This is a position piece produced in collaboration with ground station network provider and satsearch member Leaf Space.
A satellite mission requires two forms of license – one for the space hardware and applications, and the other for the ground segment.
In this article we discuss some of the common challenges that can occur in the ground station licensing process and look at ways to overcome or mitigate each of them.
Introduction to ground segment licensing
We have previously discussed the factors that need to be taken into account when deciding whether to set up a new ground station for your mission or to use an existing network.
One of the major considerations mentioned is the licensing process. Each space and ground segment that will be launched or operated as part of the mission requires proper licensing to govern the mission purpose, spectral band use and other requirements.
Proper licensing is one of the pillars of a successful mission and it requires a clear and professional approach in order to make sure the mission is compliant and not to cause any costly delays.
These are activities that Leaf Space’s regulatory unit manages for its own ground station operations, while it can also manage or provide guidance on the corresponding licensing work for its clients’ satellite missions.
Leaf Space simplifies ground segment licensing requirements by operating a network of existing stations that customers can access.
The regulatory aspects of a satellite mission can take more than two years to fully complete. It is a multi-stage process that will involve ongoing liaison with different regulators for the space and ground segments.
The process is typically overseen by in-house counsel, an employee with a legal background or a radio engineer with experience in regulatory matters. In addition, a third-party who is closely collaborated with on the mission coordinator’s behalf may also be contracted.
Many companies underestimate how long license acquisitions can take. If initiated too late in the mission planning process, when there isn’t enough time before launch to gain full compliance, there can be very disruptive and costly delays caused by re-scheduling.
Prepare early and you’ll put your mission in the best possible position. The licensing application process isn’t as daunting as it can seem; regulatory staff are very approachable and accessible, and regulatory procedures are quite standardised across countries and work well.
Timing is dictated by a few factors such as:
- The quality and completeness of your license application,
- Whether extensive coordination with other parties is required,
- The time it takes to process fees, and
- International Telecommunication Union (ITU) processes for both the ground and space segment.
The latter point can often be the main cause of long licensing timelines. The ITU is a specialised agency of the United Nations (UN) in charge of the international coordination and regulation of communication and information technologies. It plays a fundamental role in mission authorisation procedures, though these do take time.
Following a successful application the ITU will assign your mission the radio spectrum as required, but this process can take two years to complete, though it can be shorter or longer. Though at the extreme end of the range, the ITU processes may take up to a maximum of seven years.
Although the ground segment licensing at the national level can be completed quicker (in Italy for example the process is expected to take around six months for this aspect), the space segment procedure before the ITU must reach a certain stage before the ground station license may be applied for; in particular, an API/A must be published and visible in the ITU’s records. The submission of the data necessary for the API/A and its subsequent publication represent the first major milestones in the space segment licensing process overall. Timing of licensing activities is therefore mainly dictated by ITU requirements.
Once these factors are taken into account it also helps to have local representation in order to make the ground segment license acquisition as seamless as possible. If licensing your ground segment in the country in which your company or staff are located, this is of course not a problem; when applying for licensing in a different country, it may in some cases be helpful to identify local support who can communicate on your behalf with regulatory staff.
Leaf Space’s Leaf Key service enables simplified compliance with stringent requirements for capacity, latency, data transfer paths and cost-effectiveness.
Location, location, location
When taking a broad view of the topic, the regulatory frameworks for licensing across countries are relatively similar; they differ however in the details, so it is important to research and understand what the rules are in the territory in which you intend to operate.
The availability of information online about the licensing processes established in different countries can also vary - particularly concerning the base regulatory instruments that establish or influence the licensing framework and/or official guidance on navigating the application procedures.
All member states of the European Union (EU) and the United States of America (USA) for example have quite in-depth and transparent information readily available online including the basic legislation, regulatory instruments, and regulatory guidance texts. It is possible to quickly identify and pull up the foundational legislation on which the regulatory telecommunications frameworks are based and understand how this applies to current licensing conditions.
