Julie N. Zoller
Chairman of the Radio Regulations Board in 2011
Communication, navigation and broadcasting by satellite are expanding parts of our infrastructure. By registering satellite networks with ITU, Member States gain international recognition for their space-based frequency assignments and the ability to protect them from harmful interference. Every World Radiocommunication Conference (WRC) in recent memory has refined these registration procedures to ensure that they keep pace with technological advances, contribute to the orderly use of the radio-frequency spectrum and satellite orbits, and yield predictable and reliable results.
Member States file hundreds of satellite network registrations with ITU each year. Roughly one-third of the networks that start the registration process complete it. They are notified (notification is the final step of the registration process) and brought into use within the time limit.
Networks drop out of the process for a variety of reasons, some examples of which are given here. The project might be cancelled. Countries might file multiple orbital positions on the geostationary arc with the idea of letting go of all but the one orbital position for which the administration has successfully coordinated frequency usage. The filing might be suppressed based on an unfavourable technical finding. Or the filing might fail to meet the regulatory requirements, such as the requirement to be brought into use within the specified time limit.
Because frequency bands are congested, it is becoming more challenging for countries to register and coordinate new satellite systems. Some assignments recorded in the ITU Master International Frequency Register (MIFR) appear to be unused. This reservation of orbit and spectrum capacity without actual use adds to the difficulty of registering and coordinating new satellite systems.
Due diligence in applying the principles embodied in the ITU Constitution
Article 44 of the ITU Constitution calls upon Member States to bear in mind that the radio-frequency spectrum and satellite orbits are limited natural resources that “must be used rationally, efficiently and economically, in conformity with the provisions of the Radio Regulations, so that countries or groups of countries may have equitable access to those orbits and frequencies, taking into account the special needs of the developing countries and the geographical situation of particular countries.” Member States are asked to limit the number of frequencies and the spectrum used to the minimum needed to provide the necessary services. The Preamble to the Radio Regulations establishes similar principles. Essentially, we are asked to be good stewards of the radio-frequency spectrum and satellite orbits.
Resolution 80, Due Diligence in Applying the Principles Embodied in the Constitution, was first adopted by WRC-97 and subsequently revised by WRC-2000 and WRC-07. Each version of Resolution 80 has instructed the Radio Regulations Board (the Board) to develop Rules of Procedure, conduct studies, or consider and review possible draft recommendations linking the principles contained in the Preamble to the Radio Regulations to the notification, coordination and registration procedures in these Regulations, and to report to a subsequent WRC. In the case of Resolution 80 (Rev.WRC-07), these linkages were extended to include the principles contained in Article 44 of the Constitution.
WRC-12 will contemplate changes to the satellite network registration procedures, under its agenda items 7 and 8.1. The basis for this work includes the Board’s report on Resolution 80 and the report of the Director of the Radiocommunication Bureau (the Bureau) on the activities of the Radiocommunication Sector. WRC-12 has the opportunity to advance the implementation of important principles by improving the satellite regulatory procedures and the quality of the MIFR, thereby ensuring Member States’ rights in the future.
Maintaining the Master International Frequency Register
Investigations based on “reliable information”
The Master International Frequency Register contains information about frequency assignments and, in the case of space services, orbit usage. Accuracy and transparency are important because favourable recording in the MIFR is the basis for international recognition and the right to protection from harmful interference.
The Bureau is responsible for maintaining the MIFR and improving its accuracy. No. 13.6 of the Radio Regulations (RR) enables the Bureau’s review of assignments in the MIFR and their subsequent retention, suspension, or suppression. Proper application of RR No. 13.6 preserves Member States’ rights with regard to their frequency assignments and the integrity of the data. Administrations, the Bureau, and the Board have increasingly applied RR No. 13.6 since WRC-07.
A review under RR No. 13.6 is initiated by “reliable information” that a recorded assignment was not brought into regular operation or is not being used in accordance with the notified characteristics. An administration may ask the Bureau to clarify the operation of another administration’s frequency assignments. The administrations involved might also ask that the matter be brought to the attention of the Board. Other times, the Bureau initiates its own inquiry. These reviews are usually prompted by: information posted on the websites of launch providers, satellite manufacturers or satellite operators; data elements from real-time satellite tracking databases open to the public; privately-collected monitoring data; or some combination of public and private data that reveals differences from the information in ITU records.
The Board considers such information to be “reliable” for the purpose of initiating consultation, but not definitive for the purpose of cancelling, modifying or retaining an entry in the MIFR. Not all information regarding a satellite network is public, and not all information that is public is accurate. The Board takes the response by the notifying administration to an inquiry about the status of its own satellite networks and frequency assignments to be “reliable” information and the appropriate basis for decisions regarding assignments in the MIFR. Noting that “reliable” in this context does not imply validated or verified, the Board is of the view that the Bureau may seek clarification regarding such information.
The conference may wish to modify RR No. 13.6 to specify time-frames for responding to a Bureau request to clarify satellite network operations, follow-up reminders, and action on the part of the Bureau and the Board in the case of network suppression.
What does “bringing into regular operation” mean?
