Regulatory procedures

for satellite networks

not subject to coordination

Chuen Chern Loo

Head, Space Publication and Registration Division
Space Service Department, Radiocommunication Bureau
International Telecommunication Union
Email: [email protected]
 Table of Contents
• Background regulations
• Subject to coordination under Section II of Article 9?
• Overall procedure
• Advance Publication Information
• Procedures for commenting and resolution of difficulties
• Information required
• Modifications
• Notification for recording
• Bringing into use
• NGSO networks or systems identified as short-duration mission
• As-received
• Publications
Background regulations
Radio Regulations Some relevant Articles
• Article 1 Definitions
▪ Intergovernmental Treaty governing • Article 5 Table of Frequency Allocations
the use of spectrum/orbit resources • Article 9 and 11 Procedures for the advance
by administrations publication (API), coordination (CR/C) and
notification
▪ Define the rights and obligations of • Article 21/22 Power limits
Member States in respect of the use • Article 25 Amateur and Amateur-satellite
service
of these resources
• Article 29A Radio services related to Earth
▪ Recording of a frequency assignment observation
in the Master Register (MIFR) • Appendix 1 Classification of emissions
• Appendix 4 Data required for satellite filings
provides international recognition and
protection
▪ Updated every 4 years by a WRC
▪ The most recent was held in Sharm El Sheikh in
2019

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 Background regulations
• Frequency Allocations
• Frequency block allocations in Article 5 along with regulatory/technical conditions in
footnotes
• Right to international recognition
• Any frequency assignment recorded in the Master Register with a favourable finding under
No. 11.31 shall have the right to international recognition. For such an assignment, this right
means that other administrations shall take it into account when making their own
assignments, in order to avoid harmful interference. …… (No. 8.3 )
• Assigning Frequencies
• Member States undertake that in assigning frequencies to stations which are capable of
causing harmful interference to the services rendered by the stations of another country,
such assignments are to be made in accordance with the Table of Frequency Allocations and
other provisions of these Regulations. (No. 4.2)
Non-conforming Assignments
• Non-conforming assignment (No.8.4)– a frequency assignment that is not in accordance
with the Table of Frequency Allocations or the other provisions of the Radio Regulations, and
is recorded for information purposes only when the notifying administration states that it
will be operated in accordance with No. 4.4
4.4 Administrations of the Member States shall not assign to a station any frequency in derogation of either the Table of
Frequency Allocations in this Chapter or the other provisions of these Regulations, except on the express condition that such a
station, when using such a frequency assignment, shall not cause harmful interference to, and shall not claim protection from
harmful interference caused by, a station operating in accordance with the provisions of the Constitution, the Convention and
these Regulations.

• On advice that it is causing harmful interference, the station using the non-conforming
assignment must immediately eliminate this harmful interference. (No.8.5)
• Rules of Procedure relating to No.4.4
• Frequency assignments under No. 4.4 are still obligated to be notified to the Bureau (para 1.3)
• In the notification, the Administration shall provide a confirmation that it has determined that these frequency assignments
under No.4.4 will not cause harmful interference into the stations of other administrations operating in conformity with the
Radio Regulations and that it has identified measures to avoid harmful interference and to immediately eliminate such in case
of a complaint.
Subject to coordination?

• To know whether a frequency band is subject to coordination, check

the footnotes in the Table of Frequency Allocations in Article 5
• For NGSO satellite networks, pay particular attention to No.9.21,
No.9.11A and the sub provisions Nos.9.12 and 9.12A
• For coordination under No.9.11A (and Nos.9.12 and 9.12A) please
note §2.3 of Rules of Procedure related to No.9.11A: the procedure
is applicable to all other space and terrestrial services with respect
to those satellite services having allocations with equal rights and
mentioned in the specific footnotes to which this provision applies
(check TABLE 9.11A-1).
Regulatory process for satellite
networks not subject to coordination
BR BR
Submit Publish Publish
API API/A API/B Submit
Info special special Notification
section
BR Publish
section
API
“as received”

Generally 4 months
< 1 week 2 months for comments from
by the Bureau by the Bureau other administrations
(WRC-19)
Minimum 4 months (WRC-19)

