Yah 121

Telesat LEO Inc: Decision on application for
non-geostationary Earth Station Network

licence
Decision
Welsh overview available
STATEMENT:
Publication date: 10 November 2022
Contents
Section
1. Overview 1
2. Introduction and background 3
3. The Telesat consultation and response summary 12
4. Consultation responses on NGSO coexistence 15
5. Assessment of competition issues 20
6. Additional concerns raised regarding potential impacts on GSO networks 26
7. Concerns regarding the potential impact of NGSOs on the space environment 38
8. Decision 40
Annex
A1. Example Earth Station Network Licence 41
Decision: Telesat LEO Inc. NGSO ESN licence application
1. Overview
This document sets out our decision on an application by Telesat for a wireless telegraphy UK
Earth Station Network licence.
The licence is to allow Telesat to operate user terminals in the UK – such as a customer’s satellite
dish – to connect with its Lightspeed constellation of non-geostationary orbit (NGSO) satellites.
What we have decided – in brief

We have decided to grant Telesat an NGSO Earth Station Network licence.
We set out our original assessment of Telesat’s application in a consultation in July, in which we said
we were inclined to grant the licence. We have now assessed stakeholder responses about Telesat’s
ability to coexist with other current and future NGSO licence holders and considered the
competition issues raised by stakeholders in their submissions.
Stakeholders also raised broader concerns regarding the protection of GSO networks and the impact
of NGSO systems on the space environment, which we also address in this document.
In light of the consultation responses received we requested that Telesat provide us with additional
evidence regarding its approach to coordination of ITU satellite filings and its ability to coexist with
Geostationary orbit (GSO) networks. Our decision takes account of its response, which we have
published alongside this decision.
On coexistence, we believe that Telesat’s Lightspeed system is capable of coexisting with both
existing wireless telegraphy NGSO licence holders and future NGSO systems. Under the terms of its
new licence, Telesat will have an obligation to cooperate in good faith with all other NGSO licensees.
On competition, we assess that granting the application is unlikely to prevent or restrict future NGSO
systems from entering the market and that competition risks are therefore likely to be low.
This decision will enable Telesat to provide satellite connectivity services to people and businesses
in the UK. We will now proceed to issue Telesat with its new licence, subject to payment of the
licence fee. A copy of the licence will also be available under the “Existing licences” section of our
website.
1.1 NGSO satellite systems are a new way of delivering broadband services from space using a
constellation of satellites in a low or medium Earth orbit. These satellite services have the
potential to deliver higher speed and lower latency services than traditional Geo-stationary
orbit (GSO) systems.
1.2 In December 2021 we set out our new NGSO licensing process, which was designed to
encourage greater cooperation between NGSO licence holders, enhance our ability to
intervene if there is harmful interference, and ensure greater transparency by conducting
short consultations.
1.3 Telesat submitted an application for an Earth Station Network Licence (hereafter referred
to as “NGSO ESN licence”) earlier this year. In the application it set out how the licence
would enable it to provide satellite broadband services to support enterprise and mobile
1
backhaul, maritime and offshore platforms, aviation, and government services in the UK.
Telesat plans to launch satellites from 2025 and to commence initial services in the UK in
the first quarter of 2026.
1.4 On 24 June 2022, we published a consultation (the “Telesat consultation”) 1, in which we
set out our initial assessment of the licence application.
1.5 We considered the application in line with the procedures set out in our statement on non-
geostationary satellite systems. We took account of all responses to the Telesat
consultation in reaching our decision to grant the licence application.
1 See consultation Telesat LEO Inc: application for non-geostationary earth station (network) licence.
2
2. Introduction and background

2.1 This document sets out our consideration of an application by Telesat LEO Inc (“Telesat”)
for a wireless telegraphy licence to operate a UK NGSO Earth Station Network (ESN). This
licence covers the use of all user terminals for a range of different services: fixed or static
terminals (e.g. for a home broadband service), land mobile (e.g. on a train or a road
vehicle), or on an aircraft or a drone. The licence permits uplinks from user terminals to the
satellite – in the case of this application Telesat’s planned Lightspeed constellation. We
also require the holder of this licence to have control of the whole satellite network so this
licence is typically held by the satellite operator.
2.2 The application from Telesat was received on 6 June 2022. Telesat proposed to use the
radio frequencies 27.5–27.8185 GHz; 28.4545–28.8265 GHz and 29.5–30 GHz to provide
satellite broadband services to support enterprise and mobile backhaul, maritime and
offshore platforms, aviation, and Government services in the UK.
2.3 We set out our preliminary view, including our initial assessment of coexistence and
competition issues, in the Telesat consultation.
2.4 We received five responses to the Telesat consultation. In response to issues raised by
some respondents we requested additional information from Telesat before reaching our
decision on the application.
2.5 After taking account of all available evidence - including the consultation responses and
the further information provided by Telesat - we have decided to grant the licence. The
details of how we reached this decision are presented in this document as follows:
• In section 2 (this section) we explain the operation of NGSO satellite systems and
outline Ofcom’s role in licensing NGSO earth stations and the process we follow in
evaluating the NGSO applications;
• In section 3 we summarise our Telesat consultation and the responses received;
• In section 4 we consider in more detail the comments we received on NGSO
coexistence;
• In section 5 we set out a summary of the responses related to the competition risks
and benefits to consumers arising from the Telesat application and provide our
assessment of these issues;
• In section 6 we consider concerns that were raised in consultation responses related to
potential impacts on GSO networks;
• In section 7 we consider concerns raised regarding the potential impact of NGSOs on
the space environment;
• In section 8 we set out our decision and next steps.
NGSO satellite systems

2.6 NGSO satellite constellations can deliver broadband services at lower latency, and often at
higher speeds, than traditional geostationary orbiting (GSO) systems. They generally
operate in low or medium Earth orbit (i.e. in lower orbits than most GSO networks) and
3
connect a range of users to the internet or a private network via satellites which pass
overhead.
2.7 The services they deliver typically have nationwide coverage and so have a vital role in
connecting businesses and consumers in parts of the UK where terrestrial services are not
currently available. They also provide additional choice for consumers in other parts of the
UK. NGSO services can therefore play a role in delivering high quality broadband and
growth across the UK.
2.8 An NGSO satellite broadband system is made up of three components, as illustrated in
Figure 1 below:
a) One or more gateway earth stations which connect the satellite broadband network to
the internet or private networks. These earth stations can be located in the same
country as the target users or could be located elsewhere.
b) Several satellites used to relay traffic between the gateway and user terminals.
c) User terminals to provide broadband connectivity to end users, typically comprising of
an antenna and user equipment. User terminals connect with an NGSO gateway via
one or more satellites, depending on the design of the constellation.
2.9 The Telesat application for an ESN licence relates to this final component, the earth-based
user terminals in the UK that connect to its NGSO satellites.
Figure 1: Key elements of an NGSO system
2.10 Satellite broadband services tend to operate in a small number of radio frequency bands
(these are known as C band, Ku band, and Ka band 2). Within these bands, different services
use the same radio frequencies. The signals are coordinated – under international rules
laid down in International Telecommunication Union (ITU) Radio Regulations – whenever
2C band satellite services typically use 3.6 – 4.2 GHz for downlink and 5.85 – 7.075 GHz for uplink. Ku band satellite
services typically use 10.7-12.7 GHz for downlink and 14.0-14.5 GHz for uplink. Ka band satellite services typically use 17.7-
20.2 GHz for downlink and 27.5-30 GHz for uplink
4
the satellites appear close enough in the sky for their signals to be indistinguishable
(typically within 2˚ relative to the observer on the ground).
2.11 Traditional GSO satellites appear static in the sky to users on the ground so the number of
coordination agreements needed to operate without risk of causing or receiving harmful
interference (such that one or both services are degraded) is relatively limited.
2.12 Proposed NGSO satellite constellations rely on large numbers of satellites that change
position relative to the Earth. Earth station gateways and user terminals must track these
satellites in order to maintain a continuous connection. This creates a more dynamic
spectrum management environment – both in space and on the ground – and so increases
the risk of interference between NGSO systems compared to GSO networks. See figure 2
below:
Figure 2: How interference can occur between two NGSO systems
The number of satellites in each constellation In-line events have more

increases the chances of an in-line event impact when experienced by
where satellites from two different a gateway earth station
constellations appear in the same part of the because several hundred user
Network 1
terminals could be affected
sky.
As both satellites are transmitting and

receiving on similar frequencies they can Network 2
suffer harmful interference during an inline

event.
An in-line event can occur

when satellites of different
systems appear in the same
Network 1 Inline events can be brief but it
area of sky as seen from the
user terminal, resulting in
may take longer for the
interference terminal to reconnect to the
Network 2 network
2.13 As this is a new and emerging market, operators are exploring different network designs
(e.g. some will deploy a few hundred satellites, others will deploy many thousands of
satellites; some will deploy in relatively low earth orbits at an altitude of around 500 km,
others around 1,000 km and still others in medium earth orbits around 8,000 km). In
addition, operators are deploying satellites and services at different speeds as their
projects mature.
2.14 Satellites can transmit across national borders over multiple individual states, so their use
of spectrum needs to be managed globally. This management process, involving the
processing of ‘satellite filings’, is administered and overseen by the International
Telecommunication Union (ITU), a specialised agency of the United Nations. 3 International
3 The rules governing the use of the electromagnetic spectrum by satellites are included in the ‘Radio Regulations’, an
international treaty to which the UK is a signatory.
5
rules governing use of spectrum and coexistence between satellite operations are
negotiated at the ITU and published in the Radio Regulations. 4
2.15 A satellite filing enables a satellite operator to gain internationally recognised spectrum
and orbital resources prior to the deployment of a planned satellite system. The ITU Radio
Regulations require satellite operators to reach coordination agreements with co-
frequency systems. 5
2.16 Given the complexity and uncertainty inherent in deploying NGSO systems, it has proven
much harder for NGSO operators to reach these coordination agreements to date. For this
reason, we introduced new terms in our NGSO licences to encourage cooperation between
parties planning to operate in the UK.
2.17 In addition, operators are deploying satellites and services at different speeds as their
projects mature. We are keen to enable NGSO satellite services in the UK and to foster a
competitive market for several operators to provide services. However, we do not want
those systems that deploy first to unduly constrain or block those that might come later.
2.18 In relation to NGSO ESN licences, we note that competition risks could arise from the
constraints that systems operating under such a licence might impose on subsequent
entrants due to technical barriers to coexistence between systems.
2.19 For example, if there was a limited prospect of the applicant’s system and future systems
being able to technically coexist, this could form a barrier to future entry to the market,
leading to reduced competition.
Ofcom’s role in licensing NGSO earth stations

2.20 All decisions taken by Ofcom are rooted in our statutory duties and obligations. These stem
chiefly from the Communications Act of 2003 and the Wireless Telegraphy Act of 2006.
2.21 Ofcom’s principal statutory duty is to further the interests of citizens in relation to
communications matters, and consumers in relevant markets, where appropriate by
promoting competition. In meeting this duty, we also have a number of specific duties,
including to secure the optimal use of spectrum; ensure the availability throughout the UK
of a wide range of electronic communication services; and to take account of the different
needs and interests of all current or potential users of the spectrum frequencies.
2.22 The UK framework of rules for spectrum licensing is set out in section 3 of the Wireless
Telegraphy Act 2006. In carrying out our spectrum functions we have a duty under that
section to have regard, in particular, to:
a) the extent to which the spectrum is available for use, or further use, for wireless
telegraphy;
b) the demand for use of that spectrum for wireless telegraphy; and
c) the demand that is likely to arise in future for such use.
4 Radio Regulations (itu.int)

5 See Article 9.12.
6
2.23 We also have a duty to have regard, in particular, to the desirability of promoting:
a) the efficient management and use of the spectrum for wireless telegraphy;
b) the economic and other benefits that may arise from the use of wireless telegraphy;
c) the development of innovative services; and
d) competition in the provision of electronic communications services.
2.24 As set out in our December 2021 statement on NGSO Licensing we have a specific process
for considering applications for the following types of wireless telegraphy licence:
a) Satellite (Earth Station Network): this authorises an unlimited number of user
terminals 6 in the UK to connect to the NGSO system (subject to certain conditions). It
also places certain conditions on the licence holder (typically a satellite operator) to
coordinate with other licence holders and prevent interference. We refer to this
licence in the rest of this document as the “NGSO ESN licence”.
b) Satellite (Non-Geostationary Earth Station): this authorises gateway earth stations 7 in
the UK, which connect the NGSO system to the internet or to a private network. We
refer to this licence in the rest of this document as the “NGSO gateway licence”.
2.25 In considering whether to grant NGSO spectrum licences, we follow our published
guidance. This includes consideration of technical coexistence with existing and future
NGSO systems and any potential impacts on competition in the NGSO market. Details of
existing licences can be found under the “existing licences” section of our website.
2.26 The application by Telesat addressed in this document is for a Satellite (Earth Station
Network) licence.
Our licensing process for NGSO applications

