INTERNATIONAL TELECOMMUNICATION UNION AD HOC GROUP ON COST RECOVERY FOR SATELLITE NETWORK FILINGS Document 3-E 8 April 2003 English only GENEVA, 10 – 11 APRIL 2003 DRAFT Report from the ad-hoc Group on Cost Recovery For Satellite Network Filings 1 Introduction 1.1 Council-02 established the ad-hoc Group on cost recovery on Satellite Network Filings, in Council Decision 510, to consider the alternative basis for charging that does not depend on numbers of pages and to determine the factors to be considered for the evaluation, as well as the practical implications of applying cost attribution to activities associated with the processing of satellite network filings towards the application of full cost recovery. The Group was tasked to report on progress, and make recommendations as appropriate, to the ad hoc Group of Council on the financial plan and to the special session of Council to be convened just prior to PP-02. The special session of Council endorsed the recommendations of the ad-hoc Group but implementation was put in abeyance until after the Plenipotentiary Conference. 1.2 PP-02 revised Resolution 88 (Minneapolis, 1998) on the “implementation of processing charges for satellite network filings and administrative procedures" and instructed the Council, at its extraordinary session during the conference to establish a group in order to make recommendations to the 2003 session of the Council on: i) modifications to Decision 482 to give effect to resolves 1 and 2 of Resolution 88 (Rev. Marrakesh, 2002); ii) extension of the implementation of processing charges for satellite filings, received by BR as of a date to be set by the Council and not already covered in resolves 2 of Resolution 88 (Rev. Marrakesh, 2002), to include identifiable and auditable costs incurred directly in the processing of satellite network filings; iii) clarification of the meaning of the term "actual costs" referred to in resolves 4 i) of Resolution 91 (Minneapolis, 1998) of the Plenipotentiary Conference; 1.3 [Since PP-02, the ad-hoc Group has held two meetings (20-21 January and 10-11 April 2003) some XX participants from XX Member States and X Sector Members of the Radiocommunication Sector participated in its work]. 1.4 Pursuant to its terms of reference, the ad-hoc Group has reached the conclusions on: the requirement for a new time survey; modifications to Decision 482 application; [Other issues TBD]. -2- 2 Recommendations 2.1 Decision 482 charging methodology 2.2 Decision 482 cost methodology 2.2 Decision 482 application 2.4 Time survey 2.5 Cost allocation 2.6 Extension of cost recovery 3 Background The original charging methodology used in Decision 482 on the “implementation of cost recovery for satellite network filings” was based on the number of published pages in a special section of the Weekly Information Circular. However, the implementation of Resolution 30 (WRC-97) required the Radiocommunication Bureau to move to electronic publication of information on a CD-ROM thus requiring a change to the Decision 482 charging methodology. Council-02 considered a new charging methodology based on the product of specific components of a satellite network filing notice (e.g. number of frequency assignments, number of classes of station, number of emissions). Due to concerns over the projected charges applicable under the new methodology, Council-02 only adopted it on a provisional basis until the special session of Council convened prior to PP-02 and as noted in the introduction, established an ad-hoc Group to evaluate the methodology. The report of the ad-hoc Group (Document C02/99) contained a number of recommendations including extending the provisional adoption of the new charging methodology until Council-03; and, incorporating the 2001 time survey into the Decision 482 charging schedule. All the recommendations were endorsed by Council (see Annex 1 for the full text of the recommendations to the special session of Council). In the case of the two bulleted recommendations shown above, they will need further specific consideration by Council at its 2003 session. With regard to the first bulleted recommendation, Council will need to consider [whether to continue to use the new charging methodology either as currently implemented or in a revised form, or adopt an alternative methodology] and the ad-hoc Group needs to develop a Recommendation. With regard to the second bulleted recommendation, a revised charging schedule incorporating the 2001 time survey was not presented to the special session of Council and this means the Radiocommunication Bureau may not fully recover its costs in the year to Council-03. The Radiocommunication Bureau agreed to provide a revised charging schedule including the revised time survey for the ad-hoc Groups April meeting. 4 The attribution of costs for activities associated with processing satellite network filings 4.1 Time survey The ad-hoc Group’s report to the special session of Council contained a number of criticisms of the time survey1 conducted by the ITU that was used to apportion staff time to activities. From the perspective of the Radiocommunication Bureau, this survey is used to determine the overall cost of processing notices over a period of three years preceding the Council meeting at which fee revisions are to be considered, as required by Decision 482. However, the time survey does not provide ____________________ 1 The time survey covered a period of 21 months and required ITU staff to identify, on the last day of the survey, the percentage of their time devoted to cost recovery activities during the entire preceding 21-month survey period. -3- continuous monitoring and as no one in the ITU is required to complete a timesheet, it is not possible to determine the level of activity and thus the cost within individual categories. At the January meeting, the Group unanimously reaffirmed its previous concerns on the time survey and considered that a more detailed time survey was required. The aim of the new time survey should be to identify, among all the activities performed by the Radiocommunication Bureau, the percentage of those activities currently subject to cost recovery and to evaluate the percentage of each activity performed by the Radiocommunication Bureau that is not subject to cost recovery. This approach not only provides information on existing cost recovery activities but also would provide the Radiocommunication Bureau and Council, with the relevant information on the inclusion of new activities within the cost recovery framework should the application of cost recovery be extended. The Group agreed that the time survey should apply to all staff in the Space Services Department and [all staff] in the Informatics, Administration and Publications Department, with details of activities being recorded on a daily basis. It was considered that time recording would need to be performed for a minimum of a year due to the impact of WRC-03 on the work of the Radiocommunication Bureau. A list of activities to be included in the time survey was identified and the methodology for recording and collating the data agreed. The details of the time survey are presented in Annex 2. The Group were of the opinion that the time survey should be implemented as soon as possible, using if possible existing software e.g. the SAP software. 