Despite a general outcry by ITU Members and the adoption of a radical new Resolution by the
Minneapolis Plenipotentiary Conference four years ago, the issue of satellite over-filing ó
often known more familiarly as "the paper satellite problem" ó once again takes its
place among the more contentious agenda items at this yearís ITU Plenipotentiary Conference.
This yearís delegates will examine new proposals for increased filing charges, stricter
administrative due diligence along with penalties for non-payment of processing fees. But while
the scale and urgency of the problem seems accepted by all, much disagreement remains over how
it should be solved
If the issue of paper satellites is getting rather long in the tooth, itís because itís
consistently proved one of the ITUís thorniest problems. While the Union recognizes and
upholds the right of all nations ó rich and poor alike ó to equitable and affordable access
to the satellite orbit, thereís an urgent need to reconcile this with an effective way of
reducing the mountain of casual applications for satellite "slots", many of which are
filed for systems which will never see the light of day.
The Root of the Problem
Since the first satellite systems began carrying communications traffic back in the early
1960s, satellites have been enthusiastically embraced as a highly efficient means of
transporting and delivering large amounts of data across a very wide geographical area.
Todayís high-tech satellites support a broad and growing range of services, from national
and international telephone calls to broadcast radio and television and, increasingly, data-only
services like monitoring systems for remote oil and gas networks and systems which collect
weather and environmental data.
Emerging new services such as third generation mobile telephony and proposed broadband access
systems that envisage high-speed wireless connections via large constellations of rapidly moving
satellites, are also putting pressure on global demand for satellite orbits and frequencies. At
the same time, satellites are increasingly proving their worth in the developing world, where
they represent an efficient and cost-effective means of overcoming a chronic lack of inland
lines. Through both traditional telephony applications and new applications like VSAT (Very
Small Aperture Terminal), satellites are now being used to deliver a growing range of vital
services in the developing world, including business and personal communications, data exchange
for e-commerce, tele-medicine and tele-education, as well as helping provide much-needed
information through radio and television programmes.
The huge worldwide demand for satellite-based services has seen steady growth in the number
of satellites providing infocommunications services over the last 15 years, from 24 in 1985 to
an estimated 150 in 2002. While this has been a boon for service providers and consumers alike,
itís also resulted in an increasingly densely-packed neighbourhood out in space ó a
situation that, as on the terrestrial plane, is resulting in scramble for "prime real
estate" in the form of desirable orbital slots.
Sharing the Skies
Because no two satellites can occupy the same orbital position and operate on the same
frequency without causing harmful interference to one another, global coordination of radio
frequency applications is essential. As the United Nations specialized agency for
telecommunications, ITU fulfils the role of impartial coordinator of all frequency assignments,
including those associated with satellite systems.
The complexity of todayís multi-transponder, multi-service systems entails a lengthy and
complicated process for engineers working in the Space Services Department of ITUís
Radiocommunication Bureau (BR) (see box). Systems need to be positioned in orbit in such a way
that they pose no operational threat to other satellites like meteorological stations or to
existing terrestrial communication systems. Satellites which are designed to be mobile (known as
non-geostationary because, unlike traditional communication satellites which are
positioned in a static orbital slot, they constantly change position relative to the Earthís
surface) pose a particular problem, since engineers need to develop a precise system of
"air traffic control" to ensure the criss-crossing paths of each satellite in the
constellation remains temporally and spatially well-separated from its fellow satellites and
from other systems, to avoid any possibility of a collision. At the same time, BR must also
ensure the many different frequencies used by each satellite system will not interfere with
existing space-based or terrestrial services.
The strong demand for satellite-based services combined with a lengthy international
co-ordination procedure that, in the case of very complex systems, can take years to complete,
has led to deliberate and routine "over-filing" − in short, requests for
coordination for orbital positions and frequencies that are not actually needed, with a view to
"reserving" those positions and frequency bands for possible future use, or for
commercial resale to another user at a later date. With coordination services previously offered
free to ITU Member States, and with no penalty for failing to develop a notified system, it is
perhaps not surprising that regular over-filing as a provision for future needs made sense to
For the BR, however, the phenomenon of "paper satellites" poses a two-fold problem.
