Space Radiocommunication Services

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The Communications, Space and Technology Commission (CST) aims to develop a future plan regarding
the trends of the space communications services market in the Kingdom, as well as the need to update
the relevant regulatory documents to facilitate the procedures for licensing frequency spectrum for space
services, and to enable testing and experiments for innovative space services, taking into account future
applications and services for space communications services. Including non-geostationary satellite
systems, enabling narrowband satellite IoT services, direct-to-device (D2D) space communications, and
space activities including, but not limited to, Earth exploration (EO) activities, and space sustainability
and space debris management. To this end, CST is studying the current and future demand for radio
spectrum to enable satellite communications services and other space services.
This document also included a study of the most important trends, plans and needs shared by the parties
concerned with the use of the radio spectrum, as well as the developments observed in the leading
countries in the field of satellite services, particularly space radio communication services . In addition to
the CST’s role in reflecting the Kingdom’s directions at the regional and international levels, and
participating in meetings associated with the International Telecommunication Union (ITU), including the
World Radiocommunication Conference 2023 and upcoming global conferences, in order to support the
Kingdom’s directions regarding satellite communication services and other space services.
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For several years now, the Kingdom has recognized and understood the importance of the space and
satellite field, working to enable and develop technology not only with the industry but with academics
and Universities. In 19492 the KSA became a member of the International Telecommunication Union
(ITU), and in 1977 KSA established the Saudi Arabia’s National Centre for Science and Technology
(SANCST), that was later transformed into the King Abdul Aziz City for Science and Technology (KACST)
in 1985. KACST has supervised the launch of 17 Saudi satellites to provide satellite communications
services, imaging and reconnaissance services, and others such as amateur satellite services and ship
tracking services.
CST has also conducted many experiments with new technologies for non-terrestrial networks in order
to find innovative solutions that provide communication services through non-terrestrial networks and
provide means of communication in emergency and disaster situations, which in turn will contribute to
increasing network capacities for temporary events and events, in addition to enriching the market with
successful innovation experiences. Sustainable solutions, taking into account global trends in economic
and environmental aspects. Moreover, the CST has hosted different events such as the one organized
in collaboration with ITU last November 2022, under the name “Connecting the world from the Skies”. In
this forum, during a 3-days discussion, that brought together global experts in radio-communication and
space industry, as well as spectrum policymakers from national regulators and other relevant
international bodies. Furthermore,3 the former CITC (Communications and Information Technology
Commission) changed its name to the current Communications, Space & Technology Commission (CST)
to reflect the merge with the space regulatory sector and the integration of the space sector into
communications and technology. All these efforts prove how the Kingdom has historically invested in the
space and satellite industry.
Following these initiatives, the CST is publishing this new Space Radiocommunication services Outlook
to help the Kingdom to achieve its vision to ‘Unlock the potential of radiocommunication in the
Kingdom for a smarter and safer future’. This is a holistic vision that outlines the potential of the radio
spectrum to transform the Kingdom into a digital society by enabling different industries. This is also align
with the Saudi Vision 2030, by ensuring the availability of radio spectrum to meet the needs of the public
entities that deliver key safety and security services. CST also aims to ensure that the spectrum fulfils
the needs of direct spectrum users and end-users, thus serving the interest of the nation and benefitting
all Saudi Arabia.
This Outlook focuses on studying the current and future needs of radio spectrum, licenses to use
frequencies provided for satellite communications services, and other space services, as well as other
non-terrestrial network applications in the Kingdom. This document reviews the current status of satellite
2 Member States (itu.int)

3 November 20, 2022. For more information about the CST history please visit here.
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communications services and other space services in the Kingdom, including frequency band allocation
data, and the current status of frequency spectrum from the perspective of supply and demand, in
addition to reviewing current allocations and available frequency bands, then describing technical trends
in the market and identifying challenges that facing space uses. Also referred to in this document are the
main areas of work for the Kingdom, and the CST's plans to improve the use of radio spectrum and
contribute to the promotion of the satellite and space market.
The terms and phrases mentioned in this document shall have the same meanings contained in the
Communications and Information Technology Law and its Implementing Regulations; Unless the context
requires otherwise. The following terms and phrases - wherever mentioned in this document - have the
meanings indicated opposite each of them; Unless the context requires otherwise:
3.1 National Frequency Allocation Table: A document which describes the allocation of frequency
bands in the Kingdom for Radiocommunication Services in accordance with the International
Radio Regulations, which may include other information relating to conditions for use of frequency
3.2 Geostationary satellite (GSO): means a geosynchronous satellite that remains fixed or
approximately fixed relative to the Earth; and whose period of revolution is equal to the period of
rotation of the Earth about its axis.
3.3 Non-geostationary satellite (NGSO): means a satellite that does not remain fixed or
approximately fixed relative to the Earth and moves in relation to the Earth’s surface.
3.4 Non-terrestrial network (NTN): means the interconnection system that includes space
telecommunications stations and/or air-borne telecommunications stations, and may include
ground devices and equipment associated with it, and used for telecommunications purposes.
3.5 Earth stations in motion (ESIM): Earth stations communicating with GSO or non-GSO space
stations operating in the fixed-satellite service (FSS) operating on moving platforms (such as
aircraft or ships ) in specified frequency bands.
3.6 HAPS: High-altitude platform station: A station located on an object at an altitude of 20 to 50
km and at a specified, nominal, fixed point relative to the Earth.
3.7 LAPS Law-altitude platform station: Low-altitude platform station: A station located on an object
at an altitude of 1 to 12 km and at a specified, nominal, fixed point relative to the Earth
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The present section describes the status quo of space radio services from a policy and regulatory
perspective. It also includes the status of assignment of frequency bands, applications, research and
development, and current demand for specific applications of space radiocommunication services.
4.1. Policies and regulations for the space industry in the Kingdom
The Kingdom has long worked on the space industry and has historically cooperated in several missions
with other countreis including USA, China, the Russian Federation, Germany, France, and Kazakhstan;
and research bodies4. Since 1977 the Kingdom established the Saudi Arabia’s National Centre for
Science and Technology (SANCST), transformed into the King Abdul Aziz City for Science and
Technology (KACST).
In Rabi` II 1440 (December 2018), the Kingdom established the Saudi Space Commission under Royal
Decree No. A/147 dated 04/20/1440, which is a proactive step towards a more innovative future and
aspiration for the latest technologies and opportunities in the space sector in the Kingdom. The Saudi
Space Commission aims to achieve the Kingdom's aspirations for a better and more advanced life, and
its vision is compatible with creating a better and safer environment for citizens, while creating new
opportunities for more innovation and creativity. The strategy of the Saudi Space Authority requires
setting a set of goals and priorities that serve the interests of national security, protect it from space-
related risks, and encourage growth and progress in this field.
In 2021, the Communications, Space and Technology Commission established the Spectrum Advisory
Group (SAG), with the membership of (13) academic experts in the field of frequency spectrum from a
total of (10) national universities and research institutes Where aims to discuss spectrum issues, and
achieve national and international interests related to telecommunications services in general.
In November of 2022, the Supreme Space Council was established, which approves policies and
strategies for space programs, approves annual plans, monitors the implementation of strategies, and
achieves compatibility with the various needs of national sectors. Moreover, the name of the
Communications and Information Technology Commission (CITC) was transferred to the
Communications, Space and Technology Commission (CST) and transferring the regulatory and
supervisory competence for the civil space sector from the Saudi Space Commission to the
Communications, Space and Technology Commission in order to keep pace with the increasing
developments in the field of satellite communications services, which leads to changes Regulatory
positive in the competitive and investment environment.
The CST seeks to meet the current and future needs of frequency spectrum for space communications
services and other space services. The authority also leads the international discussions required to
4 International cooperation in the peaceful uses of outer space: activities of Member States.
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meet the challenges of increasing space activities, and is keen to exploit the potential of the space
economy to maximize social and economic returns.
4.2. Policies and regulations for the satellite communication industry in the Kingdom
CST believes that the age of “Wireless Proliferation” is coming to all critical sectors in our lives, and such
an age needs to be supported in order to advance these sectors. Thus, CST has been constantly working
to promote the adoption of the latest innovative and disruptive wireless technologies through several
methods that include supporting research and innovation in spectrum and wireless domains, building
strategic partnerships to conduct new technologies trials, raising awareness campaigns, in addition to
the continuous engagement with academia and universities, both nationally and internationally.
This is reflected in the efforts carried by CST to modernize the regulatory framework in a record time.
Notably, while the space economy is estimated at 371 billion dollars, the satellite telecommunications
component of the industry makes up for around 73%, with 271 billion dollars5.
The CST has also worked during the past years to update the regulatory framework for the provision of
services via satellite, especially with regard to the provision of space communications services, in line
with the space strategy and its awareness of the challenges to enable space technologies and services,
and the embodiment of the desired social and economic value in the Kingdom. Therefore, the CST issued
a Non-Terrestrial Network (NTN) regulations during 2022, as these regulations introduced a new
approach that helps facilitate the licensing of all types of non-terrestrial network applications.
4.3. Current spectrum allocation and assignments
The Kingdom’s National Frequency Plan is largely aligned with the ITU International Allocation Table and
defines the allocations for the radiocommunication services. The allocations made for satcom and other
space services, on primary basis, are described below. It should be noted that this ranges are also often
co-allocated on primary basis with other radiocommunication services.
Allocations in the National Frequency plan

12.20
6.35
3.44 2.78
0.45 0.83
L-band (1–2 GHz) S-band (2–4 GHz) C-band (4–8 GHz) X-band (8–12 GHz) Ku-band (12-21 Ka-band (26–40
GHz) GHz)
Allocated to satellite and space radiocommunication services
Figure 1: Allocations in the National Frequency plan6
5 Satellite Industry Association: State of the Satellite Industry Report.

