spectrum In this section, we consider the results of a cost-benefit assessment of the value of allocating UHFband ( MHz) spectrum for different uses specifically mobile broadband versus DTT. Within this section, we summarise our approach to modelling the costs and benefits of assigning different amounts of UHF spectrum to mobile, and to DTT, as well as describing the scenarios we have developed in order to compare benefits between the two services. We start with a description of the mobile and DTT markets in Greece, followed by an overview of the modelling approach used to calculate the economic value for both services, and the key sensitivities for each. For both mobile broadband and DTT, economic value is defined as the benefits that users get from a service minus what this service costs to produce, in additional to wider social benefits, and is often split between consumer surplus (benefit to consumers minus the price they pay), producer surplus (revenue of the producer minus the costs to provide the service) and external benefits. 4.1 Scenarios In order to calculate the relative value of different spectrum allocations, we designed a series of scenarios each of which assumed a different split of spectrum between DTT and mobile broadband services. For DTT services, we have assumed that multiplexes can either be used to accommodate standard-definition programmes (SD), or high-definition programmes (HD). Although in practice a multiplex can accommodate a mix of SD and HD channels, to simplify our model we have compared value from multiplexes being used either for SD, or for HD. Within our base case we have assumed 6 SD programmes can be delivered per multiplex or 3 HD programmes. These scenarios are outlined in Figure 4.1 below. The underlying assumptions within each scenario in relation to the spectrum allocated to mobile and to DTT use are illustrated in Figure 4.2 to Figure 4.7.

18 Property rights in UHF and 2.6GHz spectrum 15 Figure 4.1: Modelling scenario descriptions [Source: Analysys Mason, 2012] Scenario Option DTT Mobile 1 Base case: MHz is used for DTT 16 2 Mobile uses the 800MHz subband 3 Mobile uses the 700MHz and 800MHz subbands 1a DTT multiplex broadcasting in SD 1b DTT multiplex broadcasting in HD 2a Three mobile operators are each assigned 2 5MHz of 800MHz spectrum; (remaining spectrum is used by the military) 2b Three mobile operators are each assigned 2 10MHz of 800MHz spectrum; (military is transferred to other spectrum) 17 3a Three mobile operators are each assigned 2 10MHz of spectrum in 2013 (800MHz band), and 2 5MHz of spectrum in 2016 (700MHz band); in addition, a fourth mobile operator enters the market with 2 20MHz of 700MHz spectrum in b Three current mobile operators are each assigned 2 10MHz of spectrum in the 800MHz band, and subsequently (in 2016), 2 5MHz of spectrum in the 700MHz band. Military systems are also migrated from the 800MHz to the 700MHz band to use the remaining 700MHz spectrum 1a 10 multiplexes, SD programmes 1b 10 multiplexes, HD programmes 2a 8 multiplexes, SD programmes 2b 8 multiplexes, mix of SD and HD programmes 3a 5 multiplexes, SD programmes 3b 5 multiplexes, HD programmes In the absence of available 800MHz spectrum, 900MHz re-farming is accelerated 2a 2 5MHz per operator 2b 2 10MHz per operator 3a 2 10MHz per operator (three operators) in 2013 (800MHz band), an additional 2 5MHz of spectrum in 2016 (700MHz band); plus 2 20MHz of spectrum for a new entrant in b 2 10MHz per operator (three operators) in 2013; an additional 2 5MHz per operator in Military systems currently use 32 MHz of UHF spectrum from MHz (i.e. four 8MHz channels) From discussions with YME as part of this study we have noted that it is likely Greek military systems can be migrated from using the 800MHz band to using spectrum in the MHz range, at no additional cost. We have therefore performed a sensitivity analysis on Scenario 2b to assess the impact on DTT of military systems using the MHz range, in view of the resultant loss in capacity to DTT. We have also considered the impact on the DTT results in Scenario 2b DTT of a mix of SD and HD programmes being broadcast, rather than all SD. This is described in Section In this scenario, military systems could use duplex gaps in the 700MHz and 800MHz bands, plus a further 2 5MHz that is un-allocated in the 700MHz band, assuming it is possible for the military systems to use non-contiguous spectrum (which has not been confirmed within this study). It is noted that the result of an auction of 700MHz and/or 800MHz spectrum could result in a spectrum distribution that is different to our scenarios i.e. there is no guarantee that existing operators would acquire the same additional spectrum and they could each acquire different amounts. Our model has assumed an equal distribution for the purposes of estimating the welfare benefit.

19 Property rights in UHF and 2.6GHz spectrum 16 Figure 4.2: MHz band plan overview today [Source: Analysys Mason, 2012] 700MHz band MHz (92MHz) EC-recommended 800MHz band MHz (72MHz) Terrestrial television MHz (228MHz) Terrestrial television MHz (92MHz) Military MHz (30MHz) Terrestrial television MHz (40MHz) Figure 4.3: MHz band plan for Scenario 1a & 1b [Source: Analysys Mason, 2012] UHF TV band MHz (228MHz) 700MHz band MHz (92MHz) EC-recommended 800MHz band MHz (72MHz) Digital terrestrial television MHz (228MHz) Digital terrestrial television MHz (92MHz) Digital terrestrial television MHz (40MHz) Military MHz (30MHz) Figure 4.4: MHz band plan for Scenario 2a [Source: Analysys Mason, 2012] UHF TV band MHz (228MHz) 700MHz band MHz (92MHz) EC-recommended 800MHz band MHz (72MHz) Digital terrestrial television MHz (228MHz) Unused spectrum MHz and MHz (duplex gap) Digital terrestrial television MHz (92MHz) Mobile broadband 2x5MHz (x3 operators, MHz and MHz Military MHz (15MHz)

20 Property rights in UHF and 2.6GHz spectrum 17 Figure 4.5: MHz band plan for Scenario 2b [Source: Analysys Mason, 2012] UHF TV band MHz (228MHz) Proposed 700MHz band MHz (92MHz) EC-recommended 800MHz band MHz (72MHz) Terrestrial television MHz (228MHz) Terrestrial television MHz (92MHz) Duplex gap Mobile broadband 2x10MHz (x3 operators), MHz and MHz Figure 4.6: MHz band plan for Scenario 3a [Source: Analysys Mason, 2012] UHF TV band MHz (228MHz) Proposed 700MHz band MHz (92MHz) EC-recommended 800MHz band MHz (72MHz) Terrestrial television MHz (228MHz) Unused spectrum MHz and MHz (i.e. 2x5MHz), plus duplex gaps MHz and MHz (could be used for military) Duplex gap Mobile broadband 2x5MHz (x3 operators), and 2x20MHz (one operator), MHz and MHz Duplex gap Mobile broadband 2x10MHz (x3 operators), MHz and MHz Figure 4.7: MHz band plan for Scenario 3b [Source: Analysys Mason, 2012] UHF TV band MHz (228MHz) Proposed 700MHz band MHz (92MHz) EC-recommended 800MHz band MHz (72MHz) Terrestrial television MHz (228MHz) Duplex gap Duplex gap Unused spectrum MHz, MHz and duplex gaps MHz and MHz Mobile broadband 2x5MHz (x3 operators), MHz and MHz Mobile broadband 2x15MHz (x2 operators), MHz and MHz Military MHz (26MHz) Note: For each scenario, except Scenario 1a, some or all of the current military use from MHz would need to be migrated to alternative spectrum. In our scenario 2a, if the Greek Government decides to award only 15MHz of paired spectrum in the 800MHz band, rather than

21 Property rights in UHF and 2.6GHz spectrum 18 the full 30MHz paired, there is the possibility of the military retaining 15MHz of its current band (i.e. from MHz), and it could also use the remaining un-used spectrum from MHz. In other scenarios, replacement for the entire bandwidth of the 800MHz block currently used by the military use would be required. There are various options that the Hellenic Government could consider and we have shown some examples in the diagrams above. For example, it might be feasible to migrate the military to a similarly sized block of 32MHz in the 700MHz band (as illustrated by Scenario3b, where a contiguous 26MHz block is indicated for possible military use. Since the military requires 32MHz of spectrum, a further 8MHz would be required in this scenario. This could be accommodated if the military uses the 700MHz duplex gap, or the unused spectrum indicated in the diagram below, in addition to the 26MHz block identified). In Scenario 3a, where the majority of the 700MHz (and the 800MHz) band is assumed to be used for mobile systems, the remaining spectrum is in un-contiguous blocks, from MHz, MHz and MHz. We understand from our discussions with YME that the military has confirmed that use of non-contiguous blocks is viable option. We have also considered the impact on DTT of military systems using the 700MHz band in Scenario 2b, which would result in loss of capacity for DTT. We have modelled this as a loss of one multiples on DTT. It is also noted that, if military systems use the duplex gaps in the 700MHz and 800MHz bands, it precludes those gaps from being used for other commercial services, such as mobile systems using technology based on unpaired spectrum (i.e. time division duplex, or TDD), or programme making and special events (PMSE). We have not accounted for the impact of PMSE having more or less spectrum in the UHF band as part of our modelling. Finally, if no other option exists, it may be possible to move the military systems out of the UHF band entirely to another core military band. For each of the modelled scenarios as illustrated above, we considered the impact on the model drivers (both revenue and cost) and adjusted accordingly. In addition to these scenarios, we modelled a series of sensitivity tests to assess the impact of some of the key drivers being either substantially higher or lower than expected. These sensitivity tests and their impact on the model are outlined in Section 5.4 below.

22 Percentage of households Property rights in UHF and 2.6GHz spectrum Overview of mobile and broadcast markets in Greece Demographic and geographical profile Greece had a gross domestic product (GDP) of just over EUR230 billion in 2010, and a population of 11.3 million, suggesting a GDP per capita of (see Figure 4.8 below). Its population density was 87.6 persons per square metre. Greece covers a land area of square kilometres, and has a land area per capita of 11.4 thousand square metres. Figure 4.8: Greek demographic information [Source: Analysys Mason, 2012] GDP Population GDP per Population Households Land area Land area (billions) (millions) capita density (millions) per capita EUR EUR /sq km sq km sq m The 11.3 million Greek inhabitants are distributed over 4 million households, with an average of 2.8 occupants per household. As Figure 4.9 shows, most households are located within urban areas, with the split remaining fairly constant over the last few years. Owing to current economic conditions, a migration of population towards the countryside has been suggested, however, this impact is likely to be reversed as the country s economy recovers, and the overall split is not expected to change significantly in the long term. 100% 90% 80% 70% 60% Figure 4.9: Greece Historical and forecast urban and rural household distribution, [Source: Euromonitor, 2011] 50% 40% 30% 20% 10% 0% Urban Rural Mobile market There were 12.1 million mobile subscribers in Greece at June 2011, which represents a population penetration of 109.9%. As Figure 4.10 shows, mobile penetration exhibited rapid growth until 2009 (124% penetration), but declined sharply in 2010 (106% penetration at year end). This was

23 Percentage of population H 2011 Property rights in UHF and 2.6GHz spectrum 20 largely due to the reduction in the number of prepaid subscribers (8.6 million to 7.2 million) which, in turn, resulted from new government regulations to register prepaid users. 140% 120% 100% 80% Figure 4.10: Greece Historical mobile penetration (active subscribers), [Source: Analysys Mason, 2012] 60% 40% 20% 0% Mobile operators At June 2011, the mobile market was contested by three operators. COSMOTE, the mobile subsidiary of the Greek incumbent OTE, dominated the market with a 51.3% share of total subscribers (see Figure 4.11). Prior to 2007, Q-Telecom was also an active mobile operator in the Greek market but subsequently merged with WIND, its parent company % Figure 4.11: Greece - Mobile market shares (active subscribers), June 2011 [Source: Analysys Mason, 2012] 51% 28% COSMOTE Vodafone WIND 20 Source: Analysys Mason, 2011

24 Percentage of subscribers H 2011 Property rights in UHF and 2.6GHz spectrum 21 As Figure 4.12 shows, COSMOTE has historically been the mobile market leader in number of subscribers, increasing continuously from 39% in 2007 to 51.3% in The second largest mobile operator, Vodafone, has lost market share to COSMOTE over the last four years. Similarly, despite the merger of Q-Telecom and WIND in 2007, WIND has experienced a continuous yearon-year decline in market share from 2007 to 2011, dropping six percentage points over the period. 60% 50% 40% 30% Figure 4.12: Greece Historical mobile market shares (active subscribers), [Source: Analysys Mason, 2012] 20% 10% 0% COSMOTE Vodafone WIND Unlike other European countries, the Greek market has not yet seen the introduction of MVNOs. However, two major retailers, Carrefour and Marinopoulos, have acting as resellers of Vodafone s prepaid services since November Spectrum holdings and network coverage All Greek mobile operators hold 2G and 3G licences, as shown below. The most recent spectrum allocations were made in the 900MHz and 1800MHz bands through an auction that was completed in November MHz and 1800MHz spectrum was re-assigned as a result of 2G licences expiring in The new licences that have been awarded through the recent process are valid for 15 years, until Source: Analysys Mason, 2011.