In total, ≈ 6 Months to 7 Years ! MAXIMUM 7 YEARS TO

SUBMIT NOTIFICATION
AND BRING INTO USE!
• from 1.1.2021, for all satellite networks not subject to coordination:
time between receipt and publication of API is reduced from 3 to 2 months,
time between publication of API and earliest receipt of notification is reduced from 6 to 4 months.
Advance Publication Information (API)
Advance Publication Information (API)
• The submission of advance publication information under No.9.1 is a mandatory
procedure for all satellite network not subject to coordination
• For non-geostationary satellite networks where the frequency bands are not
subject to coordination
• the use of inter-satellite links of a geostationary space station communicating
with a non-geostationary space station which are not subject to coordination
• Procedure for commenting and resolutions of difficulties specified in subsection IA of
Article 9
• Cost recovery fee: 570 CHF (not applicable for filings in the amateur-satellite service)
• Note that if payment is not received by the payment due date, the filing will be
cancelled, but the invoice continues to be payable!

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API for NGSO satellite networks not subject to
coordination received in the last 10 year

Note: The number for 2020

are those received up to
end November 2020
Information required
Information required

• Specified in Annex 2 to Appendix 4 of the Radio

Regulations, including:
• Satellite name, responsible administration and op_agcy
• Orbital characteristics
• Antenna beam characteristics
• Frequency band
• Service Areas
• Power levels/designation of emissions etc.
• Associated earth or space stations
• ……

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 Information required – orbital characteristics
Update of
• Revised Appendix 4 enter into force • If reference body is Earth
23.11.2019Appendix 4 • Angle of inclination
• Number of satellites in the orbital plane
• Orbital parameters for non-geostationary
– orbital
satellite networks: • Orbital period
• Altitude of apogee and perigee
• Numberparameters
of orbital planes • Min altitude
• Constellation • Initial phase angle
• Single orfor NGSO
multiple configurations, details of • Argument of perigee
the configuration if multiple
satellite
• Reference body
• Longitude of ascending node
• Date/time at which satellite is at the location defined

networks- by the longitude of the ascending node

• Sun-synchronous orbit? If yes, local time of
ascending/descending node
2 • Additional requirements for those subject to 22.5C,
22.5D, 22.5F, 22.5L
Information required - sensors
• Sensors specific information
• Active Sensors
• Transmit beam
• Mean peak power and mean power density
• Pulse length and pulse repetition frequency
• Receive beam
• Receiver noise bandwidth
• Noise temperature at output of signal processor
• If an active sensor is submitted that do not have both transmit and
receive beams in the same notice, it is considered as incomplete
• Passive sensors
• Observed bandwidth
• Sensitivity
• To capture sensor information in SpaceCap, go to Beam tab, check
the box “Beam has Sensors”
• Class of stations – E1, E2, E3, E4

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Commenting and resolution of difficulties
Procedure for commenting and resolution
of difficulties
• No. 9.3 Commenting procedures
• Comments to an API/A should be submitted to the notifying Administration and the SpaceCom comment file
submitted to the Bureau within 4 months from the date of publication of the API/A special section
• BR now makes the comments available “as received” on the web
• The Bureau publishes the list of administrations which have sent comments within the 4 month period in an API/B
special section in a BR IFIC

• No. 9.4 Cooperation and Resolution of Difficulties

• Both administrations shall endeavor to cooperate in joint efforts to resolve any difficulties and shall exchange any
additional relevant information that may be available
• Either party can request for the assistance of the Radiocommunication Bureau (No.9.3)
• In case of difficulties, the administration responsible for the planned satellite network shall explore all possible
means to resolve the difficulties without considering the possibility of adjustment to networks of other
administrations If no such means can be found, it may request the other administrations to explore all possible means
to meet its requirements
• The administrations concerned shall make every possible effort to resolve the difficulties by means of mutually
acceptable adjustments to their networks

• 11.28.1
• Further commenting following the publication of the Part I-S for modifications of characteristics

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Submission of Modifications
Modification of characteristics for satellite networks not
subject to coordination
o According to No.9.2, amendments to the information for NGSO filing that requires a
new API are:
o Additional frequency band
o Modification of the direction of transmission
o Modification of reference body

o However, it is a good practice to submit a modification to the API any change in

characteristics including orbital characteristics, service area (adding earth stations) etc.

