Provision of Starlink satellite services in the territory of the Islamic Republic of Iran

The Board carefully considered Document RRB25-2/11 from the Administration of the Islamic Republic of Iran, Document RRB25-2/15 from the Administration of the United States and Document RRB25-2/17 from the Administration of Norway, on the provision of Starlink satellite transmissions in Iranian territory. The Board also noted Document RRB25-2/DELAYED/7 and RRB25-2/DELAYED/8 from the Administration of the Islamic Republic of Iran. The Board noted the following points:

The Administration of the Islamic Republic of Iran had again reported the continuing unauthorized operation of Starlink terminals within its territory.
The Administration of Norway had again reported that, according to its satellite operator, it would not be practicable to verify whether every single user terminal that communicated with its space stations worldwide had been brought into a territory where the service had not been authorized.
From reliable publicly available information, Starlink had been able to do so upon request in other countries.
During discussions in recent Working Party 4A meetings, satellite operators had presented operational solutions implemented in their satellite systems that allowed them to disable unauthorized operation/terminals to ensure compliance with RR No. 18.1 and Resolution 22 (Rev.WRC‑23).
With respect to resolves 3 i) of Resolution 22 (Rev.WRC‑23), the Administration of the Islamic Republic of Iran had indicated at the 96th Board meeting that it had made efforts to detect and identify the location of terminals but that it was a difficult task due to the small size and portability of the terminals and the vast geography and challenging topography of its territory, without elaborating on the nature of the efforts undertaken.
The Administration of the United States disagreed with the Board’s interpretation of resolves 3 of Resolution 22 (Rev.WRC‑23).
The Administrations of both the United States and Norway had expressed concerns regarding the publication of the case on a Bureau and Board webpage pursuant to resolves to instruct the Radio Regulations Board 2 of Resolution 119 (Rev. Bucharest, 2022) of the Plenipotentiary Conference, given their different interpretation of Resolution 22 (Rev.WRC‑23).

Taking into account the above information and the concerns regarding the interpretation and application of resolves 3 of Resolution 22 (Rev.WRC‑23), the Board expressed the following view:

When adopting resolves 3 ii) of Resolution 22 (Rev.WRC‑23), WRC‑19 had envisaged that the notifying administration and satellite operator might need to intervene to terminate the unauthorized transmission if the administration concerned had not been successful. No limitations had been placed on the means it could use to resolve the matter.
While not explicitly stated as a requirement in resolves 2 and 3 ii) of Resolution 22 (Rev.WRC‑23), there was an implied requirement for the administrations and satellite operators to use any means available and necessary, to the maximum extent possible, to resolve the issue in a satisfactory and timely manner. Therefore, compliance with resolves 2 and 3 ii) of Resolution 22 (Rev.WRC‑23) could involve geolocating and deactivating terminals remotely, if those capabilities were available to the satellite system operator. Such a requirement was consistent with the intent of WRC‑19 and the text of resolves 2 and 3 ii) of Resolution 22 (Rev.WRC‑23).
Decisions were based on the application of the current regulations and of Resolution 22 (Rev.WRC‑23), in particular as they currently stood, and are not taking into account deliberations under WRC‑27 agenda item 1.5.

Consequently, the Board:

requested the Administration of the Islamic Republic of Iran to provide detailed information on actions and measures taken since the 96th Board meeting and on an ongoing basis to identify and deactivate unauthorized operation of Starlink terminals in its territory in accordance with resolves 3 i) of Resolution 22 (Rev.WRC‑23);
urged the Administration of Norway to take all appropriate actions at its disposal, to the extent of its ability, to immediately cease unauthorized transmissions of Starlink terminals within the territory of the Islamic Republic of Iran, including by remotely disabling those terminals if necessary;
once more instructed the Bureau to invite the Administration of Norway, with copy to the Administration of the United States, to explain specifically why it had been impossible to disable all Starlink terminals operating without authorization in the territory of the Islamic Republic of Iran in the same manner as had been done in other countries and thus to comply with Resolutions 22 (Rev.WRC‑23) and 25 (Rev.WRC‑23).