25 Property rights in UHF and 2.6GHz spectrum 22 Spectrum band COSMOTE Vodafone WIND Figure 4.13: Greece Paired 900MHz MHz GHz Total paired (MHz) Unpaired (MHz) 2.1GHz Total unpaired (MHz) Total spectrum (MHz) Spectrum allocations by mobile operator [Source: PolicyTracker Global Spectrum Database, 2011; Analysys Mason, 2011; TeleGeography, 2011, YME] GSM, W-CDMA and HSPA technologies are used by COSMOTE, Vodafone and WIND. COSMOTE has also conducted trials of LTE in Athens and announced in October 2010 its success of achieving up to 100Mbit/s on its pilot mobile broadband network. 22 However, no commercial deployment has yet been made. Figure 4.14: Greece Technologies used by mobile operators [Source: Analysys Mason Wireless networks tracker, 2011] *Trialled in MHz 1800MHz 2.1GHz COSMOTE GSM, GPRS, UMTS900, LTE* GSM, GPRS, LTE* W-CDMA, HSPA, HSPA+ 64 QAM Vodafone GSM GSM W-CDMA, HSPA, HSPA+ 64 QAM, HSPA+ with MIMO, Femtocells WIND GSM, GPRS, EDGE GSM, GPRS, EDGE W-CDMA, HSPA The mobile market leader, COSMOTE, has extensive 2G and 3G networks, with the former providing coverage to 99.8% of the population and the latter 97.4% at September 2011 (source: TeleGeography, ). Launched in July 2009, COSMOTE s HSPA+ network is estimated (by TeleGeography) to have reached over 60% of the Greek population by September Vodafone s 2G network provides the same extent of coverage as COSMOTE s: 99.8%. In September 2011, its 3G network reached 95% of the population. Like COSMOTE, Vodafone launched an HSPA+ network in July 2009 which, at September 2011, provided coverage for over 50% of the population 22. WIND provided 99% 2G population coverage at September At the same point, its 3G network provided coverage to 80% of the Greek population 22. WIND s HSPA+ network is expected to be launched in the second quarter of Source: TeleGeography, 2011

26 Connections (million) H 2011 Property rights in UHF and 2.6GHz spectrum 23 According to information provided by YME for this study, the total 3G and 3G+ (i.e. HSPA+) coverage in Greece, split by geo-type as a percentage of population and of the geography of Greece, can be broken down as follows 24. Figure 4.15: 3G coverage by geo-type [Source: YME, 2011] Coverage Urban Suburban Rural Total 3G as a percentage of population G+ as a percentage of population G as a percentage of territory G+ as a percentage of territory Mobile services As Figure 4.16 illustrates, mobile voice and broadband traffic among Greek users has been rising, with fixed-mobile substitution being particularly evident in the telephony market. Although the high fixed-mobile premium initially hampered the take-up of mobile voice services, mobile voice traffic surpassed fixed voice traffic in 2008 and continued to grow thereafter. The growth has been further encouraged by a reduction in the fixed-mobile premium to 20% from January to September As a result of the substitution, fixed voice traffic has experienced a significant decline Figure 4.16: Greece Mobile and fixed voice connections, [Source: Analysys Mason, 2012] Mobile Fixed Mobile broadband has been less promising than its fixed counterpart, accounting for only 12.6% of the total broadband connections at the end of December With subscribers at the end of June 2011, COSMOTE led the mobile broadband market. 24 Coverage from each of the 2G networks exceeds 99.5%.

27 Connections (thousands) Connections (million) H H 2011 Property rights in UHF and 2.6GHz spectrum Figure 4.17: Greece Mobile and fixed broadband connections, [Source: Analysys Mason, 2012] Mobile Fixed Owing to the as yet low penetration of mobile broadband, the market has seen rapid growth since At the start of 2011, 2.6% of the Greek population connected to the Internet via modems and/or data cards on 3G networks, up from 2% in the previous year. The growth trend is depicted in Figure The surge in 2007 can be attributed to a sharp reduction in mobile broadband access tariffs. The slight slowdown in take-up, however, can partially be attributed to economic difficulties that the country is currently experiencing Figure 4.18: Greece - Mobile broadband connections, [Source: Analysys Mason, 2012] Source: TeleGeography, 2011.

28 Percentage of population * 2012* 2013* 2014* 2015* 2016* Property rights in UHF and 2.6GHz spectrum 25 Mobile data use is increasing in Greece and non-voice service revenue stood at almost 18% at the end of June The mobile operators are increasing their efforts in mobile broadband provision in order to drive additional revenue. For example, a variety of mobile broadband tariffs for laptop users and iphone 3G-based tariffs are being offered. Mobile broadband pricing Several strategies for increasing mobile broadband adoption have been implemented by the operators. COSMOTE, for example, initially focused on modem users, subsequently also promoting data usage via 3G handsets and other devices, by offering packages that enabled users to share their capacity across different mobile devices. Vodafone was successful in its mobile broadband provision, and, in April 2011, also promoted mobile data over handsets, through an unlimited web-surfing offer for EUR1 per day. Mobile broadband is offered in a variety of packages and for a range of tariffs by the Greek mobile operators, with an average of EUR per MB. When compared to the EU average of EUR per MB, this is deemed still high. Demand forecasts The prevailing economic downturn in Greece has affected the development of the mobile market in several ways, as discussed throughout this section of the report. Mobile penetration Figure 4.19 shows the development of mobile penetration in Greece. Between 2009 and 2012, penetration saw a period of decline, resulting from prepaid SIM registration requirements and the economic downturn. Forecasts suggest that following this downturn, growth in mobile penetration from 2013 is expected to recover to its pre-2009 growth levels. 160% 140% 120% 100% Figure 4.19: Greece - Mobile population penetration forecast, [Source: Analysys Mason, 2012] 80% 60% 40% 20% 0%

29 Connections (million) Connections (million) Property rights in UHF and 2.6GHz spectrum 26 Technology evolution and penetration With advances in technology, and more specifically the current LTE activity on the parts of COSMOTE and Vodafone, the Greek mobile market is forecast to move rapidly from 2G to 3G and 4G services (see Figure 4.20). The penetration of 3G services is expected to overtake that of 2G services in 2013, and the former is likely to be the dominant mobile technology in the market for several years in the near and mid-term future Figure 4.20: Greece - Technology penetration forecast by connections, [Source: Analysys Mason, 2012] G 3G 4G Services Figure 4.21 shows that, from 2012 to 2016, the growth of mobile data is predicted to follow a similar path as the preceding five years slow but steady growth. The assumed growth in mobile data is largely driven by the increasing use of smartphones as shown below Figure 4.21: Greece Mobile broadband connection and handset forecasts, [Source: Analysys Mason, 2012] Basic handset Smartphone Mobile broadband connections

30 Percemtage of service revenue Property rights in UHF and 2.6GHz spectrum 27 Mobile data revenues are forecast to represent a much larger share of total mobile service revenues over the next five years (as shown in Figure 4.22). This is primarily the result of the rapidly increasing take-up of both handset and mobile broadband data services Figure 4.22: : Greece Mobile voice and data service revenues forecast, [Source: Analysys Mason, 2012] % data revenue % voice revenue DTT market The terrestrial TV market in Greece comprises a mix of public service and private (commercial) broadcasters, which is also the case in many other European countries. There are eight private TV broadcasters with national coverage (Antenna, Mega, Star, Alpha, Alter, Skai, Makedonia and 902). At present, channel 902 does not broadcast digitally, but it is authorised to do so. In addition, there are 74 regional coverage TV stations, and 52 local TV stations. In line with other European countries, Greece intends to replace analogue terrestrial television services with DTT, in accordance with the frequency and co-ordination arrangements for DTT as defined in the ITU-R Geneva-06 agreement and plan (GE-06). The public service broadcaster, ERT, commenced trials of DTT during 2006 and this trial was subsequently transformed to a commercial service. A ministerial decision on digital switchover, on the basis of national law 3592/2007, describes the planned transition from analogue to digital terrestrial television, proposing that the DTT network will be based on 23 sites for digital transmissions. Information provided by YME for this study confirmed that, at present, 12 of the 23 sites are currently broadcasting digital transmissions; of these, two are broadcasting digital signals of analogue programmes in simulcast with analogue transmissions of the same programme. Within the transmission area of one, there is analogue switch-off; for the other areas, some TV channels that are being broadcast with analogue signals will cease when the digital transmissions of these channels starts at these sites 26. We understand that the intention is for the 26 Appendix III of the Common Ministerial Decision (CMD) for the transition period lists the analogue channels that could cease transmission once digital transmissions of these channels is commenced.

31 Property rights in UHF and 2.6GHz spectrum 28 remaining sites to be transferred to digital transmission ahead of analogue switch-off (ASO) and that it is technically and operationally possible for this migration to be completed by the end of In August 2008, the Common Ministerial Decision (CMD) was issued based on the national law 3592, in order to describe the transition from analogue to digital TV. The transition plan also assumes that the following digital capacity is provided: eight multiplexes available for the areas of Athens and Thessalonika seven multiplexes for the rest of Greece four programmes per multiplex. The digital multiplexes are to be broadcast using 23 sites that make use of frequency/area allotments that have been granted to Greece within the GE-06 plan. In total, Greece has been allocated 34 allotments within the GE-06 plan and has 357 plan assignments (across VHF and UHF bands), which use frequencies distributed across UHF Bands IV and V (up to UHF channel 66, since the channels above this are used by the military) 27. Note that a decision by the Hellenic Government to award frequencies in the 800MHz sub-band for mobile use will impact those allotments granted to Greece within the GE-06 plan that use DTT channels 61 to 66 (which will no longer be available as a result of the 800MHz band being made available for mobile use). This will potentially affect 20 of the 34 allotment areas. Our estimate of the areas affected is provided in Annex A. Although digital services have now commenced in Greece, we understand that the frequency licensing of those services is still to be confirmed. Other than terrestrial television services, there are a number of pay TV services provided over satellite and broadband (i.e. IPTV platforms). There are also two pay TV channels provided over the terrestrial network, Filmnet and Supersport. There are no cable TV services in Greece. In view of this, the Greek TV market is therefore dominated by terrestrial television viewers, at present. Information provided by YME for this study suggests the following subscribers of pay-tv services delivered over IPTV, bundled with different telecommunications services (double-play and triple play): Figure 4.23: IPTV pay-tv subscribers by package [Source: YME, 2011] Package Double play Triple play Total subscribers Total Although migration of terrestrial services to digital is now underway, the majority of terrestrial viewers are still using analogue services in view of the limited number of transmission sites that have been transferred to digital transmission to date. 27 If the 800MHz band is to be used for mobile services, 316 plan assignments will remain, since the remainder are in DTT channels 61 to 66, which would not be available for DTT if the 800MHz is used for mobile services.

