What surprises me is that the German public television operators ARD and ZDF answer in English (why?) and express an anti-innovation bias:
However, even if CR technologies are expected to provide innovative means of spectrum usage we agree with the report that “many aspects of CR technologies, including the business models, are still unclear”. We have the view that there are still a lot of investigations required to determine proper conditions for a reliable operation of services based on CR technologies and that time is premature to take any regulatory decisions on their operation.
Portable and mobile reception will additionally suffer from different interference mechanisms than fixed reception. This relates in particular to interference from CR terminals. We therefore propose to include the necessity of a full assessment of the protection criteria for all DTT reception modes in the conclusions of the report. Results of measurements in the context of the assessment of compatibility criteria between mobile services in the 800 MHz band and DVB-T suggest that these protection criteria may impose severe restrictions on CR operation.
In any case it should be avoided to take decisions on the introduction of CR systems at a stage where compatibility issues are still unclear, i.e. before the full technical and operational requirements for CR systems are determined which allow for a reliable protection of the existing services in the bands where the CR systems are to be introduced.
And some more positive contributions as the Open Spectrum Alliance contribution.
You cannot contribute to the CR consultation anymore but there we find another one:
Public consultation on the draft RSPG Work Programme 2010
The draft RSPG work programme for 2010 has been discussed by the Group at its meeting in November. Prior to finalizing the programme, the views of stakeholders and interested parties are sought on this draft. Please reply by e-mail to INFSO RSPG (INFSO-RSPG@ec.europa.eu), with PUBLIC CONSULTATION ON RSPG Work Programme 2010 in the subject line.
21 December 2009 -> 21 January 2010