2.27 Our national NGSO licensing process, which we introduced in December 2021, is designed
to encourage greater technical cooperation between NGSO operators, help us manage
interference, support a competitive market for NGSOs, and enhance transparency 8.
2.28 The main steps in the process are illustrated in figure 3 below. Guidance on the process
can be found on the NGSO licensing page of our website. This page also includes the details
of existing NGSO systems that new applicants should take into account when applying
(existing NGSO licence holders, co-frequency earth stations and earlier applicants).
6 User terminals connect the end user (e.g. the customer) to the satellite network; for example the dish and equipment
installed at a customer’s premises.
7 Gateway earth stations are hubs that connect the satellite network to the internet and/or to private networks and cloud
services.
8
Satellite operators need to submit filings for their constellations to the ITU and coordinate with all NGSO operators who
hold an older or “more senior” satellite filing. However, due to the complexity and cost of developing and launching NGSO
satellite networks not all satellite filings come to fruition in the order in which they were filed. The UK process for licensing
NGSO systems is not designed to circumvent the international regulatory regime as laid out by the ITU’s Radio Regulation
but it encourages those who are ready to deploy to cooperate in such a way that services can coexist.
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Figure 3: New NGSO licensing process
How we assess applications
2.29 The process focuses on ensuring different NGSO services can operate alongside each other.
We ask applicants to:
2.30 Demonstrate coexistence with other NGSO systems:
a) We prefer for applicants to have an agreement with other relevant licence holder(s)
already. This would ideally be an ITU coordination agreement, but it could also be a
local cooperation agreement allowing the systems to coexist in the UK.
b) If no such agreement exists, applicants should specify in detail how it would be possible
for the different systems to coexist. They should provide evidence that reasonable
measures can be put in place - by either the applicant, the existing licensee, or by both
- to achieve coexistence. Specifically, applicants should provide enough evidence to
demonstrate that the impact to existing licensees in terms of increased unavailability
and of reduction in throughput would be modest.
2.31 Demonstrate ability to coexist with future systems: we do not expect licensees to foresee
the characteristics or the number of future systems that will apply for a licence in the UK,
or how other systems may evolve. Our intention is for licensees to:
a) explain how their existing network design and operating model might facilitate
coexistence with other NGSO satellite systems and any limits to that flexibility;
b) outline any additional measures, which would allow improved coexistence with other
systems (for example, planned roll out of ground equipment, future network designs);
and
c) be aware that they may be expected to take reasonable measures to accommodate
such future applicants, in order to avoid material degradation to services in the UK.
2.32 Identify the potential impact of their application on competition in the UK. We expect
applicants to describe:
a) the benefits that the NGSO system can bring to UK people and businesses. Possible
benefits might include:
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i) improvements to an existing NGSO service;

ii) greater choice and/or allowing the applicant to compete more effectively in the UK;
and
iii) how the NGSO system may benefit its customers (e.g. a communications provider
that uses the NGSO system for backhaul) as well as end consumers (e.g. the
ultimate users of that communication provider’s services) and possibly citizens
more generally (e.g. if that communication provider’s services are of wider benefit
to society).
b) any risks to competition in the UK. This may refer to how the applicant intends to
mitigate any risks to competition, including, but not limited to, their ability to coexist
with other non-geostationary satellite systems or giving a sense of the scale of any
costs of coexistence for other operators’ systems.
2.33 It is worth noting that a new applicant for an NGSO ESN or gateway licence may hold a
senior (earlier) ITU international satellite filing than a competitor holding an existing UK
NGSO licence. Under the ITU’s Radio Regulations, the burden to ensure coexistence falls on
the operator with the junior (later) ITU filing. In this scenario, consistent with the ITU Radio
Regulations, existing UK licensees with deployed NGSOs may be reasonably expected to
make changes as required to accommodate the new UK applicant. Most should have
already designed their systems in such a way that this is possible.
2.34 We publish a short consultation on applications – along with a preliminary assessment –
and invite stakeholders to comment on that and on the information supplied by the
applicant. The questions we ask of stakeholders are based on the criteria above, with an
option to provide comments on any additional concerns.
2.35 Upon receipt of these consultation responses, we may ask the applicant for additional
information to help us address any outstanding concerns. For this application, we asked
Telesat to provide us with additional information regarding protection of GSO services and
information regarding their approach to coordination. This additional evidence has been
published alongside our Decision and can be found on the NGSO page of our website.
2.36 We take our final decision after taking into account all of the information supplied by the
applicant and all of the comments gathered from stakeholders.
Relevant NGSO ESN licence terms and conditions

2.37 We expect all licence holders to meet the conditions of their licence(s) and we have a
range of monitoring and enforcement powers to ensure they do so. Most of the conditions
in the ESN licence apply to NGSO systems and to GSO networks. However, there are some
additional conditions that are specific to NGSO operators relating to the protection of GSO
services. We have also introduced some other specific licence conditions as part of the
NGSO licensing process to enable us to take swift action in the event that one NGSO
system causes harmful interference to another NGSO system, resulting in a material and
recurring degradation of service, which in turn can cause competition risks. A full copy of
the standard licence can be found in Annex A1.
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Protection of GSO services
2.38 The NGSO ESN licence contains provisions for the protection of GSO satellite services using
the same frequencies. Specifically, condition 3.1 (c) of our NGSO ESN licence states:
“the earth stations operating with non-geostationary satellites shall ensure compliance
with the equivalent power flux-density limitations specified in Article 22 of the ITU Radio
Regulations”
2.39 As this licence covers the transmissions from NGSO user terminals this condition ensures
the user terminals don’t cause interference from Earth to space transmissions (in the
uplink) into GSO satellites.
2.40 For space to Earth transmissions (in the downlink) all satellite operators must comply with
the relevant sections in the ITU Radio Regulations. The administration who holds their
satellite filings is responsible for ensuring the satellite operator complies with the ITU
Radio Regulations.
2.41 There are some bands where those protections do not apply, as indicated in No. 5.523A of
the Radio Regulations, which states that for certain frequencies, GSO networks and NGSO
systems have to coordinate their use of spectrum on a first-come, first-served basis, based
on the date of their ITU filings. Note 1 of the NGSO ESN licence conditions states:
“This Licence does not remove any other obligations that the Licensee may have in
relation to satellite filings made under the ITU Radio Regulations”
Conditions related to the NGSO licensing process
2.42 As part of our new NGSO licensing process, we introduced five new conditions for holders
of NGSO ESN licences under section 7 of the licence (below). These give us additional
powers of enforcement should one or more NGSO system suffer material and/or recurring
degradation of service.
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“1. The radio frequencies authorised by this Licence must be used in common with other
non-GSO satellite systems authorised under wireless telegraphy licences granted by
OFCOM. The names of these licensees shall be notified by Ofcom to the Licensee from time
to time, and together with the Licensee are described as the “NGSO Licensees”.
2. The radio frequencies authorised by this Licence must only be used to communicate
with a satellite system which has transmissions authorised under a Satellite (Earth Station
Network) wireless telegraphy licence granted by Ofcom.
3. In the event that –
• one (or more than one) of the NGSO Licensees suffers a material and recurring
degradation of services to its users at a specific region or location in the United Kingdom;
and
• the degradation of services is resulting from radio transmissions from the earth stations,
the satellite or any other part of the satellite system operated by another of the NGSO
Licensees, including the Licensee; Ofcom may instruct the Licensee to cease or change the
use of particular equipment or particular radio frequencies which are authorised under a
wireless telegraphy licence (including but not limited to radio frequencies authorised
under this Licence) and are used by any part of the satellite system.
4. Any such cessation or change must be for the purposes of ensuring that such
interference is avoided and the degradation of services to users at the particular regions
or locations is resolved.
5. Following receipt of such notice, for such period of time as may be specified in the
notice, the Licensee may only operate in accordance with the terms and conditions of the
notice.“
Ofcom may take a range of monitoring and enforcement actions where

licence conditions are not met
2.43 Alongside the specific requirements for NGSO licence, the Wireless Telegraphy Licence
Conditions Booklet (the general conditions booklet) places a number of conditions on all
spectrum licence holders. It outlines some of the actions we may take in the event that
conditions in our licences are not met. This includes the power to access and inspect sites
(condition 5); modify, restrict and closedown (condition 6) services; and revoke a licence
(condition 1).
2.44 In addition, we have the legal power to take enforcement action in relation to breaches of
conditions in wireless telegraphy licences through criminal law prosecution. Similarly,
section 42 of the Wireless Telegraphy Act 2006 gives us the power to fine companies which
are in breach of the conditions in wireless telegraphy licences.
2.45 The type of enforcement action we would take in any circumstance would be appropriate
and proportionate.
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3. The Telesat consultation and response

summary
3.1 In this section we summarise the key points from the Telesat consultation and provide an
overview of the responses received. We consider and assess the responses received
relating to specific coexistence, competition and additional issues in sections 4-7.
Telesat consultation
3.2 As set out in sections 1 and 2, in June 2022 we published a consultation (the “Telesat
consultation”) in which we set out our initial assessment of the licence application for a
Non-geostationary ESN licence, to enable user terminals in the UK to operate using Ka
band (27.5 – 27.8185 GHz, 28.4545 – 28.8265 GHz and 29.5 – 30 GHz). We noted that
Telesat planned to start launching its satellites in Q3 2025 and to commence initial services
in the UK in Q1 2026 and proposed to provide satellite broadband services to support
enterprise and mobile backhaul, maritime and offshore platforms, aviation, and
government services in the UK.
3.3 We said we would assess the application, including the coexistence and competition issues
involved, as set out in our NGSO licence application process. We also set out our
preliminary view that we proposed to grant the application.
3.4 We invited comments on the application and on our preliminary views and said we would
take into account all comments received, and that we were open to changing those views
depending on responses and evidence submitted to us as part of this process.
3.5 We explained that when issuing new licences, one of Ofcom’s objectives is that all
authorised systems are capable of coexisting (in bands they are using in common), such
that they are all able to provide services to their users without experiencing harmful
interference. We outlined the coexistence criteria we asked applicants to demonstrate,
and how Telesat proposed to meet these criteria. Our initial view was that the Telesat
Lightspeed constellation of satellites should be able to coexist with existing, new and
future NGSO gateway and terminal operators. However, we noted that at the time of
writing Telesat had not reached coordination agreements with any of the existing NGSO
licence holders; we encouraged all parties to continue coordinating in good faith between
now and the launch of the Lightspeed constellation. We sought stakeholder views on this
initial view and any potential coexistence concerns.
3.6 On competition, we explained that, as outlined in the Annex A3 of our statement on
updates to NGSO licensing, our starting position with any competition check is to authorise
applications, where possible. We outlined that we would take into account four factors: a)
the extent of the likely risks to competition; b) the potential benefits from granting NGSO
licence applications; c) ensuring that time and resources devoted to the licensing process
are proportionate to the risks and benefits; and d) that NGSO services are currently in their
infancy. Following consideration of the information provided by Telesat our preliminary
assessment was that there would not be a material risk to competition associated with this
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application. We sought stakeholder views on whether granting this licence would benefit
or harm future competition between NGSO services in the UK.
3.7 We noted the potential benefits of granting the application. In our approach to
competition we had said that “A network licence is necessary for an operator to deploy
user terminals in the UK… Granting NGSO network licence applications is thus likely to
benefit customers and consumers and supports Ofcom’s strategic priority to get everyone
connected. Since issuing a new network licence allows market entry it also has the
potential, if a service is deployed, to promote greater competition (assuming that it can
coexist with other authorised systems).” 9
3.8 We noted that Telesat saw growing demand for satellite connectivity supporting enterprise
and telecommunications companies, the aviation industry, the UK maritime and offshore
energy sector and government services. Further, they had stated that the Lightspeed
network could provide multiple Gbps in each beam and can dynamically place beams in
hotspot areas where demand might be greater e.g. along busy shipping routes or airports.
As a consequence, our preliminary view was that Telesat’s Lightspeed had the potential to
provide services that provide further connectivity options to customers in the UK, in
addition to those of the existing NGSO licence holders.
3.9 Our preliminary assessment, taking the evidence presented by Telesat and our assessment
of the risks and benefits of granting this application, was that we proposed to grant
Telesat’s application for an ESN licence.
3.10 We set out that coexistence and competition were the two issues on which we expected to
make our licensing decisions (as set out in the NGSO Licensing updates Statement) but also
asked if stakeholders had any additional concerns or comments regarding this application.
Summary of responses to Telesat consultation