32 Property rights in UHF and 2.6GHz spectrum 29 Across Europe, various different approaches have been taking to licensing of DTT. These are further considered in Section 7. Many European countries have already completed digital switchover (DSO), with others to be completed over the coming year. A summary of DSO status across Europe is provided below. Figure 4.24: European DSO status [Source: Analysys Mason, 2012] Country ASO Date Status at 31/12/2011 Austria 2010 Complete Belgium 2010 Complete Bulgaria Cyprus 2011 Complete Czech Republic 2011 Complete Denmark 2009 Complete Estonia 2010 Complete Finland 2007 Complete France 2011 Complete Germany 2008 Complete Greece 2012/2013 Subject to this study Hungary Ireland 2012 Completed 24 October 2012 Italy Latvia 2010 Complete Lithuania 2012 Completed 29 October 2012 Luxembourg 2006 Complete Malta 2011 Complete Netherlands 2006 Complete Poland 2013 ASO 31 August 2013 Currently 87% population coverage Portugal 2012 Completed 26 April 2012 Romania 2015 ASO starts 2013 Slovakia 2012 Slovenia 2010 Complete Spain 2010 Complete Sweden 2007 Complete UK 2012 Completed October 2012

33 Property rights in UHF and 2.6GHz spectrum Calculating costs and benefits of different allocation options for UHF spectrum As described in the introduction to this report, the Greek Government is yet to formalise its decision on whether UHF spectrum from MHz should be used entirely for DTT or whether a portion potentially the 800MHz band, and possibly the 700MHz band might be used for mobile broadband services. We have been asked to estimate the costs and benefits of different allocation options for UHF spectrum in order to identify the scenario that provides the best outcome in terms of contribution to the Greek economy. In calculating the costs and benefits of each of our UHF spectrum scenarios, we have considered the economic benefit in terms of private value, in addition to the wider social benefits of the service (termed external benefits). The private value has been calculated on an annual basis for the assumed licence period of 20 years from 2013 (the earliest potential date for operational use of the spectrum), taking the model to This is further described below. The annual cash flows have then been discounted at a social discount rate of 5% (applied to the consumer surplus) and a commercial discount rate of 12% (applied to the producer surplus) to calculate the net present value (NPV). The 5% social discount rate is based on a study undertaken by Dr David Evans of Oxford Brookes University in The base case commercial discount rate is based on the mid-point between recent rates used by OTE and Vodafone Greece. However, given the sensitivity of the model to this assumption, and the potential variances given the current uncertainty in the Greek market, we have modelled the sensitivity of the results to the commercial discount rate in Section 5.4 above Private value Private value is defined as the welfare benefits that users get from a service, minus what this service costs to produce, and is often split between consumer surplus (benefit to consumers minus the price they pay) and producer surplus (revenue of the producers minus the costs to provide the service). Figure 4.25 illustrates the standard approach to calculating the consumer and producer surplus. 28 Dr David J Evans (October 2006), Social discount rates for the European Union. Available at

34 Property rights in UHF and 2.6GHz spectrum 31 Price Choke price Consumer surplus Figure 4.25: Private value calculation illustration [Source: Analysys Mason, 2012] Producer surplus Supply cost Selling price Subscribers Demand Consumer surplus The consumer surplus represents the direct value to the consumer over and above what they pay for the service. Figure 4.26 below illustrates, at a high level, how our mobile model calculates the consumer surplus for each service under each scenario. To begin with, we have projected demand, in terms of subscribers and average spend per user, in addition to the choke price (the price at which demand is zero), in every year of the model. Consumer surplus is then calculated using the formula: Consumer surplus = (Annual choke price annual ASPU)*(year average subscribers)/2 Subscribers ASPU Consumer surplus Figure 4.26: Consumer surplus calculation overview, mobile model [Source: Analysys Mason, 2012] Choke price Detailed inputs and calculations for the consumer surplus for each service are presented in Sections and below.

35 Property rights in UHF and 2.6GHz spectrum 32 Producer surplus The producer surplus represents the direct value to the consumer of receiving a service (reflected in what they pay) netted off against the cost to provide the service. The producer surplus also includes any additional economic value to the industry, but not to the consumers, for example advertising revenues. This additional economic value is sometimes referred to as an indirect benefit. Figure 4.27 below, illustrates how our mobile model estimates the producer surplus, at a high level, for each service and scenario. The subscribers and ARPU forecasts established to calculate consumer surplus are used to derive the producers revenues, from which the costs of production (COGS, capex and opex) are subtracted. The resulting free cash flow forms the producer surplus in each year 29. Subscribers ASPU Revenue Figure 4.27: Producer surplus calculation overview, mobile model [Source: Analysys Mason, 2012] COGS Profit=PS Opex Capex Detailed inputs and calculations for the producer surplus for each service are presented in sections and below External benefits In addition to the private value of a service, wider societal and economic benefits may result that should be taken into consideration. These benefits may include information dissemination, diversity, access and inclusion. Benchmarks for the level of external benefits that can be assumed from mobile broadband and television services vary between 5% and 10%. 30 For the purposes of this study, we have applied an additional 10% in external benefits to both the television and broadband revenues Note that the calculation does not include taxes and licence fees that the producer might incur. Ofcom, 2006, Digital Dividend Review Annexes, p

36 Property rights in UHF and 2.6GHz spectrum The mobile model We have adopted the above method of calculating private value in building the mobile model. The model is split into three sections: mobile broadband consumer surplus mobile broadband producer surplus fixed broadband consumer and producer surplus. The fixed broadband market value was modelled in order to take into account any potential losses that might be incurred through the availability of high-speed mobile broadband services. In this way, we can reflect the impact of each scenario on the industry as a whole Mobile broadband consumer surplus The mobile model is split into multiple segments in order to calculate the impact of additional spectrum on revenues and costs. These categories consist of: urban/rural 3G/LTE mobile broadband/handset standard value/high value. The following figure illustrates the approach we have used to estimate the consumer surplus for mobile broadband services. Figure 4.28: Mobile broadband consumer surplus approach [Source: Analysys Mason, 2012] Penetration (urban / rural, 3G / LTE) Population (urban / rural) Penetration (urban / rural, 3G / LTE) 3G subscribers (urban / rural, standard / high value) LTE subscribers (urban / rural, standard / high value) 3G subscribers (urban / rural, standard / high value) LTE subscribers (urban / rural, standard / high value) 3G ASPU 3G choke price LTE ASPU LTE choke price 3G ASPU 3G choke price LTE ASPU LTE choke price MBB consumer surplus Handset consumer surplus External benefit Total consumer surplus Fixed broadband penetration Fixed broadband subscribers Fixed broadband ASPU Fixed BB consumer surplus Fixed broadband choke price Note: mobile broadband handset fixed broadband

37 Property rights in UHF and 2.6GHz spectrum 34 Key inputs to the mobile consumer surplus model include: population trends penetration of mobile broadband and handsets migration from 3G and LTE, including 3G switch-off average spend per user (ASPU) choke price. Each of these inputs was considered in the light of our spectrum scenarios, and trend assumptions were adapted to reflect these scenarios. In addition, we tested base, high, low sensitivities around mobile broadband and handset penetration, split between 3G and LTE and ASPU Mobile broadband producer surplus The producer surplus model follows a similar structure, considering four main items, namely: subscriber revenues cost of goods sold (COGs) operational expenditure (opex) capital expenditure (capex). Please note, we have not included interconnect revenues or costs, as these are primarily passed between the operators within a single country and as such, do not have an impact on the private value for the country as a whole. The following figure illustrates the approach we have used to estimate the producer surplus for mobile broadband services. Figure 4.29: Mobile broadband producer surplus approach [Source: Analysys Mason, 2012] 3G ASPU 3G ASPU 3G subscribers LTE subscribers Total revenue External benefit Total revenue 3G subscribers LTE subscribers LTE ASPU Per site costs COGS Capex Producer surplus Producer surplus COGS Capex LTE ASPU Per site costs Per site costs Per subscriber costs Opex Total producer surplus Opex Per site costs Per subscriber costs Fixed BB revenue Fixed BB EBITDA margin Fixed BB producer surplus Note: mobile broadband handset fixed broadband

38 Property rights in UHF and 2.6GHz spectrum 35 In addition to the inputs used for the consumer surplus, additional inputs to the mobile producer surplus model include: total number of operators, split between urban and rural total mobile sites, split between 3G and LTE, main sites and micro sites site sharing, by technology and between operators COGs as a percentage of revenue site costs, new sites and radio upgrades, main sites and micro sites staff costs site running costs site maintenance costs site rental costs marketing bad debt G&A. Similarly to the consumer surplus, each of these inputs was considered in the light of our spectrum scenarios, and trend assumptions were adapted to reflect these scenarios. In addition, we tested base, high, low sensitivities around site sharing, and total main and microsites by technology. In our modelling, we assume that 2.6GHz spectrum will be available to mobile operators at or around the same time as the 800MHz frequencies. In many European countries, regulators are planning to award 2.6GHz licences for mobile broadband use, providing mobile operators will additional capacity suitable for delivery of high-speed data services particularly in urban areas. With a total of 2 70MHz of spectrum available in the 2.6GHz band, there is sufficient spectrum in this band for each mobile operator to acquire at least a contiguous 20MHz paired block (subject to licence conditions that might apply in individual countries, such as spectrum caps). Without 2.6GHz spectrum, it is likely that mobile broadband penetration in urban areas will be slightly lower owing to the lower data speeds caused by a smaller carrier (800MHz carrier of MHz versus a 2 20MHz carrier within the 2.6GHz band). In addition, without 2.6GHz spectrum, it is likely that mobile operators will need to add additional microsites in urban areas to increase capacity of the mobile broadband service Fixed broadband consumer and producer surplus In calculating the private value from mobile use of different amounts of UHF spectrum, we have assumed that in a scenario in which mobile operators were able to gain significant UHF bandwidth for LTE deployment (e.g. 2 15MHz or 2 20MHz per operator, which would be possible if the Greek Government were to allocate both 700MHz and 800MHz sub-bands for mobile use), there would be an increase in substitution effects between fixed and mobile broadband markets. In other words, availability of high quality, high-speed mobile broadband services might encourage some Greek citizens to abandon fixed broadband entirely, in favour of mobile services.