o This will allow other administrations/operators the chance to submit comments before
the modifications are notified for recording in the Master Register.

o If during the notification, there are changes in characteristics from the information
published in API/A, other administrations can submit comments following the Part I-S
(No.11.28.1).
Notification for recording in the Master
Register
Notification for recording in the Master Register

o Notification for recording is mandatory for frequency assignments of satellite networks,

as they are capable of causing harmful interference to a service of another
administration (No.11.2)

o Even nonconforming assignments recorded under No. 8.4 (i.e. operating under No 4.4)
shall also be notified

o Frequency assignments for satellite networks in the amateur-satellite service shall also
be notified. However, frequency assignments to earth stations in the amateur-satellite
service shall not be notified.

o If notification is submitted at the same time as the API, the notification date of receipt
will be 4 months after the date of publication of the API (effective from 1.1.2021)

o All frequency assignments in the notification must be covered fully within the frequency
bands published in the API
Receivability for notifications of satellite networks not subject to
coordination
• Notification for recording for Space Stations
• Prior procedures must be completed
• For bands not subject to coordination, prior API/A
must have been published for that band
• Checking of the date of bringing into use
• Date of receipt of the notification should not be earlier than 3 years before the date of
bringing into use indicated in the notice (No.11.25)
• Notified date of bringing into use shall not be later than the 7-year regulatory limit
(No.11.44)
• Notification must be received by the Bureau by the end of the 7-year regulatory
limit (No.11.44.1)
• Complete AP4 information must be submitted
• Check that all new AP4 items for NGSO orbits are provided!
• If GIMs diagrams are the same as in CR/C, just request BR to use the same diagrams
• Any additional notes must be provided separately in the notification submission
• If requested for operation under No.4.4, the commitment under 1.6 to ROP
related to 4.4 must be provided
Additional data to be submitted for notifications of satellite
networks not subject to coordination
• Assigned frequency, assigned bandwidth
• Date of bringing into use
• Reference to API/A special section
• Other specific data items, for example:
• Commitment under A.24.a for those notices indicated as NGSO-SDM
• Commitment under 1.6 to ROP related to 4.4 for those notices where
there is at least one group with request for No.4.4
Notice returned to administration under No.11.36

o A notice that received unfavourable findings under No.11.31 (for example due to non-
conformity with Table of frequency allocation or PFD exceedance) will be returned to
the administration under No.11.36

o BR will send a communication to the administration explaining the reason for the
unfavourable finding with an indication of the appropriate action

o Note that a notice returned under No.11.36 cannot be resubmitted under No.11.46 to
benefit from retaining the original date of receipt

o The notice can be submitted again if the 7-year deadline is not expired, but it will be
treated as a modification with a new date of receipt and new cost recovery fee,
regardless of whether there are modified parameters, or with exactly the same
parameters with an additional request for No.4.4
Bringing into use
Bringing into use of frequency assignments for NGSO satellite
networks not subject to coordination
Bringing into
use of a non- • Reference body: Earth
geostationary • FSS, BSS, MSS Service
• One satellite deployed in one notified orbital plane
satellite orbit with capability of transmitting or receiving that
frequency assignment (No.11.44C)
network – • Maintained for a continuous period of operation of
90 days (11.44C)
specific • Adm shall identify the orbital plane number
provisions (11.44C.4)
• Other services
• One satellite deployed in one notified orbital plane
with capability of transmitting or receiving that
frequency assignment (No.11.44D)
• Adm shall identify the orbital plane number
(11.44C.4)
• Reference body: not Earth
• One satellite deployed with capability of transmitting
or receiving that frequency assignment (No.11.44E)
Specifics for Amateur-Satellite Service

• Class of station - EA

• API must be submitted to ITU

• Notification under No.11.2 is required for the satellite network

• Notification for Earth stations in the amateur-satellite service are not required

• Note that frequency assignments in the notification must be covered by frequency bands in API,
therefore avoid submitting a very narrow frequency band at the API, in case there is a change needed
during the comments/consultation process

• Additional specific requirements for Amateur-satellite service spelt out in Article 25

• Administrations authorizing space stations in the amateur-satellite service shall ensure that sufficient
earth command stations are established before launch to ensure that any harmful interference caused
by emissions from a station in the amateur-satellite service can be terminated immediately (see No.
25.11)