In other countries, the information provided can sometimes be more opaque and difficult to access. As a starting point for those exploring the regulatory frameworks in certain countries the ITU has a list of notifying bodies in different countries available at this page.
It certainly helps if you can utilise local expertise or personnel in those countries in order to make the process simpler. Direct contacts and relationships will help address language barriers, smooth the process of providing hard copy forms and materials, ensure you abide by local customs and simplify country-specific financing and administration.
Engaging with national regulators can sometimes require more informal communications alongside the provision – through formalised procedures – of accurate paperwork and detailed specifications on mission requirements.
You may also benefit from contact with ancillary organisations. In the USA for example, a company wishing to begin operations in the S-band will need to first assess and discuss coordination matters with the Society of Broadcast Engineers (SBE). This is an organisation that, among other activities, operates a network of knowledgeable volunteers responsible for different regions of US states. If you want to propose new uplink activity in the S-band from US soil you need to liaise with the SBE coordinator for the region where you will operate. The coordinators are very helpful and will provide up-to-date advice.
It is very beneficial to have initial discussions with national regulators about your plans and requirements, and discuss any concerns or comments they may have, prior to actually submitting official applications. Such conversations are also very useful for setting a positive rapport. However, an understanding of local administrations and bureaucratic norms can be very important.
Leaf Space has developed relationships with regulatory authorities throughout the Europe region, including for example in Italy, Ireland, and Portugal, as well as in key countries at the global level including in the US, Canada, and New Zealand, and it continues to develop these relationships with each new ground station installation. The company also uses local teleport operators and often works with regulatory experts to ensure they can secure ground station licenses for operations in order to provide the best service for clients.
Once timescales and local requirements are understood, the next factor that can affect the licensing process is the scale and nature of the mission itself.
When a mission involves a single company launching one or multiple satellites in a constellation, and it owns its own ground segment in the same country in which the satellite is to be licensed, then the regulatory requirements are relatively simple to meet.
Yes the licensing process still takes time and will require your careful attention to make sure the paperwork is in order, but the basic requirements can be adhered to with relative ease.
However, the space industry is evolving and fragmenting. Launch and development costs are coming down and component and sub-system miniaturisation are allowing more collaborators on each mission. Missions can involve multiple parties and the mission elements can be licensed in multiple countries. This added organisational and operational complexity makes the licensing acquisition process itself more complicated.
Each stakeholder needs to take into account what elements of the ground segment they will operate in the mission in order to assess licensing requirements. It is also important that each collaborator understands what licenses the others will hold and what they will cover.
When multiple stakeholders are involved in a mission no individual actor would hold a license that covers the entire system. When different companies or actors are responsible for different elements, they will hold the license(s) for their respective elements’ communications. In such cases, all actors should provide in each of their own applications a global description of the mission operations including detailed explanations regarding the other parties and the mission elements for which they are responsible.
For both the earth and space segment licenses there are fees to be paid, which in some cases may also cover the initial processing of the application. License fees may be applied annually to maintain a license’s validity for the length of long-term operations or a fee may be issued once to cover a shorter mission period such as in the case of an experimental mission.
The actual licensing fee costs will vary depending on country, license type, and operational parameters including for example bandwidth used or the number of earth stations employed; by “type” we are referring to either a commercial license or an experimental license (note that these will have similar, but different names in different countries).
A long term commercial ground segment license can cost in European countries from approximately 2,000 to several thousand euros in total annually.
In the USA, the regulatory framework is a little more complex and the fees can be much higher for long term commercial licensing. In general, the license acquisition process in the US can take longer, while it can also be more procedurally intensive.
Licensing fees for ground stations have very strict payment deadlines, so ensure full financing is available in order to meet the stated deadlines for any payments due. However, as mentioned above, a less costly alternative to commercial licensing is to apply for experimental licensing, which is possible if certain qualifying conditions can be met.