39 Property rights in UHF and 2.6GHz spectrum 36 In scenarios within our model in which mobile operators gain 2 15MHz or more of UHF spectrum we have therefore considered that a proportion of subscribers will transfer from fixed to mobile broadband use. This results in a loss of value in the fixed broadband market, which we need to account for in our model to avoid over-estimating the private value from mobile use. The consumer surplus and revenue side of the producer surplus are calculated using subscriber, ARPU and choke price assumptions. In order to calculate the cost side of the fixed broadband producer surplus, we have used a benchmark of EBITDA margins. Additional capital expenditure is assumed to be minimal. 4.5 The DTT model We have adopted the method described above for calculating private value in building the DTT model. The model is split into three sections: DTT consumer surplus (both free-to-air (FTA) DTT and some pay-tv channels, assuming that, in line with many other European countries, the DTT network in Greece might include a mixture of FTA and paid-for content in the future) DTT producer surplus (as above) non-dtt, pay TV consumer and producer surplus. The non-dtt pay TV market value was modelled in order to take into account any potential losses that might be incurred through the availability of improved free-to-air DTT services. In other words, the availability of improved free-to-air DTT services might result in some substitutive effects (for example, cancellation of pay TV subscriptions). In this way, we can reflect the impact of each scenario on the industry as a whole. Our modelling of the value of UHF spectrum for DTT in the base case (Scenarios 1a and 1b) considers a ten-multiplex DTT network. In Scenarios 2a and 2b we have assumed that loss of the 800MHz band will result in a reduction from ten to eight multiplexes, and in Scenarios 3a and 3b, the loss of the 700MHz and 800MHz band results in a further reduction in multiplexes, from eight to five. However, we note that further optimisation of the DTT frequency plan may make it possible to accommodate additional multiplexes (e.g. by migrating from multi-frequency networks (MFN) to single frequency networks (SFN)). The frequency plan for DTT services has not been evaluated as part of this study, other than to assess the estimated impact of the loss of the 800MHz band, which is illustrated in Annex A. For the purposes of our modelling, we have assumed that each DTT multiplex can accommodate six programmes if used for SD programming, or three programmes if used for HD (using DVB-T). We have also considered the impact on economic value if DVB-T2 is used for HD programming, since using DVB-T2 for HD programming would result in an increase in the number of HD channels per multiplex, which we have estimated to be an increase from three to five.

40 Property rights in UHF and 2.6GHz spectrum DTT consumer surplus The DTT consumer surplus model is based on the total number of channels available for a given number of multiplexes, which fit within the allocated spectrum for each scenario. The channels are further split between SD and HD. The choke price on which the DTT consumer surplus is based, is calculated using an incremental value per channel curve, showing diminishing returns as the total number of channels increase. High definition channels are assumed to hold higher marginal value per channel compared to SD. The following figure illustrates the approach we have used to estimate the consumer surplus for DTT services. Figure 4.30: Approach to calculating DTT consumer surplus [Source: Analysys Mason, 2012] Number of MUX (SD/HD) Channels per MUX (SD/HD) Subscription and licence fee CPE and other cost Population coverage Terrestrial penetration Other TV platforms market share Number of channels (SD/HD) Subs Choke price ASPU Choke price Average revenue per DTT HH Subscribers DTT consumer surplus External benefit Other TV platforms consumer surplus Total consumer surplus Note: DTT other TV platforms (e.g. IPTV and satellite) Key inputs to the DTT consumer surplus model include: colour TV households pay DTT subscribers as a percentage of the total DTT multiplexes by scenario number of channels per multiplex split of multiplexes between SD and HD (HD is itself split between DVBT and DVBT-2) terrestrial television licence fees (applied to all households in Greece) DTT customer premise equipment (CPE) costs such as set-top box, antennae and installation pay DTT average spend per user (ASPU) pay DTT choke price.

41 Property rights in UHF and 2.6GHz spectrum 38 Each of these inputs was considered in the light of our spectrum scenarios, and trend assumptions were adapted to reflect these scenarios. In addition, we tested base, high, low sensitivities around pay DTT as a percentage of total DTT and the number of channels per multiplex DTT producer surplus The DTT producer surplus model introduces the indirect benefit of advertising revenues to the DTT industry. The model is structured around five key areas: subscriber revenues (including fees paid by Greek TV viewers through power supply bills and purchase of set-top boxes, antennas for digital coverage and installation fees, where applicable) advertising revenues cost of goods sold (COGs) operational expenditure (opex) capital expenditure (capex). The following figure illustrates the approach we have used to estimate the producer surplus for DTT services. Figure 4.31: Approach to calculating DTT producer surplus [Source: Analysys Mason, 2012] Total terrestrial TV advertising revenue Other TV platforms' market share Terrestrial TV market share Licence fees, subscription fees and CPE revenue Total DTT revenue Subscription revenue Advertising revenue COGS Total COGS, opex and capex Other TV platforms revenue EBITDA margin Number of sites Network capex per site Number of multiplexes Network opex per site Programming costs DTT producer surplus External benefit Other TV platforms producer surplus Other costs Total producer surplus Note: DTT other TV platforms (e.g. IPTV and satellite) In addition to the inputs used for the consumer surplus, additional inputs to the DTT producer surplus model include: total television advertising revenue terrestrial television share of advertising

42 Property rights in UHF and 2.6GHz spectrum 39 additional revenues from sponsorship and interactive services CPE equipment costs network opex per site, split between main sites and repeater sites programming costs other opex switchover cost of communications and marketing upgrade to digital cost per site, split between main sites and repeater sites upgrade cost for the distribution link per site cost per additional multiplex capex replacement cost. Similarly to the consumer surplus, each of these inputs was considered in the light of our spectrum scenarios, and trend assumptions were adapted to reflect these scenarios. In addition, we tested base, high, low sensitivities around pay DTT as a percentage of total DTT and the number of channels per multiplex Non-DTT, pay TV consumer and producer surplus In calculating the fixed broadband private value, we considered the impact of the improvement in the free-to-air DTT service through the addition of extra channels on the pay TV market and the resultant potential loss in pay TV revenues. The consumer surplus considered a uniform ASPU and choke price across all scenarios, taking into account differences in pay TV subscriber forecasts. The producer surplus is calculated based on both subscription and advertising revenues, in addition to additional revenues from sponsorship and interactive services. In order to calculate the cost side, we have used a benchmark of EBITDA margins. Additional capital expenditure is assumed to be minimal.

43 Property rights in UHF and 2.6GHz spectrum 40 5 Modelling results for the economic impact of UHF spectrum In this section we summarise the key results of our models in terms of the relative economic (welfare) benefits of different assignments of UHF spectrum to mobile and DTT services, and the key sensitivities considered. 5.1 Mobile results Figure 5.1 below shows the results of our mobile model scenarios, split between the consumer surplus and producer surplus, creating the total direct and indirect private value. Further to this, we have considered the additional external benefits to find the total economic value of each spectrum scenario. The annual figures for each of these values have been calculated for the period and discounted back to 2013 at a social discount rate of 5% (applied to the consumer surplus) and a commercial discount rate of 12% (applied to the producer surplus). We have modelled the sensitivity of the results to the commercial discount rate in Section 5.4 below. The figures below represent the net present value (NPV) of the values in Figure 5.1: Value generated by mobile broadband services (3G and 4G) between 2013 and 2032, taking into account the loss to the fixed market, all figures are in Euros, millions [Source: Analysys Mason, 2012] Consumer surplus Producer surplus Total private value Total economic value (incl. external benefits) Increment on base case Scenario 1a Scenario 1b Scenario 2a Scenario 2b Scenario 3a Scenario 3b Scenario 3a provides the highest total economic value. It is driven by i) a high consumer surplus that results from a reduction in ARPU owing to the presence of a fourth operator in the market, and ii) an elevated mobile broadband penetration that results from the increased competition and lower ARPU. 31 Scenario 3a and 3b assume that the 700MHz band is harmonised for availability from 2016 onwards. Should the spectrum not be available until 2017, the increment on the base case would drop by around 0.2% for Scenarios 3a and 3b.

44 Property rights in UHF and 2.6GHz spectrum 41 Scenario 3a produces the highest producer surplus. Take-up of mobile broadband is slightly lower than in Scenario 3a. However, there are no costs associated with building and operating an additional network, and ARPU erosion is not assumed to be as rapid. We note that one possibility to release 800MHz spectrum for mobile use might be to migrate military systems to the 700MHz band. We estimate that the impact of this (i.e. the loss of value from the entire 700MHz band not being available for mobile services in future) is around EUR1.6 billion, based upon the results above DTT results As for the mobile model, the table below shows the results of our DTT model scenarios, split between the consumer surplus and producer surplus, creating the total direct and indirect private value. Further to this, we have considered the additional external benefits to find the total economic value of each spectrum scenario. The annual figures for each of these values have been calculated for the period and discounted back to 2013 at a social discount rate of 5% (applied to the consumer surplus) and a commercial discount rate of 12% (applied to the producer surplus). We have modelled the sensitivity of the results to the commercial discount rate in Section 5.4 below. The figures below represent the NPV of the values in Figure.5.2: Value generated by DTT services between 2013 and 2032, taking into account the loss to the pay TV market, all figures are in Euros, millions [Source: Analysys Mason, 2012] Consumer surplus Producer surplus Total private value Total economic value (incl. external benefits) Increment on base case Scenario 1a Scenario 1b Scenario 2a Scenario 2b Scenario 3a Scenario 3b Scenario 1a (with ten SD multiplexes) generates the highest overall economic value. This high value is driven largely by the consumer surplus, which itself is driven by the 60 SD channels that are available in this scenario. However, the producer surplus is correspondingly lower owing to the additional programming costs of supporting all of these channels, and costs of additional multiplexes being deployed within the network. 32 This is the difference in economic impact between Scenarios 3a and 3b.

45 Property rights in UHF and 2.6GHz spectrum 42 By contrast, Scenario 3b yields the highest producer surplus, which offers only 15 HD channels, and as such bears a lower programming cost 33 and also a lower multiplex cost (only 5 multiplexes in total). The DTT producer surplus is primarily driven by network cost, owing to the fact that the revenue streams for DTT are largely uniform across scenarios. The impact on share of advertising is assumed to be relatively minimal, with a slight increase in the non-dtt pay TV share when the total number of DTT channels is reduced. An increase in the pay-dtt market share with an increase in total channels, also contributes to a slight elevation in overall revenues. The HD scenarios generate consistently lower surplus than their SD counterparts, despite an assumed higher relative value per channel for HD against SD. This is due to the reduction in the overall number of channels that can be accommodated per multiplex in HD rather than SD. It is assumed that in practice one multiplex might accommodate a mixture of SD and HD channels, although we understand that the Hellenic Government has not taken a final decision on the number of SD and HD programmes that will be broadcast per multiplex. In our model we have predominantly considered all channels per multiplex to be in either SD or HD for ease of presentation of the results. However, we have modelled a combined SD and HD scenario in Section below. As an additional sensitivity, we have also considered the impact of the use of DVBT-2for HD channels, which provides an increase in programming capacity compared to DVB-T Combined results The mobile and DTT results alone, however, do not provide a view on the total impact to the Greek mobile and TV markets of assigning UHF spectrum between the two. In order to do so, it is necessary to match the two sets of scenarios according to the spectrum assignments between the two industries. Figure 5.3 presents the combined results of all of the UHF scenarios. Figure 5.3: Value generated by mobile and DTT services by scenario between 2013 and 2032, all figures are in Euros, millions [Source: Analysys Mason, 2012] Consumer surplus Producer surplus Total private value Total economic value (incl. external benefits) Increment on base case Scenario 1a Scenario 1b Scenario 2a Scenario 2b Scenario 3a Scenario 3b We have assumed the cost of producing content in HD is higher than the cost of producing in SD, but the smaller number of channels for HD means that less programming content overall is required.

