International Satellite Coordination

The International Telecommunications Union (ITU) is the United Nations’ specialized agency for information and communication technologies, consisting of 193 Member States and more than 1000 companies, universities and international and regional organizations.  The ITU is divided into three sectors, the Telecommunication Development Sector (ITU-D), the Telecommunication Standardization Sector (ITU-T) and the Radiocommunication Sector (ITU-R). The ITU-R is responsible for:

• The allocation of bands of the radiofrequency spectrum, the allotment of radio frequencies and the registration of radio frequency assignments and of any associated orbital position in the geostationary satellite orbit in order to avoid harmful interference between radio stations of different countries; and
• Coordination efforts to eliminate harmful interference between radio stations of different countries and to improve the use made of radio-frequencies and of the geostationary-satellite orbit for radiocommunication services.

To do this, the ITU-R administers the Radio Regulations (RR), the international treaty governing the use of the radio-frequency spectrum. One of the primary functions of the ITU is the recording of satellite and earth station frequency assignments in the Master International Frequency Register (MIFR). International satellite coordination is the process by which a satellite network is registered in the MIFR at the International Telecommunications Union (ITU).
Additional ITU resources can be found on the following sites:

• https://www.itu.int/en/ITU-R/space/Pages/FAQspace.aspx
• https://www.itu.int/wrs-22/presentations/

1. The ITU Coordination Process

In general, the ITU process for coordination is analogous to that of the national U.S. coordination in that it is a multi-step process starting with filing a set of initial technical information about a satellite network or system with a regulatory body.  At the international level, the filing is submitted to the ITU in the form of an Advanced Publication Information (API) or Coordination Request (CR/C) filing, which contains technical information such as orbital characteristics, frequency bands and intended service areas (similar to the FCC’s accepted for filing public notice). 

The API is published in a bi-weekly notice known as the International Frequency Information Circular (IFIC) for other countries to review and provide comments to protect their satellite systems.  The ITU will use these comments and the procedures of Article 8 of the ITU Radio Regulations to determine the initial list of satellite systems that need to be coordinated.

Once comments are received on the API in the IFIC, but no sooner than 6 months after the receipt of the initial filing, the ITU will publish the Coordination Request, known as the CR/C. This publication contains detailed information about the satellite network or system, like the FCC’s ICFS Schedule S.  There is a comment period for countries to confirm the ITU’s list of affected systems or to identify additional systems that need to be included in the coordination process.  After the close of the second comment period, the ITU will publish the final list of systems created from the comments on the API and CR/C, as well as the procedures of Article 8 of the ITU Radio Regulations, that will need to be coordinated in a filing referred to as a CR/D special section. 

Once the CR/D is published, the filing administration and applicant/satellite operator will review the comments from the other countries and will begin to negotiate a set of operational parameters for the filed U.S. satellite with each of those administrations to ensure interference free operation.  These parameters may be the same or different for each administration and system, but the most stringent parameters will govern the satellite operations.  After the negotiations have concluded, the satellite operator will submit a Notification filing to its licensing administration that contains the final set of technical information including any adjustments necessitated by the outcome of coordination. The administration will then file the Notification with the ITU.

This notification filing must be submitted to the ITU within seven years of the initial filing date for unplanned band filings, and eight years for planned band filings.  A best practice is to notify the ITU approximately a year early in order to have time to perfect the notification filing, if necessary.  Filings that are not notified in the specified window of time are suppressed (i.e., cancelled), and the applicant/satellite operator must start the coordination process anew.

After review of the submitting filing, the ITU will publish the Notification Special Section in the IFIC with a comment period.  If there are no further concerns raised, the notified technical information will be included in the MIFR.  Having a satellite network recorded in the MIFR generally allows a satellite network to receive international recognition and protection for its operations.  However, coordination does not end with the MIFR entry. To reiterate, coordination is not complete until there is a signed agreement with all the administrations listed in the CR/D.  In addition, a satellite system will continue to coordinate for as long as it is in operation because it will be potentially affected by other newly published or modified satellite systems.

2. Description of ITU rules pertaining to international coordination

The ITU RR have various processes for international coordination dependent upon the type of satellite network (for geostationary) or satellite system (for non-geostationary) that is being proposed and the intended frequency bands of operation.  Table 1 shows the relevant Articles where the coordination procedures may be found in the ITU Radio Regulations. 

 
Table 2 breaks down the coordination cases and identifies the pertinent ITU provisions for each case.  

 
There are also frequency bands where coordination is not required.  These bands are typically identified for services like Space Operations in bands such as 2200-2290 MHz. These cases are filed under ITU RR Article 9.3.

3. Parts of an USA ITU filing

An ITU filing consists of a cost recovery letter, a cover letter, a Space Data Capture (SpaceCap) filing, and an associated Graphical Interference Management (GIMS) database. Explanations of these documents, including templates for the cost recovery and cover letter, are provided on the Space Bureau’s Transparency Initiative Part 25 Space Station License and Market Access Checklist webpage.