The Board decided to include the above issue in its report under Resolution 80 (Rev.WRC‑07) to WRC‑27. The Board also instructed the Bureau to finalize the development of the webpage related to the publication of information under resolves to instruct the Radio Regulations Board 2 of Resolution 119 (Rev. Bucharest, 2022) of the Plenipotentiary Conference, for consideration at the next Board meeting.

The Board carefully considered Document RRB25-1/14 from the Administration of the Islamic Republic of Iran and Document RRB25-1/25 from the Administration of Norway regarding the provision of STARLINK satellite services in the territory of the Islamic Republic of Iran. The Board also noted Document RRB25-1/DELAYED/2 provided by the Administration of the United States, Documents RRB25-1/DELAYED/3 and RRB25-1/DELAYED/4 provided by the Administration of the Islamic Republic of Iran in response to Document RRB24-3/DELAYED/2 and the submission by the Administration of Norway, respectively, for information. The Board noted the following:

The Administration of the Islamic Republic of Iran had again reported the continuing unauthorized operation of STARLINK terminals within its territory.
The Administrations of Norway and the United States were of the view that no evidence of detected operation of unauthorized STARLINK terminals had been provided.
From reliable information available, there were reports indicating that many STARLINK terminals were operating on the territory of the Islamic Republic of Iran.
With reference to the information provided by the Administrations of Norway and the United States, the Board again expressed regret that their responses had not focused on solutions to address the issue and again expressed grave concern at the complete lack of progress since its 96th meeting in resolving the long-standing matter.
Furthermore, the Administrations of Norway and the United States still had not provided any specific explanation as to why it had not been possible to disable systematically all STARLINK terminals operating without authorization in the territory of the Islamic Republic of Iran, given that, based on reliable publicly available information, it had been possible to do so in several other countries.
The request of the Islamic Republic of Iran related to disabling terminals operating without authorization within the Iranian territory and not to harmful interference to systems, exclusion of territories from satellite service area, or law enforcement of borders and customs.
The responsible administration of the satellite system filings under which the STARLINK system was operated was the Administration of Norway with the Administration of the United States included under item A.1.f.2 of RR Appendix 4.

The Board reiterated that once unauthorized transmissions in a specific territory were reported to the notifying administration of the satellite network or system that was associated with those unauthorized transmissions, there was an obligation for the notifying administration and the satellite operator of that satellite network or system to act, to the extent practicable, to remedy the situation pursuant to resolves 3 ii) of Resolution 22 (Rev.WRC-23). That obligation was not conditional on the ability of the reporting administration to provide information on terminals operating without authorization. The Board also concluded that compliance with the provisions of Resolution 22 (Rev.WRC-23) implied that a satellite operator having the operational capabilities to geolocate terminals communicating with its network or system was required to disable terminals operating without authorization within a territory.

Consequently, having concluded that there was evidence of unauthorized transmissions within the territory of the Islamic Republic of Iran, the Board urged the Administration of Norway to take all appropriate actions at its disposal, to the extent of its ability, to cease immediately unauthorized transmissions of STARLINK terminals within the territory of the Islamic Republic of Iran, including by remotely disabling those terminals if necessary.

The Board once more instructed the Bureau to invite the Administration of Norway, with copy to the Administration of the United States, to explain specifically why it had been impossible to disable all STARLINK terminals operating without authorization in the territory of the Islamic Republic of Iran in the same manner as had been done in several other countries and thus to comply with Resolutions 22 (Rev.WRC-23) and 25 (Rev.WRC-23).

The Board decided to accede to the request from the Administration of the Islamic Republic of Iran under resolves to instruct the Radio Regulations Board 2 of Resolution 119 (Rev. Bucharest, 2022) of the Plenipotentiary Conference and instructed the Bureau to prepare a draft dedicated webpage on that topic for consideration at the 99th Board meeting.