3.11 We received five responses from satellite operators to our consultation regarding Telesat’s
application for an NGSO ESN licence. Four of those respondents submitted confidential
responses. We have therefore outlined the issues raised in these confidential responses in
an anonymised manner.
3.12 The non-confidential response, from Viasat, has been published on our website alongside
this document.
3.13 Most stakeholders assessed that Telesat had demonstrated a technical ability to coexist
with existing and future NGSO operators. However, a number queried whether Telesat was
showing sufficient willingness to cooperate during coordination discussions. We discuss
these issues in section 4.
3.14 GSO satellite operators expressed a number of concerns, raising questions about the
potential risks of interference to their services; the potential impact of the Telesat
9 NGSO Licensing Statement, Annex A3.12.
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Lightspeed constellation on the global space environment, and potential risks to

competition in the market. We consider these points further in sections 5-7.
3.15 We note that some stakeholders raised similar issues in their response to different
questions. In addressing consultation responses, we have grouped comments together
under the most relevant topic.
3.16 Most stakeholders assessed that Telesat had demonstrated a technical ability to coexist
with existing and future NGSO operators. However, a number queried whether Telesat was
showing sufficient willingness to cooperate during coordination discussions.
3.17 In response to some points raised by respondents, we requested Telesat to provide us with
additional information regarding their approach to ITU coordination and protection of GSO
services. The additional evidence has been published alongside our decision and can be
found on the NGSO site on our webpages. We have referred to this material where
relevant throughout the rest of this document.
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4. Consultation responses on NGSO

coexistence
4.1 In this section we consider and assess the responses received with respect to coexistence
with existing and future NGSO systems.
Coexistence with existing NGSO licensed systems

Consultation summary
4.2 The Telesat consultation, along with the licence application, set out how Telesat planned to
coexist with existing licensed systems and co-frequency earth stations. At the time of
application, the existing licensees were Starlink, OneWeb and Kepler. Telesat had not
reached coordination agreements with any of these companies and so outlined in its
application how it planned to coexist with existing licence operators. It stated: “Telesat
Lightspeed can dynamically assign capacity where and as required, through the selection of
the satellite chosen to deliver the service, of the size and steering of satellite spot beams,
and of the amount of spectrum and power allocated to them”.
4.3 More detailed information regarding the likely impact of its service on existing licensed
services in terms of throughput and unavailability can be found in the annex of the Telesat
application.
4.4 Regarding specific co-frequency earth stations registered with the ITU, Telesat stated:
“With respect to the applicable specific co-frequency earth stations registered with the ITU
…Telesat is coordinating its NGSO system with the relevant operator(s) for those earth
stations under the applicable provisions of Article 9 of the Radio Regulations. Telesat
commits to take any necessary technical and operational measures not to cause
interference into those earth stations.”
4.5 Our initial view was that Telesat’s proposal to dynamically assign capacity should allow
them to coexist with existing NGSO licence holders in accordance with the approach they
described. However, we encouraged all parties to continue coordinating in good faith
before the launch of the Telesat Lightspeed constellation.
4.6 As part of the consultation, we sought views and evidence from interested parties on
existing coexistence challenges related to Telesat’s NGSO ESN licence application:
15
Consultation question 1
Do you anticipate this satellite network will pose coexistence challenges to existing
services?
Consultation responses regarding coexistence with existing NGSO licenced

systems
4.7 Two respondents thought that Telesat had demonstrated that the Lightspeed constellation
had the technical capabilities to coexist with existing NGSO operators.
4.8 Another respondent pointed out that although Telesat’s application shows their service
would be protected, Telesat had not indicated how they would expect licensees to protect
their service given Telesat has an older filing – which might create some uncertainty for
other NGSOs. The reasons for this potential uncertainty are explained in the next
paragraph.
Our assessment regarding coexistence with existing NGSO licenced systems

4.9 Telesat holds one of the oldest ITU satellite filings for NGSO systems operating in Ka band.
As already noted, under the ITU’s Radio Regulations, NGSO operators with more recent
satellite filings using the same frequencies are under obligation to make appropriate
efforts to complete coordination with earlier filings. This requirement stands, even if
operators choose to deploy their satellites and commence services before completing
coordination.
4.10 The terms of coordination agreements are usually bespoke as they take into account the
technical characteristics of each system, the services that each operator plans to provide,
and the target market. A coordination agreement can therefore require some negotiation
and compromise on both sides to enable both operators to coexist.
4.11 We summarised this in paragraph 3.31 of the NGSO Licensing Updates Statement where
we stated that: “… operators should fulfil their obligations and coordinate with earlier filed
systems as per the relevant provisions of Article 9 of the ITU Radio Regulations. At the
same time, all operators (including earlier filed ones) should negotiate in good faith in
order to enable the most efficient use of spectrum. This means not making unreasonable
demands of other operators".
4.12 Our NGSO licensing process does not require applicants to have reached a coordination
agreement, as set out by the ITU, but we do want to see evidence of proactive engagement
with other licensees; a plan to cooperate so that the risk of interference is minimised; and
a willingness to reach coordination agreements.
4.13 Moreover, condition 7.2 of the NGSO ESN licence requires that:
16
“The Licensee shall cooperate with all NGSO Licensees such that each satellite system
(comprising the satellites, earth stations and user terminals) can co-exist and operate
within the United Kingdom without causing harmful radio interference to each other, such
that network services can be provided to end users.
4.14 In view of the evidence provided in the initial application - and subsequent additional
information provided at our request - we assess that Telesat has provided adequate
information regarding its ability to protect existing licensees. The additional confidential
evidence we have seen confirms that Telesat is actively engaging in coordination
discussions with a number of operators, and, in each case, is exploring a range of options in
order to meet the requirements of both parties.
4.15 In addition, we assess the announcement in September of a coordination agreement with
Amazon 10 as demonstrating Telesat’s willingness and ability to successfully complete such
discussions. Therefore, we are satisfied that Telesat is taking the necessary steps to
progress discussions with NGSO licence holders.
Coexistence with future NGSO systems

4.16 The Telesat consultation set out how Telesat proposed in its licence application to manage
coexistence with future systems through the use of alternative satellites and avoidance
angles to avoid in-line events. It stated that the exact procedure for avoiding in-line events
would be negotiated during coordination discussions. However, the impact of in-line
events could be further lessened through dynamic assignment of spectrum and the power
allocated to each beam.
4.17 Our initial view was that the application provided sufficient comfort that Telesat’s system
would be capable of coexisting with existing and future NGSO gateway and terminal
operators.
future coexistence challenges related to Telesat’s NGSO ESN licence application:
Are the measures set out by the applicant to enable coexistence with future NGSO
systems reasonable?
Consultation responses regarding coexistence with future NGSO systems

4.19 One respondent stated that Telesat’s proposals were very flexible. However, they claimed
that Telesat was not prepared to show the same flexibility in coordination discussions,
specifically that Telesat had not accepted any increase in unavailability or decrease in
10 Letter to the FCC 09 September 2022, listed here as “Kuiper-Telesat Coordination Letter”
17
average spectral efficiency, at similar levels as those that will occur from the Telesat
system into existing services.
4.20 Another respondent made similar comments and went further, recommending that any
award of licence should be contingent upon reciprocity, i.e. accepting coordination with
future NGSO services on the same terms and conditions as Telesat is extending to the
existing NGSO services.
Our assessment regarding coexistence with future NGSO systems

4.21 With regard to future services, in the Telesat consultation we assessed that Telesat’s
application provided sufficient evidence to reassure us regarding the flexibility of their
system. We have not seen any evidence in the consultation responses to suggest that the
design of the Telesat Lightspeed constellation could not accommodate future operators.
We therefore remain satisfied regarding the technical ability of their system to coexist with
others.
4.22 In respect of coordination discussions, we recognise that a real or perceived unwillingness
on the part of Telesat to coordinate might create uncertainty for other NGSO operators,
given the seniority of the Telesat ITU filings and associated obligation on other NGSO
operators with more junior filings to coordinate with them. In extremis, this might deter
other operators from entering the UK market. We therefore requested further
information from Telesat regarding its approach to coordination.
4.23 In response, it stated: “Telesat is conducting coordination in accordance with industry
practice as developed through the relevant international expert group, which is ITU WP 4A.
Notably, recent contributions have interpreted Recommendation ITU-R S.1323, that falls in
the purview of ITU-R Study Group 4, responsible for all satellite matters, as promoting
coordination based on (1) average degradation in spectral efficiency, (2) increase in
unavailability of the lowest C/N objective. Telesat is in advanced discussions with several
NGSO (coordination under No. 9.12 of the Radio Regulations) and GSO (coordination under
Nos. 9.12A and 9.13 of the Radio Regulations) operators.”
4.24 Subsequently, in September, it was announced that Telesat had reached a coordination
agreement with Amazon 11.
4.25 This, combined with additional confidential evidence regarding Telesat’s approach to
coordination discussions has provided the necessary reassurance regarding its approach to
coordination with future licensees.
4.26 Regarding reciprocity, as we explained in paragraphs 4.9-4.11 above, all satellite operators
(and the administrations who hold their satellite filings) have obligations under Article 9 of
the ITU Radio Regulations to coordinate with those holding more senior filings. Operators
with senior filings must coordinate with good faith but this is not necessarily the same as
reciprocity.
11Letter to the FCC 09 September 2022, listed here as “Kuiper-Telesat Coordination Letter” http://licensing.fcc.gov/cgi-
bin/ws.exe/prod/ib/forms/reports/related_filing.hts?f_key=-443847&f_number=SATMPL2020052600053
18
Conclusion on NGSO coexistence

4.27 In conclusion, we continue to believe that Telesat has the technical ability to cooperate
with existing and future NGSO licensees. We have sufficient evidence to anticipate
progress on cooperation discussions, as required by the terms of our licence. We also
believe the conditions in our licence will provide us with the necessary powers to intervene
if required.
4.28 In view of the above, our overall technical assessment is that granting the application is
unlikely to impact on existing licensees or restrict future NGSO systems from entering the
market.
19
5. Assessment of competition issues

5.1 In this section we assess the competition risks, and benefits to consumers, arising from
Telesat’s NGSO ESN licence application. We cover several competition risks: interference
into other systems and associated barriers to entry and expansion, and a broader concern
over proliferation of satellites in space.
5.2 We assess these competition issues using the counterfactual method. That is, we compare
the competitive conditions which we expect to result from granting the application (the
factual) against the conditions which would have prevailed without the application (the
counterfactual). We take as our counterfactual the status quo. Specifically, we assume a
situation in which Telesat does not hold the UK NGSO ESN licence it is applying for. In the
factual we assume Telesat is granted the NGSO ESN licence and provides satellite
broadband services to UK customers.
5.3 The rest of this section is structured as follows:
• A summary of Ofcom’s consultation position on competition.
• Consultation responses related to competition.
• Our assessment of these consultation responses.
• Conclusion on competition risks.
Summary of our consultation position on competition

