The Compliance Issues with Regard to the Registration Procedure of Satellite Constellations

Large constellations, especially at low-Earth orbit, have become a popular solution for global telecommunication. With the proliferation of prospective constellations, more and more satellites will be launched and deployed in the future, which challenges the regulatory framework from several aspects. In the last decades, the International Telecommunication Union (ITU) has established a regulatory framework of space radiocommunication systems for the purpose of securing rights and protection from technical harmful interference of subsequent networks. The well-known steps in the Radio Regulations include the advance publication of information, coordination, notification, and recording of frequency assignments in the Master International Frequency Register. The network registration procedure ran well with the conventional geostationary-satellite orbit (GSO) and non-GSO satellites until the emergence of large constellations. The scope of this paper is to introduce the current approach for ITU to regulate the registration of large constellations and point out the underlying issues. Three issues come from unclear provisions. The first one is whether a non-GSO network can be kept active with fewer satellites on orbit after bringing into use and the milestone requirement. The second issue is whether a non-GSO satellite can be used for bringing into use of different networks. The third issue is whether there should be an error tolerance for the notified orbital parameters in practice. Possible solutions such as postmilestone procedure and tolerance of orbital parameters are discussed. The chance for both ITU and Committee on Peaceful Uses of Outer Space (COPUOS) to explore the potential was also analyzed to implement mutual reference for constellation registration. Furthermore, if the collaboration of the 2 regimes going deep, it could also explore to build up a one-to-one mapping database to figure out the relationship between Master International Frequency Register fillings with actual deployment of large constellations in space.