On 15 March 2022, Ofcom published a proposed Space Spectrum Strategy (Strategy) for consultation. The Strategy replaces an existing Space Spectrum Strategy published by Ofcom in 2017 and specifically sets out practical work actions Ofcom will focus on over the next two to four years.

Due to the essential nature of spectrum to the space sector, Ofcom’s Strategy will be relevant to any space sector company with ground-based infrastructure in the UK, or with plans to establish such infrastructure in the UK.

This article sets out:

  1. the importance of Ofcom’s Space Spectrum Strategy;
  2. why Ofcom is publishing a new Space Spectrum Strategy; and
  3. an overview of the main actions proposed by Ofcom as part of its new Space Spectrum Strategy.

The importance of Ofcom’s Space Spectrum Strategy

Ofcom, as the communications regulator for the UK, is responsible for the management of spectrum, including ensuring the efficient use of spectrum. Ofcom’s responsibilities include:

  1. representing UK interests in relation to spectrum allocation, in accordance with international processes (i.e identifying which frequencies can be used and what those frequencies can be used for);
  2. establishing processes for authorising the use of such frequencies, through the issuing and management of licences and license exemptions; and
  3. managing ongoing use of spectrum by way of imposing conditions on licences, and conditions for licence exempt use.

Spectrum is a fundamental element to any space operations, being used to facilitate wireless communications between Earth and space for satellite communications, satellite broadcasting, Earth observation and radio astronomy. Spectrum is also used by launch operation equipment, and more broadly in Earth observation activities for “sensing” natural phenomena.

Ofcom’s Strategy sets out:

  1. how Ofcom will manage radio frequencies used by the space sector, looking specifically to spectrum management issues relating to: (a) spectrum access; and (b) efficient use, sharing and assurance; and
  2. specific work actions Ofcom will be targeting over the next two to four years.

On the above basis, Ofcom’s proposals will have real practical impacts on space sector operations, and Ofcom’s support will be essential to whether emerging space technologies and deployments using spectrum, or novel uses of spectrum, will be possible, or not.

Why is Ofcom publishing a new Space Spectrum Strategy?

Ofcom’s Strategy seeks to refresh an existing Ofcom space spectrum strategy published in 2017. The 2017 strategy focused on enabling growth in satellite broadband and Earth observation. However, the way spectrum is used by the space industry is constantly evolving as:

  1. technologies that use spectrum continue to develop and pose new challenges for spectrum management;
  2. new technologies develop that can make uses of frequencies not traditionally used by the space sector;
  3. international regulations relating to the use of spectrum evolve and develop, such as through decisions at ITU World Radio Conferences (WRCs); and
  4. as business needs for spectrum change.

Ofcom is updating its Strategy in response to several changes to the space sector, and how spectrum is used and will need to be used.

What actions is Ofcom proposing?

Ofcom’s work actions are focused on “spectrum access” (relating to access to spectrum) and “efficient use, sharing and assurance” (relating to spectrum sharing and continued spectrum access).

Ofcom has split its proposed work actions across four main areas:

  1. communications;
  2. Earth observation and navigation;
  3. activities that facilitate understanding and enabling access to space; and
  4. NGSO issues.

Below, we briefly summarise some of the main proposals for Ofcom in each of the four work areas noted above.


Ofcom’s work actions relating to communications touch on several areas including ESIMs, satellite to mobile phone technology, IoT applications.

  • Ofcom will develop proposals for future use of the 14.25-14.50 GHz band for uplink, including use by user terminals.
  • In response to plans by future satellites to use the Q/V bands, Ofcom will develop an approach to licensing Earth stations in Q/V bands and higher frequencies.
  • Ofcom plans to update ship, aeronautical and network licences for “Earth stations in motion” in Ku and Ka bands. This includes potential extension of licences to permit ESIMs in the 14.25 – 14.5 GHz band, and review of arrangements for ESIMs in the 27.5-30 GHz band.
  • In respect of technologies proposing direct communication between satellites and mobile phones and other terrestrially based devices, Ofcom will monitor developments, but confirms its preference is for satellite services to transmit in satellite allocated frequencies. Ofcom will monitor developments in respect of the use of non-satellite allocated bands for such communications.
  • Ofcom will monitor identification of new frequency allocations for narrowband mobile satellite systems suitable for IoT applications, but does not propose to make any new allocations at present.
  • Ofcom will determine protection criteria for fixed satellite services (i.e in respect of two services, how much interference one service is expected to accept from the other).

Earth observation and navigation

Ofcom is proposing a number of work actions in respect of Earth observation and navigation.