5.4 In general, our starting position on new NGSO ESN licence applications is that they will not
raise material competition risks. 12
5.5 However, in our statement on NGSO licensing we also noted that “in principle competition
concerns could arise from the constraints that systems operating under a network licence
might impose on subsequent entrants due to the technical barriers to coexistence between
systems (e.g. due to a lack of flexibility in the design of systems). If there was a limited
prospect of the applicant’s system and future systems being able to technically coexist,
then this could form a barrier to future entry to the market. This would be a particular
concern if it results in market power. However, the magnitude of this risk is currently
unclear.” 13
5.6 Telesat, in its application, claimed there was growing demand for satellite connectivity
supporting various sectors and services, such as the aviation market and the provision of
mobile backhaul through satellite links for local telecommunication operators. Further
details can be found in its application.
12 Statement, Annex A3.14. We also noted in the Statement that “a network licence is necessary for an operator to deploy
user terminals in the UK. As set out in section 2, satellite connections can be used to support a range of consumer and
business services. Granting NGSO network licence applications is thus likely to benefit customers and consumers and
supports Ofcom’s strategic priority to get everyone connected (see above). Since issuing a new network licence allows
market entry it also has the potential, if a service is deployed, to promote greater competition (assuming that it can coexist
with other authorised systems).” See Statement, Annex A3.12.
13 Statement, Annex A3.11.
20
5.7 In the Telesat consultation our preliminary view was that Telesat’s system was able to
“manage coexistence with future systems”, and that “under condition 7.2 of the network
licence, Telesat will be required to cooperate with other licensees”. 14 On this basis, our
view was that there would not be a material risk to competition from granting the network
licence to Telesat.
5.8 On consumer benefits, we noted that Telesat’s Lightspeed constellation had the potential
to deliver services “that provide further connectivity options to customers in the UK, in
addition to existing NGSO network licence holders.” 15 Telesat’s application also stated that
its “Lightspeed satellite service will offer communications capabilities in areas where wired
and wireless networks are absent or might not provide adequate coverage or performance
compatible with the requested applications.” 16 In addition, the application noted that
“Telesat Lightspeed will facilitate applications related to critical infrastructure, disaster
communications, corporate communications, telemedicine and other remote
communications that will positively affect users’ efficiency and quality of life”. 17
competition concerns related to Telesat’s NGSO ESN licence application:
Do you believe this application would benefit or harm future competition between NGSO
services in the UK? Please provide details.
Consultation responses related to competition

5.10 Two respondents thought this application could harm future competition between NGSO
services in the UK. They each made similar points. For example, one of these respondents
stated that “this application may harm future competition between NGSO services in the
UK as Telesat’s track record for completing coordination agreements with other NGSO
systems at the time of writing appears to be non-existing and would in effect possibly pose
an obstacle for future systems to establish Ka-band based NGSO services in the UK”.
5.11 Viasat and another operator were concerned that Telesat's network would change after
receiving a licence (in particular, with regard to the type of antenna used). They said that
this would undermine the current interference-free environment for GSO operators and
would deter future operators from entering the UK market. Viasat suggested that Ofcom
require that Telesat “not modify the characteristics of its LEO system without filing a
modification application with Ofcom that Ofcom approves (in order to maintain its
authorisations in the UK)” and that “Telesat provide, every 6 months, a report showing
compliance with the obligations attached to the authorisations granted.”
5.12 In addition, Viasat stated in its response that it considered that “the proposed Starlink
system alone would consume the entire aggregate downlink EPFD ‘budget’ in both Ku and
14 See paragraph 2.17 of the Telesat consultation.

15 See paragraph 2.21 of the Telesat consultation.
16 See Annex to Telesat application: TELSAT-NET-1-Annex.pdf (ofcom.org.uk).
17 See Annex to Telesat application: TELSAT-NET-1-Annex.pdf (ofcom.org.uk).
21
Ka band. Telesat’s NGSO system has the potential to worsen the aggregate EPFD
exceedances created by the Starlink system, causing far more interference into GSO
networks than is permitted by ITU Radio Regulations under the Res. 76 aggregate EPFD
limits” 18. Additionally, it argued that the combined impact of these two operators would
“foreclose opportunities for other parties to operate their own NGSO systems in the UK,
harming competition”.
5.13 One respondent considered that the large-scale use of certain orbital regions could harm
competition in space.
Our assessment of consultation responses related to competition

5.14 Respondents to the consultation raised concerns that can be grouped into four types of
competition risk:
a) Risk 1: granting the NGSO ESN licence would harm competition between NGSO
services in the UK, given a perception among some respondents that Telesat had a
poor track record for completing coordination agreements.
b) Risk 2: Telesat might change their network design after being granted a licence, which
could have the effect of undermining GSO operators’ current interference-free
environment, and potentially disincentivise future entrants to the market.
c) Risk 3: The SpaceX system combined with authorising Telesat’s system in the UK would
consume all of the aggregate EPFD “budget” allowed for under ITU regulations. This
would cause interference into GSO networks and would also foreclose opportunities
for other satellite operators to deploy their own NGSO systems in the UK, harming
competition.
d) Risk 4: Large-scale use of certain orbital regions could harm competition in space if it
leads to the exclusion of other operators in those regions.
5.15 We assess each of these risks in turn below.
Risk 1: granting the NGSO ESN licence would harm competition between NGSO services in the UK,
given a perception among some respondents that Telesat had a poor track record for completing
coordination agreements.
5.16 As we have explained, we are aware that NGSO operators with more senior ITU filings have
more rights than more junior ITU filings. We explained that we do not want those systems
that deploy first to unduly constrain or block those that might come later. Under the terms
of an ESN licence, licensees will have an obligation to cooperate in good faith with all other
NGSO licensees. In the event that a licensee was found to be making unreasonable
demands of other operators and was causing harmful interference we could take action
using our enforcement powers. However, the announcement of a coordination agreement
18The ITU Radio Regulations stipulate that, in most frequency bands, NGSO systems shall operate without causing harmful
interference to, or claiming protection from, GSO networks (Article 22.2). The Radio Regulations also define a set of
interference limits, called equivalent power-flux density (EPFD limits), used to check whether NGSO systems meet this non-
interference condition in certain bands.
22
with Amazon demonstrates Telesat’s willingness and ability to successfully complete such
discussions. Accordingly, we consider this competition risk is unlikely to be significant.
Risk 2: Telesat might change their network design after being granted a licence, which could have
the effect of undermining the current interference-free environment enjoyed by GSO operators,
and potentially disincentivise future entrants to the market.
5.17 Operators are required to comply with Article 22 of the ITU Radio Regulations and comply
with our licence conditions (which also refer to Article 22). Our licence conditions therefore
require operators to comply with these interference limits irrespective of any changes to
the design of their system. Further information on this can be found in section 6.
5.18 Respondents that commented on this risk proposed certain remedial actions that Ofcom
should impose on Telesat, such as regular reporting on network design. We assess it would
be unnecessarily onerous to require NGSO ESN licence holders report on network design at
regular intervals as network designs tend to change infrequently.
5.19 However, as we outlined in section 4, we believe it is important that licence holders have
sufficient certainty regarding the likely operation of Lightspeed so that they can deploy
their services in a timely manner and/or to avoid a degradation of existing services when
Lightspeed starts to deploy. We assess that the terms of our licence are sufficient to
address this issue. If harmful interference arises, we have powers to deal with this as set
out later in section 6. Accordingly, we consider this competition risk (which would arise
from interference) is unlikely to be significant.
Risk 3: The SpaceX system combined with authorising Telesat’s system in the UK would consume
all of the aggregate EPFD ‘budget’ allowed for under ITU regulations. This would cause
interference into GSO networks and would also foreclose opportunities for other satellite
operators to deploy their own NGSO systems in the UK, harming competition.
5.20 The Radio Regulations set limits on the aggregate interference caused by all co-frequency
NGSO systems into GSO networks in Article 22.5K and Resolution 76 (Rev. WRC-15). 19 This
resolution states that, in the event that aggregate interference exceeds the prescribed
limits, administrations operating NGSO systems shall take all necessary measures
expeditiously to reduce the aggregate interference levels.
5.21 Telesat has confirmed to Ofcom in its response to our further information request that it
will “operate its Lightspeed system in order to comply with all applicable provisions of the
ITU Radio Regulations with respect to meeting ‘single-entry’ limits (i.e. Nos. 22.2, 22.5C,
22.5D and 22.5F of the Radio Regulations) and with respect to meeting the ‘aggregate’
limits indicated in Annex 1 to Resolution 76.” Telesat and the administration that holds its
filings are obliged to abide by the ITU regulations and we are satisfied that they are able to
meet the relevant single-entry and aggregate EPFD limits in Article 22 based on the
information they have provided. However, respondents have also raised the possibility of
aggregate limits being exceeded when considering the joint contribution of Starlink and
Telesat.
19 Telesat response to Telesat further information request, Q2b.
23
5.22 As explained in Resolution 76 of the Radio Regulations, existing single-entry EPFD limits
were derived assuming a maximum effective number of NGSO systems of 3.5. This means
that, if each system complies with the existing single-entry limits, it is reasonable to expect
no exceedance of the aggregate limits until at least 4 NGSO systems are in operation.
There are currently fewer than four systems licensed and only one operating in the bands
Telesat wishes to use as only Starlink operates in the Ka band in the UK. Therefore, at this
stage we are satisfied that there is a low risk that the licenced NGSO systems will exceed
the aggregate EPFD limits in the UK. Nonetheless, we expect each satellite operator to
comply with the single-entry limits regardless of the number of filings under which they
operate. This is discussed in further detail in section 6.
5.23 On the basis of the above, we assess that the competition risk (which would stem from
non-compliance) against this concern is low.
Risk 4: Large-scale use of certain orbital regions could harm competition in space if it leads to the
exclusion of other operators in those regions.
5.24 We note that Telesat’s NGSO ESN licence application to provide satellite broadband
services in the UK would be delivered by Telesat’s Lightspeed system. This satellite system
would comprise of:
“LEO Satellites - In the initial phase, 188 satellites plus 10 in-orbit spares will be deployed
considering both polar and inclined orbits. Additional satellites will be added in a second
phase, bringing the total number to 298. Polar orbits provide global coverage, with a higher
concentration of satellites in the Polar Regions. Inclined orbits allow to concentrate
satellites over equatorial and mid-latitude areas where demand for communications
services is greater, thereby focusing most of the capacity on populated areas. By using
these two complementary orbits, the system achieves true global coverage while
concentrating satellite resources on the areas of greatest demand, thereby maximizing the
system efficiency.” 20
5.25 This demonstrates that Telesat’s Lightspeed system is designed for “global coverage”, with
satellites located in “polar regions” as well as over “equatorial and mid-latitude areas”.
This suggests that while Telesat’s system of 298 satellites would concentrate satellite
resources on the areas of greatest demand, this would not lead to a concentration of
satellites in orbital paths over the UK.
5.26 As set out in our December 2021 statement, our competition assessment considers the
potential effect on competition to supply satellite broadband to UK customers from issuing
the NGSO ESN licence to Telesat. We compare this potential effect against the
counterfactual (i.e. not granting the licence). For the application to raise competition
concerns in the UK in the manner set out in Risk 4, it would need to be the case that:
a) granting this UK NGSO ESN licence drives the deployment of a sufficient proportion of
Telesat’s planned additional 298 global satellites in certain orbital regions; and
20 See Annex to Telesat’s application: TELSAT-NET-1-Annex.pdf (ofcom.org.uk).
24
b) this deployment leads to harm to competition in the UK.