The distinction between a frequency assignment recorded in the MIFR and actual satellite operation is an important one when it comes to understanding “bringing into regular operation.” Data filed with ITU reflect the operations of real satellites, but there is not a one-to-one relationship between a satellite network filing and a particular physical satellite. In fact, a satellite network filing may relate to more than one physical satellite, either at the same time or over the lifetime of the filing. A satellite (or series of satellites) may have arrived at the notified orbital position directly from launch or after being moved from one location to another.
In order to bring a satellite network into use, a satellite (or series of satellites) capable of operating in the notified frequency bands must be deployed at the notified orbital location. Operation of a geostationary satellite network at a registered orbital location for a few months would generally be considered sufficient to declare the frequency assignments to be in “regular operation” in the absence of an anomaly or other relevant factors. Activation of multiple satellite network filings with a single satellite, however, may be seen as reservation of orbit and spectrum capacity without actual use, and as being contrary to the Union’s basic principles.
The conference may wish to express its views on these matters, although establishing rigid criteria, such as a minimum number of days to meet the “regular operation” criterion, might be difficult at this juncture.
Suspending the use of a recorded assignment to a space station
No. 11.49 of the Radio Regulations allows the use of a recorded assignment to a space station to be suspended for up to two years. Suspensions under RR No. 11.49 may be declared by the notifying administration at its own initiative or in response to an inquiry made under RR No. 13.6. Nearly one-quarter of the recent inquiries made under No. 13.6 resulted in suspensions under No. 11.49. In some cases, operation was actually suspended many months earlier but the Bureau was not informed until after the inquiry. Yet RR No. 11.49 requires that the notifying administration inform the Bureau “as soon as possible” of the suspension date.
The conference may wish to clarify RR No. 11.49 to minimize delays between the time that frequency assignments are suspended and the time that the Bureau is notified and provide greater certainty with regard to the actual date of bringing the assignment back into regular operation.
The Board frequently treats requests for its assistance regarding harmful interference. Historically, these requests have mainly involved terrestrial services. But recently, such requests have increasingly involved space services. The Board and the Bureau have had no difficulties applying the interference procedures in Article 15 of the Radio Regulations. Nevertheless, the harmful interference persists in some situations, and this is cause for concern.
The Board has also addressed cases involving interfering signals that appeared to be of a nature that is forbidden under the Radio Regulations. For example, some interference of this type was reported to consist of a high-power carrier continuously sweeping the entire satellite transponder bandwidth and timed to coincide with specific broadcasts. Such transmissions can cause loss of service and possibly damage the satellite. Harmful interference reports of this type, commonly known as “jamming,” have increased. Despite the application of the administrative procedures in the Radio Regulations, the harmful interference sometimes continues. This has given rise to the idea that something more might be needed to identify and eliminate the source of interference.
Given that ITU is the leading United Nations agency for the global management of the radio-frequency spectrum and satellite orbits, it is appropriate that problems of harmful interference or “jamming” should be treated and resolved within ITU through the diligent application of the Constitution, Convention and Radio Regulations. From the outset, ITU has successfully relied upon Member States exercising goodwill and mutual assistance. But studies may be needed to determine what additional measures could be incorporated in the Radio Regulations to improve the protection of satellite networks and enable this type of harmful interference to be resolved expeditiously.
International monitoring system
Article 16 of the Radio Regulations concerns international monitoring. Stations that are recognized as part of the specially designated international monitoring system have historically focused on terrestrial monitoring. Measurements from such stations could assist the Bureau and the Board in reconciling conflicting information about satellite operations, although the data would only reflect operations at a particular instant in time or during a finite period of time and might not be conclusive. Monitoring stations would be particularly useful in helping to resolve harmful interference. Data from some stations capable of geo-locating sources of interference have already been of assistance to the Bureau in identifying the causes of harmful interference to space networks.
The Bureau does not have the capability to conduct monitoring, which requires substantial resources. A greater number of specially designated stations in the international monitoring system, particularly with the addition of satellite monitoring capabilities, would provide more options to locate interference sources and resolve harmful interference.
The conference may wish to consider modifying the harmful interference procedures not only to accelerate assistance from the Bureau, but also to expand the ability of administrations to seek support in identifying a source of harmful interference, which could include activating the international monitoring system. Developing countries would particularly benefit from access to these monitoring resources, which may ultimately lead to the more effective use of the radio-frequency spectrum and satellite orbits.
The challenge for WRC-12
Three conferences have considered Resolution 80, Due Diligence in Applying the Principles Embodied in the Constitution. The Board reported the results of its studies on Resolution 80 to WRC-2000 and WRC-03. These conferences took no action, but WRC-07 included some of the earlier work from the Board in the revisions to this resolution.
As WRC-12 considers changes to the satellite network registration procedures, it will also consider the Board’s recommendations for linking the registration procedures for satellite networks to the principles contained in Article 44 of the Constitution and the Preamble to the Radio Regulations. These new concepts include ways to improve the MIFR and address harmful interference. The challenge for WRC-12 is to decide how to treat the Board’s recommendations and ensure that the satellite regulatory procedures meet the evolving needs of the Union’s members.