  • Ofcom will consider matters relating to protection of downlink sites for Earth observation data, specifically in respect of the 26 GHz band and 8 MHz band.
  • Ofcom will consider inter-satellite links and spectrum that may be allocated (which Ofcom notes is most likely to be in the Ka band under existing fixed satellite service allocations).
  • In respect of spectrum access for climate change monitoring and weather forecasting, Ofcom confirms support for WRC-23 agenda item (AI) 1.12 and AI 1.14, which would allocate spectrum at 45 MHz for active Earth observation satellite services (EESS) and 231.5 – 252 GHz for passive EESS (respectively).
  • Ofcom will work with the UK government to understand potential spectrum requirements relating to the UK Government’s consideration of investment in Position Navigation and Timing capabilities.
  • Ofcom will continue to protect spectrum used for Earth observation measurements, while balancing the needs of Earth observation against new communications services in the same bands (including 5G and future services using terahertz bands).
  • Relevant to Earth observation sensors, Ofcom will propose updates to the ITU-R Recommendations dealing with EESS system characteristics.
  • Ofcom will continue to engage in ITU-R work to find a solution to efficient use of the S-band for tracking, telemetry and control, through developing a new Recommendation on the optimal use of the S-band.
  • In respect of existing positioning, navigation and timing systems, Ofcom confirms that manufacturers should use more robust GNSS receivers to ensure resilience against out of band interference, and that Ofcom will not generally take action in respect of out of band interference.

Understanding and enabling access to space

Ofcom has specifically proposed work actions relating to activities supporting and enabling the use of space, e.g space launch and managing the safe use of space.

  • Ofcom will lead development of regional European policy for WRC-23 agenda item 9.1A, for development of an international regulatory framework for space weather spectrum access (space weather, being the physical conditions in the space environment).
  • Ofcom confirms that spectrum authorisations needed for spaceflight from the UK will be managed through Ofcom’s existing processes, rather than the creation of new licences.
  • Ofcom confirms support to create an international framework for communications to and from sub-orbital vehicles (i.e flights to the edge of space, for research and space tourism purposes) under Agenda Item 1.6 of WRC-23.
  • Ofcom will consider appropriate access to spectrum for radars to track movements of objects in space, relevant to enabling safe use of space. Ofcom will also engage with the CAA and UK Space Agency in relation to physical risks from space debris.
  • Ofcom will make proposals for the protection of radio astronomy sites as a result of preparing to authorise future outdoor wireless broadband services in the 26 GHz band and proposals to consider new licence conditions in NGSO system licences to ensure protection of radio astronomy. Ofcom will engage with the CEPT and ITU in developing appropriate solutions to protect radio astronomy sites in the UK and abroad from satellite emissions.

Non-geostationary orbit (NGSO) system issues

In December 2021, Ofcom published a statement on changes to the licensing process for NGSO system licences, as well as introducing several new conditions for NGSO licences. Such changes were in response to the growing number of NGSO systems seeking to deploy constellations of up to thousands of satellites.

In the Ofcom Strategy, Ofcom proposes further work to address ongoing “challenges” raised by NGSO systems for spectrum management (in particular, the risk of interference). Such work actions include:

  • Considering updating existing licences that authorise the use of earth station terminals in conjunction with NGSO satellites, so as to authorise use of frequency ranges to include those that are already available for use by earth station terminals communicating with satellites in geostationary orbit.
  • Supporting work on WRC-23 Agenda Item 1.16 in relation to NGSO ESIMs.
  • Engaging internationally in efforts to address the shared use of spectrum by NGSO systems.
  • Developing Ofcom’s national interference monitoring capabilities and promoting development of a globally harmonised approach to handling interference through ISRMM and the ITU.
  • Considering extending NGSO licensing to additional spectrum bands (e.g 14.25-14.5 GHz).
  • Considering updates to Satellite Earth Station licence fees, to reflect opportunity cost. This is a deviation from the current fee model used, which is based on administrative cost only.
  • Introducing licence terms to put conditions on NGSO downlink and develop Ofcom’s capabilities to handle NGSO to GSO interference.
  • Engaging in studies on sharing between NGSO ESIM on aircraft and ships and fixed links.
  • In respect of MSS NGSO communication systems below 1 GHz, considering moving national authorisation from exemption to light licensing, supporting reform of the CEPT framework for MSS systems below 1 GHz, and monitoring WRC-23 agenda item for new MSS allocations.

Cross cutting actions

Ofcom also proposes a number of actions which are relevant across several work areas.

  • Ofcom will work to identify frequency and authorisation options relevant to new cubesat/smallsat applications.
  • Ofcom will consider greater use of network licences in the space sector, as opposed to licence exempt use.
  • Ofcom will consider additional conditions on UK authorised equipment to manage the potential for interference from satellite downlink signals.


Consultation responses will be accepted by Ofcom until 5pm on 24 May 2022.

DLA Piper continues to monitor updates and developments relating to Ofcom’s Space Spectrum Strategy. For further information or if you have any questions please contact the authors or your usual DLA Piper contact.