46 Property rights in UHF and 2.6GHz spectrum 43 The combined results reflect the trends in the mobile broadband model, with Scenario 3a (three mobile operators are assigned 2 15MHz of spectrum each, and 5 SD multiplexes are deployed) producing the highest overall economic value. This is because of the largest welfare impact from use of spectrum derives from the mobile, rather than the DTT, market. 5.4 Modelling sensitivities In order to understand the sensitivity of our valuations to some of the key trend inputs, we have modelled a series of sensitivity tests for both the mobile and the DTT models. The sensitivities used and the impact of these on the final results are shown below Mobile A series of assumptions on mobile broadband take-up and spend, along with the split of subscribers by network technology (i.e. 3G, or 4G such as LTE) are the primary drivers within the mobile model. We have considered the sensitivity of several of these assumptions using a high and low variant from the base case. We note that no UHF spectrum is assigned for mobile use in our base case. Therefore, Scenarios 1a and 1b assume that the existing mobile operators will deploy mobile broadband services in their existing spectrum holdings (e.g. by re-farming 900MHz networks from 2G to 3G technology) and in the 2.6GHz band. In all other scenarios, spectrum in the 800MHz (or 700MHz and 800MHz) band is available for mobile broadband use. In these cases, we have assumed that penetration is correspondingly higher as a result of the greater availability of new, sub-1ghz spectrum that can be used to deploy mobile broadband services more cost effectively. Figure 5.4: Summary of sensitivities under five scenarios for mobile broadband model [Source: Analysys Mason, 2012] Scenarios 1a & 1b Scenario 2a Scenario 2b Scenario 3a Scenario 3b MBB penetration (2032) High case 39% 53% 57% 62% 61% Base case 35% 48% 52% 56% 55% Low case 32% 43% 47% 50% 50% Handset penetration (2032) High case 165% 165% 165% 165% 165% Base case 150% 150% 150% 150% 150% Low case 135% 135% 135% 135% 135% MBB ASPU (2032) High case Base case Low case Handset ASPU (2032) High case Base case Low case

47 Property rights in UHF and 2.6GHz spectrum DTT We also considered the sensitivity of two of our DTT assumptions on the total economic value, namely the market share of non-dtt pay TV, and the share of pay DTT programmes relative to the total number of DTT programmes. Figure 5.5: Summary of sensitivities under three scenarios for DTT model [Source: Analysys Mason, 2012] DTT viewers as % of all TV viewing 34 (2032) Scenario: 1a 1b 2a 2b 3a 3b High case 22% 23% 20% 21% 28% 25% Base case 20% 21% 18% 19% 25% 23% Low case 18% 19% 16% 17% 23% 21% Pay DTT subs as % of all DTT subs (2032) High case 9% 9% 9% 9% 9% 9% Base case 8% 8% 8% 8% 8% 8% Low case 7% 7% 7% 7% 7% 7% Number of channels per multiplex SD High case Base case Low case Number of channels per multiplex HD High case Base case Low case Combined The results of the combined DTT and mobile broadband sensitivities are shown in Figure 5.6. Figure 5.6: Summary of results of the combined DTT and mobile broadband sensitivity modelling, all figures are in Euros, millions [Source: Analysys Mason, 2012] Total economic value (incl. external benefits) Base case High case Low case Scenario 1a Scenario 1b Scenario 2a Scenario 2b Scenario 3a Scenario 3b Noting that by 2032 it is expected that an increasing number of households might receive TV services via IPTV, or via satellite, rather than terrestrially.

48 Property rights in UHF and 2.6GHz spectrum 45 The results of the sensitivities produce a 4 15% variation from the base case in the total economic value. However, they do not make a difference to Scenario 3a, which generates the highest total economic value (Scenario a assumes that spectrum in the 700MHz and 800MHz bands is assigned for mobile use, 35 and DTT is deployed in the remaining part of the UHF band (i.e MHz) Additional sensitivities In addition to the sensitivities above, we considered the impact of deploying DVBT-2 standards for HD multiplexes, rather than DVBT, which we have assumed will increase the number of programme channels that can be offered from 3 to 5. Figure 5.7 below shows the impact of this on the HD scenarios previously modelled. Figure 5.7: Summary of results of the HD standard DTT sensitivity modelling: Value generated by DTT services by scenario, all figures are in Euros, millions [Source: Analysys Mason, 2012] Total economic value (incl. external benefits) DVB-T DVBT-2 Scenario 1a Scenario 1b Scenario 2a Scenario 2b Scenario 3a Scenario 3b The DVBT-2 sensitivity shows that the deployment of DVBT-2 as the HD multiplex technology can significantly reduce the gap in value between SD and HD. Indeed, the deployment of HD in Scenario 2b is more attractive than the deployment of SD in Scenario 2a. It is likely that instead of rolling out all multiplexes on either SD or HD, there will be a combination of the two. As such, we have modelled a sensitivity that assumes a mix of SD and HD multiplexes in Scenario 2b 36, using either DVB-T or DVBT-2. The results are shown in Figure 5.8. Figure 5.8: Summary of results of combined SD and HD sensitivity modelling. Value generated by mobile and DTT services by scenario between 2013 and 2032, all figures are in EUR (million) [Source: Analysys Mason, 2012] NPV (EUR million) Consumer surplus Producer surplus Total private value Total economic value (incl. external benefits) Increment on base case Scenario 2b: no variations Variation on Scenario 2b: seven SD multiplexes and one HD multiplex (HD in DVBT) Variation on Scenario 2b: seven SD multiplexes and one HD multiplex (HD in DVBT-2) Except for a small block of 2 5MHz in the 700MHz band, which is un-used for mobile services in Scenario 3a (but could be used to accommodate military use). We have assumed that 20% of multiplex capacity will be HD, and the rest SD, i.e. seven SD multiplexes and one HD multiplex.

49 Property rights in UHF and 2.6GHz spectrum 46 Furthermore, we have modelled a range of values for the commercial discount rate, in order to assess the impact of the discount rate applied and the uncertainty around this figure given the current economic challenges. Figure 5.9: Summary of results of the commercial discount rate sensitivity modelling. Value generated by mobile and DTT services in Scenario 2b between 2013 and 2032, all figures are in EUR (million) [Source: Analysys Mason, 2012] Scenario 2b Consumer surplus (not affected by sensitivity) Producer surplus Total private value Total economic value (incl. external benefits) Increment on base case 7% % % % % % % % % % % In summary, the results demonstrate that the commercial discount rate has a significant impact on the producer surplus value, with around a 50% variation in value above and below the base case of 12%. A final sensitivity considered is the impact of moving the military into the 700MHz band. We understand that the current military equipment can be tuned down to the 700MHz frequencies at relatively little additional cost. However, this would have an impact on the availability of spectrum for either DTT or mobile broadband. The impact on mobile broadband is already implied by the difference between Scenarios 3a and 3b, as outlined in Section 5.1. As such, in the sensitivity below, we demonstrate the impact of the removal of one DTT multiplex, the spectrum for which would instead be occupied by the military. Note: We have not included any re-tuning costs for military equipment within this calculation (we understand from YME that the existing 800MHz military systems can be moved to use MHz spectrum at no cost). This sensitivity is performed on Scenario 2b.

50 Property rights in UHF and 2.6GHz spectrum 47 Figure 5.10: Summary of results of the impact on DTT of the military moving to the 700MHz band sensitivity. Value generated by mobile and DTT services in Scenario 2b between 2013 and 2032, all figures are in EUR (million) [Source: Analysys Mason, 2012] Scenario 2b Consumer surplus Producer surplus Total private value Total economic value (incl. external benefits) Increment on base case Scenario 2b: Military is vacated from the MHz spectrum entirely Scenario 2b: Military is migrated to the 700MHz band 21,149 2,824 23,972 26,370 3,674 20,773 2,903 23,676 26,043 3,348 The impact of this sensitivity on the total economic value is EUR326 million, or 1.2% of the total value of Scenario 2b (EUR million).

51 Property rights in UHF and 2.6GHz spectrum 48 6 Market value of 800MHz and 2.6GHz mobile licences In this section we consider the potential market value of 800MHz and 2.6GHz mobile licences in Greece, based upon benchmarks of auction results from other European countries where similar spectrum has been awarded. Typically, market value is equivalent to the value that an operator (e.g. a mobile operator) would place on exploiting the spectrum commercially, and how this relates to the return that could be made when the spectrum is fully utilised. This is therefore different to the economic impact, or welfare, of the spectrum described in the previous section. One way to approach market valuation is to consider the prices paid for similar spectrum in different European countries, adapted to the Greek market. This gives a high-level estimate of the potential value of spectrum. In the remainder of this section we apply this approach to considering the market value of spectrum in the 800MHz and 2.6GHz bands. We note that detailed valuation was not intended to form part of this study and is considered to be part of a subsequent phase of work, based on the results of this study. However, it should be noted that the prices paid for mobile spectrum vary significantly across European countries, and that several factors can influence the prices paid for spectrum, including technical value (i.e. auctions of lower-frequency spectrum tend to result in higher spectrum prices due to their favourable coverage capabilities), international harmonisation, regulation and the format of the auction of licences. These factors are further described in the following sections. 6.1 Summary of factors affecting spectrum price We have noted the following key factors affecting the market price for spectrum, which suggests that our indications of market value set out in the remainder of this section should be treated with some caution: European and international harmonisation of frequency bands is important to create a market that is significant enough to allow for the economies of scale associated with mobile handsets in particular. Use of non-harmonised spectrum increases handsets costs for operators and has a negative effect on the value of these bands in auction results. This is primarily why we do not recommend that the Greek Government proceeds with award of property rights for mobile use in the 700MHz band, until such time as a harmonised European band plan is in place. A lack of competition will have a significant negative impact on revenues gained from auctions. As noted elsewhere in this report it is also not clear that sufficient demand exists in the Greek mobile market for 700MHz spectrum in addition to 800MHz and 2.6GHz.

52 Property rights in UHF and 2.6GHz spectrum 49 Operators are more willing to pay higher prices in markets that present good revenue opportunities and where there is high potential for growth Sometimes regulators have specific objectives in mind for certain frequency bands (e.g. increase market competition through tools such as spectrum caps, reserve prices or auction formats), which can affect the value of bands in auction results Reduced level of competition in a market will lead to lower spectrum prices, since, with an increasing number of players in the market, spectrum becomes a scarce resource for which operators must compete, increasing their bids during auctions. This is a key issue in Greece in view of their being only three mobile operators in the market. 6.2 Comparison of spectrum benchmarks between Greece and other European countries We have compared the prices paid for spectrum in a number of European countries in Sections 6.2 and 6.3 below. Typically, prices are calculated as EUR/MHz/population, to reflect differing populations in different European countries. However, there are other factors (other than population) that affect spectrum value for example, operators will be able to obtain proportionally higher ARPUs in countries with a stronger economy. This is not always reflected in higher margins though, since markets with higher GDP per capita also tend to have higher costs, thus reducing operator margins. Additionally, high mobile penetration will lead to a reduction in ARPU, and operators increasingly base their strategy on pricing and service differentiation. For example, new mobile services such as mobile broadband and IPTV over mobile might be anticipated as key drivers for 4G deployment. In concentrated markets where a limited number of operators control the majority of subscribers there tends to be stronger competition on prices, which can result in market fragmentation, i.e. no dominant player is present and market shares are reasonably similar. Thus, the majority of Western European mobile markets appear to be quite fragmented. To provide benchmarks for the market value of spectrum in the 800MHz and 2.6GHz bans, we have compared the prices paid for spectrum in different European countries relative to three key factors that we have identified as impacting spectrum value. These factors are ARPU, level of concentration in the market (defined by the Herfindahl-Hirschman index, or HHI) 37 and GDP, on the basis that: mobile operators will be able to generate higher ARPUs in countries with higher GDP per capita higher mobile penetration will lead to lower mobile ARPU due to the maturity of the market increased competition in a mobile market will negatively impact the level of potential revenues that operators will be able to generate. 37 HHI provides a measure of the competition between firms within a particular industry and hence is a commonly accepted measure of market concentration.