It is often possible to acquire this shorter-term license format providing you can demonstrate the mission is experimental in nature, involves the demonstration of a new technology and/or features novel use of existing technology or techniques.
An experimental license is usually cheaper, faster and easier to acquire, particularly for the ground segment. Do note however that an experimental mission will fly on a strictly non-interference basis and will be required to cease operations if and as soon as interference is experienced by another established operator and the experimental mission licensee is made aware of it.
Commercial missions using mature technology would not qualify for an experimental license but in-orbit demonstration (IOD) services may be able to. For any particular mission, it is strongly advised to initially consult with the regulatory staff to determine if it qualifies for the scope and conditions of the experimental licensing programme.
It can be much quicker to secure an experimental license, however it is important to note that you will still need to abide by ITU guidelines which may take some time to comply with, so build this into your mission plans.
The application process
As you hopefully now appreciate, there is a clear distinction between the licensing of the space segment and the ground segment. If you are managing both from an operational perspective then there is a lot of work to coordinate, but it is achievable if you prepare early enough.
Ensure the schedules don’t conflict - the initial space segment licensing steps need to be taken first as this application is necessary for and informs the ground segment license paperwork.
Although the regulatory frameworks of different countries and the mission’s own requirements will affect the specific nature of the process, the following steps are applicable in most mission scenarios:
Determine whether to apply for a commercial or experimental license.
Hold an initial conversation with the regulator to let them know about all the mission activities and stakeholders involved so they understand the broad scope and plans of the mission. They can likewise use the conversation as an opportunity to offer initial guidance, express any concerns and share useful licensing advice related to the mission operations under discussion.
Determine the exact frequency requirements shortly before you submit the space segment license. Required frequency levels can change in mission planning so it is important that you use the most up-to-date information.
Submit the initial space segment license application to the relevant national notifying body. This is called an API/A and the notifying body will send it on to the ITU. The API/A will contain parameters such as preferred frequency band and number of uplinks/downlinks. It will also include a ‘narrative component’ which explains in non-technical details what is going on in the mission. Your informal discussion in step 2 will have helped inform how this aspect should be developed.
Once the API/A is complete, coordination data on the ground segment may now be submitted.
The ITU will publish your API/A to other notifying bodies within 3 months of receiving it. These bodies then have 4 months to review the submission and provide technical comments if they believe operations in their remit may be affected by your proposed mission. In some instances these may require that a coordination discussion should take place if there are actors who would be interfered. These comments should be addressed and responded to in a second submission.
Once the ITU has collated all of the comments on the API/A it will then publish an API/B that will include the specific coordination requirements (if any) you should address.
The coordination can then be addressed through your notifying body and, once complete, a notification will be sent to the ITU and your licenses will (hopefully!) be granted.
When it comes to licensing a ground station it pays to prepare as early as possible - just like every aspect of a space mission!
If your company is a small startup needing one ground segment system for a simple mission, space and ground segment license acquisition is both achievable and cost-effective. This is particularly true if you can qualify for an experimental license.
However, for more complex needs and for commercial enterprises that need to meet operational scale quickly, there are a lot of steps involved in the compliance.
Such missions and services will require a secure and developed network, a high revisit rate, and advanced data processing at those locations.
Leaf Space is an experienced ground station operator based in Italy founded in 2014, operating an established global ground station network featuring all of these capabilities and helping clients get to market at a lower cost.
The company has built a network of ground segment facilities that are offered to satellite operators on a ground-segment-as-a-service basis. Moreover, since its establishment Leaf Space has handled over 15 ground segment licensing efforts, thus helping secure the ground infrastructure for all clients involved, while also supporting the development of their overall mission capacities.
Given the potentially large investment of resources that must be made when developing and licensing a mission’s ground segment, such services can play a valuable role in helping a young satellite operator get to market faster and start producing revenue sooner.
Find out more about the company’s history, services and expertise here or if you would like to speak to Leaf Space about your specific ground segment requirements, you can contact them through their satsearch supplier page right here.