11.28.1 Comment Submission Guide
(This page was updated on 10 June 2025.)
The regulatory procedure of commenting under No. 11.28.1 of the Radio Regulation
From
1 January 2025, administrations may submit a copy of the comments made under
the provision No. 11.28.1 of the Radio Regulation on Part I-S
publications to the Bureau if modifications
to the characteristics initially published under No. 9.2B (API) are believed to cause
unacceptable interference. See Circular Letter CR/519 dated 10 June
2025 for details.
11.28.1 In case of satellite networks or systems not subject to the coordination procedure under Section II of Article 9, an administration believing that unacceptable interference may be caused to its existing or planned satellite networks or systems by submitted modifications to the characteristics initially published under No. 9.2B may provide its comments to the notifying administration with copy to the Bureau. The Bureau shall publish any such comments received on its website. Both administrations shall thereafter cooperate to resolve any difficulties. (WRC-23)
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Comments on the Part I-S notification publication shall be sent from the commenting administration to the notifying administration of the notification notice, as well as recorded on SpaceCom software and submitted via the e-Submission system to the Bureau. This page introduces the guidance to record and submit comments to the Bureau under No. 11.28.1.
The comments submitted via the e-Submission system are published as received on the ITU As Received webpage.
Comments submitted within 4 months from the date of publication of the notification notice are consolidated and presented in this page.
Please note that administrations submitting comments under this provision are required to ensure that such comments are related solely to modifications to the characteristics initially published under No. 9.2B. Therefore, administrations should verify whether the Notification characteristics published in Part I-S differ from those previously published in the API prior to submitting their comments.
New interface for commenting under No. 11.28.1 on SpaceCom software
The interface to capture comments to Part I-S under No.11.28.1 can be accessed by clicking the “11.28.1 Part I-S" button at the bottom of the main page of the latest SpaceCom software.
Main page of SpaceCom software
The procedure and interfaces to capture comments to Part I-Ss on SpaceCom are similar with those to Special Section API/A.
The features to capture comments to Part I-S common with API/A:
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| Part I-Ss subject to No. 11.28.1 are listed on SpaceCom when designating an IFIC number and an IFIC database. |
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| Operating agencies can capture comments, which those administration can merge. |
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| Captured comments need to be validated to check the completeness of comments to all Part I-Ss subject to No. 11.28.1 contained in the same BR IFIC. A validation report is exported. |
The features to capture comments to Part I-S that differ from those for API/A:
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| Comments are captured for each group in Part I-S. |
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| The file of comments captured on SpaceCom is named “NOTIF-IFICxxxx_ADM.mdb" (where 'XXXX' represents the number of that specific BR IFIC) and stored in a local computer of an administration.
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Interface of SpaceCom software to capture comments to each group in a Part I-S subject to No.11.28.1
Update of the e-Submission system to submit comments under No. 11.28.1
A comment file captured on SpaceCom software can be uploaded to “SpaceCom Comments" category on the e-Submission system, submitted to the Bureau and published as received as well as other types of comments captured on SpaceCom software.
Please note that:
- Only the file name “NOTIF-IFICxxxx_ADM.mdb" is accepted as comments to Part I-S under No.
11.28.1 on the e-Submission system.
- Only the comment files which have been validated for completeness on SpaceCom software can be submitted to the Bureau via the e-Submission system.
Support and Contacts
- The Bureau remains at your administration's disposal, via the brmail@itu.int address, for any clarification it may require with respect to the content of this circular letter.
- Queries relating to the software's installation and functionality may be addressed to e-mail brsas@itu.int.
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