53 EUR/MHz/pop Property rights in UHF and 2.6GHz spectrum Market value of 800MHz licences Six European countries have auctioned the 800MHz band to date. Figure 6.1 shows the prices paid for this spectrum in each country. Note that the licence duration in each country is not the same, which is also shown in the table below. Figure 6.1: Prices paid for spectrum in the 800MHz band [Source: Analysys Mason, 2012] Country Market value of spectrum (EUR/MHz/population) Licence duration Sweden years, 9 months France years Italy years Portugal years Germany years Spain years Average years Taking the average of the market prices for 800MHz, i.e. EUR0.6/MHz/population, and applying that to Greece (which has a population of 11.3 million), suggests that the market price per 10MHz paired licence in Greece would be around EUR over the licence duration, and hence the market value of the entire 800MHz band in Greece would be EUR , over the licence duration. Based on the average licence duration from other European countries, this would be equivalent to around EUR per annum per 10MHz paired licence, or EUR per annum in total for three licences. However, if we compare the prices obtained in the selected countries with the identified market factors (HHI, ARPU and GDP), we obtain the variation in prices across different markets, as illustrated below in Figure 6.2 to Figure 6.4. The results suggest that using an average price benchmark for Greece is not appropriate, given the wide variations in market conditions and market structure within the benchmark countries, as illustrated below. Figure 6.2: 800MHz auction results versus normalised HHI [Source: Analysys Mason, 2012] Italy France Germany Spain Portugal Sweden ,000 1,200 1,400 1,600 1,800 Normalised HHI

54 EUR/MHz/pop EUR/MHz/pop Property rights in UHF and 2.6GHz spectrum 51 Figure 6.3: 800MHz auction results versus ARPU [Source: Analysys Mason, 2012] Italy Germany France Portugal Spain Sweden Total blended ARPU (EUR) Figure 6.4: 800MHz auction results versus GDP [Source: Analysys Mason, 2012] Italy Germany France Portugal Spain Sweden Thousands GDP per capita (EUR thousands) By comparison, the relevant metrics for Greece are shown in Figure 6.5 below. Figure 6.5: Greece market statistics [Source: Analysys Mason, 2012] Parameter Value GDP per capita ARPU 21.2 HHI 502 Number of mobile operators in the market 3

55 Property rights in UHF and 2.6GHz spectrum 52 Noting some similarities between Greece and Portugal in terms of number of mobile operators in the market, as well as the relationship between GDP per capita versus average mobile ARPU (as noted below) 38, if we select Portugal as a benchmark for comparison of spectrum price, we can calculate that the market value of an 800MHz licence in Greece might be EUR97,180,000, with the total 800MHz band having a value of EUR291,540,000. This would be equivalent to EUR per licence per annum, if the licence duration is 15 years, or EUR per annum for three licences 39. By way of comparison with Greece, market metrics for Portugal and the results of the recent mobile auction in Portugal are summarised in Figure 6.6 Figure 6.7. By comparison, the relevant metrics for Greece are below. Figure 6.6: Portugal market statistics [Source: Analysys Mason, 2012] Parameter Value GDP per capita 21,473 ARPU 15.4 HHI 1,245 Number of mobile operators 3 Figure 6.7: Results of the mobile auction in Portuga [Source: Analysys Mason, 2012] Operator 800MHz 900MHz 1800MHz 2.6GHz Total price (EUR million) TMN 2 10MHz 2 14MHz 2 20MHz 113 Vodafone 2 10MHz 2 5MHz 2 14MHz 2 14MHz + 25MHz unpaired 146 Optimus 2 10MHz 2 14MHz 2 20MHz 113 TOTAL We also note that the price of 900MHz spectrum auctioned in Portugal in 2011 was similar to the prices obtained in Greece, at EUR0.28/MHz/population compared to EUR0.37/MHz/population in Greece. The price paid in Portugal is for a 15-year licence term and so we have assumed the same term for this comparison.

56 ARPU (EUR) Property rights in UHF and 2.6GHz spectrum Switzerland Ireland France Netherlands Norway Figure 6.8: ARPU versus GDP per capita in Europe [Source: Analysys Mason, 2012] Belgium Denmark Spain United Malta Kingdom Sweden Austria Slovenia Finland Italy Czech Slovakia Republic Estonia Portugal Germany Greece Hungary Latvia Poland Bulgaria Lithuania Romania ,000 40,000 60,000 80,000 GDP/pop (EUR) 6.4 Market value of 2.6GHz licences To date, 12 European regulators have completed auctions of 2.6GHz spectrum and a number of other awards are planned to take place in the near future. At the time of writing, 2.6GHz licences have so far been awarded in Sweden, Denmark, Finland, Norway, Netherlands, Germany, Belgium, France, Spain, Austria, Portugal and Italy. The licence duration varies across countries: in Denmark, Finland and France, licences have a duration of 20 years in the Netherlands, Germany, Belgium, Portugal, Norway, Sweden and Austria, licences have a duration of 15 years in Spain and Italy, licences have a duration of 18 and 17 years, respectively. In accordance with the European plan, the 2.6GHz band is suitable for both FDD and TDD technologies, since the band plan comprises a combination of paired and unpaired spectrum. Of the eleven European regulators that have auctioned 2.6GHz licences to date 40, the majority have offered both paired and unpaired bands for award, and spectrum has been packaged for award in accordance with the European plan, with a fixed number of spectrum packages for paired and unpaired use. There are a few exceptions to this however, which are noted below: In France, the regulator decided to include only the 2.6GHz paired spectrum in its 2.6GHz auction held during 2011, and the unpaired spectrum was not awarded. The Norwegian regulator envisaged there could be greater demand for unpaired spectrum than existed within the European plan and so designed a more flexible band plan that enabled 40 Sweden, France, Italy, Denmark, Norway, Netherlands, Portugal, Germany, Spain, Finland, Belgium.

57 Property rights in UHF and 2.6GHz spectrum 54 bidders to purchase selected paired channels in unpaired block. The designated blocks were purchased by one of the mobile operators in Norway with the intention to use as paired blocks in accordance with the European plan, however. In the Netherlands, both paired and unpaired spectrum was offered for auction, but in a flexible band plan (in which participants could bid for either paired or unpaired channels). At the end of the auction, only the paired spectrum was sold however and the unpaired spectrum was unsold. To date, all European regulators that have sold 2.6GHz spectrum have chosen to use auctions as the means of assigning licences. However, various different auction formats have been used. Various different approaches to packaging spectrum for award have also been used, with some countries awarding spectrum in 5MHz blocks, and others in larger blocks, as follows: In Norway, paired spectrum was auctioned in 5MHz lots whereas unpaired spectrum was auctioned in 10MHz lots. In Sweden and Finland, paired spectrum was auctioned in 5MHz lots whereas the unpaired spectrum was auctioned in a single 50MHz lot. Regulators in Denmark, Germany and the Netherlands auctioned paired and unpaired spectrum in 5MHz lots (although in the Dutch auction, the unpaired spectrum remained unsold at the end of the auction). The regulator in Belgium offered paired spectrum in four blocks of 2 15MHz and two blocks of 2 5MHz, with the unpaired block offered as a single 50MHz block (incorporating a 5MHz guard band). Due to the various different award formats and spectrum packaging used in each country, as well as different levels of demand for licences in different countries, there have been substantial differences in prices paid for 2.6GHz spectrum across Europe to date, making comparison between countries difficult. In the figures below, we show prices in 2.6GHz auctions achieved different European countries to date, along with an average value. We have split the prices achieved in each auction into those obtained for paired and unpaired spectrum respectively, in view of the variation in demand and price between paired and unpaired blocks (with the paired spectrum typically selling for substantially higher amounts than the unpaired, as the figures illustrate).

58 EUR / MHz / pop EUR / MHz / pop Sweden Belgium France Italy Italy Sweden Belgium Norway Portugal Norway Germany Germany France Spain Portugal Finland Finland Netherlands Property rights in UHF and 2.6GHz spectrum Figure 6.9: Prices paid for paired 2.6GHz spectrum in other European countries. Prices are in Euros per MHz per head of population 41 [Source: Analysys Mason, 2012] Paired Average Figure 6.10: Prices paid for unpaired 2.6GHz spectrum in other European countries 42 [Source: Analysys Mason, 2012] Unpaired Average The duration of licences varies across countries, as described elsewhere in this document. The duration of licences varies across countries, as described elsewhere in this document.

59 EUR / MHz / pop Denmark Sweden France Italy Belgium Norway Portugal Austria Germany Spain Finland Netherlands Property rights in UHF and 2.6GHz spectrum Figure 6.11: Combined 2.6GHz price comparison 43 [Source: Analysys Mason, 2012] Combined: paired and unpaired Average If we adjust these benchmarks for Greece, we obtain the following value of 2.6GHz spectrum in Greece, assuming the average values from the charts above: 2 5MHz paired: EUR 5,254,076 5MHz unpaired: EUR 1,331,586. Noting that there is a total of 2 70MHz of paired spectrum and 50MHz of unpaired spectrum available in the 2.6GHz band, the benchmarks above would suggest that the total market value of the spectrum if the entire band were to be assigned and sufficient demand exists for its use would be up to EUR85.5 million assuming the average benchmark price above 44. A 20MHz paired licence might raise up to EUR20.8, based upon average price benchmarks. Since other licences issued in Europe in the 2.6GHz band have an average duration of 16 years, this would equate to a licence value for Greece of EUR per annum. However, we note that the level of market demand for 2.6GHz spectrum in Greece may not be sufficient for all paired and unpaired spectrum to be required for mobile broadband use by existing operators in the market. This is primarily because the spectrum auctions conducted in other European auctions to date have revealed that bidders have primarily bought either 2 10MHz or 2 20MHz of paired spectrum. Hence, we consider it unlikely that the price of 2.6GHz spectrum in Greece would reach the maximum value above, and is most likely to be some way below this. However, it is also noted that the average of prices paid for 2.6GHz spectrum in other European countries disguises a significant variation in prices between different countries Ibid. This assumes that 45MHz of the 50MHz of unpaired spectrum is assigned with a 5MHz block reserved as guard band between unpaired and paired blocks.