5.27 Our assessment is that the link between granting a UK NGSO ESN licence and the global
design of the Telesat Lightspeed constellation is unlikely to be strong. This is because the
UK represents a small market compared to global demand for satellite broadband.
Therefore, our assessment is that granting this UK licence is unlikely to drive the
deployment of a substantial proportion of Telesat’s Lightspeed constellation.
5.28 Further, the planned geographic locations of Telesat’s constellation – as discussed in
paragraphs 5.24-5.25 above – suggests that there is unlikely to be a concentration of
Telesat satellites in orbital paths over the UK designed to meet UK demand. Therefore, our
assessment is that it is unlikely that the Lightspeed deployment would harm competition in
the UK by preventing the use by others of orbital regions capable of being used to serve
the UK.
Conclusion on competition risks

5.29 In view of the above, our overall competition assessment is that granting the application is
unlikely to create significant competition risks. We also note that there is potential for
consumer benefits which could arise from the Lightspeed network following the grant of
the licence, which are discussed at paragraph 5.8.
25
6. Additional concerns raised regarding

potential impacts on GSO networks
6.1 In our Telesat consultation, as well as our statement on non-geostationary satellite
systems, we explained that coexistence with existing and future NGSO systems and
competition are the main issues on which we expect to make our licensing decision.
However, in our consultation we also asked stakeholders if they had any additional
concerns or comments.
Do you have any additional concerns or comments regarding this application?
6.2 Stakeholders raised two additional issues:

a) Protection of GSO networks from interference from NGSO systems – which we
consider in this section; and
b) Environmental concerns – which we consider in section 7.
Interference from NGSO systems into GSO networks

6.3 Our NGSO licensing process focuses on the mitigation of interference between two NGSO
systems. This is because NGSOs are dynamic by nature, creating a complex spectrum
management environment – both in space and on the ground – and thereby increasing the
risk of interference. Whilst there is also the potential for interference between NGSO and
GSO services which use the same frequencies, international rules and our licence
conditions are intended to prevent this, and also address the management of any issues
should they arise. We discussed these briefly in the annex to our Statement on NGSO
Licensing Updates and will explain them in more detail here.
6.4 There are two potential sources of interference from NGSO systems into GSO networks: (i)
interference from the NGSO earth station(s) uplink into the GSO satellite (as illustrated in
figure 4); and (ii) interference from the NGSO downlink into the GSO earth station(s) (see
figure 5).
26
Figure 4: Potential for NGSO earth stations to cause interference into GSO Services in the uplink
(Earth to space) as they communicate with NGSO satellites passing in front of the GSO arc
NGSO earth sta�on could temporarily cause

interference into the GSO satellite (which is opera�ng
in the same frequencies) as theirsignal paths overlap
NGSO satellites
GSO satellite
NGSO earth sta�on communicates with

satellites in the NGSO network, tracking GSO earth sta�on communicates with the GSO
them as they pass overhead satellite
Figure 5: Potential for NGSO services to cause interference into GSO earth stations (space to Earth)
as the NGSO satellites pass in front of the GSO arc
GSO satellites remain sta�c in the sky rela�ve to their earth sta�on.
NGSO satellites move rela�ve totheir earth sta�on and pass in front of a GSO satellite.
If both GSO and NGSO satellites transmit on the same frequencies, the gateways may
experience temporary interference
NGSO satellites
GSO satellite
Interference may occur here
NGSO earth sta�on tracks NGSO GSO earth sta�on (sta�c)

satellites as they pass overhead
6.5 In the uplink interference scenario. Ofcom is responsible for licensing NGSO earth stations
to transmit in the UK and for managing associated interference issues (see figure 6).
6.6 In the downlink interference scenario, GSO earth stations could experience two forms of
interference from NGSO networks:
a) Single entry interference, caused by satellites from one NGSO network;
b) Aggregate interference, caused by the combined signals of satellites from multiple
NGSO systems, all operating in the same frequencies as the GSO earth station.
27
6.7 Ofcom does not license signals transmitted by a space station (satellite) into the UK.
International rules and procedures apply to these as we explain in the following
paragraphs.
Figure 6: Description of a typical satellite service and the regulations that govern their use
International rules on coexistence between NGSO systems and GSO networks

6.8 The way NGSO systems and GSO networks coexist is primarily managed through the ITU
Radio Regulations. The Radio Regulations are part of an international treaty that is binding
to ITU Member States (including the UK), who shall operate their radio stations so that
they do not cause harmful interference to the radio services of other Member States
operating in accordance with the provisions of this treaty.
6.9 This means that, unless there is another specific agreement in place, the UK in its
authorisation and spectrum management processes will take into account (and if
necessary, take steps to protect) stations of other administrations 21, following the
provisions of the Radio Regulations. Here, the term “station” can refer to a satellite in
space or an earth station on the ground. In turn, we expect that other administrations will
operate their stations in accordance with the Radio Regulations and protect UK stations
accordingly. Article 15 of the ITU Radio Regulations sets out the process for resolving cases
of harmful interference between member states.
6.10 The ITU Radio Regulations stipulate that, in most frequency bands, NGSO systems shall
operate without causing harmful interference to, or claiming protection from, GSO
networks (Article 22.2). The Radio Regulations also define a set of interference limits,
called equivalent power-flux density (EPFD) limits, used to check whether NGSO systems
meet this non-interference condition in certain bands.
6.11 These EPFD limits are defined in the Radio Regulations articles 22.5C (limits on Earth for
emissions from NGSO satellites), 22.5D (limits on the geostationary orbit for emissions
21The ITU Radio Regulations define an administration as “any governmental department or service responsible for
discharging the obligations undertaken in the Constitution of the International Telecommunications Union, in the
Convention of the International Telecommunications Union and in the Administrative Regulations.”
28
from NGSO earth stations) and 22.5F (limits on the geostationary orbit for emissions from
NGSO satellites).
6.12 Upon reception of a new satellite filing, the ITU Radiocommunication Bureau runs a
calculation to see if the proposed new system would conform with the stated limits.
Further, tables 22-4A, 22-4A1 and 22-4B in the Radio Regulations contain additional limits
that have to be met when measured at any operational GSO fixed-satellite service earth
station. An NGSO system that complies with all these limits is deemed to be not causing
unacceptable interference to GSO networks (see Article 22.5I). In the event that the ITU
Radiocommunications Bureau concludes that the limits are exceeded, the filing will receive
an unfavourable finding and will not have full international recognition for the use of its
orbits and frequency bands.
6.13 The Radio Regulations also set limits on the aggregate interference caused by all co-
frequency NGSO systems into GSO networks in Article 22.5K and Resolution 76. This
resolution states that, in the event that aggregate interference exceeds the prescribed
limits, administrations operating NGSO systems shall take all necessary measures
expeditiously to reduce the aggregate interference levels.
6.14 Article 22.2 does not apply in the bands at 18.8-19.3 GHz (space-to-Earth) and 28.6-29.1
GHz (Earth-to-space), which are subject to number 5.523A of the Radio Regulations
instead. This means that GSO networks and NGSO systems have to coordinate their use of
this spectrum on a first-come, first-served basis, based on the date of their ITU filings, and
later systems will be expected to take into account earlier systems regardless of their type.
6.15 It is reasonable for us to expect that NGSO satellite operators will comply with the Radio
Regulations and protect GSO networks according to the relevant provisions. The national
administration responsible for the NGSO system is ultimately responsible to ensure such
compliance.
6.16 Ofcom acts as the UK notifying administration under ITU procedures in relation to
international management of the radio spectrum and orbit resources. It is responsible for
ensuring that these filings (and the satellite networks operating under these filings) comply
with the ITU’s Radio Regulations. This covers the submission of satellite filings on behalf of
companies registered in the UK, British Overseas Territories, the Channel Islands and the
Isle of Man.
6.17 However, Ofcom is not the notifying administration responsible for the satellite filings
under which Telesat’s Lightspeed system shall operate.
What our licensing framework requires

6.18 In our licensing statement 22 we said that at this time we did not think that there was a
material risk to GSO networks, given the existing national and international regulations we
covered in paragraphs 6.9 to 6.14. Therefore, our process for considering NGSO licence
22 Paragraph A2.6 in the annexes to our NGSO Statement.
29
applications focused on requiring applicants to demonstrate that they can coexist with
other NGSO systems.
6.19 It is a requirement of our ESN licence conditions that all satellite operators operating in the
UK under this licence must comply with the relevant sections in the ITU Radio Regulations,
including the provisions relating to GSO networks as detailed above. NGSO systems can use
mitigation techniques to coexist with GSO networks
6.20 We consider that NGSO systems have a range of mitigation techniques at their disposal
that allow them to provide services while meeting the above conditions to protect GSO
networks; examples are the use of a suitable GSO arc avoidance angle, or the selective
reduction of transmit power at certain times.
6.21 Given the static positioning of GSO satellites, protecting GSO networks is typically easier
than protecting another non-GSO system. For example, for a non-GSO system serving the
UK, the elevation angle of earth stations will often be higher than the elevation angle of
the GSO arc, as shown in Figure 6. When this is the case, NGSO earth stations will radiate
most of their power away from the GSO arc.
Figure 6: Angular avoidance between GSO and NGSO
6.22 There are bands where Article 22.2 does not apply, as explained in para 6.13 above. In
practice, the same technical measures used by NGSO systems to protect GSO networks in
other bands would be available and could be used to support coordination in the 18.8-19.3
GHz and 28.6-29.1 GHz bands. Thus, we do not foresee major difficulties in achieving
coexistence in the bands.
Consultation responses concerning interference into GSO networks

6.23 While our process for considering NGSO licence applications only requires applicants to
demonstrate that they can coexist with other NGSO systems, we have considered the
consultation responses received on the potential risk of NGSO systems causing
interference into GSO networks. We have also further reviewed Telesat’s capabilities to
30
coexist with GSO networks, including the capability of their satellites to protect GSO earth
stations providing services to the UK.
Consultation responses
6.24 Comments on protection of GSO were largely made by two respondents but mirror some
of the responses that we saw to the consultations on updates to the NGSO Licence and our
proposed Space Spectrum Strategy. Here, the comments broadly focused on:
• Compliance with single entry interference and aggregate interference limits;
• Angular separation with the GSO arc;
• Operation in bands not subject to article 22.2 of the ITU Radio Regulations;
• Monitoring and enforcement of interference from NGSO systems.
Compliance with single entry and aggregate interference limits
6.25 Viasat stated that “the ITU’s methodology and implementing software for assessing
expected EPFD levels from NGSO operations rely on an algorithm that derives a “worst-
case geometry” found at one particular location on the Earth’s surface.” Viasat added that,
due to ITU’s methodology and implementing software’s limitations, in its view “an ITU
evaluation would not be expected to reveal the exceedances of EPFD limits in the UK.”
6.26 Viasat suggested that the Starlink system alone would consume the entire aggregate
downlink EPFD “budget”. Accordingly, Viasat considered that the aggregate EPFD levels
generated by both Starlink and Telesat would harm competition. It asserted that Ofcom
should perform compliance analysis to ensure that the Telesat system meets the ITU RR
Article 22 EPFD limits in the UK, both individually, and in the aggregate considering all
other co-frequency NGSO serving the UK.
6.27 Viasat further recommended that we develop a mechanism by which we can ensure that
the aggregate EPFD “budget” and the burden to resolve aggregate interference is
apportioned equitably amongst all NGSO systems that serve the UK.
6.28 If we were to move ahead with granting the licence, Viasat also suggested we implement
some additional conditions in the ESN licence to ensure that Telesat complied with the
EPFD limits.
Angular separation with the GSO arc
6.29 Viasat claimed that unless “Telesat’s communication links are angularly separated from the
GSO arc by a sufficient amount, they could easily degrade service levels and cause capacity
losses to the GSO networks with which Telesat seeks to compete, including those that
serve the UK and Europe.”
6.30 Viasat added that: “If Ofcom were nonetheless to consider granting Telesat a spectrum
authorisation, it should, at a minimum: (i) calculate the minimum GSO arc avoidance angle
that would ensure that the Telesat NGSO system protects from interference GSO networks
serving the UK and Europe; (ii) allow interested parties to evaluate the efficacy of the
proposed value; and (iii) require Telesat to maintain a suitable GSO arc avoidance angle as
a condition of any authorisation that ultimately may be granted in this proceeding.”
31
6.31 Another operator noted that: “Telesat’s application states that it can prevent undue
interference to GSO downlinks by using a GSO exclusion angle greater than 4.5 degrees as
viewed from the victim Earth Station”. However, their view was that this would be
impossible to implement, given that the GSO and NGSO gateways could be in any location.
Operation in bands not subject to Article 22.2
6.32 One respondent stated that: “The current guidance for NGSO licensing anticipates that
modifications to networks could change the interference environment for current users of
the spectrum. It states that Ofcom “would expect operators to keep us informed and to
cooperate with other licensees ahead of making such changes in order to ensure they can
continue to coexist”. Licensees would also be subject to an ongoing obligation to cooperate
and coexist with other NGSO licensees. However, there are no such obligations with
respect to the prevention of interference to GSO operators from NGSO systems in key
parts of the Ka-bands.”
6.33 We understand this remark to refer to operations in the band 28.6 – 29.1 GHz, where GSO
networks and NGSO systems have to coordinate their use of spectrum on a first-come,
first-served basis, based on the date of their ITU filings, as set out above.
Monitoring and enforcement of interference from NGSO systems
6.34 A respondent queried how Ofcom would monitor possible interference from NGSO
systems into GSO networks. The respondent expressed a desire for Ofcom to rise to the
challenge of implementing independent interference monitoring so that it can ensure that
undue interference is not caused to other spectrum users in the UK.
Our assessment of concerns about interference into GSO networks

