ITU WRC 2023 - Call to Modernise international satellite rules

ccianet.org • Europe Hub • @CCIAeurope Brussels, 2 November 2023 Modernising international satellite rules to support Europe’s future economic security and achieve digital targets As the 2023 World Radiocommunication Conference (WRC-23) approaches, we are seeking your support for a future agenda item (FAI) with important implications for the future of your citizens’ and businesses’ connectivity. Since the launch of the Digital Decade Policy Programme in 2022,1 the European Commission recently concluded that we are far from achieving its ambitious connectivity targets.2 It is increasingly clear that we are at a crossroads and that a successful outcome will require summoning all broadband technologies available. Amongst these, the EC has recognised the ability of Low Earth Orbit (LEO) satellite communications to provide high speed Internet in areas where networks are still unstable or unavailable.3 Like other wireless communications systems, satellites require the use of spectrum to operate. Currently, the spectrum used by LEO constellations is subject to equivalent power flux-density (EPFD) limits, with the aim of protecting existing geostationary orbit (GSO) networks from potential interference. Set more than 25 years ago, these limits are outdated and unreasonably restrictive on LEO constellations because they do not account for the latest technological developments and spectrum management techniques. This is why we believe that modernising EPFD limits while continuing to protect the GSO networks, would have tremendous positive impacts for citizens and businesses worldwide. Modernising the EPFD limits will allow LEO constellations to increase capacity and serve more customers using existing satellites, reducing their manufacturing, launching and managing costs and benefiting consumers and new entrants (including smaller constellations).4 More affordable satellite-based broadband will be particularly valuable for citizens and businesses in rural and remote areas, where fibre deployment reportedly does not yield sufficient return on investment according to some incumbent telecom operators.5 According to a study for the European Commission, using alternative technologies to reach 1 Decision (EU) 2022/2481 of 14 December 2022 establishing the Digital Decade Policy Programme 2030: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022D2481 2 The European Commission finds that fibre networks only reach 56% of households whereas high-quality 5G stands at 41% of the Union’s population. See first report of the DDPP: https://digital-strategy.ec.europa.eu/en/library/2023-report-state-digital-decade 3 Summary Report on the results of the exploratory consultation on the future of the electronic communications sector and its infrastructure: https://digital-strategy.ec.europa.eu/en/library/results-exploratory-consultation-future-electronic-communic ations-sector-and-its-infrastructure. Additionally, during the press conference following the informal ministerial meeting on telecommunications in León on the 23-24 October, Commissioner Breton noted that “not all areas will be covered by fiber, and for this reason we have proposed a new satellite infrastructure, including low, medium and geostationary orbit to encompass the entire territory”. 4 The Economic Benefits of Updating Regulations that Unnecessarily Limit Non-Geostationary Satellite Orbit Systems, Harold Furchtgott-Roth (August 13, 2023): https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4538619 5 E.g. Le 100 % fibre est-il un objectif atteignable en France ?, ZDNET (October 18, 2023) https://www.zdnet.fr/actualites/le-100-fibre-est-il-un-objectif-atteignable-en-france-39961920.htm Rue de la Loi 227, First Floor • 1040 Brussels • Belgium pg.1  ccianet.org • Europe Hub • @CCIAeurope these areas could save European taxpayers more than €11 billion6 but, to materialise, we need to ensure the right conditions for LEO constellations, including appropriate EPFD limits. LEO satellite constellations are also part and parcel of Europe’s ambitions to ensure an open strategic autonomy. In October, the European Commission identified LEO constellations as one of ten critical technologies for the EU’s economic security7 and Europe is in the process of developing its own constellation for enhanced communication capacities (IRIS2).8 Furthermore, with the recent public consultation on an EU Space Law, the EU has reiterated its commitment to avoiding potential congestion in Space.9 Ensuring appropriate EPFD limits will reduce the number of LEO satellites in orbit and their cost, supporting Europe’s objectives in these areas. For the above reasons, we urge you to support the inclusion of a future agenda item on EPFD limits under Agenda item 10, recommending to the Council items for inclusion in the agenda for the next WRC, and items for the preliminary agenda of future conferences, in accordance with Article 7 of the Convention and Resolution 804 (Rev.WRC-19). Sincerely, Daniel Friedlaender Senior Vice President & Head of Office, CCIA Europe 6 Investment and funding needs for the Digital Decade connectivity targets, WIK-Consult (July 12, 2023): https://digital-strategy.ec.europa.eu/en/library/investment-and-funding-needs-digital-decade-connectivity-t argets 7 Commission recommends carrying out risk assessments on four critical technology areas: advanced semiconductors, artificial intelligence, quantum, biotechnologies, press release (October 3, 2023): https://ec.europa.eu/commission/presscorner/detail/en/ip_23_4735 8 IRIS²: the new EU Secure Satellite Constellation, EC information page: https://defence-industry-space.ec.europa.eu/eu-space-policy/iris2_en 9 Targeted consultation on an EU Space Law: https://defence-industry-space.ec.europa.eu/targeted-consultation-eu-space-law_en#:~:text=The%20Letter %20of%20Intent%20includes,of%20space%20activities%20and%20operations Rue de la Loi 227, First Floor • 1040 Brussels • Belgium pg.2 Saatja: <=?utf-8?Q?T=C3=B5nu_Nirk?=> Saadetud: 02.11.2023 10:11 Adressaat: <"MKM info"> Teema: FW: ITU WRC 2023 - Call to Modernise international satellite rules Manused: CCIA Europe letter - Modernising international satellite rules.docx.pdf Paluks mulle ja Silverile teadmiseks. Tänud. Tõnu From: Daniel Friedlaender <[email protected]> Sent: Thursday, November 2, 2023 10:00 AM To: Tiit Riisalo <[email protected]>; Tõnu Nirk <[email protected]> Cc: Daniel Friedlaender <[email protected]>; Maria Teresa Stecher <[email protected]> Subject: ITU WRC 2023 - Call to Modernise international satellite rules Dear Minister Riisalo, dear Mr Nirk, I hope this email finds you well. As the 2023 World Radiocommunication Conference (WRC-23) approaches, we are reaching out to respectfully draw your attention to the issue of equivalent power flux- density (EPFD) limits, and the need for a review of these limits. As explained more in detail in the attachment, a revision of these limits will ensure more accessible and affordable satellite connection for citizens, would benefit the industry, and would help the European Union to reach its ambitious Digital Decade connectivity targets. We are thus seeking your support for the inclusion of a future agenda item on EPFD limits under Agenda item 10, recommending as well to the Council items for inclusion in the agenda for the next World Radiocommunication Conference in 2027. We trust you will take full consideration of the enclosed letter, and remain at your disposal should you desire any further information on the issue. With thanks and best regards, Daniel Friedlaender -- Daniel Friedlaender Head of Office [email protected] M: +32498255156 Computer & Communications Industry Association (CCIA Europe) EU Register number: 15987896534-82 ccianet.org | @CCIAeurope