Satellite Spectrum Management: Navigating ITU Coordination

Radio frequency spectrum is arguably the most contentious resource in the satellite industry. Unlike orbital slots or launch windows, electromagnetic spectrum cannot be physically allocated: two transmitters on the same frequency in the same geographic area will interfere with each other, regardless of who has the better legal claim. The result is a complex international framework administered by the International Telecommunication Union (ITU) that operators must navigate carefully to secure and protect their spectrum rights.

The ITU Framework

The ITU is a United Nations specialized agency responsible for global coordination of radio communications. Its Radio Regulations treaty, updated every four years at the World Radiocommunication Conference (WRC), allocates frequency bands to different services (fixed, mobile, satellite, radionavigation, etc.) and establishes the rules for coordination and notification that member states must follow.

For satellite operators, the relevant body is the ITU Radiocommunication Sector (ITU-R), which maintains the Master International Frequency Register (MIFR), the authoritative record of all frequency assignments worldwide. A satellite network's frequency use is not protected under international law until it is recorded in the MIFR following a successful coordination process.

The Filing Process Step by Step

The ITU satellite network filing process is notoriously lengthy. For systems in planned frequency bands (primarily GEO), the process can take 7–9 years from advance publication to regulatory recognition:

• Advance Publication Information (API): Filed 2–5 years before the anticipated frequency use. Puts the international community on notice that a network is being planned. Does not confer priority rights.
• Request for Coordination (RfC) or Notification: Filed at least 3 months before bringing the network into use. For most bands, an RfC triggers a coordination period during which potentially affected administrations must respond. Failure to respond within the prescribed period is deemed acceptance.
• Coordination agreements: The filing administration (or its licensee) negotiates bilaterally with any administration that claims potential interference. Agreements are technical documents specifying power flux density limits, interference protection ratios, and any operational constraints accepted by both parties.
• Due Diligence submission: For most satellite systems, the operator must demonstrate to their national administration that the network has actually been brought into use within seven years of the coordination/notification date. Failure to meet due diligence results in cancellation of the filing.

Priority Rights and the "Paper Satellite" Problem

The ITU filing system operates on a priority principle: earlier filings generally receive protection against interference from later filings. This has historically created an incentive for administrations to file for spectrum resources they have no near-term intent to use ("paper satellites") purely to reserve priority rights that can later be licensed to commercial operators.

The due diligence rules introduced after WRC-03 were designed to address this by requiring demonstrated actual use within seven years. However, the definition of "bringing into use," which requires only a short operational demonstration, not full commercial service, has been interpreted in ways that do not entirely prevent strategic filing. Regulators and industry continue to debate reforms at successive WRCs.

National Licensing and FCC Coordination

ITU filings are made by national administrations on behalf of licensed operators. In the United States, the FCC coordinates spectrum use for commercial satellites, processing market access applications and filing with the ITU on behalf of U.S. licensees. Operators must hold an FCC license (or market access authorization) before the ITU filing can proceed; the regulatory chain runs from the national regulator to the ITU, not directly.

For operators targeting U.S. market access, the FCC's satellite licensing process under Part 25 of its rules requires a technical showing of compliance with ITU coordination obligations, power flux density limits at the Earth's surface, and domestic interference avoidance. Licenses specify authorized frequency bands, orbital locations, and emission characteristics.

Practical Implications for Operators

• Begin spectrum coordination planning at the satellite bus design phase, not after you have committed to frequencies
• Engage a spectrum consultant or regulatory attorney early. ITU filings require technical expertise and relationships with national telecom administrations
• Budget for the time: for LEO constellations under the self-coordination framework, timelines are somewhat faster, but still require careful management
• Monitor competitor filings in your intended frequency bands through the ITU's BR IFIC database to anticipate coordination counterparties

SpaceNexus tracks regulatory developments and spectrum policy through the Spectrum module and the Regulatory Hub.