6 Source: National Frequency Plan for the Kingdom of Saudi Arabia.
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The allocation, assignment and use of spectrum is fundamental to further develop the satellite and space
industry. and to enable of several applications including civil and governmental uses. The assignments
are divided as follows:
Assignments of spectrum for space services in the Kingdom
126
107
58
12 16
2
L-band (1–2 GHz) S-band (2–4 GHz) C-band (4–8 GHz) X-band (8–12 GHz) Ku-band (12-21 GHz) Ka-band (26–40 GHz)
Figure 2: Assignments of spectrum for space services in the Kingdom
The abovementioned assignments for satcom and other space services include several applications
provided within the Kingdom. The most common uses in the frequencies for satcom and other space
services are described in the following table. It should be noted that bands are allocted for services other
than space services, thus in many cases, available bandwidth is shared or divided between services to
ensure operation and coexistence of services.
Band Applications
Some of the uses in this band includes Global
Positioning System (GPS) carriers and satellite mobile
L-band (1–2 GHz)
phones for providing communications at sea, land and
air.
including weather radar, surface ship radar, and some
S-band (2–4 GHz)
communications satellites
covering satellite communications, EESS, full-time
C-band (4–8 GHz)
satellite TV networks or raw satellite feeds
uses such as radar applications, weather monitoring, air
X-band (8–12 GHz)
traffic control and maritime vessel traffic control
The uses in this bands vary from TV and satellite
Ku-band (12 - 21.2 GHz)
communications to ESIMs in aircrafts and vessels.
Ka-band (26–40 GHz) Satellite communications and Gateways.
TABLE 1: ASSIGNED SPECTRUM FOR SPACE SERVICES IN THE KINGDOM.
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The services that are licensed in the Kingdom, measured by the granted licenses under the previous
regime (before the issuance of the NTN regulations framework described in the last part of this section),
are as follows:
Issued licenses for satellite services

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3
1
VSAT GMPCS Broadband satellite service
Figure 3: Licenses issued for space and satellite services7
Currently, CST is analysing the need to update the allocations made for satcom and other space services
in the Kingdom aligned with market needs and international best practices, in order to update it
accordingly.
The 2100 MHz auction for non-terrestrial services was conducted in November 20228, as per the
announcement previously made by the Kingdom, considering the evidence of competitive demand for
the available blocks.9 Finally, in December 2022 all available blocks were awarded and the license holder
is now required to build an Air to Ground (A2G) network covering the air routes in the Kingdom with
internet access services, and to operate mobile satellite services (MSS) across the Kingdom to provide
applications that leverage MSS allocation and technological advancements and trends. 10
4.4. Current spectrum demand and planned applications
The demand for satcom and other sapce servoces spectrum has increased over the last years due to
several applications that include universal and remote connectivity and smart geospatial analytics for
agriculture. Other emerging applications have also contributed to the increasing demand of spectrum,
including IoT, Earth exploration-satellite services, non-geostationary satellite systems, novel medium and
low-Earth orbit satellites, satellite systems in global maritime distress and safety systems, and Earth
stations in motion.11 On top of that, there is an increasing need of spectrum for R&D initiatives triggered
by academics and Universities, which the CST supports and values.
In addition, newer services, also require spectrum to operate and put presents additional spectrum
needs. A survey conducted by the CST during May and June of 2022 shows that demand for satcom
7 Source: CST public registry of valid licenses.

8 Information Memorandum of the Spectrum Auction for NTN in the 2100MHz Band.
9 Spectrum Auction of 2100 MHz Radio Licenses for Non-Terrestrial Networks, Information Memorandum.
10 CST announces NTN auction results.
11 BCG (2020), “The Coming Battle for Spectrum”.
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services and applications is also expected to grow and with it, the requirements to access the spectrum
to operate. Over half of the survey’s participants (53.6%) mentioned they have plans to provide additional
services and acquire more licenses; while the rest (46.4%) currently have no plans to expand their
services. as shown below:
33.3%
26.7%
20.0%
6.7% 6.7% 6.7%
IoT Broadband satellite ESIM Air to ground Aeronautical Private comms

services navigation
FIGURE 4: ADDITIONAL SERVICES UNDER CONSIDERATION. AERONAUTICAL NAVIGATION REFERS TO THE SERVICES PROVIDED FOR RADIO
NAVIGATION ONBOARD AIRCRAFTS AND THE ASSOCIATED OPERATION WITH GLOBAL POSITIONING SYSTEMS.
In terms of the demand of satcom services, 82.1% of the participants expect an increase, while 10.8%
foresee a decrease based on the growth of mobile terrestrial services, and the remaining 7.1% expect
the demand to stay constant.
The demand for satcom and non-satcom services in the Middle East and North Africa (MENA) region is
expected to grow by 2030 at a compound annual growth rate (CAGR) of 11% reaching 374 billion. This
is particularly driven by the following services: positioning, navigation, and timing; communications ; and
Earth observation.12
Additionally, in terms of potential demand, it should be considered that the Kingdom spans a vast territory,
and a large portion of its population live in remote areas, and 15.71% of the population lives in rural
areas,13 where terrestrial networks may not reach, or are more costly to deploy, making satcom
connectivity the most efficient solution in many cases.
Likewise, the Kingdom’s industry will also demand more connectivity, as modern production increasingly
relies on always connected devices, particularly those on remote places, usually out of reach of terrestrial
networks, and operating moving assets (such as vehicles and other transportable devices). For instance,
the IoT market in the country is expected to expand over the next five years and 82% of the medium and
large organizations in the Kingdom will adopt an IoT solution by 2023, 14 meaning more demand for
connectivity and satcom services is expected.
12 KSA Space Strategy presentation, CITC work document not published.

