Today, the International Telecommunications Union (ITU) is facing a growing challenge due to the emergence of broadband satellite megaconstellations. Founded in 1865, the ITU, originally known as the International Telegraph Union, was an intergovernmental body established to facilitate global communication through international frameworks and standard operating procedures. Throughout its history, the ITU has adapted in tune with the technologies du jour, drafting international legislation for telephony by 1885 and for radio communications by 1906. Today, the ITU supports the international space system by coordinating satellite orbits and overseeing the global allocation of radio frequencies.
Similar to its previous adaptations amidst historic technological shifts, the ITU needs to adjust its radio frequency (RF) assignment approach to better consider the variability in space capability across countries. To this end, the ITU should consider implementing an RF cap and trade system to ensure long-term access to space for less mature spacefarers.
We can think of radio frequencies as a finite set of many roads that enable cars of data to transfer between satellites and Earth. When there are relatively few satellites in orbit, there is enough available frequency for all interested parties to simultaneously transfer data. However, the rise of broadband internet-providing satellite megaconstellations from companies such as SpaceX, OneWeb, and Amazon significantly complicates this coordination task. With each project containing hundreds to thousands of satellites—equivalent to radio frequencies in rush hour traffic—the ITU’s role in satellite management is increasingly challenging.
Further complicating the coordination problem is that operating within the space domain adds uncertainty to every part of the decision-making process. Space missions are difficult, expensive, and time-intensive. While an entity may feel confident in its technical and management abilities, even a minor disruption, such as a funding or supply chain issue, or an engineering setback, can delay large-scale missions by years. Still, space operators need to know that they will have access to available frequencies for their technologies once they launch. To accommodate this, satellite operators can apply for frequency allocation from the ITU and secure the industry term “warehouse” for retaining the allocation for seven years before their expected deployment date. As such, frequency allocation planning is done under the uncertainty of what missions will actually launch.
When the relative demand for frequencies was low, these challenging aspects of the space industry were of little concern to the ITU’s allocation process; if a project was perceived as legitimate when first allocated RF but later ran into troubles, the ITU honored its past allocation. Yet, given the dramatic increase in satellite launches in recent years, the ITU now requires operators to substantiate their allocation claims to prioritize the most feasible space projects.
Specifically, while operators are still granted seven years to develop a project after receiving frequency allocations from the ITU, since 2019, there have been subsequent milestones that certain non-Geosynchronous orbit projects, including Low Earth Orbit broadband constellations, must reach to avoid significant reductions in their RF allocation. Two years after the regulatory seven-year period, missions must reach 10 percent operational satellite deployment; after five years, 50 percent is required; by seven years post regulatory period, 100 percent minus one satellite is expected.
The increased ITU accountability requirements will likely help prevent unrealistic projections. OneWeb, for example, drastically overprojected its proposal to the Federal Communications Commission (FCC) and subsequently reduced the number of nearly 48,000 satellites to around 6,000 after about a year. Still, there is a pressing international component to this problem. Due to the first-come, first-served nature of its RF allocation process, the ITU is, in effect, heavily favoring developed space economies, risking that the limited resource of frequency bands will become too saturated, while more nascent space-faring countries can produce constellations.
Take China, for example. Multiple scholars in the country, as well as some government and military officials, are concerned about the prevalence of Starlink, viewing it as a potential military and political risk. To address this security concern, China has sought to subsidize a domestic broadband constellation, Qianfan and Guowang, in response to Starlink. However, significant issues with faulty satellites and low launching capacity mean that reaching 10 percent of the 28,000 expected satellites for both projects by 2026 is a near-impossible goal. Per the 2019 ITU regulation, when this goal is not reached, the ITU can significantly reduce China’s frequency allocation. Further pressing for China is that at the same time as this looming setback, SpaceX already has over 8,000 operational Starlink satellites, a consistent launch cycle, and plans for a constellation of 42,000 satellites in total.
China is not the only case. As more countries mature in space and seek to develop their constellations, strain will be placed on the status quo system. While no direct mention of the ITU, French President Emmanuel Macron recently expressed explicit concern about remaining competitive in the constellation market, suggesting plans to develop parallel domestic capacity. The European Union has taken more tangible steps with plans to develop a 290-satellite constellation called Infrastructure for Resilience, Interconnectivity and Security (IRIS).
As it stands, the ITU is a non-enforcing body that states obey out of self-interest; in exchange for their compliance, the ITU protects them from interference by other states. Once this status quo is no longer useful, states will have limited incentive to utilize only the frequencies they have been allocated. For one example, China might decide that the payoffs of building its own megaconstellation outweigh the benefits of following ITU regulations. Such a decision would destabilize radio frequency optimization processes, yielding fragmented communication and signal interference. It is important to note, though, that this unruly behavior would not be due to reckless disregard for international norms but instead a consequence of incentives from a system that prioritizes currently developed space operators and unintentionally limits aspiring ones.
Thus, while any specific policy change for the ITU will require both legal and technical precision as well as nuance to avoid exploitation or bad-faith warehousing, the ITU’s present rule structure is not equipped to handle the realities of emerging space countries, which will need access to frequencies that are already allocated. As a potential solution, the ITU could grant guaranteed frequency allocations to member states today, preserving states’ ability to harness RF until they are technologically equipped to launch their own larger-scale projects, like megaconstellations. If the ITU acts soon, this policy should not require redistributing previously allocated frequencies. Further, regarding concerns about reducing progress today for increased equity, states should be able to sell frequency permits, allowing the most efficient operators to still buy and utilize the RF access they require. Through revenues from permit sales, such a system would even support less developed, non-space-faring states that do not seek space to harness technologies. Regardless, the current system of frequency stratification needs reconsideration to properly account for future strain from megaconstellations.