The Board carefully considered Document RRB24-3/16 from the Administration of the Islamic Republic of Iran, Document RRB24-3/21 from the Administration of the United States and Document RRB24-3/22 from the Administration of Norway, on the provision of STARLINK satellite transmissions in Iranian territory. The Board also noted Documents RRB24-3/DELAYED/3 and RRB24-3/DELAYED/4, provided by the Administration of the Islamic Republic of Iran in response to the submissions of the Administrations of the United States and Norway, respectively and Document RRB24-3/DELAYED/7, provided by the Administration of Norway in response to Document RRB24-3/DELAYED/4, for information. The Board thanked the three administrations for providing the information requested at its 96th meeting and noted the following issues:

The Administration of the Islamic Republic of Iran had again reported the continuing unauthorized operation of STARLINK terminals within its territory.
The Administration of the Islamic Republic of Iran had reconfirmed that despite its efforts to detect and identify the terminals’ locations, it was not practically feasible to detect all STARLINK terminals operating without authorization within its territory owing to the small size and portability of the terminals and to the vast geography and challenging topography of its country. However, no details had been provided on the nature of the efforts undertaken.
With reference to the information provided by the Administrations of Norway and the United States, the Board expressed regret that their responses had not focused on solutions and expressed grave concern at the complete lack of progress since its 96th meeting in resolving the long-standing matter. It further clarified that there was no obligation for the satellite operator or notifying administration to track earth stations licensed by other countries to determine their location and compliance with its service contract or to remove a territory from the satellite coverage area, but that once unauthorized transmissions were reported in a specific territory, there was an obligation for the satellite operator to act, to the extent practicable, to remedy the situation pursuant to resolves 3 ii) of Resolution 22 (WRC‑19); that obligation should not be conditional on the ability of the reporting administration to provide information on terminals operating without authorization.
The Board reconfirmed that the services provided by STARLINK were within the scope of Resolution 25 (Rev.WRC-03).
Furthermore, the Administrations of Norway and the United States had not provided any explanation as to why it was not possible to disable systematically all STARLINK terminals operating without authorization in the territory of the Islamic Republic of Iran, given that, based on reliable publicly available information, it had been possible to do so in several other countries.

Consequently, the Board reminded the Administrations of Norway and the United States that establishing administrative, contractual and operational restrictions on STARLINK customers did not qualify as compliance with the provisions of Article 18 and Resolution 22 (WRC-19) or the resolves of Resolution 25 (Rev.WRC-03) but that such compliance meant obtaining authorization from the administration in whose country the STARLINK terminals were operating and stopping transmissions where such operation had not been authorized.

The Board instructed the Bureau to invite the Administrations of Norway and the United States to explain specifically why it had been impossible to disable all STARLINK terminals operating without authorization in the territory of the Islamic Republic of Iran in the same manner as it had been done in several other countries and thus to comply with Resolutions 22 (WRC-19) and 25 (Rev.WRC‑03).

Considering that further information was expected, the Board decided that it remained premature to accede to the request from the Administration of the Islamic Republic of Iran under resolves to instruct the Radio Regulations Board 2 of Resolution 119 (Rev. Bucharest, 2022) but that, in the absence of the requested explanation and information at its 98th meeting, the Board would reconsider its decision in that regard.

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The Board carefully considered Document RRB24-2/9 from the Administration of the Islamic Republic of Iran and Document RRB24-2/11 from the Administration of the United States of America, on the provision of STARLINK satellite services within Iranian territory. The Board also noted for information Document RRB24-2/DELAYED/2 from the Administration of Norway, and Documents RRB24-2/DELAYED/4 and RRB24-2/DELAYED/5, submitted by the Administration of the Islamic Republic of Iran in response to the submissions of the Administrations of the United States and Norway, respectively.

The Board thanked the Administrations of Norway and the United States for providing the additional clarification requested at the 95th Board meeting and also thanked the Administration of the Islamic Republic of Iran for the additional information provided.