13 Rural population (% of total population) - Saudi Arabia
14 IoT Demand in Saudi Arabia A Survey-Based Study
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4.5. Advancements in research and development
The Kingdom has a long track-record of working on the development of trials to enable innovative
services, particularly regarding satellite communications and novel applications. This also includes the
advancement of academic trials and projects regarding, among others, the development of CubeSats,
as well as international cooperation with several nations for research and development purposes. As part
of this path, CST successfully launched the Non-Terrestrial Network program with the objective of
capturing the importance of NTN and allowing the best framework for companies to test and deploy this
technology.
NTNs are variants of space-borne and aerial communication networks including GEO, MEO and LEO
satellites and other technologies such as High-Altitude Platform Systems (HAPS), Low Altitude Platform
Systems (LAPS), and air-to-ground (A2G) networks. While these concepts will be further discussed and
analysed in the next chapter, this section will describe how the “NTN Program” will enable the NTN
technologies to facilitate the roadmap to the 6G communications. In particular, this section describes the
trials already conducted and their outcomes.
This trial was conducted in collaboration with Inmarsat and Zamil Marine, to explore the capabilities of
the technology to connect offshore vessels and utilising data-driven insights from Inmarsat’s applications
partner, VPS Decarbonisation, to reduce emissions from operations. With a very positive outcome during
the initial trial, Zamil Marine is now rolling Inmarsat’s Fleet Data solution out across the entire fleet, to
support their fleet digitalisation requirements. The trial showed some ship operators seeing up to a 20%
CO₂ reduction on certain vessels, by utilising smart data to drive emission reductions. Based on current
prices in the market, the savings could equal more than USD 0.5 million annually on a single vessel. 15
This trial was conducted with the aim of demonstrating the potential use of 5G NB-IoT over LEO satellite
to cover remote areas, and it took place in one of Aramco’s remote sites located in the Ain Dar area. The
use case was defined in collaboration with Aramco to represent important data and parameters for its
operation, such as temperature, humidity, CO2, GPS, etc. This data was collected every 2 hours from
the sensors where the transmitted packets were contained. An ultra-high reliability connection was
achieved showing that, the LEO-aided 5G -IoT satellite can be used to provide coverage to remote areas
in harsh environments.16
15 For more information about this trial please visit CST website here.
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This trial goal was to show the speed for a transition of data and the latency for Broadband Satellite using
NGSO satellite network that supports data transmission from remote locations that does not have a
network coverage. The trial was conducted in one of Aramco's remote sites located in the Shudgm area.
The trials result show a download speed of 2514 Mbps, and upload speed of 96 Mbps and network
measurements of round trip latency 23ms, 98% successful pings and jitter 2ms. It also enabled video
conference meeting, internet surfing and streaming.17
The trial was conducted to test the A2G technology in the airspace between Riyadh and Jeddah, with a
Saudi Airbus A321 that flew on its regular route service. In order to achieve this test, several A2G base
stations were deployed on the ground to provide seamless broadband connectivity to this aircraft. The
solution used for this specific test was quite similar to the commercial setup, which consists of an aircraft
modified with a Wi-Fi cabin network and an A2G terminal, the ground network, and service operations. 18
At the beginning of 2022, Saudi Arabia became the first country to successfully conduct a trial to provide
5G coverage in the Red Sea Project using a High-Altitude Platform Systems (5G HAPS). The trial was
facilitated by CST in cooperation with Stratospheric Platforms company, using a Grob 520 aircraft which
transmits radio waves from the sky towards the ground. The trial provided a high-speed, and low-latency
connectivity to foster the provision of high-speed communication services to remote areas, enabling
emergency communications and temporary coverage for events and tourist hotspots.19
This trial tested satellite and cellular mobile, hybrid communications with an Unmanned Aerial Vehicle to
demonstrate direct-to-device possibilities for smart phones and IoT devices at a global level. The trial
was conducted by Airmarket and Omnispace, who tested D2D ubiquitous mobile voice and data
communications using both mobile cellular and Omnispace’s satellite non-terrestrial network (NTN)
system. The trial took place at the Aramco, Dhahran Fire Training Center while a drone was controlled
remotely from Edmonton, Canada and flown in Dhahran using the simulated hybrid satellite and cellular
mobile network. The objective was to successfully connect the drone to both the Omnispace existing
non-geostationary satellite orbit (NGSO) network and the Saudi Telecom Company (STC) cellular
18 For more information about this trial please visit CST website here
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network. The overall objective was achieved, demonstrating hybrid command and control of a UAV using
both cellular and satellite communication systems.20
Question No. (1): How can the CST, through its relevant regulatory documents, allow the
implementation of academic projects that require the use of radio frequency spectrum?
Question No. (2): What are the needs of the academic community that require concrete regulatory
provisions to enable research and development in the field of space radiocommunications?
Question No. (3): What are the regulations that can be added to licenses for current experiments and
tests in order to ensure the implementation of research and development efforts?
Question No. (4): What are the regulatory obstacles that currently exist in front of expanding investment
in tracks and testing in the Kingdom, and what are the possible proposals to solve these obstacles?
Question No. (5): What are the challenges that have not been addressed or addressed currently when
updating the relevant regulatory documents? What are the possible proposals to overcome these
challenges?
Question No. (6): What does the space market in the Kingdom need to enable satellite systems to
provide various radio communication services?
5.1. Technologies of satellite communication services

The field of space communications services is witnessing continuous development and progress, as it
has been noted recently that many non-geostationary satellite systems have been launched into low
Earth orbit, and there is also a rapid development in the provision of various services in MEO and GEO
orbits. Examples of satellite communications services are:
I. Broadcasting Satellite Services:
Broadcasting satellite services also known as direct-to-home services allow television programs and
other media content to be delivered to viewers around the world through satellite communication
technology. These services work by sending a signal from the broadcasting center to a satellite in the
geostationary orbit, and the satellite sends the signal back to Earth to be received by the satellite
receiving antenna and the remote control or the receiver built into the TV. Satellite broadcasting services
provide a wide range of programming, including live sports, news, movies and television programmes,
and provide access to media content in remote or rural areas where terrestrial broadcasting infrastructure
may be limited or non-existent.
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II. Mobile Satellite Services:
This service is used to provide connectivity to mobile devices such as smartphones and other wireless
devices. Mobile satellite services enable communication in areas where traditional terrestrial networks
are not available, such as in remote areas or when natural disasters occur. Mobile satellite networks are
typically designed to provide voice and data services for personal and commercial use, and tracking and
monitoring services (MSS) can also be used, such as managing and tracking air and sea fleets.
III. Fixed Satellite Services:
A type of satellite communication service that provides point-to-point and point-to-multipoint connectivity
between fixed locations. FSS services are mainly used to transmit voice, video and data. FSS services
operate on a range of frequency frequencies, including: (C), (Ku) and (Ka) bands, and provide high
bandwidth and reliable communication services to companies, governments and individuals in all
countries. around the world.
FSS services are used in a variety of industries, such as communications, oil and gas, marine, aviation
and defence. This service is particularly useful for remote and hard-to-reach locations where traditional
terrestrial communication infrastructure is not available. FSS services provide flexible and cost-effective
solutions for customers who need to establish a reliable communications network over long distances .
5.1.1 The latest technologies used in satellite communication services

