Written Evidence Submitted by Hughes Europe and EchoStar Mobile Limited

(SPA0053)

 

Overview:  Hughes Network Systems Limited (Hughes) and EchoStar Mobile Limited (EML) hereby provide their comments on the proposed UK Space Strategy and UK Satellite Infrastructure call for evidence by the Parliament.[1]  Hughes is a satellite operator and a UK Space Licensee for a number of fixed satellite service networks in the Ka, Q, V and E frequency bands.  EML holds a license for mobile satellite services in the 2 GHz frequency band. 

 

Response:

 

 

The UK, with regard to commercial satellite systems, is particularly well-suited to be successful as a nation as a filing and licensing administration. Today, the UK has a well-established program for supporting filings for satellite systems through the International Telecommunications Union (ITU), which provides predictability and certainty for satellite operators.  In addition, the UK has announced its intentions to retain a reasonable approach to liability with regard to launch authorisations. 

 

While these two areas are attractive for satellite operators to work within the United Kingdom, the United Kingdom could become more attractive to the extent that further support is provided for retaining existing and making available access to additional needed spectrum for satellite networks both at the Ofcom and the ITU level.  By increasing the support of the commercial satellite industry for spectrum access, the satellite operators will be further incentivized to puruse the development, licensing and launch of their satellite networks through the United Kingdom.

 

 

 

 

 

 

 

Imposing unnecessary cost and administrative burdens on commercial satellite networks has meant that other countries have found themselves less attractive as satellite licensing administrations. While such a regulatory approach may have been acceptable in the past, as more countries seek to become space powers, then the imposition of unnecessary burdens and costs deters entry.  To this end, it is important that the UK, both at the Ofcom and UK Space levels (soon to be Civil Aviation Authority) levels, regularly review their regulations and processes to reduce unnecessary burdens and costs.  This includes a range of areas, including ensuring that filing and other fees are cost-based and eliminating or loosening reporting requirements.  

 

 

 

It is important that the UK Space Strategy continue to focus on the development of innovative technology.  The UK, because of its history of technology development, is well-situated to take a leading position in this area. However, to do so, the UK must be willing to support research and development through grants and other financial incentives. 

 

With regard to the UK launch potential, Hughes and EML are pleased with the recent direction of these policies that will serve to protect the space resource, without imposing unnecessary costs or uncertain liabilities on launch licensees.

 

 

With regard to communications satellite systems, including broadband networks, as discussed above, it is critical to future proof such systems that spectrum access and retention be a focus.  Satellite networks can last as long as 20 years in space and during that time, there need to continue to access the specturum resource on their payloads is required to support the development, manufacture, launch and operation of the satellite network. In addition, satellite networks can take several years to develop, manufacture and launch.  During this time and through the life of the satellite, the satellite operator must have long term certainty with regard to the spectrum access on its system. Further, as demand for broadband satellite services increase, like terrestrial systems, the UK must support access to additional spectrum for commercial communications satellite systems. 

 

(July 2021)


[1] Call for evidence - Committees - UK Parliament