60 EUR/ Mhz/ pop EUR/ MHz/ Pop Property rights in UHF and 2.6GHz spectrum 57 Comparing spectrum price by HHI, ARPU and GDP gives the following illustrations of how 2.6GHz spectrum price varies in different European markets. Figure 6.12: 2.6GHz auction results versus normalised HHI [Source: Analysys Mason, 2012] Denmark Sweden France 0.08 Italy 0.06 Belgium 0.04 Germany 0.02 Portugal Norway Netherlands Spain Finland ,000 1,500 2,000 2,500 3,000 Normalised HHI Figure 6.13: 2.6GHz auction results versus ARPU [Source: Analysys Mason, 2012] Sweden Denmark France Italy Belgium Portugal Norway Germany Finland Spain Netherlands Total blended ARPU (EUR)

61 EUR/MHz/ pop Property rights in UHF and 2.6GHz spectrum 58 Figure 6.14: 2.6GHz auction results versus GDP [Source: Analysys Mason, 2012] Sweden Denmark France Italy Belgium Portugal Norway Germany Spain Finland Netherlands 0.00 GDP per capita (EUR thousands) Using a benchmark of price in Portugal, as before, would suggest that the market value of a 2.6GHz licence of 20MHz paired spectrum in Greece would be around EUR11,300,000, or a total of EUR39,550,000 if the entire 70MHz of paired spectrum were to be sold in Greece. Assuming a 15-year licence duration, as before, this would be equivalent to EUR per annum per licence, or EUR per annum for three licences 45. By comparison however, if we were to use one of the lowest price benchmark in Europe to date (e.g. Finland), the market value would reduce to EUR 1,356,000 for each 20MHz paired licence, or EUR in total. 45 Assuming that three mobile operators in Greece were awarded 20MHz of paired spectrum and 10MHz remains un-sold.

62 Property rights in UHF and 2.6GHz spectrum 59 7 Licensing approach for DTT This section describes licensing options for DTT, taking into account the experience in other European countries in relation to the digital switchover (DSO). It is structured as follows: Section 7.1 presents options for the assignment of DTT frequencies whether these are assigned to the multiplex operator or to the DTT broadcasters, and whether frequencies are assigned in blocks or individual transmitters are licensed separately Section 7.2 describes frequency assignment fees and subsidies Section 7.3 deals with roll-out obligations on DTT Section 7.4 covers the different technology options used for DTT. 7.1 Licensing approaches Many European regulators are now adopting market-based approaches, such as auctions and secondary trading, to the assignment of mobile spectrum. However, these approaches have not always been applied to spectrum used for broadcasting services, for various reasons. For example, the UK, Spain and France use auctions to assign spectrum for mobile services, but spectrum for broadcasting services has been directly assigned to the holders of the DTT content and/or multiplex licences. Different approaches have also typically been applied for allocation of licenses to existing analogue broadcasters for DTT and to new commercial broadcasters for example, DTT licences are typically allocated directly to analogue broadcasters and through a beauty contest for new commercial broadcasters. There are three levels of licensing that can be considered for DTT: digital channels (i.e. bits within a multiplex) multiplexes (i.e. spectrum) transmission and associated facilities (i.e. sites). The approach adopted for the licensing of DTT therefore depends on the structure of the DTT market in question and specifically, whether the broadcasting market is vertically integrated or not. 46 Figure 7.1 summarises the different award and frequency assignment methods used in these countries. 46 Vertical integration refers to the national broadcaster(s) also operating the transmission network for the terrestrial broadcast network. In some countries, separation has been applied between broadcasters and the transmission network, so that independent multiplex operator(s) provide the transmission infrastructure for some or all broadcasters.

63 Property rights in UHF and 2.6GHz spectrum 60 Figure 7.1: Comparison of DTT licensing approaches [Source: Analysys Mason, 2012] Country Award method Frequency assignment France Direct award to PSB channels Beauty contest for other TV channels Germany Direct award to PSB channels, and applications/beauty contest for regional commercial programming Italy PSB awarded incremental multiplex No incremental frequencies assigned to commercial broadcasters Broadcasters allowed to purchase frequencies from local players to build multiplexes for digital Spain Direct award to established players and a beauty contest for new entrants Sweden Broadcasters with analogue licences were invited to participate in the development of the DTT platform, but had to apply for a licence UK Direct award for PSB Beauty contest for commercial multiplexes Frequencies are assigned by TV channel Frequencies are assigned by multiplex Frequencies are assigned per multiplex Frequencies were assigned by TV channel before the analogue switch-off (ASO) and by multiplex after the ASO Frequencies are assigned by TV channel Frequencies are assigned per multiplex As noted above, in some countries there is a vertically integrated DTT market in which broadcasters also provide transmission of DTT services, whereas in other countries, there is a separate, independent, transmission operator(s) in the market. This is reflected in different approaches to the award of DTT spectrum licences, as shown below in Figure 7.2. Figure 7.2: Comparison of treatment on network operators and content providers in Europe [Source: Analysys Mason, 2012] Country Industry structure UK 6 DTT multiplexes and over 50 FTA DTT TV channels, all of which are transmitted by Arqiva France Transmission carried out by Télédiffusion de France (TDF), Antalis and towercast (independent network operators) Germany Multiplex licences are issued independently by the Federal State Media Authorities. Multiplex deployment varies from one state to another. In addition to regional multiplexes, Germany also has two national DTT multiplexes: one public multiplex operated by Arbeitsgemeinschaft der öffentlich-rechtlichen Rundfunkanstalten der Bundesrepublik Deutschland (ARD); and one public multiplex operated by Zweites Deutsches Fernsehen (ZDF) Italy The market is vertically integrated but legislation has imposed separation of transmission towers Spain Transmission towers are managed by Abertis Telecom Sweden Transmission is carried out by Boxer-TV Access (Teracom)

64 Property rights in UHF and 2.6GHz spectrum 61 Figure 7.2 shows that assigning frequencies by multiplex is the method most commonly used, rather than assigning frequencies by individual DTT programming channel, or by DTT transmitter. The former approach enables multiplex operators to plan the DTT network within the available frequencies assigned to the multiplex, in accordance with the agreed co-ordination parameters (i.e. as defined within the ITU-R GE-06 Agreement and Plan 47 and the associated bilateral agreements with neighbouring countries). 7.2 Frequency assignment, fees and subsidies Where subsidies have been applied for DSO, Governments have generally subsidised the purchase of the equipment required to upgrade public broadcasting stations from analogue to digital, including subsidies towards the purchase of set-top boxes (STBs). Annual licence fees paid for DTT frequency assignments are typically paid by the licence holders (typically broadcasters or the DTT multiplex operator(s) depend on national regulations, but there are different approaches and fee levels applied across Europe. Some countries, such as the UK, have considered the application of market-based pricing to DTT spectrum (i.e. pricing that reflects the opportunity cost of spectrum); however, this has not been implemented as yet. 48 Figure 7.3 summarises different licence fees, and subsidies, applied for the DSO in selected European countries. Note that we have not been able to obtain information in relation to the approach adopted in some of the countries shown. Figure 7.3: Pricing of spectrum used for DTT and DSO subsidies [Source: Analysys Mason, 2012] Country Frequency assignment fee Subsidies France No spectrum fee for broadcasters. The 30 September 1986 law requires the use of spectrum for radio and TV broadcasters to be free of charge Germany An initial one-off fee was paid when a frequency licence is awarded (EUR125 per 10km² covered (min. 450)) An annual fee is also paid, comprising a spectrum administration fee and an electromagnetic compatibility fee (EUR23.72 per 10km² covered) Italy Annual fees depend on the number of inhabitants that a licence allows the licensee to reach Moreover, there are frequency fees for the TV broadcasting network licensees which vary depending on the bandwidth held Spain Annual fees depend on several factors including area covered by the licence and radio bandwidth used The government subsidised the cost of upgrading the public broadcasters analogue equipment The incentives and subsidies provided to terrestrial TV broadcasters increased their commitment to DTT roll-out 47 Results of the ITU Regional Radio Conference 2006: 48 See

65 Property rights in UHF and 2.6GHz spectrum 62 Country Frequency assignment fee Subsidies Sweden No information No information UK Calculated differently depending on the type of broadcaster. For some categories, the annual licence fee is calculated as a percentage for different brackets of the licensee s relevant turnover (revenues of the licensed services net of value-added tax) for the year ending 31 December 2008 Ofcom allows monthly payments when the annual licence fee exceeds GBP For other categories, a fixed fee is charged annually The government launched the Switchover Help Scheme to subsidise the switch-over to digital for households in which one or more members are at least 75 years old, or receive a Disability Living Allowance or Attendance Allowance, or are registered as blind or partially sighted 7.3 Roll-out obligations Roll-out obligations on DTT multiplexes are typically defined as part of the DSO process. In some cases, coverage obligations for digital broadcasting have been set at a lower threshold (of population and/or geography) in comparison to previous analogue obligations. This sometimes reflects a change in market conditions, in that in many countries, TV viewers may use alternative platforms (e.g. satellite, cable or IPTV) for digital broadcasting, compared to analogue. Therefore, the reliance upon terrestrial broadcasting as the only means of receiving TV services is somewhat reduced in comparison to earlier years. In some cases, the roll-out obligation upon PSB multiplexes is set at a higher level that for the commercial multiplexes. Figure 7.4 summarises some roll-out obligations on DTT applied in different European countries. Figure 7.4: Summary of DTT roll-out obligations [Source: Analysys Mason, 2012] Country Coverage obligations Channel obligations France 95% by 2011 (expressed in terms of number of transmission sites to be used for DTT) Germany Frequency licensees are subject to coverage obligations Italy 70% for RAI after three years; 50% for other channels after three years Maximum coverage obligation: 80% Spain Year 1: 80% for established players and 25% for new entrants Year 2: 80% for new entrants Year 4: 90% Year 6: 95% for commercial broadcasters; 98% for PSBs Sweden 99.8% for PSB multiplex 98% for other multiplexes Simulcasting FTA - Simulcasting FTA of existing analogue channels in SD Simulcasting FTA Four channels per multiplex recommended - UK 90.5% for all 6 multiplexes by % for 3 PSBs by 2012 Simulcasting FTA 2 multiplexes (ITV and ITV/Channel 4) have obligations in terms of spectrum

66 Property rights in UHF and 2.6GHz spectrum 63 Country Coverage obligations Channel obligations PSBs must offer their public service broadcasting channels to all the main distribution platforms, which have a corresponding obligation to make them available on an FTA basis usage (to be reserved for ITV, Channel 4, Channel 5 and S4C Wales programming BBC only broadcasts BBC channels Spectrum needs to be fully used 7.4 DTT technology options The most widely used standard for DTT to date has been digital video broadcasting terrestrial (DVB-T), although many countries are now planning migration from this to DVB-T2. The DVB-T standard uses coded orthogonal frequency division multiplexing (COFDM) and includes three different modulation schemes (QPSK, 16 QAM and 64 QAM), as well as different configurations of guard interval and error correction. The standard bit rate varies between 8Mbit/s and 27Mbit/s, depending on the modulation level used. Different versions of MPEG coding can also be used (e.g. MPEG-2 and MPEG-4), which affect picture quality and the capacity of the multiplexes to carry programme channels. The choice between MPEG-2 and MPEG-4 (and between DVB-T and DVB-T2) affects the number of programming channels that can be delivered per multiplex. This typically ranges from up to 8 SD or 1 HD channel per multiplex (using MPEG-2 and DVB-T), to around 20 SD or 5 HD channels (using MPEG-4 and DVB-T2). Figure 7.5 summarises the deployment approaches used to DTT deployment in selected European countries. Figure 7.5: Comparison of approaches used to DTT deployment [Source: Analysys Mason, 2012] Country Compression standard Transmission standard France MPEG-2/MPEG-4 for pay TV and HDTV Germany MPEG-2/MPEG-4 for pay TV (DVB-T2 trials) DVB-T: one multiplex has been converted to HD and the remaining multiplexes are SD DVB-T2 trials are underway Italy MPEG-2/MPEG-4 for HDTV Europa 7 HD is now operating using one DVB-T2 multiplex Spain MPEG-2/MPEG-4 for HD transmissions DVB-T2 trials are underway Sweden MPEG-2/MPEG-4 for multiplex 6 HD services over DVB-T2 were launched during November 2010, providing FTA channels plus pay TV channels via the provider Boxer. It is estimated that HD coverage will reach 70% of the population by the end of Services have been launched using a new sixth UHF multiplex, with a seventh VHF/UHF multiplex also planned UK MPEG-2/DVB-T2 used for HDTV One of the six national DTT multiplexes has been converted to Freeview HD, using DVB- T2, which launched in 2009/2010