I. Non-geostationary satellite systems: They are groups of satellites launched into low earth
orbit, i.e. Earth-centered orbits with an altitude of (2000) km or less. The first systems from
these satellites (Globalstar, Iridium) were launched in Late 1990s In the past years,
investment growth has increased dramatically in such systems, and companies such as
(Starlink and OneWeb) have emerged, which currently provide their services through
networks of this type of satellite, in addition to many other companies such as Amazon
Kuiper.
The number of launches of low-Earth orbit satellite constellations has increased dramatically,
and the number of satellites of this type is likely to double in the coming years.
II. Satellite IoT: Satellite IoT technologies can work on communication between satellite
networks and IoT sensors or IoT end nodes. With the development of Internet of Things (IoT)
technologies and the spread of its applications, satellite communications are sometimes
relied upon to ensure the connection of IoT devices and machine-to-machine (M2M)
communications. IoT technologies have also changed the technologies used in many
industries, such as agriculture, livestock and marine, transportation, logistics, energy, and
infrastructure.
III. Direct-to-device (D2D) satellite communication services: Direct-to-device (D2D) satellite
communication services are considered one of the most important services that allow direct
communication between mobile cellular devices and satellites, which creates business
opportunities with companies working on this type of technology, such as (Iridium, Lynk,
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GlobalStar, AST SpaceMobile, SpaceX) and others. Recent years have seen rapid
developments to make the service commercially available worldwide. The technology is
advancing faster than the regulatory side, which creates a challenge in its widespread use
around the world. Direct-to-device (D2D) satellite services are based on the use of MSS bands
or on bands traditionally used primarily by the Mobile Service (MS) which are often licensed at
expensive auctions.
5.2. Positioning, Navigation and Timing (PNT) Services:
This type of activity is a mixture of three main operations, as positioning means the ability to locate
objects with coordinates with high accuracy, navigation also represents the ability to navigate and
determine the current location and specify the destinations to be reached, while timing includes the
ability to obtain accurate timing And maintain the global standard in timing anywhere in the world.
The countries of the world have focused their efforts on improving flexibility and efficiency through
positioning, navigation and timing systems, and exploiting them mainly in the security and
economic fields, as these systems are an essential element for critical infrastructure operations
across many sectors, such as agriculture, transportation, electric power networks, and emergency
services. , and others.
5.3. Space activities
I. Space Debris Mitigation: Space Debris Mitigation is defined as all inactive or active man-made
objects, including fragments and other elements, that are around the Earth's orbit or that return to the
Earth's atmosphere. Space debris threatens and endangers many space missions and may affect many
existing space services. The increasing number of satellite launches of many objects in space poses a
threat to the activities of the space economy and existing services that depend on satellite services. The
increase in the number of non-geostationary satellite systems is one of the main causes of the increase
in space debris. Not only is space debris management essential to the long-term sustainability of outer
space activities; It also provides existing business opportunities for space debris removal solutions as a
proactive activity to address problems and ensure sustainability.
II. Earth Observation and Imaging (EO): Earth observation is one of the space activities carried out by
satellites with imaging capabilities to collect physical, chemical and biological data of the planet through
remote sensing techniques. These activities are not only conducted by companies or governments;
Rather, academics and scientists participate in it. Earth observation activities can detect changes in the
Earth's natural environment, which scientists can later assess and use in environmental damage
prevention, crisis management, and other activities. Earth observation operations are also witnessing
funding aimed at launching many projects to develop the sector in a number of countries of the world, as
the European Space Agency (ESA) - for example - has used Earth observation satellites within its "Earth
Explorer" missions for several years to take advantage of technologies in data collection in business
environmental research and development.
III. Astronomy and Space Exploration: Astronomy is the scientific field that studies celestial bodies,
outer space, and the universe as a whole. While space exploration refers to the exploratory activities of
space using advanced technologies. The field of astronomy and space exploration meet in the fields of
developing, manufacturing and operating the scientific instruments used in these activities. Therefore,
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many countries around the world are establishing national scientific bodies for astronomy and space
science to promote exploration and experiments in space.
IV. Space tourism: Space tourism means human travel in outer space for the purposes of pleasure and
tourism, without the need for the professional and educational level of the astronaut. Although
commercial space flights manned by civilians or planetary inhabitants do not seem easy in the near
future, commercial suborbital flight missions have already taken place, for example flights organized by
companies such as Blue Origin and Virgin Galactic. As the cost of this mission amounts to nearly half a
million dollars, which may prevent space tourism activity from being widely available at the present time.
Many companies are constantly working on their designs and technologies for this activity to expand and
increase economic activity.
V. Weather Radars: Weather radars are technical tools placed on satellites that transmit electromagnetic
pulses in order to measure the location and intensity of precipitation, hail and snow in real time. This
technology provides the possibility of obtaining measurements for the National Meteorological Services
and other organizations, as well as alerting in the event of storms or severe weather conditions, as the
global market value of this type of activity reached (233.1) million US dollars in 2019 AD and is expected
to reach (261.4) million US dollars by 2027.
VI. Assembly and manufacturing services in space (ISAM): It aims to provide general services and
maintenance of various satellites, as this activity has become a focus for some countries, and it is
expected to have a major role in building the new space economy. Among the services provided are
space refueling and in-orbit maneuverability. And since there are increasing needs for these services,
the United States of America published a strategy on assembly and manufacturing services in space in
April 2022, and established a working group in this field with the aim of covering the growing interest in
this activity.
VII. Space situational awareness (SSA): This activity relates to the observation of objects in space.
The systems developed in the framework of this activity aim to track objects in orbit and predict their
whereabouts at any time. Such systems have already been developed and used by several countries
such as: the United States and the European Union (European Space Program (Galileo) and satellites
(EGNOS), (Copernicus GOVSATCOM) and Russia. These systems continue to improve, which is
reflected in the presence of more accurate and better data to prevent The occurrence of future space
collisions between satellite operators in space.
VIII. Radar imaging techniques (SAR): It is a type of radar that is used to create two-dimensional
images or reconstruct three-dimensional images of objects using remote sensing technology, as it can
penetrate the cloud cover, allowing to see the physical changes of the earth's surface, collapses,
earthquakes and geophysical movement to the ground. Capella Space, UMBRA Space, ICEYE is one
example of a technology company that builds satellites for such purposes that are used by regional
organizations such as the European Union Space Agency.
5.4. Global regulatory updates
The CST, in its role as a national regulator of frequency spectrum, determines the future need of
frequency spectrum for space services, especially since these innovative and modern services may
17
require the inclusion of new definitions at the international level for the distribution of their frequency
spectrum. Therefore, the Kingdom actively participates and leads the discussion in the region and abroad
towards enabling modern technologies in non-terrestrial networks in general and space networks in
particular.
5.4.1 US: Spectrum for space launches and experimental licenses
The US made a change on its National Frequency Allocation Table in order to ensure spectrum is readily
available for the operation of commercial space launches, considering the proliferation of several types
of launches from traditional satellite communications systems to more advance services aiming to
transport crews into space, they all require access to spectrum in order to communicate with the mission,
thus, the FCC introduced a footnote to designate a band23 specifically to support commercial space
launches, the allocation is limited to use by space operations for the telemetry and tracking operations
of launch vehicles during pre-launch testing and space launch operations.24
The US also introduced the “Spectrum Horizons experimental radio license”, a type of license for testing
and marketing devices on frequencies above 95 GHz where there are no existing service rules 25. The
license differs from traditional test licenses because it has broader eligibility, longer term, and less
burdensome requirements, in order to allow experimentation and innovation, additionally, 21.2 GHz are
designated for unlicensed use to test devices operating in bands above 95 GHz.
5.4.2 UK: Updated spectrum management policy
Likewise, the UK published a public consultation to update the space spectrum management policy 26,
considering the large numbers of NGSO satellites that are being deployed; the increasing importance of
information collected by Earth observation satellites on climate change and the increase in space activity
in general. The third element27 of the UK’s proposed plan is the use of spectrum for space activities,
particularly space launch, in-orbit servicing, debris tracking and removal, considering that demand for
these activities is growing and each of them may have spectrum requirements of their own 28. The
proposal also includes space weather as the set of services used to monitor outer space conditions that
impact operations of satellites, and other application relying on satellites, such as aeronavigation, power
and infrastructure and off course, space operations. The proposed line of work includes working on
forthcoming ITU decisions and recommendations for space weather. In terms of space launches the UK
considers that their current licensing framework is sufficient to address these needs. However, for
additional in-orbit operations such as vehicles, and other operations the UK indicates the need to start
working on analysing the specific needs of spectrum, and even if particular allocations should be
included.
5.4.3 Canada: Space Strategy
In 2019, the Canadian government published “Exploration, Imagination, Innovation: A New Space
Strategy for Canada” which refers to Canada’s past, current and future role in the space industry.
This Strategy was drafted to identify and highlight Canadian strengths like robotics, and advance science
and innovation. Their innovative practice areas focused on artificial intelligence (AI) and biomedical
18
technologies, at the time. It prioritizes the concept of acknowledging space applications and inventions
as solutions to important challenges on Earth; challenges like extensive access to broadband services,
the protection of Canada’s sovereignty through space-based defence assets, or the utilization of space
medicine to improve healthcare in remote communities.
Since the publication of the Strategy, the government decided to update the document and launched in
2023 a public consultation in order to ensure that Canadian industry is equipped with a modern regulatory
framework for space. This review aims to make Canada's space-related regulations updated with the
changes in the global space sector so that they enable innovative space companies to prosper in the
country.
5.4.4 Australia: New Space Outlook
In 2022, the Australian Space Agency published on their website the Australian Space Outlook. This
publication offers a more commercial and inclusive view of the Australian Space Agency, its people and
operations. New Australian Space Agency partnerships and industry agreements are being explored as
well as the progress of the Australian Space Agency, Australian companies and their new technologies
and products. The training and education of the next generation of space professionals is also addressed
as key topic for the country.
5.5. Funding of space research and development and human capital
Space radiocommunications activities are very high in research and development and pose a lot of risks
and uncertainties, making it a very time-consuming endeavour. In this context, the public sector
participation on the space economy is evolving from developer to customer.
However, Government’s participation is still very relevant to activate the space economy, offering an
opportunity to act as a partner and fill the funding gaps where the private investment may not be available.
Because of this, several nations have traditionally invested resources for the development of capabilities,
research and overall partnerships with the Academia. Some examples are described below:
 United Kingdom Several calls have opened in 2023 offering funding to UK research institutions
and academia with no commercial interest. Such programs are the “Call for the ESA Earth
Observation programme, InCubed2”, regarding proposals to develop innovative and commercially
viable products and services that generate or exploit the value of Earth observation imagery and
datasets- where the total funding amount is £1,400,000. The “2023 Call for Mars Exploration
Science” via which the UK government is making funding available for science research that
utilises data from current Mars exploration missions, by offering £2,000,000 - indicatively.
 Canada The “Canadian Student Participation in Space Conferences and Training Events” is a
program that addresses Canadian students and their participation to national and international
space conferences and training events, offering them the opportunity to learn about and be
involved in the latest developments in space science and technology, to develop their professional
network, and in some cases, to present their research results at the national and international
level.
19
5.6. NTN Future Market Analysis
Satellite and space services are gaining a new momentum with the opportunity for the Kingdom to
leverage it and extract economic and social value from these services and applications.
Within this context, several other applications based on satellite and space spectrum use are emerging
around the world. This can be illustrated by analysing the number of constellations by applications, as
shown below:
Number of constellations by application