The Board noted the following points:

The Administration of the Islamic Republic of Iran had reported that no action had been taken by the notifying administration to disable unauthorized STARLINK terminals operating from within its territory despite the Board’s decisions at its 95th meeting. The administration had repeated its requests to the Administration of Norway, as the notifying administration for the relevant satellite systems providing STARLINK services, and to the Administration of the United States, as an associated administration to the notifying administration, to disable such terminals.
The responses to the two questions explicitly asked to the Administrations of Norway and the United States raised aspects that were mostly not related to the issue of the provision, in direct contravention of the provisions of Article 18 and of resolves 1 and 2 of Resolution 22 (WRC-19) and the resolves of Resolution 25 (Rev.WRC-03), of transmissions from within any territories where they had not been authorized.
While the notifying administrations had confirmed that STARLINK terminals were not marketed, sold or activated within the territory of the Islamic Republic of Iran, the operator had only disabled specific terminals reported.
No evidence had been provided that the operator had made efforts to disable all other STARLINK terminals operating within Iranian territory.
In that regard, the Board further noted, based on reliable publicly available information, that the operator had been able to and had disabled terminals and terminated service in a general manner in several countries where their operation had not been authorized and that such action had been taken based on the geographical location of those terminals.
While a reporting administration in whose territory the presence of unauthorized transmitting earth stations was identified had a responsibility under resolves 3 i) of Resolution 22 (WRC‑19) to take all appropriate actions at its disposal to the extent of its ability to stop such unauthorized transmissions, the notifying administration of the satellite system had the obligation under resolves 3 ii) of Resolution 22 (WRC-19) to cooperate with the reporting administration, to the maximum extent possible, in order to resolve the matter in a satisfactory and timely manner.
The Administration of the Islamic Republic of Iran had indicated that it was not able to detect and verify the operation of all unauthorized STARLINK terminals throughout its entire territory.

Consequently, the Board reiterated that the provision of transmissions from within any territories where they had not been authorized was in direct contravention of the provisions of Article 18 and of resolves 1, 2 and 3 of Resolution 22 (WRC-19) and the resolves of Resolution 25 (Rev.WRC-03). The Board strongly urged the Administration of Norway, as the notifying administration for the relevant satellite systems providing STARLINK services, and the Administration of the United States, as an associated administration to the notifying administration, to comply with those provisions by taking immediate action to disable STARLINK terminals operating within the territory of the Administration of the Islamic Republic of Iran in the same manner as the operator had done in several other countries.

The Board instructed the Bureau to:

invite the Administrations of Norway and the United States to provide further information on any additional actions taken since the 95th Board meeting to comply with resolves 1, 2 and 3 of Resolution 22 (WRC-19) and the resolves of Resolution 25 (Rev.WRC-03);
invite the Administration of the Islamic Republic of Iran to provide further information on any actions it had taken since the 95th Board meeting to comply with resolves 3 i) of Resolution 22 (WRC-19).

Considering that further information and actions were expected on this issue, the Board decided that it was premature at this stage to accede to the request from the Administration of the Islamic Republic of Iran under resolves to instruct the Radio Regulations Board 2 of Resolution 119 (Rev. Bucharest, 2022).

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The Board carefully considered Document RRB24-1/10 from the Administration of the Islamic Republic of Iran, Document RRB24-1/11 from the Administration of Norway and Document RRB24-1/13 from the Administration of the United States of America, on the provision of Starlink satellite services in Iranian territory. The Board also noted Document RRB24-1/DELAYED/2 provided by the Administration of the Islamic Republic of Iran in response to the submissions of the Administrations of Norway and the United States, for information.

The Board thanked the Administrations of Norway and the United States for providing the information requested at the 94th Board meeting and also thanked the Administration of the Islamic Republic of Iran for the additional information provided.

