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WRC-23: Time to Get the Rules Right for Satellite Broadband

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As the 2030 deadline for achieving the Sustainable Development Goals fast approaches, the global digital divide stubbornly persists. The International Telecommunication Union (ITU) counts more than 2.7 billion people worldwide who remain offline. In the least developed countries, only 36% of people are online. The digital divide is not evenly spread throughout the world. Historically marginalized communities and people living in rural and remote locations far from urban cores are most likely to live without the Internet. For these communities, legacy technologies and business models have failed to deliver the connectivity they need.

Communities that lack access to affordable and reliable broadband connectivity fall further and further behind in an increasingly connected world. Broadband connectivity has become a prerequisite for social and economic development, education, medical and emergency services, employment, and civic participation.

Thankfully, the world has an opportunity next month at the ITU World Radiocommunication Conference (WRC-23) to meaningfully address the pernicious digital divide. By merely agreeing to study outdated satellite regulations and developing regulatory solutions to revise them as needed, ITU Member States can help unleash the most promising emerging technology for expanding global broadband access.

The Promise of LEO Broadband

Advances in satellite broadband — especially Non-Geostationary Orbit (NGSO) systems — offer incredible promise for connecting the unconnected around the world. New NGSO systems will offer high-capacity, low-latency connectivity to unconnected or under-connected communities, even in remote locations where current broadband services are non-existent, inadequate, or uncompetitively priced.

NGSO satellite systems provide a variety of applications that the modern digital economy demands. These systems can serve communities by providing connectivity for both individual users and for enterprise users such as schools, hospitals, or businesses. In cooperation with existing mobile operators, NGSOs can provide backhaul services between distant communities and core fiber networks. NGSO satellites can provide flexible, secure broadband to connect remote assets across land, sea and air for transportation and agricultural purposes. They can also supplement existing infrastructure with redundant connectivity, which becomes essential when terrestrial networks fail — be it due to natural disasters, cyber-attacks or human error.

Old Regulations Threaten NGSO Innovation

But outdated ITU rules thwart the benefits that NGSO systems can deliver. Regulations around equivalent power flux-density (epfd) limits in the Ka and Ku frequency bands create a huge stumbling block for the growth of NGSO broadband systems. This framework, which is found in Article 22 of the ITU’s Radio Regulations, limits the amount of energy a satellite can emit when it transmits data and requires NGSO satellite operators to essentially “turn-off” other satellites. In other words, these regulations force NGSO systems to throttle back their services to provide connectivity. The ITU adopted these limits more than 25 years ago when NGSO satellite technology was in its infancy and spectrum management looked very different.

The ostensible purpose of epfd limits is to allow NGSOs to operate without causing harmful interference to Geostationary satellite orbit (GSO) satellites. In practice, however, epfd limits increase costs for consumers, decrease available capacity, and result in inefficient use of spectrum by preventing NGSOs from activating their satellites over large geographies. 

These limits impose restrictions on NGSO systems beyond what is necessary to protect incumbent GSO systems. In fact, epfd limits are the single greatest operational restriction for NGSO systems. In effect, epfd limits have evolved from a technical framework into a protectionist barrier that inhibits competition in the market for delivering broadband connectivity.

ITU Member States need to consider modern system characteristics and spectrum management techniques for efficient and equitable use of spectrum for NGSO systems. This is entirely aligned with the ITU’s goal of efficient use of shared spectrum resources.

A recent economic analysis by former Commissioner of the U.S. Federal Communications Commission (FCC) Dr. Harold Furchtgott-Roth found that updating epfd limits would create a profound economic impact worldwide — welfare benefits to customers ranging from $10 billion to $100 billion or more. And it would most benefit the billions of people without any internet access, those who need broadband access the most.

A separate engineering study showed that improving epfd limits could increase broadband capacity by up to 180%. The analysis indicates that modernizing these limits would improve connectivity while also lowering costs for enterprises and customers alike.

WRC: The Opportunity for Change

Because the epfd limits are part of the ITU Radio Regulations, they can only be changed by WRC action. To be able to study and potentially update epfd rules, Member State delegations will need to adopt a future agenda item (FAI) at WRC-23.

Agreeing to the FAI commits the ITU Member States to studying the spectrum bands where epfd limits apply and developing potential updates. Then, based on the results of those studies, the ITU will make recommendations, as appropriate, for addressing epfd limits in time for the next World Radiocommunication Conference, WRC-27.

There is growing pressure from industry and non-governmental organizations to make this happen. A new group called the Alliance for Satellite Broadband launched in October with the sole focus of advocacy around updating epfd limits. The group includes Amazon and a collection of leading think tanks all seeking to expand access to broadband connectivity by modernizing restrictive global regulations.

Amazon and SpaceX both have separately expressed their support for the FAI. Last week, the companies also filed a joint letter asking for the FCC’s continued support on the future agenda item at the meeting in Dubai.

There is also growing support for an FAI among ITU Member States. The countries of the Americas, through the body CITEL, collectively submitted an Inter-American Proposal in support of the FAI. Countries from the Asia-Pacific and African regions have filed multi-country proposals in support as well, while other countries throughout the world have expressed their intention to support the FAI over the course of negotiations.

WRC-23 offers a chance to get the rules right. Epfd limits should be based on what our NGSO systems and spectrum management principles look like today and not what they looked like in 1997. With better methods, we can continue to protect GSOs from unacceptable interference while enabling more global broadband connectivity. An agreement at WRC-23 in support of a future agenda will bring us one step closer to bridging the digital divide.

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