• Amateur-satellite service is exempted from cost recovery fee for both the API and the notification
(please refer to DEC 482)
Non-geostationary satellite networks or systems identified
as short-duration mission not subject to the application of
Section II of Article 9 (NGSO-SDM)
Resolution 32 (WRC-19) Regulatory procedures for frequency
assignments to non-geostationary satellite networks or
systems identified as short-duration mission not subject to the
application of Section II of Article 9 (NGSO-SDM)
o New procedure for satellite networks indicated as NGSO-SDM
o NGSO-SDM must meet the following criteria
o Using bands not subject to coordination
o total number of satellites ≤ 10
o Period of validity ≤ 3 years, no possibility of extension, after which the
recorded assignments shall be cancelled
o Shall comply with the conditions for use of the frequency band that is
allocated to the service within which they operate;
o Those using spectrum allocated to the amateur-satellite service shall
operate in accordance with the definition of the amateur-satellite service
as contained in Article 25;
o Shall have the capability to cease transmitting immediately in order to
eliminate harmful interference
Regulatory procedure for NGSO-SDM – API

• Notifying administration must identify in the submission whether the non-GSO

networks or systems is operating as short-duration mission (NGSO-SDM)
(Appendix 4 data item A.1.g)
• Advance Publication Information
• For API, submit the orbital characteristics (Appendix 4 data item A.4.b.4)
planned at the early development stage of the satellite project
• Commenting
• Comments to API/A will be made promptly available “as-received”, on the
ITU website (No. 9.3.1)
Regulatory procedure for NGSO-SDM – Notification

• Notification information cannot be communicated to the Bureau at the same time as API,
and can only be submitted after the launch of the first satellite, but not more than 2 months
after date of bringing into use
• Additional commitment required for Notification (item A.24.a of Appendix 4) that, in the case
that unacceptable interference caused by NGSO-SDM is not resolved, the administration
shall undertake steps to eliminate the interference or reduce it to an acceptable level
• Findings and characteristics under No.11.31 to be published in the BR IFIC and on BR
website within no more than 4 months from the date of receipt of complete information of
the Notification
• Date of bringing into use
• In the application of No. 11.44, the date of BIU of a NGSO-SDM shall be defined as the
launch date of the first satellite
• Provisions concerning modifications to recorded assignment (Nos. 11.43A, 11.43B) and
suspension of frequency assignments (11.49) cannot be applied for NGSO-SDM
NGSO-SDM – special bands for the space operation service

For the following bands used for space operation service which are normally subject to
coordination under Section II of Article 9, they are exempt from coordination procedures if
submitted as NGSO-SDM under Resolution 32 (WRC-19) and meet all additional conditions:

• 137.175-137.825 MHz (space-to-Earth)

• exempt from No.9.21 (No.5.209A)

Note that the use of the entire band 137.025-138 MHz for space operation
service (space-to-Earth) is limited to NGSO-SDM under Resolutions 32 and 660
(WRC-19)

• 148-149.9 MHz (Earth-to-space),

• exempt from No.9.11A (No.5.219)
• exempt from No.9.21 (No. 5.218A), must meet PFD limit to qualify for exemption
As-received
As-received – Resolution 55 (Rev. WRC-19)
All notices are published “as received”, within 30 days of receipt and made freely available on ITU
website: https://www.itu.int/ITU-R/space/asreceived/Publication/AsReceived
As-received – comments to API/A for
publication in API/B
Publications
Publication: API/A special section

Contains advance publication information on

a planned satellite network.

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Publication: API/B special section

Contains a list of administrations which

have sent comments within 4 months.

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Publications: Notifications
PART I-S Complete Information received by the Bureau.
Constitutes the receipt acknowledgement.
Published within 2 months from date of receipt.(Provision 11.28)

PART II-S Frequency Assignments which obtained

FAVORABLE FINDING after the examination by the Bureau.
They are recorded in the MIFR !

PART III-S Frequency Assignments which obtained

UNFAVORABLE FINDING after the examination by the Bureau.
They are returned to the Administration.

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 Thank you!

ITU – Radiocommunication Bureau

Questions to [email protected] or [email protected]