The Board noted the following points:

The Administration of Norway had questioned references to Resolution 25 (Rev.WRC‑03), on the grounds that the resolution covered only applications of global mobile personal communications by satellite (GMPCS) in frequency ranges below 3 GHz.
Both the Administrations of Norway and the United States had indicated that they imposed licensing obligations to limit operations of terminals to territories where authorization had been obtained.
Both administrations had indicated that Starlink had contractual and operational limitations preventing individuals within the territory of countries where its services were not authorized from obtaining both network service and terminal equipment, based on the location of the account address and the terminal ID of the earth station.
The Administration of the United States had indicated that it was not practicable for a space station operator to verify the location of every single user terminal that communicated with its space stations.
Although the satellite operator, upon receipt of information of the Administration of the Islamic Republic of Iran had deleted user accounts from its list of authorized accounts and permanently disabled all terminals identified by the reporting administrations, the Administration of the Islamic Republic of Iran had indicated that the Starlink Internet service was still accessible within its territory.
The satellite system was apparently able to determine the location of transmissions of satellite user terminals as originating from within the territory of the Islamic Republic of Iran, as such Starlink transmission triggered a warning message in English and Persian to the users.

The Board further noted that:

recognizing d) of Resolution 14 (WRC‑23) stated that unauthorized use of non-GSO FSS and MSS earth stations was prohibited;
according to reliable public information, the space operator had disabled Starlink services over specific areas in the past.

The Board concluded that Resolution 25 (Rev.WRC‑03) related to the provision of public personal communication by means of fixed, mobile or transportable terminals, without mentioning any specific frequency ranges in its resolves and, consequently, the services provided by the Starlink system were within the scope of the resolution.

The Board also concluded that, although the administrations had indicated that it might not be practicable for the space operator to verify all user terminal locations, the warning message in English and Persian to the users seemed to confirm the systematic checking of the user terminal location.

Consequently, the Board further reiterated that the provision of transmissions from within any territories where they had not been authorized was in direct contravention of the provisions of Article 18 and of resolves 1 and 2 of Resolution 22 (WRC‑19) and the resolves of Resolution 25 (Rev.WRC‑03). The Board urged the Administration of Norway, as the notifying administration for the relevant satellite systems providing Starlink services, and the Administration of the United States, as an associated administration to the notifying administration, to comply proactively with those provisions by taking immediate action to disable Starlink terminals operating within the territory of the Administration of the Islamic Republic of Iran.

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The Board carefully considered Document RRB23-3/8 and considered Document RRB23-3/DELAYED/3 for information; both contained information provided by the Administration of the Islamic Republic of Iran on the provision of Starlink satellite services in its territory. The Board thanked the Administration of the Islamic Republic of Iran for providing the information requested at the 93rd Board meeting. It also thanked the Administrations of Norway and the United States for having provided an initial response (Document RRB23-3/DELAYED/2, considered for information) to the Bureau’s letter on the case. The Board noted the following points:

The information provided by the Administration of the Islamic Republic of Iran demonstrated that Starlink terminals were able to send transmissions from within its territory and that the satellite system was able to determine the transmissions of the satellite user terminals as originating from within the territory of the Islamic Republic of Iran.
According to the Administration of the Islamic Republic of Iran, the terminals in question had been illegally imported into its territory, in contravention of its national regulations, and were operating under subscriptions associated with physical addresses outside its territory.
The Administration of the Islamic Republic of Iran had not received an application for or granted a licence for the provision of Starlink satellite services from within its territory.
Stipulating in the terms of service with its customers that the utilization of terminals in territories where they were not authorized was prohibited did not suffice to waive the satellite operator’s and service provider’s responsibility to disable the operation of terminals in such territories.

Consequently, the Board reiterated that the provision of transmissions from within any territories where they had not been authorized was in direct contravention of the provisions of RR Article 18 and of resolves 1 and 2 of Resolution 22 (WRC‑19) and the resolves of Resolution 25 (WRC‑03), and requested the Administration of Norway, acting as the notifying administration for the relevant satellite systems providing Starlink services, and the Administration of the United States, as an associated administration to the notifying administration, to comply with those provisions by taking immediate action to disable Starlink terminals operating within the territory of the Administration of the Islamic Republic of Iran.