First, demand for complex coordination work continues to outstrip the Bureauís resources,
resulting in a large and growing backlog of coordination requests and increasingly more complex
processing for BR technical staff. At present, the backlog of systems still awaiting full
coordination stands at around 1,200, with BR regularly receiving between 400-500 requests
for new systems each year, only around one tenth of which will ever make it to the launch pad.
In addition, the existence of a large number of paper satellites greatly hinders the speedy
coordination of real systems, and can add significantly to their cost. This is because each
satellite needs to take account of the frequency and positioning requirements of all other
systems. Since paper satellites which have completed the coordination process are eventually
listed in the ITUís Master International Frequency Register just as if they were real systems,
their operating parameters and requirements need to be taken into account when coordinating new
real-life systems, generating a great deal of unnecessary work and technical problems for
While the problem of paper satellites has been recognized for many years, coming to grips
with the issue has proved particularly tricky, not least because of resistance by various
stakeholders, and in particular many of the larger satellite-operating countries, which have
generally opposed the application of fees because of the added financial burden this would
impose on an industry already beset by extremely high costs and financial risks.
These larger players have in turn found unexpected and perhaps unlikely support from a
handful of developing countries, which have argued that the imposition of fees contravenes the
international principle of fair and free access to orbital spectrum.
That said, with timeframes for coordination running into several years and debate on the
issue at WRC-97 and WRC-2000 failing to make any real headway, the Minneapolis Plenipotentiary
Conference did succeed in introducing an administration and processing fee for all new systems,
through the adoption of Resolutions 88 and 91.
Applied on a sliding scale which takes into account the type and capacity of system, the
number of frequency bands requested and the difficulty of coordination (for example, when
systems are planned in bands that are already in extremely heavy use), the new fee ranges from
around CHF 5 000 ó CHF 21 000, representing a tiny fraction of typical
satellite development, build and launch costs. Given also that fees did not apply to those in
the backlog at the time of the decision, the charges have only recently started to be imposed.
How Are Satellites Brought Into Service?
Regardless of whether a new satellite system will be operated by government or
privately, all requests for satellite orbital positions and frequency use are
submitted by national administrations on behalf of operators.
The first stage, known as advance publication information (API), sees the
administration supply details of the identity of the satellite system, the expected
date of bringing into use, and orbital and network characteristics (such as the
frequencies requested, and transponder and power emission data). At this early
stage, ITU simply ensures all information is complete and publishes it in the
International Frequency Information Circular (IFIC), which is distributed to all ITU
Members. This provides an opportunity for other governments to determine whether the
planned system poses any potential threat to existing terrestrial or satellite
services (including those already under coordination), in terms of orbital position
or interference. Administrations have four months to comment on the proposed system.
The second and more complex phase of the process - coordination - involves formal
coordination between the proposing administration and all countries reported by the
ITU as being affected by the proposed system. At this stage, ITU also verifies that
the proposed system conforms to all relevant provisions of the Radio Regulations,
the internationally-binding treaty governing the use the radio frequency spectrum.
The proposing administration completes a form providing detailed system
characteristics, including the characteristics of earth stations and their proposed
locations - Appendix 4 of the Radio Regulations.
Administrations then work multilaterally through a series of coordination
meetings to resolve difficulties, normally by adjusting the technical parameters of
the proposed new system to ensure it does not interfere with existing services.