Compliance with single entry and aggregate interference limits
Protection of GSO networks from uplink interference
6.35 The NGSO ESN licence contains provisions for the protection of GSO satellite services using
the same frequencies. Specifically, condition 3.1 (c) states:
“earth stations operating with non-geostationary satellites shall ensure compliance with
the equivalent power flux-density limitations specified in Article 22 of the ITU Radio
Regulations”;
6.36 Additionally, we have sought further information from Telesat on their capabilities to meet
the relevant limits in Article 22. Telesat has confirmed that it will “operate its Lightspeed
system in order to comply with all applicable provisions of the ITU Radio Regulations with
respect to meeting “single-entry” limits (i.e. Nos. 22.2, 22.5C, 22.5D and 22.5F of the Radio
Regulations) and with respect to meeting the “aggregate” limits indicated in Annex 1 to
Resolution 76 (Rev. WRC-15).”
6.37 Telesat also outlined a range of mitigation techniques which it claimed would allow it to
comply with the single-entry and aggregate EPFD limits. These include: the use of steerable
32
and shapeable narrow beams operating in a multi-colour frequency reuse scheme,

dynamic modulation of the EIRP spectral density of the transmissions generated by a
satellite or earth station, depending on its pointing direction with respect to the GSO arc,
use of beam-hopping, use of a minimum separation angle between two or more satellite
beams operating simultaneously and co-frequency.
6.38 Telesat noted that WRC-23 is likely to amend this Resolution under Topic J of its Agenda
Item 7 23 and highlighted that Telesat is actively engaged in the discussions related to this
topic and will comply with any provisions that may come into force following the
Conference’s deliberations on the matter. Telesat also noted that the COMMSTELLATION,
CANSAT-LEO and TELSTAR-LEO satellite systems, for which Telesat is licensed by the
administration of Canada have each received a favourable finding following the ITU
Radiocommunication Bureau’s examination under Resolution 85.
6.39 We are therefore satisfied that Telesat is capable of meeting the Article 22 limits in the
Earth-to-space direction, that is when transmitting from their user earth stations towards
their NGSO satellites.
6.40 Should we receive a report of suspected harmful interference being caused to a GSO
satellite receiver by a UK licensed earth station, we would use our investigation and
enforcement powers and, if needed, instruct the licensee to cease transmissions in order
to remove interference 24.
Protection of GSO networks from downlink interference
6.41 While we do not license Telesat’s satellites as such, we recognise that the presence of
terminals in the UK results in Telesat needing to place downlink beams (that is, to transmit
signals from their satellites towards the Earth) in Ka band where terminals are located. As a
consequence, granting an NGSO ESN licence which enables the use of user terminals in the
UK would be expected to result in additional downlink emissions in the areas where user
terminals are located. According to Viasat, the evaluation carried out by the ITU could fail
to reveal exceedances of EPFD limits in the UK (see paragraph 6.26 above).
6.42 We have considered the remark made by Viasat and have sought further information on
this point from Telesat. In their response, copied in paragraph 6.37 above, Telesat have
confirmed they will operate in compliance with the relevant EPFD limits in the radio
regulations also in the space-to-Earth direction.
6.43 As a consequence, we are satisfied that Telesat is capable of meeting the Article 22 limits
in the space-to-Earth direction as well. If interference from any NGSO system is suspected,
UK licensed operators should contact our Spectrum Monitoring Centre; upon reception of
such a report we will evaluate the report and use our investigation powers if required. If
we deem it necessary, we could also reach out to the filing administration in order to have
the interference mitigated.
23See section 4.3 in document 4A/856: https://www.itu.int/md/R19-WP4A-C-0856/en

24In considering the appropriate course of action, we would take into account a number of factors including the extent and
impact of the interference and the international regulatory framework that would apply in the circumstances.
33
6.44 In the interests of proportionality, we would normally use our investigation powers in the
event of material and recurring degradation to the victim’s service, and that is not
necessarily the same as one of the limits in Article 22 being breached.
6.45 It is worth reiterating that limits in the space-to-Earth direction present in the Radio
Regulations apply unless administration agrees to less stringent limits in their territory. In
the strictest sense, it is for Ofcom to decide whether less stringent limits are also
acceptable on the ground in the UK and act accordingly.
6.46 In our space spectrum strategy, we state that we consider the existing approach to
protecting GSO earth stations from harmful interference to be sufficient. However, we will
also consider whether introducing a new licence condition (into the NGSO ESN Licence) in
relation to the downlink would enable us to enforce more quickly and directly against a UK
NGSO licensee (under the new licence condition) if there was harmful interference to GSO
receivers in the UK. This could give Ofcom added enforcement options beyond reaching
out to the filing administration responsible for the interference.
Need for an independent assessment of single entry and aggregate entry
6.47 As we have stated above, we have requested further information from Telesat and as a
result we are satisfied that they are able to meet the relevant single-entry and aggregate
EPFD limits in Article 22. However, respondents have also raised the possibility of
aggregate limits being exceeded when considering the joint contribution of Starlink and
Telesat.
6.48 As set out in Resolution 76 of the Radio Regulations, existing single-entry EPFD limits were
derived assuming a maximum effective number of NGSO systems of 3.5. This means that, if
each system complies with the existing single-entry limits, it is reasonable to expect no
exceedance in the aggregate limits until at least four NGSO systems are in operation.
6.49 Therefore, at this stage we are satisfied that the risk of exceedance of the aggregate EPFD
limits from emissions from all licensed NGSO systems in UK is low. There are currently
fewer than four systems licensed and only one operating in the bands Telesat wishes to
use as only Starlink operates Ka band in the UK; in addition we expect each of them to
comply with the single-entry limits regardless of the number of filings under which they
operate.
6.50 In the event that aggregate interference were to exceed the prescribed limits, under the
current international framework it is the responsibility of administrations operating NGSO
systems to take all necessary measures expeditiously to reduce the aggregate interference
levels.
6.51 The ITU is discussing potential changes to international regulations to provide further
guidance to administrations operating NGSO systems and may encourage yearly meetings
between them to ensure the overall limits are met.
6.52 As explained above, if interference is suspected to a GSO earth stations, UK licensed
operators should contact our Spectrum Monitoring Centre; upon reception of such report,
we will use our investigation powers and, if needed, reach out to the responsible
administrations in order to have the interference removed. In the interests of
34
proportionality, we would normally use our investigation powers in the event of material
and recurring degradation to the victim’s service.
Angular separation with the GSO arc

6.53 As stated above, our assessment is that NGSO systems have a range of mitigation
techniques at their disposal that allow them to provide services while meeting the
necessary conditions to protect GSO networks, and the use of a suitable GSO arc avoidance
angle is one example.
6.54 At this point we do not think it would be proportionate to impose a specific angle
avoidance that licensees should comply with, or any other specific technical measures
beyond the obligation to meet the relevant limits in Article 22. Doing so would be a
significant departure from the way we usually licence space systems; for example, when
licensing GSO earth stations we do not impose specific technical conditions to ensure the
protection of other co-frequency satellites.
6.55 For the same reason, we do not propose to pursue other additional licence conditions
suggested, such as requiring six-monthly reports on compliance, which we consider would
be unnecessarily onerous.
Operation in bands not subject to Article 22.2

6.56 We have already stated that that all satellite operators must comply with the relevant
sections in the ITU Radio Regulations, including when it comes to engaging in coordination
discussions in good faith with other operators. We have also stated that NGSO systems
have a range of mitigation techniques at their disposal that allow them to provide services
while coexisting with GSO networks.
6.57 We therefore expect Telesat to coordinate in good faith with GSO operators to achieve
solutions that allow both parties to make the best possible use of the spectrum.
6.58 Given the deployment timelines, we do not consider that granting this licence would create
additional risks. On the contrary, given that Telesat holds a senior satellite filing and that
our process allows us greater scrutiny of the coordination process, we see greater benefit
in granting Telesat a licence at this early stage as this will support us in monitoring that all
the necessary cooperation agreements are in place in a timely manner.
Monitoring and enforcement of interference from NGSO systems

6.59 We have explained above in paragraphs 6.40, 6.43-6.44 and 6.52 the mechanisms available
should any satellite operator suspect harmful interference from an NGSO system. If
interference from any NGSO system is suspected, UK licensed operators should contact our
Spectrum Monitoring Centre. At that stage we would expect victim operators to provide
evidence of the degradation they have experienced.
6.60 Our approach to handling interference will depend on the type of interference scenario:
a) In the case of suspected interference arising from NGSO satellites to a GSO receiving
earth station, we will seek evidence of harmful interference from measurements
35
conducted at the victim earth stations (i.e. at the user or operator’s site), and we may
also use our satellite monitoring facility at Baldock.
b) In the case of suspected NGSO interference to a GSO satellite receiver we would rely
on evidence of harmful interference provided by the victim satellite operator, as
monitoring stations on the ground cannot measure interference to satellite receivers.
6.61 We are taking steps to further develop the UK’s capabilities to detect and handle NGSO
interference to GSO receiving earth stations. At our Baldock monitoring station we are
developing methodologies and processes to collect evidence of harmful interference to
satellite receivers, in close collaboration with NGSO and GSO operators. These
methodologies will be used to support investigations when required.
Conclusion on potential impacts on GSO networks

6.62 Whilst our process for considering NGSO licence applications only requires applicants to
demonstrate that they can coexist with other NGSO systems, we have considered the
consultation responses which raised concerns over the potential for NGSO interference
into GSO networks and the subsequent impact on quality of service. We have further
reviewed Telesat’s capabilities to coexist with GSO networks, including the capability of
their satellites to protect GSO earth stations providing services to the UK.
6.63 We recognise that granting a NGSO ESN licence would enable Telesat to provide services in
the UK, resulting in additional emissions. Nonetheless, in view of the information provided
in the initial applications, and in response to our subsequent request for further
information, we are satisfied that Telesat is capable of meeting the Article 22 limits for
both uplinks and downlinks. We are also satisfied that that there should be no exceedance
of the aggregate EPFD limits from emissions from all licensed NGSO systems in UK as a
consequence of granting a NGSO ESN licence to Telesat.
6.64 There is an existing framework to protect GSO networks from harmful interference from
NGSO systems. At an international level, all satellite operators must comply with the
relevant sections in the ITU Radio Regulations which mandate that non-GSO systems shall
not cause interference to, or claim protection from, GSO networks in the relevant
frequency bands.
6.65 Further, in the UK our NGSO ESN licence explicitly requires the operator to comply with
Article 22. In the event of suspected harmful interference from an NGSO system, there are
a number of actions available to Ofcom and GSO operators to take action in relation to
these provisions.
6.66 We will continue to support the principles of the current ITU framework for NGSO systems,
including the need for later filed systems to seek agreement from earlier filed systems, and
the obligation for operators to negotiate coordination in good faith. Further, we will work
within international bodies to promote improvements to the international framework for
NGSO systems
36
6.67 In view of the above our conclusion is that it is unlikely that a decision to grant a NGSO ESN
licence to Telesat would result in harmful interference to GSO networks. However, in the
event that this were to occur we would look to take action to address this.
37
7. Concerns regarding the potential impact of

NGSOs on the space environment
7.1 Respondents raised a number of concerns centred on the risk of collisions in space; space
debris; and the impact of releasing large amounts of vaporised aluminium into the
atmosphere.
7.2 A stakeholder noted that “Credible studies have raised issues related to the impact of
mega-constellations on orbital debris, the chemistry of the upper atmosphere, and light
pollution.” They suggested that “mega-constellations should be subject to the same kind of
environmental impact study and assessment that is typically done for large projects on
Earth”.
7.3 One stakeholder raised concerns about the way NGSO systems could use orbital resources.
It claimed: “large-scale use of certain orbital regions could result in a de facto exclusion of
other players from those regions. This issue, and its impact on both competition and
innovation, is poorly understood and needs further study. It has been noted that such
orbital exclusion could violate the 1967 Outer Space Treaty. It could also create space-
based dominant “platforms” that restrict competition in space similar to the impact of
dominant digital platforms on Earth. Such a position could have a significant impact on
national broadband internet access markets and be of considerable detriment to end
users. [Our] concern is about a rush to launch low earth orbit constellations that could
have a meaningful impact on both the sustainability of space and of our planet without the
necessary impact analysis and resulting regulatory safeguards at both a national and
international level.”
Our assessment of responses regarding the potential impact of

