Satellite Issues Take Center-Stage at WRC-23

Satellite issues are taking a leading role on a global stage, satellite industry regulatory experts agree after the International Telecommunication Union (ITU) World Radiocommunication Conference (WRC). As the satellite industry grows in the number of players, the applications it serves, and technological innovations, satellite issues are playing a larger role at the international spectrum gathering.

WRC is the international spectrum gathering that takes place every four years that brings together thousands of delegates from Member States of the ITU to review and revise the ITU Radio Regulations, the international treaty that governs the use of precious radio frequency spectrum and satellite orbits. WRC-23, which was held in Dubai, wrapped up in December.

“Anybody that was there on the floor during the discussions noticed that a large majority of the agenda was about satellite,” says Isabelle Mauro, director general of the Global Satellite Operators Association (GSOA), which represents 70 members in the satellite ecosystem. “For me, it reflects the evolution of the satellite industry and the fact that we've never seen as much innovation and growth as we have seen in the last few years. It emphasizes the role the satellite industry is having on communications, connectivity, innovation, and science and research.”

“The interest in satellite is amazing,” says Jennifer A. Manner, senior vice president of Regulatory Affairs at EchoStar Corporation. “It was shown by the fact that the WRC-27 agenda — 80 percent of the items are satellite. They range from additional [spectrum] allocations, to looking at increased flexibility.”

There are two aspects of the WRC process, to negotiate and make changes to the Radio Regulations on existing agenda items, and to set agenda items for the upcoming conference, WRC-27.

Experts applauded additional frequency bands opened up for satellite services, and expanding frequency bands for Earth stations in motion (ESIMs) at WRC-27. There were also a number of hot-button issues like satellite power limits for Non-Geostationary Orbit (NGSO) systems, and nations emphasizing their need for equitable access and sovereignty.

Regional Concerns Play Out in Hot-Button Issues

One contentious issue at WRC was satellite power limits, known as equivalent power flux-density (EPFD). Technically, this is defined as a calculation of how powerful a radio signal should be as it reaches an area on the surface of the Earth based on the distance from a transmitter. These limits facilitate spectrum sharing by Geostationary (GEO) and NGSO operators.

NGSO operators Amazon and SpaceX urged the conference to adopt a future agenda item to study and potentially update the EPFD rules, while some GEO operators and countries strongly opposed adopting an agenda item.

The outcome is that EPFD limits are not an agenda item for WRC-27. There will be studies through 2027, but they are not intended for regulatory action to be taken at WRC-27.

Manner said that while a number of countries understand that it’s important to look at new ways to share spectrum, they want to make sure their GEO systems are protected. There were concerns that things were moving too fast if EPFD limits were added as an agenda item.

“This was a really far-reaching agenda item that included C-, Ku-, and Ka-bands. Changes would be pretty monumental. Taking a more incremental approach is probably better,” Manner says. “Countries and operators like EchoStar have spent a huge amount of money on building their GSO fleets and we still haven't answered important issues about NGSO.”

Julie Zoller, head of Global Regulatory Affairs for Project Kuiper at Amazon, says that while EPFD issues have always been contentious, she saw momentum at the conference to revisit the limits and perform the technical studies needed to make sound judgements for future revision.

“The momentum that gathered at WRC 23 around revisiting the EPFD limit will continue and results in reporting of the technical studies to WRC 27, which we believe will show there's a better approach to the EPFD limits that ensures the protection of Geostationary networks,” Zoller said. “If the results of the technical studies show there's a better approach to EPFP limits, that ensures the protection of Geostationary networks — as we believe they will — it would be hard to argue for the status quo and against making those improvements.”

Zoller argues that the current rules are outdated and limit the full potential of Low-Earth Orbit (LEO) satellite broadband to provide more connectivity to unserved and underserved communities around the world.

“The competitive landscape is also very different today. Satellite technology and spectrum management principles have changed a lot, but the rules just haven't kept pace. They've been overdue for review,” Zoller says.

A number of experts identified a theme of growing concern from developing countries with developing space and satellite industries to protect their interests in space. This played out in the EPFD conversations, but other issues as well.

John Janka, chief officer of Global Government Affairs & Regulatory at Viasat, was a leading voice against changing the EPFD limits. But beyond this specific issue, Janka says there is growing concern about countries wanting to protect their own interests in space, and how spectrum is shared among Non-Geostationary Orbit (NGSOs) operators.

He described an environment where countries are interested in LEO developments, but want control over what companies serve their territory, and want to ensure spectrum and orbits are available so they are not beholden to one or two players.

“More and more countries are recognizing that they have a place in the new space age, but they need to carve out room for themselves now — otherwise space will have filled up and they’ll be shut out,” Janka says. “The world was very clear that they don't want space dominated by a few companies. It’s the first time that I have seen so many nations speaking up at the conference very strongly to protect their national and sovereign interest in space,” he adds.

Manner identified this thread of concern as well, and related it to a future agenda item that will study how to set a precedent for equitable access to the Q- and V-bands.