120
103
100
80
66
60 51
43
40
22 24
14 16 17 18
20 10 11 13
0
Constellation-as-a-service
Weather
Broadband internet
Orbital Data Relay
Synthetic Aperture Radar
Internet of Things/Machine
Optical Earth Observation
Others
Automatic Identification
Space Situational
Hyperspectral Earth
Laser communications
Infrared Earth Observation

Awareness
Observation
to Machine
System
FIGURE 5: NUMBER OF CONSTELLATIONS BY APPLICATION21
The NTN market has a potential value of 19.6 USD billion by 2036 from broadband and internet access
(9B USD) and B2B and business applications, mainly IoT (10.7 USD). It is of great importance to highlight
the momentum that NTNs have gained in the satellite and space field, which CST has recognised since
the beginning by supporting and maximising its benefits.
21 NewSpace Constellations by applications. The category “others” comprises applications with under 10 constellations, including services such as: 3D
Imaging, Asteroid tracking, Blockchain, GNSS Reflectometry, Mineral prospecting, Astrophotography, Earthquake, Mars, Orbital Display
(advertising), Wireless energy supply, GNSS Radio Occultation, On-orbit servicing, Space weather, Active Debris Removal, Asteroid prospecting, In-
orbit computing, QKD (quantum key distribution), Satellite-to-device.
20
CST seeks comments on:
Question No. (8): What are the other modern trends - not mentioned above - whether in the field of
space or the field of satellites?
Question No. (9): What are the other regulations that must be taken into account?
Question No. (10): What are the experiences of other countries - not mentioned above - in setting
specific policies and regulations for non-terrestrial networks? Have other countries - not mentioned
above - requested public consultations on this subject?
Question No. (11): What are the regulatory directions that you think are more related to the
technologies of direct-to-device (D2D) satellite communication services?
The radio spectrum is scarce and finite resource which must be efficiently managed. For satellite and
space services, spectrum is the essential element that enables all their operations. Therefore, the
emergence of new technologies, applications, as well as the evolution of existing ones, presented in
previous sections, create several challenges for satellite and space spectrum management.
Consequently, administrations must adapt their frameworks to enable the operation of these solutions
and the materialization of the social and economic value that spectrum utilization can create.
6.1. Spectrum Licensing mechanism
This challenge requires administrations to implement efficient mechanisms for spectrum licensing,
particularly, implementing a flexible approach. The move from the traditional command and control 22
approach to the flexible approach is being implemented by administrations around the world as part of a
modern spectrum management. This management implies that spectrum is shared between services,
when technically possible, and administrations do not enforce rigid elements giving room to promote
innovation. This approach is based on market mechanisms and undertakings can decide the amount of
spectrum required, the alternatives for transacting in the secondary market23, and general authorizations
22 The command-and-control approach was the first implemented by administrations when wireless technologies started their massification, based on
the premise that to ensure the correct use of the spectrum a strict centralized definition of the band that could be used, the amount of spectrum
that could be licensed, the eligible users, the technical parameters and conditions, the analysis of the proposed uses and services to be provided,
and then the administrative decision to grant permission to use the defined band under the specified conditions. Command-and-Control Approach
to Spectrum Management, GAO report 04-666 Spectrum Management.
23 Where spectrum licenses are transferred between assignees when efficiently possible.
21
are issued to use bands that have been allocated exclusively for specific services ensuring no
interference will take place24.
International best practices for spectrum licensing are based on the premise that spectrum licensing
regulatory framework should focus on eliminating the artificial market access barriers deriving from
licensing procedures, for example, not requesting individual licenses if no coordination or efficiency
issues arise. This approach is widely used in European jurisdictions, where decisions to harmonize the
use of the spectrum have been implemented.25
Additional leading jurisdictions (Australia, Brazil, Canada, Russia, and the United States) allow issuing
of a network license that would cover several earth stations if there were no interference with terrestrial
services. The Kingdom currently applies this approach for several applications such as ESIMs, GMPCS,
VSAT, BBSS and others. Likewise, the mentioned jurisdictions set forward rules for licensing of NGSO
systems, acknowledging their particularities and challenges, regarding spectrum use and ensuring
competition for future systems, while the Kingdom’s current framework does not fully include these
conditions.
Moreover, CST has already identified the importance of employing several mechanisms for spectrum
licensing to allow for more efficient uses and management. The Kingdom recognizes the existence of
differentiated licensing regimes26 (i.e., licensed, lightly licensed, and license exempted) and how they are
applicable to different bands and uses. For instance, the document recognizes the need to evaluate and
implement a light licensing regime in bands that allow for non-interference operations subjected to a prior
registration on a database and implement the license exempt regime for some bands mainly for WLAN,
Wi-Fi, and the unused bands in the 66-71 GHz range.
Therefore, to ensure the efficient management of space and satellite spectrum, it is necessary, to further
move from the command-and-control approach and consolidate the modern and flexible approach as
seen in the benchmark of international best practices and early regulatory developments to address
spectrum challenges for satellite and space services.
As shown in this section, the emergent space services will require the revision of the satellite services
licensing and allocations, in order to accommodate and promote these newer services. While some
countries are already advancing in the efforts, it is very likely that agreements at the international level
will be required. The Kingdom recognises its position to exploit this opportunity and contribute to the
ongoing discussions while updating the domestic framework.
24 Also, under this approach spectrum auctions are designed to obtain more coverage of services rather than receiving larger fees for the granted
licenses ICT Regulation Toolkit, produced by the Information for Development Program (infoDev) and the International Telecommunication Union
(ITU), Module 5.
25 Decisions such as ECC/DEC/(18)05, ECC/DEC/(15)04, ECC/DEC/(19)04, ECC/DEC/(06)02, ECC/DEC/(06)03 and ERC/DEC/(99)06.
26 Spectrum Outlook for Commercial and Innovative Use 2021- 2023.
22
In this sense, the Kingdom actively promotes research, innovation, and testing of newer technologies
and spectrum use, and will lead the development of test and use cases and will contribute to the
international decision-making process.
6.2. ITU rules and filing procedure
Traditional allocations have been challenged for the last few years with the massification of NGSO
satellite systems, the increased services and applications they can serve, and the need for strong
coordination from these systems, considering they are constellations composed of thousands of satellites
constantly moving over the Earth. Concretely, the operation of NGSO mega constellations may pose a
risk for the deployment of future services and thus imply regulatory challenges from both competition and
spectrum coordination perspectives with present and future systems, which may also impact the quality
of services.
To address these challenges, at the international level, the ITU has been working on adapting the
applicable rules to assess coordination needs and to prevent radio-frequency spectrum warehousing,27
including the mile-stone approach adopted in the World Radio Conference (WRC) in 201928. The
approach establishes the requirement to deploy 10% of their constellation within two years after the end
of the current regulatory period for usage, 50% within five years, and complete 100% of the deployment
within seven years. However, further developments at the ITU level are still required, to set out clear
common rules regarding the procedures to conduct international coordination and the notification and
filing procedures. Said rules are needed to address the challenge of accessing orbital resources by
several different stakeholders and the announced crowding of space that requires clear conditions to
prevent speculative satellite systems or those intended to warehouse orbital resources.
6.3. Newer services increase demand for spectrum allocation for space services
Traditional allocations and radio services definitions are currently challenged by the appearance of novel
services and applications that may not have any licensing in place yet. While the discussions and
decisions will have to be agreed at the international level, some nations are starting to adapt their
regulatory framework and allocations to enable newer services.
The increase in outer space activities ranging from establishing crewed stations orbiting the Moon and
the lunar surface, human habitation concepts either in orbit or as crew transport vehicle to Mars or
elsewhere, and several other projects also pose a challenge for spectrum allocation and licensing,
because frequencies are required to transmit and receive space operations signals to control the satellite
and communicate.29 For instance, as management of space debris becomes a more and more pressing
27 ITU and space: Ensuring interference-free satellite orbits in LEO and beyond.
28 Master International Frequency Register (MIFR).
29 Managing radio frequency spectrum amid a new space race.
23
issue, it is also turning into an economic opportunity, with technologies being actively developed to
conduct debris removal as a proactive activity to clean up space.30
Likewise, in-orbit servicing solutions are also being developed around the world by both public agencies
and private companies looking to extend satellites life span31 and to provide services to crews stationed
in orbit. The first commercial in-orbit servicing mission was launched in 2019, making this still a nascent
industry, however it could represent a USD 3 billion market over the 2017-27 period, mainly driven by
satellite life extension services.32 Recently, the US issued the In-space Servicing Assembly and
Manufacturing (ISAM) national strategy to advance its capabilities in the field33, setting out a set of goals
to ensure the development of the in-orbit servicing industry incentivized by public sector demand and
coordination.
All of these spacecrafts providing services in orbit will require communication between satellites and to
the mission control or related components, posing the need to ensure spectrum frequencies and
authorization can be granted for these services and their effective operation. In addition, space traffic
management (STM) will also present a commercial opportunity and will require the use of spectrum
frequencies for its operation.
Space activities are increasingly presented with the need for a space traffic control authority that would
serve to direct satellites and instruct them on how to avoid collisions. Traffic management systems
demand high data gathering and processing capabilities, and therefore also involves surveillance
activities.34 While a STM solution will probably require a centralized operation to ensure international
coordination needs are met35 it is likely that specific frequencies will also be needed to operate this type
of system.
The evolution of technologies, the increased number of applications as well as the realization of the long-
awaited promise of enabling connectivity directly from satellites to end-user’s personal mobile devices
worldwide poses several challenges for spectrum management. One example is direct to device (D2D),
which refers to the direct connection with end-users’ mobile cellular devices with satellite capacities.
While this idea is not new, the recent years have seen the rise of companies announcing they have
achieved the necessary developments to make the service commercially available worldwide. 36 As usual,
technology moves faster than regulations, creating the situation where regulatory frameworks are
challenged by a technology that is ready to go to the market and could be massively used around the
world. The D2D technology presents regulatory challenges including the possibility of allocating and
30 ESA commissions world’s first space debris removal.

