Have your say – World Radiocommunication Conference 2027

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The Union Position for the World Radiocommunication Conference 2027

About this initiative: The conference is expected to take multiple decisions that might affect EU law, policies or programmes relying on the radio spectrum. This initiative will propose a common position to guide EU Member States when negotiating on the EU’s behalf at the World Radiocommunication Conference 2027, organised by the ITU from 18 October to 12 November 2027.
Feedback period: for stage 2 it is 14 July 2026 – 11 September 2026
Link: ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/18804-World-Radiocommunication-Conference-2027-EU-position_en

Agenda 2027: https://www.itu.int/md/S24-CL-C-0064/en
Agenda 2023: https://www.itu.int/dms_pub/itu-r/opb/act/r-act-wrc.16-2024-pdf-e.pdf

Feedback from Europeans for Safe Connections

1. Evaluation of RF-EMF Exposure Densification (Agenda Items 1.6, 1.7, 1.8, 1.10, 1.11 & 1.13)
The EU position should apply the Precautionary Principle when negotiating new spectrum allocations and emerging communication technologies. The EU should ensure that the cumulative impact of the measures addressed under Agenda Items 1.6 to 1.13 does not undermine the principles of the Budapest Declaration, which identifies “new and emerging issues, such as electromagnetic radiation” as requiring attention.

The introduction of Direct-to-Device (D2D) satellite systems should not be assessed in isolation from terrestrial telecommunications infrastructure. D2D is developing as part of an increasingly integrated hybrid terrestrial–satellite communications system.

For example, Satellite Connect Europe has announced investment in 5 ground stations in Europe to support D2D satellite connectivity. This illustrates that the overall RF-EMF exposure environment associated with D2D should consider not only the satellite-to-device link, but also the terrestrial infrastructure required to support and integrate satellite services.

At the same time, D2D has the potential to reduce the need for some terrestrial infrastructure in areas where satellite connectivity can provide coverage without requiring terrestrial base stations. This potential should be explicitly considered in EU policy.

The EU should therefore encourage an exposure-optimisation approach, rather than treating the deployment of each new communication technology independently. Where D2D or other Non-Terrestrial Network (NTN) technologies can provide adequate coverage and capacity, their potential to reduce the need for terrestrial transmitters should be assessed (e.g. to enable the decommissioning or relocation of existing transmitters).

Particular attention should be given to locations in the vicinity of homes, schools, kindergartens and hospitals. The objective should be to minimise unnecessary population exposure while maintaining reliable communications services.

2. Protection of „Human Radio Quiet Zones“ (Agenda Item 1.16)
As D2D moves from an experimental „proof of concept“ to a structural component of 5G/6G networks (3GPP Release 17), it aims for ubiquitous coverage that effectively eliminates remaining „low radiation zones“. ESC advocates for:

• Designation of Natura 2000 sites as Radio Quiet Zones to preserve biodiversity in accordance with the Habitats Directive.
• Protection of Human Settlements: Establishing low radiation areas for Electromagnetic Hypersensitive (EHS) individuals is critical, as the „always-on“ nature of satellite-to-mobile connectivity leaves no place for recovery.

3. Rights to Integrity and the Shift to Sovereign Communications
The D2D market is increasingly focusing on Defence, Government, and Sovereign communications rather than just consumers, as these sectors offer higher margins and strategic resilience. In line with Article 3 of the EU Charter of Fundamental Rights, the EU must ensure that this strategic shift does not lead to involuntary exposure of the general public to wireless digital infrastructure. Technical progress in defense and IoT must not supersede the right to physical and mental integrity. The EU should therefore ensure that security, resilience and strategic communications objectives are not pursued independently of public-health and exposure considerations.

4. Transparency and Mandatory Public Information
To ensure digital transformation proceeds democratically, ESC proposes mandatory transparency for both state and private enterprises. This requires the regular, mandatory publication of technical parameters and the precise location of all transmitters. This is essential for monitoring terrestrial RF-EMF exposure resulting from WRC-27 spectrum decisions and is a prerequisite for protecting public health and the environment.

5. Prioritizing Wired Alternatives for Security and Sustainability
The Commission’s goal for „Gigabit connectivity“ cannot be met by D2D alone, as satellite shared capacity is limited and unstable. Wired infrastructure (Fiber-to-the-Desk) remains the only secure, energy-efficient, and high-performance solution for indoor environments where D2D fails. The EU position at WRC-27 should emphasise that satellite links are a „cost of resilience“ or „complement,“ while the core digital infrastructure must remain wired to protect data security and reduce the digital carbon footprint.

6. Non-Discrimination in the Satellite-to-Mobile Transition (Agenda Item 1.5)
Using satellite spectrum to „bridge the digital divide“ risks creating a new divide based on health and data privacy. With over $30 billion recently invested in frequency resources for D2D, spectrum has become a matter of national sovereignty. The EU must ensure that international regulatory measures (Item 1.5) do not force citizens into a „satellite-only“ ecosystem, preserving the fundamental right to choose safer, wired alternatives that do not rely on constant RF-EMF exposure.

7. Implementation of New Monitoring KPIs
The EU should use the WRC-27 process to establish Key Performance Indicators (KPIs) that track the aggregate RF-EMF environmental burden. These KPIs should specifically measure long-term chronic exposure from all RF sources (Non-Terrestrial Networks and terrestrial networks) to monitor impacts on public health and the environment, ensuring that the „mobile network from space“ does not proceed without a robust framework for biological impact assessment.

Best regards
Europeans for Safe Connections
This feedback was sent from a wired internet connection
– No use of harmful radiation
– Less electricity consumption
– Increased data security

The link to our feedback: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/18804-World-Radiocommunication-Conference-2027-EU-position/F33568308_en

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