The ITU charges an ITU cost-recovery fee for each of the required filings.  Any applicant, licensee, or other entity associated with any ITU satellite filing forwarded by the FCC is unconditionally responsible for paying these fees in a timely fashion directly to the ITU. The fees vary based on the type of filing, the complexity of the filing and the provisions under which coordination is sought.  In 2024, fees were 570 Swiss Francs (CHF) for an API and ranged from 5710 CHF to ~67,000 CHF for a CR/C, and 15,910 CHF to ~116,000 CHF for a Notification filing.  The cost recovery fees are due 6 months after the date of the invoice.  If the fees are not paid, the system filings are cancelled. The CR/D is a generated ITU report and does not include cost recovery fees.

4. Additional Information on IFIC Comments and Letters

As noted above, the FCC receives three primary types of letters from other administrations and the ITU regarding new filings.  The Space Bureau forwards those letters to the appropriate satellite operators for their review and response. 

The first type of letter is a request from the ITU for clarification or additional information regarding an ITU filing or the operation of a filed system.  These typically have a 15-day or 30-day response time.  The Space Bureau will forward these letters to the operator’s point of contact on file and request a response at least 3-4 days prior to the ITU deadline.  This allows for the SB processing time and to discuss any issues with the operator prior to the ITU deadline.  Failure to meet the ITU deadline will delay the receivability of a filing putting the US filing further back in the received queue, or in the case of questions about the operation of a satellite system, may lead to suppression of the filing. Therefore, it is critical that the operator maintains an up-to-date point of contact with the Commission and notify the Commission as soon as possible if the point of contact changes.

The second type of letter is the general response to the API or CR/C.  This letter typically includes a list of potential affected satellite systems from a particular administration.  These letters typically do not require a response from an operator until the operator is ready to initiate coordination discussions. The SB provides a generic message indicating receipt of this type of correspondence.

The third type of letter is a more specific request for technical information from another administration.  These letters typically ask for more details about the service area, or other technical information of a satellite system to assist the requesting administration in determining if detailed coordination is needed. These letters generally need a response, preferably within 60-90 days. 

In addition to these three types of letters, on occasion the ITU will send reminder letters for filing notification and bring in to use (BIU) dates.

5. Coordination

Coordination begins as soon as a satellite filing is published in the IFIC and comments are received.  There are two types of coordination discussions:  those held during an administration-to-administration level meeting, and those held between the satellite operators.  Both types of discussions require a written arrangement, which is then approved by the respective administrations. Once both administrations approve the arrangement, the ITU is informed and coordination for that set of systems is noted as complete.

Most coordination activities can be conducted by correspondence or virtual meetings between satellite operators.  These discussions require the exchange of technical information and analysis.  The new satellite system must protect any system that was filed before it (sometimes referred to as ITU priority or date priority).  Both operators analyze the interference situation and then negotiate a technical solution, which may require the new system to reduce power, change orbital parameters or other technical mitigation methods to prevent interference.  The earlier systems must do their best to accommodate a new system.  This technical solution is then written into a formal arrangement, which is submitted to the respective administrations for approval.  The FCC has a set of “rules” for these types of interactions which can be found in Guidelines for Operator-to-Operator Coordination webpage.

Sometimes there are many satellite systems that need to be coordinated between two administrations, or there is an unusually difficult coordination issue that requires the administrations to be involved in the discussions. In these cases, an administration-to-administration level meeting is convened. In the event that a large number of satellite systems need to be coordinated, meeting time must be made available for operator level discussions to occur and agreements to be reached and documented.  Once this is done, the operator level agreements are grouped together in a large summary record and this larger document is tentatively approved by the administration representatives at the meeting.  The summary record is then reviewed again at a later date by the respective administrations with the satellite operators to ensure no errors were made, and final approval is given by each administration and the ITU is informed.  

If the cause of the administration-to-administration level meeting is a difficult coordination issue, then the two administrations and the two satellite operators meet to work through the difficulties.  Again, these discussions are documented, and once a final coordination arrangement is reached, the administrations will approve it and inform the ITU.  This is a very rare circumstance, as satellite operators should in good faith make every effort to reach a coordination arrangement.

Please note that these meetings involve both the new satellite system and existing systems in all stages of development and operations.  As stated above, coordination responsibilities do not end after notification.  Failure to participate in coordination discussions where required may lead to interference being caused to a satellite system.  Silence, or no response, is considered agreement at the ITU in these cases. In the absence of participation in the coordination process for new entrants, the FCC and ITU deem interference caused by the new entrants to be acceptable interference to the existing operator.  That is not to say the FCC will not try to support an operator mitigate interference, but the outcome is much less certain than if coordination is undertaken.

6. Unused filings

To avoid spectrum and orbital warehousing, the ITU and FCC have procedures to ensure that filings are used by operators.  In the event that a GSO orbital location is vacated by an operator or there are frequencies that cannot be used on a satellite at a particular location (e.g., an onboard transmitter failure), the ITU rules permit a 3-year suspension of the usage requirements.  This suspension is executed by a letter request to the ITU from the FCC at the behest of the satellite operator.  The satellite operator should send an email that includes the name of the filing to be suspended as well as the location and the frequency bands to Joseph Hill (joseph.hill@fcc.gov) or Kathyrn Medley (kathyrn.medley@fcc.gov) to initiate this process. If the mission is ended and there are no plans to restore service in accordance with the notified filing for those operations, the satellite system filing should be suppressed at the ITU.  A similar procedure to the one for suspension is used.