Header graphic for print
Global Media and Communications Watch The International Legal Blog for the Tech, Media and Telecoms Industry
Posted in Policy & Regulation, Technology Photo of Tony LinPhoto of George John

CSSMA Highlights WRC Advocacy, Earth Station Service Industry

At a recent Commercial Smallsat Spectrum Management Association (CSSMA) meeting, small satellite (smallsat) operators, earth station service providers, Federal agency spectrum managers, and other attendees discussed strategies to effectively influence global spectrum policy through the World Radiocommunication Conference (WRC) and opportunities in the growing earth-station-as-a-service industry. The meeting was part of CSSMA’s ongoing efforts to help develop the smallsat industry by facilitating spectrum coordination and harnessing the industry’s collective voice on pertinent regulatory and policy matters.

The meeting took place in Silicon Valley, California, following the annual SmallSat Symposium. More than thirty-five CSSMA members attended the meeting, along with participants from U.S. regulatory agencies including the Department of Commerce, the Federal Communications Commission (FCC), the National Aeronautics and Space Administration, the National Oceanic and Atmospheric Administration, and the National Telecommunications and Information Administration (NTIA), as well as the International Telecommunications Union (ITU).

WRC Proceedings

Multiple sessions focused on the ITU’s process for developing international spectrum policy through the WRC, which occurs approximately every four years. Three panels offered an overview of the history, structure, and operating practices of the ITU, a report on outcomes from WRC-19 in Sharm-el-Sheik, Egypt, and a discussion of issues being teed up for WRC-23.

The panelists identified three WRC-19 outcomes as being particularly impactful for commercial smallsat systems:

  • Agenda Item 1.2 – Establishing new power limits for earth stations operating in 399.9-400.05 MHz and 401-403 MHz with a ten-year exception that applies to grandfathered operators.
  • Agenda Item 1.13 – Establishing new global allocations for international mobile telecommunications, or terrestrial 5G services, which implicate several bands having space and science applications, including the Ka-band frequencies (24.25-27.5 GHz).
  • Agenda Item 7 – Establishing deployment milestones for non-geostationary satellite orbit Mobile-Satellite Service, Fixed-Satellite Service, and Broadcasting-Satellite Service systems. Previously, a constellation was considered to be in use as long as one satellite was in use. Now, there are build-out requirements. Failure to meet the requirements can lead to the reduction of a constellation’s size.

The panelists offered insight to help companies navigate the WRC process, which involves four years of meetings at the ITU working party level leading up to WRC-23. Panelists emphasized that companies should understand the relationship among agenda items, resolutions, and the various working parties so that they can engage more effectively in policy negotiations. CSSMA members from Kepler and Hiber also discussed their efforts at WRC-19 to push agenda items on spectrum allocations, intersatellite links, and ITU filing notification procedures for WRC-23.

To participate in working party meetings, companies must contact the head of their national delegation for each working party. For the smallsat industry, the relevant working parties are 7B and 7C for science services and 4A and 4C for satellite services. Companies can also work through their national “spokesperson.” For the commercial sector, the spokesperson is the FCC. On the federal side, NTIA is the spokesperson.  The FCC and NTIA have a significant influence on developing U.S. spectrum policy positions in coordination with the State Department.


Participants enjoyed a three-part conversation about the earth-station-as-a-service industry. The companies represented on the panels reflected diverse business models and experience in the industry, but the panelists appeared to agree on several important areas of opportunity for the sector. Incorporation of new technologies, including optical communications and intersatellite links, into the market was a topic of discussion during all three panels. Innovation around operations and process was another recurring theme. Panelists were particularly interested in scalability, geographic diversification, automation, and interoperability. Related to these questions of operational efficiency, there was a thoughtful discussion on striking a balance between standardization and customization, particularly as businesses seek to grow.

During the final session, the discussion turned to regulatory hurdles to obtaining necessary approvals and the importance of spectrum coordination. Panelists emphasized the importance of engaging regulators early and working to educate them about the product and the mission. The desired uses often are not contemplated by the service rules, so an ongoing dialogue is key to success. By creating more opportunities for businesses to expose regulators to their work, CSSMA can be a valuable resource for earth-station-as-a-service companies and other smallsat providers.