“There’s a concern by developing countries about not being able to get access to orbit and spectrum resources,” Manner says. “There is a need for more spectrum, there's a need for regulatory regimes to govern this new world. And there's also a need to make sure that the resources are used efficiently and on an equitable basis.”

One resolution adopted deals with “explicit agreement” — that Member States have the sovereign right to regulate telecommunications within their territory, including limiting what services can operate in their country. Representatives from Iran raised the issue of Starlink terminals operating without authorization within the country, which has been documented in news reports.

Representatives from Iran questioned how connections from Starlink terminals are authorized within territories of countries where they had not been authorized, and how this can be prohibited, according to ITU minutes reviewed by Via Satellite.

“A lot of countries were very vocal that service was being provided in their country without their consent, and they have national laws that are being violated,” Janka says. “They were saying, we need something to be done at the ITU to backstop our national laws. This is not about precluding LEO service, it’s about ensuring that LEO service occurs only where it's authorized.”

Hazem Moakkit, vice president of Spectrum Strategy at Intelsat, says that overall, regional groups are playing a larger role in discussions, and it’s more important for the satellite industry to be present in regional preparatory meetings before WRC-27.

“Regional groups are becoming more technically competent and are shaping the outcome of many of the agenda items,” Moakkit says. “We as an industry constantly have to be active in forums in the regions to constantly talk to them about what we want to do and what they can achieve with agenda items.”

More Spectrum for Satellite

There’s been a narrative in the past that satellite has to cede spectrum to the mobile industry — like vacating parts of the C-band for 5G in the United States. However, there were a number of developments that moved in the opposite direction at WRC-23 as satellite and mobile industries work more closely together.

Intelsat was a fierce advocate against the mobile industry pushing into the Ku-band, Moakkit says. The FCC had proposed identifying parts of the Ku-band for mobile 6G services, but this was not adopted as a future agenda item. Moakkit says there seems to be a greater understanding of which bands will achieve the most benefit for mobile use.

“Nobody wants to be the administration that said no to progress, or no to more mobile. We all rely on mobile — we're not anti-mobile. We think there's a symbiotic relationship between us,” he says. “But it's the issue of: How much is enough?”

One area of overlap between the mobile and satellite industry is supplemental coverage from space, or direct-to-device services that supplement mobile networks with coverage from satellites. The topic of satellites using mobile terrestrial spectrum to provide service was identified as a future agenda item for WRC-27, and it was assigned to the satellite study group instead of the terrestrial group.

Manner says that study group allocation illustrates how much interest there is in satellite. She believes it's even more than the excitement around Iridium, Teledesic, and Globalstar in the 1990s. “I see even more excitement now than then. I really see the art of the possible,” she says.

In addition, this was the third WRC in a row that granted more opportunities for ESIMs, which are mobile satellite terminals used on planes and ships. This was a positive development for many operators that are pursuing business in mobility for aeronautical and maritime, notes Anna Marklund, director of Spectrum Management & Development at SES.

Another issue was the adoption of a regulatory framework for satellite-to-satellite links in Ka-band, which Marklund championed. With this framework in place, she says SES is able to serve customers in Low-Earth Orbit with satellite-to-satellite links using its Ka-band assets in both Geostationary and Medium-Earth Orbit (MEO).

This will allow customer satellites in LEO to downlink data to satellites in GEO or MEO, which can then relay it to the ground, allowing nearly real-time download, she says. Marklund tells Via Satellite this is an important development for Earth observation satellites, and can impact climate and disaster relief.

Another issued to be looked at for the future is space sustainability — and what role the ITU-R should play in it. The ITU is a specialized agency under the United Nations. While the ITU deals with spectrum issues, and the UN Office for Outer Space Affairs deals with issues of space sustainability, people are asking questions about how these overlap.

Some are raising the question about how orbital debris could affect a nation’s ability to use their spectrum efficiently, and if the ITU should take a larger role in space sustainability to ensure equitable access to spectrum.

“The outcome of the resolution that was crafted was clear on the ITU-R mandate, that ITU-R should cooperate closely with other UN organizations,” Marklund says. “This is still the start of a discussion. There were very interesting debates at the Plenipotentiary Conference at the end of 2022, but it’s the first time that we're really digging into [this issue] at the ITU-R. There are interesting times ahead.”

These issues being discussed WRC are the consequence of what is happening in the market, GSOA Director Mauro emphasizes. Industry innovation is driving the regulatory conversation, not the other way around. In fact, she says GSOA will have to dedicate even more resources throughout the next four years to support the regulatory interest and support its members in the study cycle.

She said there was widespread alignment within the satellite industry in positions for WRC-23, and sees the areas where there are differing views as a sign that the industry is evolving in a positive and competitive way.

“The fact that members of an association may have different positions on some of the issues I think is a reflection of a more competitive environment. I don't think it's anything surprising [for] an industry that is evolving, that is innovating, that has more players, and is becoming increasingly competitive," Mauro says. "It brings challenges that you need to address as an industry. It takes some time to adapt to these changes and to see what works best.” VS