The Board instructed the Bureau to invite the Administrations of Norway and the United States to provide further clarification on the following points to the Board’s 95th meeting:

What measures had been taken, besides stipulations in customer terms of service, to prohibit the provision of Starlink services in territories where they had not been authorized, to ensure compliance with the provisions of RR Article 18, resolves 1 and 2 of Resolution 22 (WRC‑19) and the resolves of Resolution 25 (WRC‑03)?
What steps had been taken to resolve cases where Starlink terminals were operating without authorization pursuant to resolves 3 of Resolution 22 (WRC‑19)?
How were connections from Starlink terminals authorized from within territories of countries where they had not been authorized?

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The Board considered in detail the submission from the Administration of the Islamic Republic of Iran concerning the important matter of the provision of Starlink satellite services in its territory, as contained in Document RRB23-2/10, and thanked the administration for the additional information and measurement results provided. The Board noted that:

from the measurement results provided, the Administration of the Islamic Republic of Iran had been able to demonstrate that transmissions and an international Internet connection to an Internetwork Packet Exchange (IPX) in a foreign country could be established with a Starlink terminal from within the territory of the Administration of the Islamic Republic of Iran;
the Administration of the Islamic Republic of Iran had not granted a licence for the provision of Starlink satellite services from within its territory;
some uncertainty remained as to whether the transmissions qualified as unauthorized but communications to an IPX in a foreign country from a country that had not authorized the service within its territory should not have been possible;
in response to the instruction of the Board, the Bureau had sent a letter on 1 June 2023 to the Administration of Norway, acting as the notifying administration for the relevant satellite systems providing Starlink services on behalf of the Administrations of Norway and the United States, reminding the notifying administration of the need to comply with the provisions of RR Article 18 and Resolution 22 (WRC-19);
unfortunately, at the time of the 93rd Board meeting the Administration of Norway had not replied.

The Board instructed the Bureau to:

invite the Administration of the Islamic Republic of Iran to provide to the 94th Board meeting details of the manner in which the tests had been performed, whether a subscription to the Starlink service had been entered into and, if so, whether the physical address for the subscription was within the territory of the Administration of the Islamic Republic of Iran;
assist the Administration of the Islamic Republic of Iran in its efforts and to report any progress to the 94th Board meeting;
send another letter to the Administration of Norway, urging the administration to comply with RR Article 18 and Resolution 22 (WRC-19) and strongly reminding it to respond to requests from the Bureau and the Board, and to copy the letter also to the Administration of the United States as an associated administration to the notifying administration for the satellite systems that provide Starlink services.

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With reference to Document RRB23‑1/7, the Board considered the submission from the Administration of the Islamic Republic of Iran and noted that:

as per RR No. 18.1, no transmitting station may be established or operated by a private person or by any enterprise without a licence issued in an appropriate form and in conformity with the provisions of these Regulations by or on behalf of the government of the country to which the station in question is subject’;
as per resolves 1 of Resolution 22 (WRC‑19), ‘the operation of transmitting earth stations within the territory of an administration shall be carried out only if authorized by that administration’;
furthermore, as per resolves 2 of Resolution 22 (WRC‑19), ‘the notifying administration for a satellite network or system shall, to the extent practicable, limit the operation of transmitting earth stations on the territory of an administration on which they are located and operated to only those licensed or authorized by that administration’;
the Administration of the Islamic Republic of Iran had taken actions as foreseen in Resolution 22 (WRC‑19);
the Administration had stated that some satellite Internet services had been provided in its territory without authorization but did not provide details of its investigations.
The Board reminded administrations of the need to comply with the provisions of RR Article 18 and Resolution 22 (WRC‑19) and instructed the Bureau to:
invite the Administration of the Islamic Republic of Iran to provide to the 93rd Board meeting details of its investigation of the presence of unauthorized transmitting earth station transmissions in its territories;
assist the Administration of the Islamic Republic of Iran in its efforts and to report any progress to the 93rd Board meeting;
again remind the Administration of Norway, as the notifying administration of the relevant satellite networks, of its obligations under RR Article 18 and Resolution 22 (WRC‑19).

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