The final phase of the process, notification, sees the ITU perform a final
verification that formal coordination has been successfully completed and that the
system still conforms to the Radio Regulations. If a favourable finding is given,
the system is recorded in the Master International Frequency Register (MIFR). If
not, the notice is returned to the proposing administration which then has the
option of continuing negotiations until a favourable outcome is achieved or no
objections or complaints are made about the transmissions within a four month
The Marrakesh Agenda
While there are some early indications this new fee may be going some way to dissuading
casual filing, over-filing nonetheless remains a significant problem. Whatís more, the cost
recovery charges decided by the Minneapolis Plenipotentiary only go part way toward offsetting
the high cost of system coordination, with many of the real costs excluded from the methodology
used to determine the fee structure.
In recognition of the urgent need to clear a backlog that continues to seriously hamper
operatorís business plans and usersí access to new services, ITU Council 2001 established
the Satellite Backlog Action Group (SAT-BAG, Council Resolution 1182). The Recommendations of
this group will form the basis of much of the discussion at Marrakesh, and include proposals for
revising the processing fee schedule and improving budget flexibility by not including cost
recovery fees within the limits on expenditure currently exercised.
With the Union under increasing pressure to keep contribution costs pegged and with demands
on BR resources continuing to climb thanks to the growing popularity of wireless services and
the advent of new wireless technologies, many delegates at Marrakesh are expected to support a
substantial increase to the current fee, which remains extremely low in relation to total system
costs. Proponents of higher fees argue that the imposition of charges that were more in line
with actual costs would not only act as a strong and effective disincentive to future spurious
filings, but would help boost available resources for additional trained personnel, new and
improved software systems and better administrative support ó factors that would themselves
greatly expedite processing times to the benefit of all.
The Conference will also review current administrative due diligence requirements that oblige
all operators and administrations filing system coordination requests to provide full details of
system contractors, including manufacturers and launch companies, along with a planned schedule
of system deployment. While this provision was accepted by the Minneapolis Plenipotentiary
Conference in an effort to ensure all future filings related to genuine systems, current
arrangements still only oblige operators to provide details once a system is about to be
launched, offsetting any real dissuasive effect.
For the moment, large satellite operating nations are once again expected to oppose any
increase in fees or administrative requirements, on the basis that additional charges and
paperwork would add to the heavy financial burden on an industry already weighed down by onerous
construction, launch and insurance charges.
Whether they ultimately carry the day remains a moot point; the only real certainty is that
the backrooms of the Marrakesh Palais des CongrŤs will see plenty of energetic lobbying by a
number of large and powerful delegations and leading satellite operators during weeks leading up
to the debate.
One last but important issue expected to be tackled at Marrakesh is the question of what
action to take if administrations filing a satellite coordination request fail to pay their
processing fee. Under a decision taken at WRC-2000, administrations have six months in which to
settle their fee, after which the filing is automatically cancelled. The bringing into effect of
this decision is to be considered by the Marrakesh Plenipotentiary. There will be arguments from
some nations, mostly in the developing world, that arbitrary cancellation effectively
contravenes their right to unrestricted access to the orbit. With opinions strongly polarized
over an issue that many argue currently favours rich over poor, the question of non-payment of
fees also seems certain to be a future source of vigorous debate.
Resolution in Sight
In the long run, it may simply be that the economic downturn now afflicting the telecoms
industry worldwide ultimately proves the most effective way of resolving the chronic problem of
With the once-vast pool of venture capital for costly new satellite systems virtually dried
up within the space of a few short months and many of the customers for satellite services, such
as major telecoms carriers and broadcasters, now labouring under crippling mountains of debt,
existing satellite operators are batoning down the hatches in anticipation of a rocky ride
Meanwhile, ongoing work to resolve the problem through SAT-BAG and the Radiocommunication
Bureauís own efforts have already seen increased processing efficiencies through new in-house
software development and a doubling of the Bureauís technical examination staff from four to
eight space systems engineers.
With requests currently down 50% over previous years to around 15 new systems per month and
the number of coordination requests processed now reaching around 50 per month, if current
conditions prevail todayís backlog should be cleared within three-to four years.