NGSOs on the space environment
7.4 In the UK, policy on safe and sustainable use of space is determined by UK Space Agency
and the Department for Business Energy and Industrial Strategy. Further, the UK regulator
with responsibility for issues concerning the safety of space, including space launch and
space debris is the Civil Aviation Authority, as outlined in the Space Industry Act 2018. As
outlined in section 2, our duties and powers come from separate legislation.
7.5 As discussed in section 5, we assess that granting a UK NGSO ESN licence is unlikely to
influence or impact the number of satellites that Telesat puts into space. The Telesat
Lightspeed constellation is planned to be a global system serving a global market.
7.6 We recognise the role spectrum will play in enabling safe and sustainable use of space. We
will consider appropriate access to spectrum for radars to track the movements of objects
in space. We will also seek to understand whether changes to international spectrum
allocations are needed to support in-orbit servicing and other safe space initiatives.
7.7 We have shared the concerns raised in the consultation with our responsible counterparts
in the CAA and the UK Space Agency for their consideration.
38
Conclusion on the potential impact of NGSOs on the space

environment
7.8 Whilst we recognise the importance of safe and sustainable use of space and continue to
discuss the spectrum issues related to space debris and space sustainability with the
relevant government departments and agencies, this is not a consideration within our
current NGSO ESN licence application process.
39
8. Decision
How we decide whether to grant a licence
8.1 In our NGSO statement we set out how we would decide whether to grant a licence. In
this, we referred to our statutory duties, with our principal duty being to further the
interests of citizens and consumers in relation to communications matters. In accordance
with these statutory duties, when deciding whether to grant a licence application, we said
that we would be mindful that our objective is to enable citizen and consumer benefits
arising from innovative satellite services, such as improved connectivity, and would take all
relevant factors into account including in particular:
• (in the case of gateway licence applications) the availability of gateway sites within the
UK;
• any risks to competition for UK consumers; and
• the ability of networks to coexist in terms of radio interference management.
8.2 We confirmed that in reaching our decision we would thus take account of both our
technical check, our competition check, and our statutory duties and objectives. In
achieving our aim, we would also take account of the available relevant evidence, including
responses to the Invitation to Comment.
Our decision
8.3 We have decided to grant an NGSO Earth Station Network licence to Telesat LEO Inc. in
light of the evidence presented by Telesat, stakeholder responses and the reasoning set
out in this document on the risks and benefits to citizens and consumers of granting this
application.
8.4 This will authorise Telesat user terminals in the UK – such as a customer’s satellite dish- to
connect with its Lightspeed constellation of non-geostationary orbit (NGSO) satellites.
8.5 This will authorise Telesat to provide satellite connectivity services in the UK in future,
improving connectivity for UK citizens and consumers. Telesat has indicated that it plans to
launch satellites from 2025 and commence initial services in the UK in 2026, such as
satellite broadband services to support enterprise and mobile backhaul, maritime and
offshore platforms, aviation, and government services.
Next steps
8.6 We will now proceed to issue Telesat with its new licence, subject to payment of the
licence fee.
8.7 A copy of the licence will also be made available under the “Existing licences” section of
our website.
40
A1. Example Earth Station Network Licence

Wireless Telegraphy Act 2006
Satellite (Earth Station Network)
Sector/class/product <Product>
Licence number <Lic_No>
Licensee <Lic_Name>
Licensee address <Address>
Trading as <Tradename>
Licence first issue date <Issue_Date>
Licence version date <Date>
Payment interval <Year>
1. This Licence is issued by the Office of Communications (“Ofcom”) on <Date> and

replaces any previous authority granted in respect of the service subject to this
Licence by Ofcom or by the Secretary of State.
2. This Licence authorises <Lic_Name> (“the Licensee”) to establish, install and/or
use radio transmitting and/or receiving stations and/or radio apparatus as described
in the schedule(s) (hereinafter together called "the radio equipment") subject to the
terms set out below and subject to the terms of the General Licence Conditions
booklet (Version OfW 597).
ISSUED BY OFCOM
41
Satellite (Earth Station Network) Licence

SCHEDULE 1 TO LICENCE NUMBER <Lic_No>
TERMS, PROVISIONS AND LIMITATIONS COVERED BY THIS LICENCE
This schedule forms part of Licence <Lic_No>, issued to <Lic_Name>, the Licensee on
<Issue_Date>, and describes the terms and equipment specifications covered by this
Licence.
1. The Licensee may establish and use:
1.1. Permanent, transportable or mobile sending and receiving network earth station(s)
("the station(s)") for the purpose of providing wireless telegraphy links between the
station(s) and geostationary or non-geostationary satellite(s).
2. Limitations on use
2.1. The stations(s) operating with geostationary satellites shall:
a) transmit within one or more of the following frequency ranges: 14.0-14.5 GHz,
27.5-27.8185 GHz, 28.4545-28.8265 GHz, 29.4625-30 GHz;
b) for aeronautical stations, not transmit within the frequency range 14.47-14.5 GHz;
c) transmit only to the satellite and its associated orbital longitude specified in
Schedule 2.
2.2. Land station(s) operating with non-geostationary satellites shall:
d) transmit within one or more of the following frequency ranges: 14.0-14.5 GHz,
27.5-27.8185 GHz, 28.4545-28.8265 GHz, 29.5-30 GHz;
e) transmit only to the satellite network specified in Schedule 2.
2.3. Aeronautical station(s) operating with non-geostationary satellites shall:
f) transmit within the frequency range 14.0-14.47 GHz;
g) transmit only to the satellite network specified in Schedule 2.
2.4. Additionally:
h) stations(s) that transmit with e.i.r.p. greater than 55 dBW shall operate only with
prior consent from Ofcom and registration of the station(s) against the Licence;
i) station(s) that transmit within the frequency range 14.0-14.5 GHz inclusive shall
not operate at any location that is less than or equal to 5 km from the two
geographical locations specified in Schedule 3 without prior consent from Ofcom
and registration of the station(s) against the Licence;
42
j) station(s) that transmit with e.i.r.p. greater than 50 dBW and less than 55 dBW
(50 dBW < e.i.r.p. < 55 dBW) in the frequency range 14.0-14.5 GHz inclusive
shall not operate at any location that is greater than 5 km and less than or equal
to 7 km from the two geographical locations specified in Schedule 3 without prior
consent from Ofcom and registration of the station(s) against the Licence; and
k) station(s) shall not operate within the perimeter fence of any of the aerodromes
specified in Schedule 4 without prior consent from the Civil Aviation Authority or
stated Airport Authority.
2.5 Protection of radio astronomy and fixed links in the 14.25-14.5 GHz band
l) To protect radio astronomy operating between 14.47-14.5 GHz, a land or

maritime station shall not transmit from a location within a 175 km radius of the
national grid references below:
• Jodrell Bank – focus point of circle is NGR SJ5739392556;

• Cambridge – focus point of circle is NGR TL5439992385.
m) Licensees shall protect fixed links at 14.25-14.5 GHz in accordance with the
Notice issued by Ofcom.
3. Apparatus
3.1. The Licensee shall ensure that:
a) The wireless telegraphy apparatus comprised in the station(s) ("the apparatus")

is so designed, constructed, maintained and operated, that its use does not
cause any undue interference to other users of the spectrum;
b) The apparatus complies with (and is maintained in accordance with) the relevant
performance specification(s) published by the operator(s) of the geostationary or
non-geostationary satellite(s);
c) The earth stations operating with non-geostationary satellites shall ensure
compliance with the equivalent power flux-density limitations specified in Article
22 of the ITU Radio Regulations; and
d) The apparatus used for transmission complies with the Radio Equipment
Directive and UK Interface Requirement 2077.
4. Additional conditions for mobile operation
a) The radio equipment shall be established or installed so that transmissions from

the radio equipment may only be made when the radio equipment’s operation is
enabled by the crew of the vehicle, aircraft, vessel or train upon which it is
mounted, and under the operational control of the network control facility. The
radio equipment shall provide the crew with a means immediately to terminate
transmissions;
b) Where an aircraft or vessel is registered in the United Kingdom, Channel Islands

or the Isle of Man, the Licensee shall ensure that all radio equipment on board
43
that aircraft is endorsed by either a separate licence or exemption under the

Wireless Telegraphy Act 2006;
c) Transmissions from the radio equipment shall automatically be terminated on

loss or significant degradation of the downlink signal from the relevant satellite;
d) For operation with geostationary satellites, the radio equipment shall employ a
stabilised platform with the ability to maintain a pointing accuracy +/-0.2 degrees
towards the relevant geostationary satellite throughout transmissions; and
e) For operation with geostationary satellites, the maximum EIRP at angles greater
than or equal to 2.5 degrees from the antenna main beam axis shall not exceed
20 dBW/40 kHz from any individual station.
5. National and international obligations
a) The relevant satellite data shall have been submitted to ITU in accordance with
established ITU procedures; and
b) All transmissions from the radio equipment must be terminated prior to any
change of location; unless the apparatus used for transmission is designed for
mobile operation and incorporates a stabilised platform or is operating under a
specific exemption authorised by Ofcom.
6. Requirements specific to Satellite (Earth Station Network) Licences
a) The Licensee shall keep a record of the operational characteristics of all

terminals in the network, including the locations of fixed installations or, for
mobile operation, details of the vehicles, aircraft, vessels or trains on which the
terminals are installed and the associated route or defined area of operation,
which Ofcom may wish to have access to for enforcement purposes;
b) The radio equipment shall implement independent local control and monitoring
functions at the terminal, and be authorised, supervised and administered by a
network control and monitoring centre;
c) The Licensee shall have the facility to disable individual terminal transmission;
and
d) For satellite networks in MESH configuration, the network operator must

nominate and notify Ofcom of those earth station(s) located in the UK which
have independent centralised control and monitoring functionality and possess
the capability to suppress transmissions from any earth station within the
network. Earth stations that are capable of dynamic assignment as point-to-
multipoint and point-to-point configuration may only be licensed as permanent
earth stations.
44
7. Additional conditions for operation with non-geostationary satellites
7.1. The radio frequencies authorised by this Licence must be used in common with other
non-geostationary satellite systems authorised under wireless telegraphy licences
granted by Ofcom. The names of these licensees shall be notified by Ofcom to the
Licensee from time to time, and together with the Licensee are described as the
“NGSO Licensees”.
7.2. The Licensee shall cooperate with all NGSO Licensees such that each satellite system
(comprising the satellites, earth stations and user terminals) can co-exist and operate
within the United Kingdom without causing harmful radio interference to each other,
such that network services can be provided to end users.
7.3. In the event that –
a) one (or more than one) of the NGSO Licensees suffers a material and recurring
(or ongoing) degradation of services to its users at a specific region or location in
the United Kingdom; and
b) the degradation of services is resulting from radio transmissions from the earth
stations, the satellite or any other part of the satellite system operated by any of
the NGSO Licensees, including the Licensee;
Ofcom may by notice instruct the Licensee to cease or change the use of
particular equipment or particular radio frequencies which are authorised under a
wireless telegraphy licence (including but not limited to radio frequencies
authorised under this Licence) and are used by any part of the satellite system.
7.4. Any such cessation or change must be for the purposes of ensuring that such
interference is avoided and the degradation of services to users at the particular
regions or locations is resolved.
7.5. Following receipt of such notice, for such period of time as may be specified in the
notice, the Licensee may only operate in accordance with the terms and conditions of
the notice.
8. Interpretation
8.1. In this and subsequent schedule(s):
l) “earth station” means a radio transmitter located on the surface of the earth or
mounted on a vehicle, aircraft, vessel or train and intended for communication
with one or more satellites;
m) “geostationary satellite” means a satellite in geostationary orbit which remains

approximately in a fixed position relative to a position on the surface of the earth;
n) “non-geostationary satellite” means a satellite that does not remain fixed relative
to a position on the surface of the earth; and
o) “IR” means the United Kingdom Radio Interface Requirement published by

Ofcom in accordance with Article 8 of the Radio Equipment Directive (Directive
45
2014/53/EU of the European Parliament and of the Council on the harmonisation

of the laws of the Member States relating to the making available of radio
equipment on the market (known as the Radio Equipment Directive)).
Notes
1. This Licence does not remove any other obligations that the Licensee may have
in relation to satellite filings made under the ITU Radio Regulations.
2. This Licence does not affect the requirement, when necessary, to obtain licences
or authorisations under other Acts, such as the Broadcasting Act.
3. Some terminal installations require local authority planning approval. Advice

should be sought from the Department for Business, Enterprise and Industrial
Strategy and the appropriate local authority planning department.
4. The Licensee must apply for a variation of the Licence from Ofcom before
making any changes which may contravene the conditions of the Licence.
5. Technical terms used in clause 2 shall have the meanings assigned to them in
the ITU Radio Regulations.
6. For radio equipment installed on aircraft, licensees are advised that they must
comply with Civil Aviation Authority (CAA) airworthiness requirements and
regulations.
7. Further information, in respect of airworthiness requirements and certification

requirements before installation, can be obtained by contacting the CAA:
Civil Aviation Authority