31 By fixing components, adding software or hardware updates, and replenishing consumable resources such as batteries and propellants.
32 Space sustainability: The economics of space debris in perspective.
33 US in-space Servicing Assembly and Manufacturing (ISAM) national strategy.
34 Space Traffic Management: a new era in Earth orbit.
35 Chinese perspective on an international regime of space traffic management.
36 The Coming Era of Satellite Direct-to-Handset Connectivity.
24
assigning spectrum licenses for MSS on bands traditionally used primarily by MS and that are usually
licensed by expensive auctions. Likewise, the need to ensure service availability, the challenges
terrestrial providers should also face to adjust their networks, and to avoid harmful interferences are also
situations that should be addressed in the following years 37.
These challenges go beyond national decisions, requiring standardization, particularly at the ITU level,
in order to ensure harmonization in the use of the spectrum frequencies, particularly, regarding the
coexistence of the MSS and MS, and eventually, also the FSS; considering these radiocommunication
services are no longer operating independently, but complementarily and connecting to the same device.
Likewise, international harmonization would be required to ensure users can benefit from these
technological advancements and employ their devices beyond national borders without causing harmful
interferences.
Another key element of discussion is the increasing complementary attribute of the space and terrestrial
technologies to provide connectivity anywhere and anytime. The approach of technologies being
complementary instead of independent and sometime even competitors, is challenging the regulatory
landscape around the world. Currently, the main trend is based in the conception that complementary
can be leveraged to enable use cases and applications. Thus, current allocations and the applications
traditionally associated to each of them, are being challenged by the possibility of new technologies being
able to operate with spectrum resources and end-user devices traditionally limited to specific frequencies
and radiocommunication services. Notably, the “3GPP’s Releases 17 and 18”, address the fact that 5G
terrestrial services are expected to operate with satellite services for personal and industrial
applications.38
CST seeks the following comments:

Question No. (12): What, in your opinion, are the appropriate mechanisms for licensing the use of
frequency spectrum for space services and space communications? Do you see the continuation of the
exclusive licensing, reduced and exempt licensing mechanisms? mentioning the details
Question No. (13): What do you think are the appropriate mechanisms to reduce interference to space
radio technologies? And how can these mechanisms enable a wider range of cases of access to the
shared frequency spectrum while ensuring coexistence between other users and wireless systems?
Question No. (14): What are the other regulatory mechanisms, in your opinion - other than those
mentioned above - that could allow the sharing of frequency allocations?
Question No. (15): What are the main missing elements in the regulatory documents related to the
frequency spectrum used for space services and satellite communications in the Kingdom?
37 Satellite 2.0: going direct to device.

38 NTN & Satellite in Rel-17 & 18.
25
Question No. (16): What are the challenges that were not addressed or proposed to be addressed in
this section?
To define the additional bands that may be required for both satellite and space services, it is necessary
to consider the following elements:
 CST needs to determine the optimum use of spectrum across all different use categories. Since
spectrum is finite, any expansion of use by one service will come at the expense of a reduction in
use by another. Hence, the expansion of satellite and space spectrum needs to be supported and
justified by economic analysis.
 CST cannot unilaterally identify spectrum given the multi-national nature of satellite services.
Satellite and space spectrum needs to be identified via a formal international process involving
the ITU which typically makes major decisions at World Radio Conferences. CST will be working
with other countries and will lead the discussion to determine future spectrum bands for satellite
and space services.
 Administrations need a clear signal from the satellite and space industry on the new spectrum that
is needed and an identification of the bands that would be useful.
In the process of identifying and defining additional bands, the CST conducted a survey to consult the
industry’s needs, building on the requests and necessities of companies. This survey was conducted at
the beginning of March 2023, looking for providing first-hand information about their plans and needs
regarding use of spectrum and future services.
As per the received responses, companies are mostly considering the spectrum needs for the operation
of 5G NTN applications, including D2D , followed by ESIM and IoT applications. Inter satellite links and
emergency communications occupy the third place in responses.To date, space services such as launch,
end of life, debris removal and lunar communications were mentioned in a smaller proportion,
The participants also indicated the frequencies they will require to operate the applications and services.
The following tables describe the bands for the applications the participants described as their main
interests.
26
5G NTN D2D
470-698 MHz
470-890 MHz
617-652 MHz
663-698 MHz
806-840 MHz
856-890 MHz
L 942-960 MHz
1518-1559 MHz
1626.5-1660.5 MHz
1645.5-1646.5 MHz
1668-1675 MHz
1695 - 1710 MHz
1980-2110 MHz
1429 – 2690 MHz
1880-1920 MHz
1980 – 2020 MHz
S 2170-2200 MHz
2010 - 2025 MHz
3300-3315 MHz
3385-3400 MHz
TABLE 2: SPECTRUM REQUIRED FOR 5G NTN APPLICATIONS.
ESIM
C 5925-6425 MHz (Earth-to-space) 3700-4200 MHz (space-to-Earth)
12.75-13.25 GHz (Earth-to-space)
13.75- 14.5 GHz (Earth-to-space) 10.7 – 12.7 GHz (space-to-Earth)
Ku
14.0-14.5 GHz (Earth-to-space) 10.7-12.75 GHz (space-to-Earth)
14-14.25 GHz (Earth-to-space)
17.3-20.2 GHz (space-to-Earth)
27.5-30.0 (Earth-to-space) 17.3-21.2 GHz (space-to-Earth)
Ka
27.5-31.0 (Earth-to-space) 17.7-21.2 GHz (space-to-Earth)
Q/V
Table 3: Spectrum required for ESIM applications.
Internet of the Things (IoT)

148-150.05 MHz (Earth-to-space)/ 137-138 MHz (space-to-Earth)
VHF 235-322 MHz (Earth-to-space)/(space-to-Earth)/387-390 MHz (space-to-
Earth)/400.15-401 MHz (space-to-Earth)
312-315 MHz (Earth-to-space)
335.4-399.9 MHz (Earth-to-space)/(space-to-Earth)
UHF
399.9-400.05 MHz (Earth-to-space)
406-406.1 MHz (Earth-to-space)
27
1518-1559 MHz
1610-1626.5 MHz
1626.5-1660.5 MHz
1668-1675 MHz
L 1645.5-1646.5 MHz
1695 - 1710 MHz
1880-1920 MHz
1980-2010 MHz
1980 –2020 MHz
2170-2200 MHz
2010-2025 MHz
2170 – 2200 MHz
S
2483.5-2500 MHz
3300-3315 MHz
3385-3400 MHz
Table 4: Spectrum required for IoT applications.
Intersatellite links
1626.5-1660.5 MHz (Earth-to-
L space) 1518-1559 MHz (space-to-Earth)
C 5925-6425 MHz (Earth-to-space) 3700-4200 MHz (space-to-Earth)
Ku 12.75-14.8 GHz (Earth-to-space)
22.55 to 23.55 GHz (Earth-to-
Ka space)
27.5-30 GHz (Earth-to-space)
Table 5: Spectrum required for intersatellite links.
Phone, emergency, mobile

