Ofcom has released a draft of its proposed Plan of Work for FY 2024-25 for consultation.  

The proposed Plan of Work sets out Ofcom’s key priorities and work programmes for the 2024/25 financial year, and also provides an insight into key regulatory developments that will emerge or are likely to emerge over the 2024-25 financial year.

Key to these priorities is the continued implementation of Ofcom’s 2022 Space Spectrum Strategy, and consideration of WRC-23 outcomes, and their impact on policies and priorities. Ofcom has already foreshadowed its likely approach to implementation of the WRC-23 resolutions in its Space Spectrum Strategy from 2022 and its September 2023 Statement regarding updates to Non-Geostationary Earth Station licences from 2023.

The key activities which can be expected in FY 2024-25 are summarised below.

Licensing and authorisation

1. Authorisation of NGSO Ka band ESIM on aircraft – Currently in the UK, NGSO Ka band ESIM are not authorised for operation on aircraft.
   
   WRC-23 Agenda item 1.16 considered issues relating to the regulation of NGSO Ka band ESIM on air and maritime platforms. Ofcom notes in its proposed Plan of Work that it will plan to consult on whether to implement decisions to extend frequencies available to satellite services under the Satellite (ESN) Licence, subject to WRC-23 developments.
   
   Given WRC-23 adopted regulatory decisions for NGSO Ka band ESIM, it is likely that we can expect Ofcom will authorise NGSO Ka band ESIM under the existing Satellite (ESN) Licence.  
   
2. Intersatellite links in bands additional to 24.45 – 27.5 GHz – WRC-23 adopted a regulatory framework for satellite-to-satellite links in the Ka band.
   
   In Ofcom’s Space Spectrum Strategy consultation, it noted that it will need to ensure appropriate protection of existing UK services. Ofcom has not noted such work as part of its Plan of Work, however as new systems begin to employ such intersatellite links, this is likely to be become more of a priority for Ofcom.
   
3. Licensing of earth station gateways in the Q/V Band (37.5-40.5, 47.2-50.2, and 50.4-52.4 Ghz), and potentially the e-band (i.e 60 to 90 GHz) – Ofcom has confirmed in its proposed Plan of Work for FY 24/25 that a statement on authorisation of such gateways is expected in Q2 2024/25.
   
4. Updating satellite filing procedures after WRC-23 – WRC-23 considered several matters relating to satellite filings, including improving international rules for NGSO satellite filings (acceptable levels of interference between NGSO systems, how much NGSO systems can change without affecting its status and priority, and improved modelling of potential NGSO to GSO interference).
   
5. Call for input relating to developments that enable satellite transmission directly to mobile devices expected Q1 2024/25.

Spectrum Management Framework

Ofcom has confirmed it will look at the impact of changing demand from specific sectors / services.

Ofcom has already engaged in activity where it has re-considered whether spectrum allocated to specific uses should be re-allocated to enable other uses, including mmWave spectrum in the 26 GHz and 40 GHz band.

Ofcom’s specific plans for FY 2023-24 will include review of review of spectrum demands for fixed links and mobile satellite services, including satellite direct to device.

Perhaps as a start to this activity, Ofcom issued a discussion paper in October 2023, relating to spectrum management for next generation wireless broadband (covering technologies including 6G, next generation Wi-Fi and NTN satellite) and has foreshadowed an increase in the need for spectrum sharing to ensure that spectrum is available for all such technologies. Further, in December 2023, Ofcom released a Statement in response to its March 2023 consultation on the future use of unpaired 2100 MHz spectrum currently held by MNOs, which is a key band for MSS and other services.  

Next steps

Ofcom’s consultation on its proposed Plan of Work closes on 9 February 2024.

DLA Piper continues to monitor updates and developments to Ofcom’s work in the satellite and telecoms sector. For further information or if you have any questions please contact the author.