Tel: 0330 022 1500
http://www.caa.co.uk
46
Decision: Telesat NGSO ESN licence application
SCHEDULE 2
Licence <Lic No> Licence <Date> Payment <1 Year>

No version date interval
Earth Station Network Name Emergency Telephone Number (24

hours)
<Network_name> <Emergency_telephone>
Network Type Satellite Type Satellite / Geostationary

Satellite Orbital Longitude
Network (degrees)
Name
<Network_type> <Geostationary/Non- <Sat_name> <Orbit_long>
Geostationary>
Frequency band
14.0 – 14.25 GHz
27.5 – 27.8185 GHz
28.4545 – 28.8265 GHz
29.4625 – 30 GHz (GSO)
29.5 – 30 GHz (NGSO)
Operations are subject to the provision of Article 4.4 of the ITU Radio Regulations (non-
interference basis to users of this spectrum) prior to international coordination.
SCHEDULE 3
Restrictions on equipment to be located within 7 km of the following National Grid
References apply - see Schedule 1, Sections 2 i) and j) for further details.
SE 20900 56100
SS 20500 12600
1
SCHEDULE 4
Permission to operate equipment subject to this Licence from any location within the perimeter fence of the aerodromes listed below must be
obtained from either the CAA or the Airport Authority.
CAA Contact: 0330 022 1500
Aerodrome name Address Postcode Telephone UK/CI/NI Easting Northing Aerodrome POC
Aberdeen / Dyce Aberdeen Airport AB21 7DU 01224 723714 UK 387997 812609 Duty Tels Officer
Alderney Alderney Airport GY9 3AJ 01481 822851 CI 556723 5506468 Senior Air Traffic Controller
Belfast Aldergrove Belfast International Airport BT29 4AB 028 9448 4281 NI 315195 380283 Duty Air Traffic Engineer
Belfast City Belfast City Airport BT3 9JH 028 9045 4871 NI 337483 376510 ATC Supervisor
Benbecula Benbecula Aerodrome HS7 5LA 01870 602051 UK 78483 855733 Senior Air Traffic Controller
Biggin Hill Biggin Hill Airport TN16 3BN 01959 574677 UK 541691 161064 ATS Manager
Birmingham Birmingham International Airport B26 3QJ 0121 780 0922 UK 417220 284022 Duty Engineering Officer
Blackpool Blackpool Airport FY4 2QY 01253 343434 UK 332307 431071 Senior Telecommunications Officer
Bournemouth Bournemouth International Airport BH23 6SE 01202 364150 UK 411201 97844 ATS Manager
Bristol Bristol Airport BS48 3DY 08701 212747 UK 350055 165098 Air Traffic Engineering Manager
Cambridge Cambridge Airport CB5 8RX 01223 293737 UK 548723 258544 Senior Air Traffic Controller
Cardiff Cardiff International Airport CF62 3BD 01446 712562 UK 306643 167265 Duty Engineering Officer
Carlisle Carlisle Airport CA6 4NW 01228 573629 UK 348265 560609 Senior Telecommunications Officer
Coventry Coventry Airport CV8 3AZ 02476 308638 UK 435519 274761 Senior Air Traffic Engineer
Cranfield Cranfield Aerodrome MK43 0AL 01234 754761 UK 494909 242446 Manager ATS
Dundee Dundee Airport DD2 1UH 01382 643242 UK 336868 729382 Senior Air Traffic Controller
Doncaster/Sheffield Robin Hood Airport DN9 3RH 01302 624870 UK 46603 39807 ATC Manager
East Midlands East Midlands Airport DE74 2SA 01332 852910 UK 445367 326168 Duty Engineering Officer
1
Edinburgh Edinburgh Airport EH12 9DN 0131 317 7638 UK 314389 673842 Duty Air Traffic Engineer
Exeter Exeter Airport EX5 2BD 01392 367433 UK 300326 93702 Senior Air Traffic Controller
Farnborough Farnborough Airport GU14 6XA 01252 526015 UK 485452 153678 Senior Air Traffic Controller
Filton Filton Aerodrome BS99 7AR 0117 969 9094 UK 359103 180229 Senior Air Traffic Controller
Glasgow NATS, Control Tower PA3 2SG 0141 840 8029 UK 247869 666993 Manager Engineering
Gloucestershire Gloucestershire Aerodrome GL51 6SR 01452 857700 UK 388598 221747 Duty Aerodrome Controller
Guernsey Guernsey Airport GY8 0DJ 01481 237766 CI 528960 5476102 Senior Air Traffic Controller
Hawarden Hawarden Airport CH4 0DR 01244 522012 UK 334748 364998 Senior Air Traffic Controller
Humberside Humberside Airport DN39 6YH 01652 682022 UK 509295 409914 Air Traffic Manager
Inverness Inverness Airport IV2 7JB 01667 464293 UK 277380 851836 ATC Inverness
Isle of Man Isle of Man Airport IM9 2AS 01624 821600 UK 228463 468452 Senior Air Traffic Engineer
Jersey Jersey Airport JE1 1BW 01534 492226 CI 558699 5451100 Senior Air Traffic Controller
Kirkwall Kirkwall Airport KW15 1TH 01856 886205 UK 348020 1008196 Senior Air Traffic Controller
Land’s End / St Just Land’s End Aerodrome TR19 7RL 01736 788944 UK 137630 28983 Senior Air Traffic Controller
Leeds Bradford Leeds Bradford International Airport LS19 7TU 0113 391 3277 UK 422418 441129 Duty Air Traffic Engineer
Liverpool Liverpool Airport Plc L24 1YD 0151 288 4300 UK 343507 382196 Senior Air Traffic Controller
London City London City Airport E16 2PX 020 7646 0205 UK 542674 180487 Duty Air Traffic Engineer
London Gatwick London (Gatwick) Airport RH6 0NP 01293 601060 UK 526676 140318 Duty Air Traffic Engineer
London Luton London Luton Airport LU2 9LY 01582 395029 UK 512422 220804 Duty Air Traffic Engineer
London Stansted London Stansted Airport CM24 1QW 01279 669316 UK 553916 223081 Duty Air Traffic Engineer
Londonderry City of Derry Airport BT47 3PY 028 7181 1099 NI 253681 422039 Senior Air Traffic Engineer
/Eglinton
Manchester Manchester Airport M90 1QX 0161 499 5025 UK 381796 384132 Duty Air Traffic Engineer
Manchester Manchester Woodford SK7 1QR 0161 439 3383 UK 390174 382355 Senior Air Traffic Controller
Woodford
Manston Kent International Airport CT12 5BP 01843 825063 UK 633140 165662 Senior Air Traffic Controller
2
Newcastle Newcastle Airport NE13 8BZ 0191 214 3244 UK 419802 571483 Senior Air Traffic Controller
Northolt RAF Northolt HA4 6NG 020 8833 8228 UK 509755 184987 Air Traffic Supervisor
Norwich Norwich Airport NR6 6JA 01603 420645 UK 622014 313753 Tels/Engineering
Oxford/ Kidlington Oxford Airport OX5 1RA 01865 844272 UK 446949 215594 Senior Air Traffic Controller
Pembrey Pembrey Airport SA16 0HZ 01554 891534 UK 240360 204220 Senior Air Traffic Controller
Plymouth Plymouth City Airport PL6 8BW 01752 515341 UK 250511 60229 Senior Air Traffic Controller
Prestwick Glasgow Prestwick International KA9 2PL 01292 511107 UK 236746 626815 Senior Air Traffic Controller
Airport
Redhill Terminal Building RH1 5YP 01737 823377 UK 530105 147698 Senior Air Traffic Controller
Scatsta Scatsta Aerodrome ZE2 9QP 01806 242791 UK 438844 1172284 Senior Air Traffic Controller
Scilly Isles / St Mary’s St Mary's Airport TR21 0NG 01720 422677 UK 92020 10300 Senior Air Traffic Controller
Shoreham Shoreham Airport BN4 5FJ 01273 467377 UK 519999 105406 Senior Air Traffic Controller
Southampton Southampton Airport SO18 2NL 023 8062 7113 UK 445278 116962 Duty Air Traffic Engineer
Southend London Southend Airport SS2 6YF 01702 608120 UK 586898 189290 Senior Air Traffic Controller
Stornoway Stornoway Aerodrome HS2 0BN 01851 707415 UK 145851 933141 Senior Air Traffic Controller
Sumburgh Sumburgh Airport ZE3 9JP 01950 460173 UK 439533 1110613 Senior Air Traffic Controller
Swansea Swansea Aerodrome SA2 7JU 01792 204063 UK 256904 191635 Senior Air Traffic Controller
Teesside Teesside International Airport Ltd DL2 1LU 01325 332811 UK 437041 512801 Senior Air Traffic Controller
Warton British Aerospace PR4 1AX 01772 852374 UK 341805 427980 Senior Air Traffic Controller
Wick Wick Aerodrome KW1 4QP 01955 602215 UK 336317 952799 Senior Air Traffic Controller
Wolverhampton Wolverhampton Aerodrome DY7 5DY 01384 221378 UK 382473 291103 Senior Air Traffic Controller
Wycombe Air Park / Wycombe Air Park SL7 3DP 01494 529261 UK 482630 190993 Senior Air Traffic Controller
Booker
Yeovil / Westland Yeovil Aerodrome BA20 2YB 01935 475222 UK 353823 115831 Senior Air Traffic Controller

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Telesat LEO Inc: Decision on application for

non-geostationary Earth Station Network

Welsh overview available

What we have decided – in brief

2. Introduction and background

NGSO satellite systems

The number of satellites in each constellation In-line events have more

As both satellites are transmitting and

suffer harmful interference during an inline

An in-line event can occur

Ofcom’s role in licensing NGSO earth stations

4 Radio Regulations (itu.int)

Our licensing process for NGSO applications

Figure 3: New NGSO licensing process

How we assess applications

i) improvements to an existing NGSO service;

Relevant NGSO ESN licence terms and conditions

Protection of GSO services

Conditions related to the NGSO licensing process

Ofcom may take a range of monitoring and enforcement actions where

3. The Telesat consultation and response

Summary of responses to Telesat consultation

9 NGSO Licensing Statement, Annex A3.12.

Lightspeed constellation on the global space environment, and potential risks to

4. Consultation responses on NGSO

Coexistence with existing NGSO licensed systems

Consultation responses regarding coexistence with existing NGSO licenced

Our assessment regarding coexistence with existing NGSO licenced systems

Coexistence with future NGSO systems

Consultation responses regarding coexistence with future NGSO systems

Our assessment regarding coexistence with future NGSO systems

Conclusion on NGSO coexistence

5. Assessment of competition issues

Summary of our consultation position on competition

Consultation responses related to competition

14 See paragraph 2.17 of the Telesat consultation.

Our assessment of consultation responses related to competition

19 Telesat response to Telesat further information request, Q2b.

20 See Annex to Telesat’s application: TELSAT-NET-1-Annex.pdf (ofcom.org.uk).

b) this deployment leads to harm to competition in the UK.

Conclusion on competition risks

6. Additional concerns raised regarding

6.2 Stakeholders raised two additional issues:

Interference from NGSO systems into GSO networks

NGSO earth sta�on could temporarily cause

NGSO earth sta�on communicates with

Interference may occur here

NGSO earth sta�on tracks NGSO GSO earth sta�on (sta�c)

International rules on coexistence between NGSO systems and GSO networks

What our licensing framework requires

22 Paragraph A2.6 in the annexes to our NGSO Statement.

Consultation responses concerning interference into GSO networks

Compliance with single entry and aggregate interference limits

Angular separation with the GSO arc

Operation in bands not subject to Article 22.2

Monitoring and enforcement of interference from NGSO systems

Our assessment of concerns about interference into GSO networks

and shapeable narrow beams operating in a multi-colour frequency reuse scheme,