410-430 MHz (Earth-to-space)/(space-to-Earth)
L
1626.5-1660.5 MHz(Earth-to-space)/(space-to-Earth)
1668-1675 MHz(Earth-to-space)/(space-to-Earth)
S
2170-2200 MHz (space-to-Earth)
Table 6: Spectrum required for phone, emergency and mobile applications.
28
Telemetry, Tracking and Command (Normal operations and close proximity
operations)
L 1427-1429 MHz (Earth-to-space) 401-402 MHz (space-to-Earth)
S 2025-2110 MHz (Earth-to-space) 2200-2290 MHz (space-to-Earth)
5926.5 -6422.5 MHz (Earth-to-space) 4199 - 4199.5 MHz (space-to-Earth)
C
6338 - 6342 MHz (Earth-to-space) 3945-3955 MHz (space-to-Earth)
18.305 -18.31 GHz (space-to-Earth)
29.0 GHz - 29.8 GHz (Earth-to-space)
Ka 18.34 -18.345 GHz (space-to-Earth)
29.25 - 31.0 GHz (Earth-to-space)
19.45 – 21.2 GHz (space-to-Earth)
Table 7: Spectrum required for telemetry, tracking and command.
Regarding specific bands, participants offered additional comments:

 One company suggested to develop new service allocation in FSS for the KA BSS band (21.4-22
GHz)
 Another highlighted the importance to balance the uplink and downlink spectrum accessible for
user terminals in Ku-band, by reviewing the conditions of operations for GSO and NGSO satellite
systems in 13.75-14GHz band, subject to ITU RR 5.502 and 5.503.
 Companies working on NB-IoT, with applications that require small bandwidths raised the need
for a distribution plan of channels in the mobile satellite service. In this case, it seems that certain
companies struggle to find spectrum availability because MSS networks with higher bandwidths
do not make effective use of the spectrum assigned.
 Overall, the comment that was repeated and mentioned the most, was one: “Enable access to
new frequency bands, even those not generally allocated to satellite services in Article 5 of the
RR”. Companies agreed that, due to the constant development of technology and services, the
current allocation of bands should be extended to new and more diverse uses. For example, while
some companies requested to expand the current use of the Ka Band for ESIMs, other companies
expect that bands allocated for MS may be allocated for MSS to operate newer D2D applications.
 Other companies highlighted the importance of updating the National Frequency Allocation Table
(NFAT) of the Kingdom, to accommodate the space services requirements and needs. The
revision of the NFAT should also consider the recent decisions adopted at ITU level and WRC
cycles. Harmonization with other regional groups such as CEPT was also recommended. The
CST takes note of this comment and will incorporate them in the process that will lead to update
the national NFAT of the Kingdom.
The CST will analyse the abovementioned spectrum needs and requirements to adjust the National
Frequency Table to ensure the required allocations are in place, and alignment with the ITU’s
International Allocation Table.
Additionally, concerning spectrum management, participants also expressed their needs to CST,
indicating:
29
 The need to ensure a flexible approach towards new services, while securing the adequate level
of protection and non-interference with current incumbents in the Kingdom.
 A large number of companies expressed their interest in conducting trials and test in the Kingdom,
but in order to make that happen, companies suggested to the CST to adopt a flexible spectrum
allocation approach for temporary test and demonstration licenses. Another interesting response
suggested the adopt a “default service rules” similar to the decision implemented by the Federal
Communications Commission. This approach would enable operators to receive licenses—
including earth station licenses—for spectrum in bands that have been allocated to satellite
services, but for which there are not yet established technical rules, subject to baseline technical,
coordination, and protection requirements, while still ensuring efficient coordination that protects
incumbent and adjacent-band users.
CST is committed to optimising the use and allocation of spectrum, while protecting the current operators
and ensuring no interference will take place. Promoting the development of new technology and services
will always be align with protecting the rights of already assigned spectrum. This is also the principle that
will apply for the regulation and licensing of mega-constellations.
More general comments were also received, regarding the licensing process, asking for streamlined
market entry procedures based on objective criteria that support rapid deployment and innovative
business models while allowing market competition. Other companies also mentioned tax or economic
benefits or fee discounts for companies working to deploy certain activities in the Kingdom that would
help bring coverage to certain areas of the Kingdom. The need for a physical gateway in the Kingdom or
the request of information for foreign satellites registrations was also challenged.
Beyond the results of this survey, the CST is constantly seeking feedback from different stakeholders to
ensure a flexible and dynamic spectrum management. Therefore, receiving input form the industry and
monitoring of the spectrum needs, as the main element required to provide space radiocommunications,
is a permanent activity for CST. In this context, with the present Outlook the CST welcomes additional
input and feedback from stakeholders regarding any other regulatory action, or spectrum need,
concerning the abovementioned issues or additional ones.

