UK Space Spectrum Strategy update - and what it means for satellite constellation operators

Ofcom has opened a consultation on an update to its Space Spectrum Strategy, which comes in response to the growth in size and value of the UK space sector and trends that have emerged since it published its last strategy in 2017, in particular in satellite technology and the advances in and greater affordability in the launch market. This consultation is likely to be of interest to a wide range of stakeholders across the space industry; in particular those involved in low-Earth orbit (LEO) satellite constellations – a key focus area.

Regulating spectrum

Many wireless service providers depend on the availability of, and access to, spectrum to operate their technology and provide services to end users - from mobile services and the roll-out of 5G, to navigation and the operation of space activities, such as satellite communications.

Ofcom is the UK regulator responsible for managing spectrum and enforcing a regulatory framework to ensure that this scarce natural resource is used efficiently, and in accordance with both UK and international law.

Ofcom's role in the space sector is critical: issuing the required authorisations for satellite communications and submitting satellite filings on behalf of UK entities to the International Telecommunication Union (ITU) which allow operators to obtain internationally-recognised spectrum and orbital positions. These are often crucial in both assuring investors of the viability of a proposed space activity, and for obtaining the regulatory approvals needed to launch and operate their satellites.

The timing of this consultation

Since 2017, the UK space sector has continued to grow with the industry’s income most recently estimated by the UK Space Agency at £16.4 billion) and has experienced a steady rise in the level of private investment. It now comprises around 1,200 organisations, including manufacturers and satellite operators.

The UK's National Space Strategy (which we analysed in 2021) recognised both the commercial and strategic importance of the space sector. The Government's objective is to increase its share of the global space economy (estimated at around $371 billion, according to Bryce’s State of the Satellite Industry Report 2021), and plans to do so by continuing to invest and encourage innovation in the sector, including through the development of a UK launch market.

Ofcom considers it the right time to undertake a “strategic refresh” of its current Space Spectrum Strategy to take account of these changes in the UK sector, and to review aspects of its regulatory framework for managing access to spectrum for different space activities.

Managing spectrum needs for the space sector

In this strategy update, Ofcom has prioritised three specific areas within the sector where it considers its actions will have the greatest benefit: where it perceives further regulatory changes are most likely to be necessary, and where significant market changes are occurring:

• Satellite communications – the key priority area in Ofcom’s consultation because of the developments in satellite technology, and  the improved and new services being provided, e.g. communications to remote locations and in-flight passenger connectivity. The main focus is on non-geostationary orbit (NGSO) satellites, where decreased costs and increased manufacturing speed have enabled the development and deployment of constellations in LEO of hundreds and even thousands of satellites.
  
  
• Earth observation and navigation – ensuring access to spectrum for satellite Earth observation data is critical for the UK in meeting its climate goals, as well as supporting weather forecasting, sectors like agriculture and in enabling emergency services. Navigation services are also indispensable for global positioning and the transport sector.
  
  
• Access to space – spectrum needs in relation to the safe access to space (e.g. being able to track in-orbit space debris) and for UK spaceflight are both seen as priority areas.

Focus on low-Earth orbit NGSO satellite constellations

The predominant focus on communications and the market opportunities and spectrum challenges of satellite constellations is perhaps unsurprising given that the UK has attracted some of the main NGSO satellite operators, which make up about 20% of the 38 operators whose international satellite filings are managed by Ofcom.

It also follows the update Ofcom made in 2021 to its licensing approach for these specific satellite systems, which included the introduction of a new application process and adding new licensing conditions for future and existing NGSO networks. These licensing changes were intended to address some of the main regulatory challenges presented by constellations, including:

• the appropriate mechanism for licensing the hundreds (or thousands) of satellites within a constellation and allocating frequency bands to be used; and
  
  
• how to address the risk of spectrum interference both between these satellites and towards other users of spectrum.

Main proposals

Ofcom proposes several additional actions  likely to be of interest to operators developing and/or operating NGSO systems and the uses of derives services, including:

• Addressing spectrum access for NGSO systems - including updating mobile Earth station network licences (such as those on aircraft and ships) to align, where appropriate, the frequency ranges available for NGSO systems with those currently available for geostationary satellites.
  
  
• Ensuring the efficient use and sharing of NGSO systems - which includes working at the ITU level to seek regulatory changes or create guidance on key issues, such as the level of interference that the various NGSO constellations, and the thousands of satellites within them, should be prepared to accept from one another.
  
  
• Extending the current UK NGSO licensing framework - to cover additional spectrum bands (such as those in the 14.25 – 14.5 GHz range).

Next steps

The consultation closes on 24 May 2022. Ofcom's response and the final spectrum strategy for the space sector is expected later in 2022 or early 2023.