FEBRUARY 2025

Key comment on the document: 

 In the commented document, we propose removing the intention of the Czech Telecommunication Office (as mentioned, for example, on pages 4, 12, and 13) to prepare a proposal for adjusting the amount of fees for the use of radio spectrum (and the principles for their determination). Specifically, we propose abandoning the measure under which the Czech Telecommunication Office (CTO) would prepare a draft amendment to Government Regulation No. 154/2005 Coll., on the determination of the amount and method of calculating fees for the use of radio frequencies and numbers, for the Ministry of Industry and Trade during 2025.

Justification:

We are submitting this key comment relating to the removal of the intention and abandonment of the measure aimed at adjusting the amount of fees for the following reasons:

The CTO states that, as an integral part of the proposed measures, the Strategy also includes the CTO’s intention to prepare a proposal to adjust the amount of fees for the use of radio spectrum (and the principles for their determination). The aim of such an adjustment is, in particular, to promote the efficient use of radio spectrum by removing barriers to its use, deploying new technological solutions, and supporting the development and provision of modern and related electronic communications services.

We understand the announced activity of the CTO to mean that the adjustment of the fee amount refers to an increase in fees. The document is unclear in this respect; therefore, we primarily request clarification as to the direction the CTO intends to take when it states that it will prepare a proposal to adjust the amount of fees for the use of radio spectrum, including the principles for their determination. Given that the CTO is proposing this adjustment, we assume that the Office already has at least a preliminary concept of how it should be structured. Otherwise, it would not announce such a significant measure with potentially substantial market implications. Our comment is made on the assumption that the proposed adjustment refers to an increase in fees, rather than a reduction.

The CTO plans to initiate further discussions on the fee policy for the use of radio frequencies to promote efficient use of frequencies and create opportunities for the further development of existing and new services, including supporting their maximum possible availability and encouraging innovative approaches to the use of radio frequencies, while taking into account best practices in fee policy.

Considering that it should also be taken into account that “the collection of fees for the use of radio frequencies is gradually increasing and the primary goal of adjusting the fee policy is not to maximise revenue from fee collection”, as stated by the CTO in the document, we consider the proposal to change the fee amounts and the principles for their determination to be an unjustified and unnecessary step in terms of market needs from the perspective of television broadcasting operators.

From a market perspective, we believe there is no need to commission any study or similar document, nor to conduct a professional debate to consider the economic impacts of the fee policy on spectrum users. Given that an increase in fees would undoubtedly impose a heavy burden on the affected entities, we consider the investment of public funds in such investigations a waste of taxpayers’ money. Considering the economic situation in the Czech Republic as well as in the entire European Union, we consider it essential that entrepreneurs using the radio spectrum are not subjected to additional economic burdens—that is, that the current fee policy be maintained without any changes. Therefore, we do not consider updating Government Regulation No. 154/2005 Coll., on the determination of the amount and method of calculating fees for the use of radio frequencies and numbers, to be a strategic priority or necessary, and request that this activity be removed from the CTO’s strategy without replacement, as the current fee levels are appropriately set for the Czech business environment, including with regard to the upcoming period covered by the strategy.