Question No. (17): To what extent do you think that the information collected in this section reflects
meeting the need for spectrum allocation in the future?
Question No. (18): What are the other uses that can arise under the current distribution of frequency
spectrum?
Question No. (19): In your opinion, what is the appropriate licensing system that the Communications,
Space and Technology Commission should adopt when liberalizing the commercial frequency bands
listed in this section? For example exclusive license, diluted license or other.
30
Question No. (20): What is the impact of the licensing system proposed in the previous question on the
use of the frequency spectrum?
The current context described above, together with the emerging challenges trigger by new technologies
and developments in the space and satellite field, leaves countries with no option but to update their
frameworks and policies as fast as the market moves. While CST has the obligation to ensure that every
new (and traditional) technology is applied in the safest way, it also supports the growth of the industry
by allowing trials to test the latest innovations and updates the legal frameworks accordingly.
The section below lists the most important issues that CST will monitor, as well as the concrete steps
that will be taken in the next years to position KSA as the leader in the satellite and space field.
8.1. Developments to monitor
Based on the previous analysis, CST is working to advance the Kingdom’s position by ensuring the
required spectrum is available and enabling the performance of test, experimentation, and trials to
develop innovative space services. In addition to the above-mentioned satellite services, the CST is also
looking to determine the future need for spectrum for space services, particularly for those newer
innovate services that may even require new definitions at the international level for their allocation. In
this sense, the Kingdom will actively participate and lead the discussion at the international and regional
level.
The present section describes the next steps CST will follow to enable satellite and space spectrum use,
while leading the discussion at the international level for the identification and definition of new allocations
to ensure the strengthening of the space sector.
8.1.1 Developments to monitor in the Satellite Services
In March 2023 the CST conducted the “Survey for Space Spectrum Outlook” which presented an
overview from the supply-demand perspective, and the identified international trends and possible
requirements. Based on the results of that survey and the analysis conducted in the previous sections,
the CST has identified satellite areas of work to monitor, such as:
 Satellite licensing: the renew interest in LEO constellations together with the increase of traditional
and new satellite activities, have reshaped the regulatory landscape and spectrum management
field. Consequently, administrations are starting to put in place particular licensing considerations
for satellite services. CST will keep updated on the latest trends in the satellite field in order
to enact the most convenient regulations that allow innovation while ensuring compliance
with the fundamental security standards.
 Partnerships and consolidations: Traditional operators in the satellite field are turning their
investments into new areas throughout the entire supply-chain. This trend is inevitably leading to
a market consolidation, with GSO operators moving also to the NGSO field. The merges and
31
fusions that are potentially taking place due to this phenomenon could create some problems from
a licensing perspective, with overlaps and duplication of licenses that do not cover the new
activities. CST will analyse the best way to approach this potential problem, based on an
international benchmark and best-practises taken around the world. Furthermore, CST will
update its licensing mechanism accordingly, to support companies’ decisions and current
movements.
 Improved ITU process. Other regulators have voiced concern that the current ITU process for filing
satellite applications is not well suited to the current trend for multiple filing of “mega-
constellations” and that new approaches may be needed. CST is aware of the issues and potential
abuses that are becoming clear and are supportive of studies to consider alternative approaches
that would better match the changing competitive environment. CST will lead discussion among
global regulators, setting up workshops and conferences to suggest alternative
approaches to managing space resources in the future and build a consensus for change.
In doing this, CST will become the global convener and leader to ensure that the global
space spectrum management framework is fit for the future.
 Space-based transmission in terrestrial bands (D2D). Some proposals for direct-to-device
transmissions aim to use the mobile bands with the agreement of the terrestrial owner of the
cellular licence. This could be both for satellite and HAPS transmissions. Interference would be
avoided by aiming beams at those areas without cellular coverage. CST is, in principle, supportive
of such usage, and will consider further whether changes to terrestrial licences might be needed
and issues of international coordination that are likely to arise. CST will work with the HAPS and
NGSO industry and the local mobile operators to come up with a proposed framework for
the use of terrestrial mobile spectrum, particularly the S band is being analysed to pioneer
this approach and will publish and consult on these concepts and socialise them
internationally as a way to allow important new services. As a result, CST will become the
global leaders in direct-to-device communications.
 Space-based IoT and NB-IoT. The effective deployment of Space-based IoT and NB-IoT are being
challenged by the necessity of adapting devices and technology, creating a barrier for
commercially valuable proprietary solutions. That’s why recent developments in standard based
solutions are key. For example, certain companies are developing solutions that utilise terrestrial
technologies such as NB-IoT and LoRa to transmit from space to IoT devices. There is
consideration of potential future allocations of narrowband spectrum for these systems, analysing
alternatives for the S and L band, under Agenda Item 1.18 at WRC-23. Should such allocations
find favour internationally – whether in this WRC23 cycle or in the WRC-27 with a redefined
agenda item and including the radiocommunication services that should be allocated spectrum
bands to operate NB-IoT applications – CST will act swiftly to make them available in KSA as far
as possible, understanding that there may be incumbents in any bands identified. In advance of
any decision CST will enable trials in these bands, working with incumbent terrestrial users to
deliver innovative ways to enable shared access to the spectrum. CST will proactive reach out
32
to companies intending to deliver space-based IoT to understand their plans and regulatory
requirements.
 Increased earth observation activity. As earth observation becomes ever more important there is
a need to ensure spectrum access to earth observation services to exploit the continuous data
that is captured from space, including the operation of intersatellite links that enable
communications between NGSO and GSO satellites, and the definition and protection of
frequencies for the operation of Telemetry Telecommand and Control (TT&C) earth stations. CST
will commission studies that shows spectrum demand for earth observation for the coming
10-20 years, critically assessing whether such spectrum can be shared and understanding
the value delivered, so that future decisions on spectrum need can be made based on clear
evidence.
 Space sustainability and space debris related spectrum. CST will monitor the need to allocate
spectrum for the operation of space services such as launches, space monitoring (space weather)
and tracking of space objects (radars). CST will develop proposals for a global framework for
delivering a sustainable future, working with bodies such as the ITU and GSOA to build a
plan that all major stakeholders agree to. Furthermore, in addition to lead the discussion
around space sustainability, CST will promptly adopt the decisions made at the
international level, to ensure this concept is incorporated domestically and the regulatory
documents reflect the importance of sustainability in the space exploration and spectrum
utilization. Likewise, this will be reflected accordingly in the guidelines and process to be
adopted by the Kingdom to act before the ITU as the notifying entity of satellite systems
and networks.
In order to achieve the Kingdom’s vision regarding spectrum use for social and economic wellbeing, CST
has analysed the international best practices being under construction or implementation to meet the
current and future demands related to space and satellite spectrum and has identified the main areas
and priorities where actions will be implemented to advance the Kingdom’s position in spectrum
management and increase the social and economic benefits deriving from this strategic resource.
The Authority has identified the importance of using several mechanisms for licensing the frequency
spectrum to allow for more multiple uses and more efficient management, as the Authority is aware of
the importance of having different licensing systems (ie licensed, lightly licensed, and license-exempt)
and how they apply to different bands and uses.
In the case of satellites and space spectrum, the spectrum regulations for satellite services will mainly
discuss the licensing of earth stations. The authority will monitor the market needs to determine the
possibility of including space and satellite frequency bands under the reduced licensing regulations. The
33
regulations will also include updating the regulatory procedures and conditions for licensing frequency
spectrum for non-terrestrial networks
These regulations will specify the requirements to fulfill the procedures of the International Radio
Regulations that must be carried out before the operations of notification and registration of satellite
networks with the International Telecommunication and Coordination Union across the Kingdom.
The CST will review its current national frequency allocation table, and will update the national table and
regulations after the decisions of the World Radiocommunication Conference 2023 AD (WRC-23),
especially the new regulations for Earth Stations in Motion (ESIM), space-to-space links, sub-orbital
vehicles, and any other related technology.
Defines spectrum licensing procedures for satellite services, including best practices on individual
licenses, networks, experimental and temporary assignments, and exempt frequencies..
The Authority will seek to determine the frequency spectrum requirement for the operation of existing
space services, such as Earth Exploration Satellite (EESS), Satellite Service (ISS), Research Space
Services (SRSS), and Navigation Services, in order to determine the need to define specific measures.
To protect these services from interference.
The authority will also seek to make available the frequency spectrum for the operation of space services,
such as launches, space monitoring (space weather), and tracking of space objects (radars), which can
be done either by providing specific frequency bands for these services.
In view of the emergence of new services, the CST will study the current needs of frequency spectrum
for these new services, and closely monitor global developments regarding service definitions and
modern frequency bands, and the Authority will work to issue spectrum regulations to enable the
operation of narrow-band satellite applications.
34
Question No. (21): What other frequencies should the Communications, Space and Technology
Commission include in the planned reduced licensing regulations? What are the main implications of
this update?
Question No. (22): What are the procedures that you consider adding to meet the needs of the market?
Question No. (23): Are there any additional developments that you think should be monitored by the
Commission?
The table below provides a summary of the key documents CST is planning to publish throughout 2023
and beyond, including an indicative publication date.
Type of
Initiative Content Date
document
Studying the most important
trends, plans and needs shared
by the parties concerned with
the use of frequency spectrum,
as well as the developments
Space
observed in the leading
Radiocommunication Consultation Q3 2023
countries in the field of satellite
services Outlook
services, specifically space
radio communication services,
to determine the demand for
frequency spectrum for current
and future space services.
These regulations target the

rules for the distribution and
allocation of frequency
spectrum for satellite radio
services in the Kingdom, the
Regulations for the use of Consultation
relevant licensing procedures,
radio spectrum for satellite followed by Q3 2023
fees, rights, obligations of the
services Regulations
parties concerned, the relevant
technical standards, and
monitoring and implementation
by the Communications, Space
and Technology Commission.
35
Type of
document
Replaces the few mentions
currently on Section 7 of the
previous document known as
“operational procedures” and
defines a complete framework
for the advance publication,
Consultation
Satellite system and coordination, and notification of
followed by Q1 2024
networks filings satellite systems in the name of
Regulations
the Kingdom before the ITU,
and for the assignment of orbit
and frequency usage rights. It
includes a section considering
particularities applicable to
NGSO systems.
GSO traditional applications,

and Earth stations operating
with NGSO satellite systems
and Earth Stations in Motion
(ESIMs) can be deployed within
existing satellite allocations.
Regulations will be updated as
Satellite services and needed to allow for innovate
Application Ongoing
applications application in existing
allocations and bands. There
are no immediate plans to make
available additional bands for
satellite use, but CSTC will keep
this under review and will work
with the ITU on satellite
allocations.
Replaces current form and

includes the technical required
details for licensing,
Application form (ground
distinguishing particularities for Form Q1 2023
segment)
GSO/NGSO systems and other
space services for example:
space science services
36
Type of
document
A template with the typical terms
License template (ground
and conditions applicable to a Template Q1 2023
segment)
license
User friendly explanation of the
Applicant’s guidelines Q2
applicable procedures and Guidelines
(ground segment) 2023
requirements.
User friendly explanation of the
Applicant’s guidelines Q2
applicable procedures and Guidelines
(space segment) 2023
requirements.
CST will make adopt the
Consultation
Earth Exploration satellite regulatory definitions that may
followed by Q1 2024
services regulations be required to enable EESS in
Regulations
the Kingdom.
CST will monitor and work on

making the required adjustment Consultation
Narrow band applications to the regulations to enable followed by Q3 2024
operation of narrow band Regulations
applications.
37
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2

2 Member States (itu.int)

Allocations in the National Frequency plan

Allocated to satellite and space radiocommunication services

Figure 1: Allocations in the National Frequency plan6

5 Satellite Industry Association: State of the Satellite Industry Report.

Assignments of spectrum for space services in the Kingdom

Figure 2: Assignments of spectrum for space services in the Kingdom

Issued licenses for satellite services

VSAT GMPCS Broadband satellite service

Figure 3: Licenses issued for space and satellite services7

7 Source: CST public registry of valid licenses.

6.7% 6.7% 6.7%

IoT Broadband satellite ESIM Air to ground Aeronautical Private comms

12 KSA Space Strategy presentation, CITC work document not published.

5.1. Technologies of satellite communication services

5.1.1 The latest technologies used in satellite communication services

Number of constellations by application

Synthetic Aperture Radar

Infrared Earth Observation

FIGURE 5: NUMBER OF CONSTELLATIONS BY APPLICATION21

30 ESA commissions world’s first space debris removal.

CST seeks the following comments:

37 Satellite 2.0: going direct to device.

Internet of the Things (IoT)

Phone, emergency, mobile

Regarding specific bands, participants offered additional comments:

CST seeks the following comments:

These regulations target the

GSO traditional applications,

Replaces current form and

CST will monitor and work on

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