FAQ: Coordination

Answer

Coordination is required for any satellite network because satellite beams are large when compared to most terrestrial based services, creating more opportunity for the transmissions to cross a national boundary or interfere with localized services in the same country.  Secondly, almost all satellite spectrum is shared with terrestrial or other satellite services which could cause or receive interference. Coordination is the process by which such interference is minimized.

For coordination with international services, the ITU will determine the systems an operator must coordinate with on the basis of the ITU filing.  Within the US, coordination typically depends on other co-primary users in the band.  Coordination of non-federal government systems is conducted by the FCC during the grant stage for satellite-based operations, or through a third-party spectrum coordinator in the case of earth station operations.  For federal government systems, pre-coordination with NTIA is strongly encouraged in certain frequency bands in addition to the pre-grant coordination that is done by the FCC during the grant process. Please see Informal Satellite Frequency Coordination ("Pre-Coordination") for more details of the pre-coordination process.

Answer

Coordination of a new satellite network officially begins when an administration (such as the FCC) submits an Advanced Publication Information (API) or Coordination Request (CR/C) to the ITU. Therefore, the first step in coordination is to make and submit an ITU filing to an administration. The purpose of coordination is to enable administrations and operators interested in providing satellite services to exchange information, analyze potential interference scenarios and develop solutions that will allow their existing and planned satellite networks to operate without causing harmful interference to one another.

Answer

The United States has a responsibility to supervise the activities of its licensed space stations, including coordination with other administrations. That supervision is facilitated by operating US-licensed space stations pursuant to US-ITU filings. Accordingly, the FCC has routinely asked applicants wishing to operate under a US license to also submit US ITU filings for the operations, even in the presence of additional non-US ITU filings. If you have a pre-existing non-U.S. filing, we will in some instances agree to a bringing into use or maintaining in use that filing, based on a case-by-case determination.

Answer

First consult this Space Bureau Transparency Initiative webpage: How to Prepare a U.S. ITU Filing  

In summary, to make an ITU filing, you will need to obtain an ITU network name and the latest version of ITU software.  Once you have downloaded, and ensured you have the latest version of ITU software, open SpaceCap and begin capturing the required filling information.  You will use the ITU network name assigned to you. Once the filing is complete, run the validation software (SpaceVal) to ensure that no fatal errors exist. If there are fatal errors, correct them and revalidate until there are none.  If the errors are due to the type of system being requested, a detailed explanation of why these errors exist is required. 

Once the package is complete (i.e. the filing, the GIMS information, the FCC ITU Filing Cover Letter and in the ITU Cost Recovery Letter) email them to both joseph.hill@fcc.gov and . To avoid issues with the Commission computer network, please change the file extension on the filing/GIMS database file(s) from .mdb to .int and if you use a .zip file, you will need to change that extension to .abc. To receive confirmation that the Bureau received your package, we recommend sending a second email afterwards, without attachments, notifying the Bureau that the previous package was sent.

Answer

Appendix 4 of the ITU Radio Regulations provides the detailed filing information required in the ITU filing. ITU software (e.g. SpaceCap, SpaceVal, GIMs) is also needed to include the required information in the filing database and ensure that no fatal errors exist. The information required by an ITU filing is similar to that needed in the Part 25 application.

Answer

Yes, the ITU charges an ITU cost-recovery fee for each of the required filings, except for any special section that the ITU publishes a a result of the comment period. 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.

Answer

A filing may be cancelled within 15 days of submission to the ITU. To do this, a licensee would send a written request via email to Joseph Hill and Kathyrn Medley  asking for the cancellation. Please include a draft letter requesting the cancellation to speed our processing time. This should be done as quickly as possible, but no later than 10-days, after the submission of the complete filing package. In this case, there will be no cost recovery fees assessed by the ITU. After this 15-day period, a filing may still be cancelled but the full cost recovery fees are due to the ITU.

Answer

Once an administration submits and ITU filing (.mdb file) to the ITU, and the BR receives the filing, it cannot be modified without the submission of a formal ITU modification filing. To create a modification, an applicant must create and validate a new .mdb filing with the revised parameters and a cover letter that clearly indicates the specific changes. Then, the applicant should similarly follow the instructions for submitting an ITU filing.

Answer

The Commission reviews ITU filings to make ensure the frequencies and the technical parameters such as the orbital and beam characteristics are consistent with the underlining application. The Commission also validates the administration information including the “operating agency code” and runs SpaceVal on the SpaceCap file to confirm that no fatal errors exist.

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The Commision may correct minor or non-substantive errors. However, for more substantive errors the Commission will inform the applicant and request correction of such errors in a timely manner.

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Under these scenarios, the ITU normally informs the Commission through a letter/telefax of the questions or determination including the area of the filing that would lead to an unfavorable finding. The Commission will then forward that letter to the applicant and request a draft response, including any correction necessary to make the filing acceptable to the ITU. The Commission will then use the draft response from the applicant/licensee to prepare a letter back to ITU to bring the filing into good standing.