67 Property rights in UHF and 2.6GHz spectrum 64 8 Conclusions from the study In this report we have considered the allocation of property rights in UHF ( MHz) and 2.6GHz spectrum in Greece. In particular, we have considered the potential value of the digital dividend of UHF spectrum over a period of 20 years, and whether this spectrum should be allocated for mobile broadband use, or for DTT. This section presents a summary of the main conclusions from the study, relevant to YME s consideration of assignment of property rights in UHF and 2.6GHz spectrum. 8.1 Conclusions from the study Our key finding concerning the economic impact of different assignments of UHF spectrum is that there is a significant benefit to the Greek economy of around EUR3.5 billion if part of the UHF band is awarded for mobile use, rather than for DTT. The key results from our modelling are as follows: The value generated if all available UHF spectrum is awarded for DTT use is EUR11.0 billion; the assignment of only MHz results in a limited reduction in value, to EUR10.3 billion. In terms of mobile broadband services, we have found that the value generated from the migration of the mobile market from 3G to 4G mobile broadband services equates to EUR11.7 billion, if services are deployed using the existing 2G/3G spectrum and in the 2.6GHz band (our base case). If the 800MHz band is also available for mobile use, we estimate that the total value generated by the mobile market increases to EUR15.9 billion, primarily as a result of a faster roll-out of 4G services such that mobile broadband penetration levels increase more rapidly than in our base case. 49 The economic value for DTT is slightly higher if DVB-T2 is used to accommodate HD programmes in one multiplex than if DVB-T is used. The contribution of DTT to the total economic value also increases if we assume a mixed SD/HD use of DTT multiplex capacity, rather than assuming all multiplexes are used just for SD. Therefore if the 800MHz band were to be allocated for mobile use in Greece, the combined value of DTT and mobile broadband services in the UHF band which represents the total economic or welfare impact of the award of UHF spectrum would be around EUR26.2 billion, over a period of 20 years. The majority of this value around EUR15.9 billion is value generated from mobile services, whilst the remaining EUR10.3 billion is derived from the switchover of analogue to DTT. 49 This requires that military use is vacated from the 800MHz band and the band is assigned in Greece in accordance with the EC s harmonised plan set out in Decision 2010/267/EU.

68 Property rights in UHF and 2.6GHz spectrum 65 If the 700MHz and the 800MHz band were to be allocated for mobile use in Greece, a further EUR1.0 billion of economic benefit is derived 50, assuming the entry of a fourth operator in the Greek market. Military systems currently occupy part of the 800MHz band in Greece. One possibility to release spectrum in this band for mobile use might be to migrate military systems to the 700MHz band. However, this may preclude the 700MHz band from being used for mobile services in the future. We estimate that the impact of the 700MHz band not being available for mobile use (i.e. the loss of value from the entire 700MHz band not being available for mobile services, as a result of military systems occupying part of this band) is around EUR1.6 billion 51. The reduction in value from the DTT model if the 700MHz band is not available (e.g. if 700MHz is used for military or other systems) is smaller, at around EUR326 million, or 1.2% of the total value already shown in Scenario 2b (EUR26.3 billion). We therefore conclude that the optimal configuration would be mixed use of the UHF spectrum, with the 800MHz band being allocated for mobile use. We also recommend that the 2.6GHz band be awarded for mobile use, in line with the EC s Decision 2008/477/EC, as described earlier in this report. 8.2 Market value of 800MHz and 2.6GHz spectrum We have also considered the potential market value of 800MHz and 2.6GHz mobile licences in Greece, based upon benchmarks of auction results from other European countries where similar spectrum has been awarded. We have estimated the following market value for the 800MHz and 2.6GHz bands in Greece. Figure 8.1: Market prices for 800MHz and 2.6GHz licences in Greece 52 [Source: Analysys Mason, 2012] Frequency band Market value per licence (2 10MHz for 800MHz and 2 20MHz for 2.6GHz) (EUR million) Annualised value per licence (EUR million) 53 Total value if all spectrum is sold in each band (EUR million) 800MHz 2.6GHz Up to based upon the average of European auction prices, or up to 97.2 using Portugal as a benchmark Up to 20.8 based upon the average of European auction prices, or up to 11.3 using 6.5 Up to based upon the average of European auction prices, or up to using Portugal as a benchmark 0.7 Up to 85.5 based upon the average of European auction prices, or up to 39.5 using Portugal as a Allocating the MHz spectrum to mobile results in only five multiplexes being deployed, but the mobile use benefit increase offsets the loss associated with the reduction in the amount of spectrum assigned to DTT (overall DTT value is EUR8.7 billion) This is the difference in economic impact between Scenarios 3a and 3b, as described in Section 5.1. Based upon a range of values from a lower benchmark of Portugal, to an average benchmark Based upon a benchmark with Portugal prices and a 15-year licence duration.

69 Property rights in UHF and 2.6GHz spectrum 66 Portugal as a benchmark benchmark (licence duration 20 years) However, whilst we have indicated a market value for the entire 2.6GHz band above, we consider it unlikely that there will be sufficient demand for spectrum within the current Greek mobile market for the entire 2.6GHz band to be required. This is because of the relatively limited competition in the Greek mobile market and because, with a total of 2 70MHz of paired spectrum available in the 2.6GHz band, all of the spectrum would be sold only if individual operators demand more than 2 20MHz of spectrum each. Based upon demand exhibited in other European auctions, this level of demand appears unlikely in Greece. 8.3 Recommendations from the study Our overall recommendations regarding mobile and DTT licensing in Greece in the UHF and 2.6GHz bands are as follows: The Hellenic Government should proceed with planning for the award of the 800MHz subband for mobile use, in line with the European Commission Decision of 6 May 2010 on harmonised technical conditions of use in the MHz frequency band for terrestrial systems capable of providing electronic communications services in the European Union (2010/267/EU). 54 This will necessitate the migration of military systems from the upper part of the 800MHz band, to alternative spectrum. We understand that the Hellenic Government is considering alternative options for this, including the possibility of migrating military systems from the 800MHz to the 700MHz band. The Hellenic Government should also proceed with planning for the award of the 2.6GHz band for mobile use, in line with the harmonised European plan set out in the Commission Decision of 13 June 2008 on the harmonisation of the MHz frequency band for terrestrial systems capable of providing electronic communications services in the Community (2008/477/EC). 55 However, it is not clear that sufficient demand exists in the market for the entire 2.6GHz band to be sold given the current market conditions in Greece. Therefore, we recommend that consideration be given to awarding only part of the 2.6GHz band at the current time, with the remaining spectrum reserved for future use. We note that award of 2.6GHz spectrum is contingent on the current legal matters regarding existing usage of the band in Greece for multi-point video distribution systems (MVDS) being resolved. Spectrum for mobile use in the 800MHz and 2.6GHz bands should be awarded via an auction Commission Decision of 6 May 2010 on harmonised technical conditions of use in the MHz frequency band for terrestrial systems capable of providing electronic communications services in the European Union (notified under document C(2010) 2923). Available at Commission Decision of 13 June 2008 on the harmonisation of the MHz frequency band for terrestrial systems capable of providing electronic communications services in the Community (2008/477/EC). Available at

70 Property rights in UHF and 2.6GHz spectrum 67 The Hellenic Government should proceed as soon as is practically possible with the award of rights to access and use spectrum in the MHz band for DTT, to accelerate the migration from analogue to digital terrestrial television and in the ASO process. Rights to access and use spectrum to transmit DTT services could be granted alongside multiplex licences, that is whichever company(s) is awarded a digital multiplex licence(s) could also be granted rights to access frequencies to be used to transmit services. Digital broadcasting (content) licences for DTT could be awarded (a) by direct award to current analogue TV broadcasters (i.e. for simulcasting), and (b) by beauty contest to additional DTT content providers. The following observations should be noted in relation to our recommendations regarding UHF spectrum in particular: Although our modelling scenarios indicate that further value is created from using the 700MHz band for mobile services in addition to the 800MHz band, we do not recommend that the Hellenic Government allocate the 700MHz band for mobile use at the present time. This is because the European Allocation Table does not contain a primary mobile allocation in the 700MHz band at the current time (although this might change as a result of future WRCs). As a result, there is no harmonised band plan for 700MHz mobile use in Europe and hence equipment manufacturers are not developing mobile products for this band in Europe. By contrast, LTE800 equipment (for use in the 800MHz band) is becoming widely available. We do not recommend that decisions on award of 700MHz spectrum are made until a European harmonisation decision is developed for mobile use of the 700MHz band. We also recommend the remainder of UHF spectrum, from MHz, should be assigned for digital terrestrial broadcasting in Greece to facilitate DSO and switch-off of analogue services (it is also noted that the Greek Government is considering whether spectrum in the 700MHz band could be used to accommodate military systems that will need to be re-located from the 800MHz band in order for that band to be released for mobile use).

71 Property rights in UHF and 2.6GHz spectrum A 1 Annex A Allotment areas using DTT channels The following illustrations provide our assessment of the DTT allotments that include use of channels 61 to 66, noting that these channels will not be available for DTT use if the 800MHz band is awarded for mobile services. Figure A.1: Channel 61 to 66 allotments [Source: Analysys Mason, 2012] PAGGAIO PLAKA EVROS FLORINA IOANNINA LARISSA KERKYRA AKARNANIKA BOLOS KARPENISI LAMIA LESVOS AINOS ATTIKI PYRGOS SAMOS PATRA KALAMATA KYKLADES C.CRETE Figure A.2: Channel 61 allotments [Source: Analysys Mason, 2012] THASSOS FLORINA KERKYRA KARPENISI ATTIKI SAMOS PATRA SPARTI C.CRETE

72 Property rights in UHF and 2.6GHz spectrum A 2 Figure A.3: Channel 62 allotments [Source: Analysys Mason, 2012] EVROS THESSALONIKI IOANNINA KARPENISI BOLOS TRIPOLI KYKLADES Figure A.4: Channel 63 allotments [Source: Analysys Mason, 2012] PAGGAIO EVROS LARISSA LAMIA KORINTHOS KALAMATA

73 Property rights in UHF and 2.6GHz spectrum A 3 Figure A.5: Channel 64 allotments [Source: Analysys Mason, 2012] THASSOS METAKSAS AKARNANIKA LESVOS LAMIA KORINTHOS PYRGOS SPARTI C.CRETE Figure A.6: Channel 65 allotments [Source: Analysys Mason, 2012] PAGGAIO LARISSA KORINTHOS SAMOS

74 Property rights in UHF and 2.6GHz spectrum A 4 Figure A.7: Channel 66 allotments [Source: Analysys Mason, 2012] THESSALONIKI PLAKA THESPROTIA AINOS KORINTHOS

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