4.2 Extending cost recovery to new activities In the report to the special session of Council, the ad-hoc Group recommended that cost recovery be extended to a new range of activities that, if they were to be implemented, required PP-02 to revise Resolution 88. However, due to concerns on the lack of available details on reallocation of costs and the uncertainty with the charging methodology, many participants had considered that charges related to this extension of cost recovery should not be implemented until these issues had been resolved. At PP-02, a decision was taken to extend the scope of cost recovery and consequently, this will require consideration at Council-03. It is noted that the concerns expressed by the ad-hoc Group in its report to the special session of Council-02 have still not been resolved. Nevertheless, some administrations are of the view that work on activities associated with the processing of satellite network filings but not currently incorporated in the cost recovery process, should now be included in cost recovery charges. A list of potential activities for inclusion in the cost recovery process is contained in Annex 3. Other administrations are still of the view that the extension of cost recovery needs to be delayed until the costs are clearly identifiable and auditable. The Bureau noted, in Document 2003/6 to this ad-hoc Group, “that the 2004-07 Financial Plan has been approved on the basis of full cost recovery” and therefore there was a need to extend the activities subject to cost recovery. [The ad-hoc Group do not agree with this view; PP-02’s adoption of the Financial Plan was not based on moving to full cost recovery for satellite network filing but an extension of cost recovery to other activities, as noted in the report of the ad-hoc Group on the Financial Plan to the special session of Council (see Document C02/98). In addition, the provision of a free filing for all Member States and the deliberate exclusion of specific General Secretariat reallocated costs, by Council, from the cost recovery process prevent full cost recovery. It was noted that the projected costs for the 2004-05 biennium (approximately CHF 31m) on which the Bureau would be basing their charges exceeded the total expected income in the 2004-07 Financial Plan of CHF 30m. However, it was also noted that the estimated costs and the projected income are based on two different concepts, making it difficult to link costs with income and difficult to achieve consistency, as noted in recommendations 8 and 11 of the external auditors report (see also § 5.1). In order to assess the costs associated with extending cost recovery to new activities, the Bureau was requested to provide a breakdown of the direct and reallocated costs for these new activities.] -4- 4.3 Actual costs As noted in the introduction (see 1.2 iii) one of the tasks of the Group is to clarify the meaning of the term "actual costs" as referenced in resolves 4 i) of Resolution 91 (Minneapolis, 1998) which requires that Council implement cost recovery in a way which “ensures that no more than the actual costs of providing products and services are recovered.” There are two divergent views on the meaning of the term “actual costs”. The first view, currently implemented in Decision 482, is that the actual costs are those of the Space Services Department together with the associated reallocated costs. This view is supported by the Radiocommunication Bureau and some administrations. Other administrations are of the view that the “actual costs” are the direct and reallocated costs associated with processing individual satellite network filings. [Further explanation required on implications of different views] 5 Cost recovery methodology options 5.1 Cost assessment methodology The current cost methodology in Annex B of Decision 482, is based on an estimation of the costs over the preceding three year period as well as the average numbers of coordination requests received in the same period whereas the budget receipts are estimated on the prospective number of satellite network filings processed in the forthcoming two years. In case of fluctuations in the number of filings processed, Resolution 91 (Minneapolis, 1998) resolves 4 iii) provides for a means of adjusting the charge for the product or service based on actual costs or actual income. To date, this had been achieved by reviewing the fee schedule at least once every two years, as mandated by Decision 482. However, in cases of large fluctuations in the number of satellite network filings processed it would be possible, under the current cost methodology, to either issue additional invoices if the number of satellite network filings processed are less than expected during a certain period or issuing refunds if the number of satellite network filings processed are more than expected. It is recognised by both the Bureau and the Group that the application of any supplementary charges would be extremely unpopular and therefore potentially counter productive. The Bureau believes that such fluctuations could be avoided if the fees were established using budgetary prospective costs as well as a projected number of filings, thus making the charges stable over at least a budgetary period. There was support for further examination of this proposal, several administrations noting that receiving a supplementary charge for processing a satellite network filing would not be welcome. The Bureau agreed to provide an alternative methodology and examples of how it would operate. 5.2 Charging (unit) methodology Following concerns expressed on the application of the unit methodology at the ad-hoc Group’s previous meeting, and the potential to generate excess charges for a small number of filings, the Bureau provided information on the application of a cap to the processing charges in each category. The cap could be based on page numbers within each category in publications made in the last three years. However, the Bureau noted that application of a cap may result in an under-recovery of costs. An alternative methodology could be to apply a flat fee. The current methodology is outlined in § 3 above and the Bureau admitted that the extremely high charges that could be produced did not necessarily reflect the work involved in processing the filing, as beyond a certain size of filing there was no real increase in processing costs. In the debate that followed a variety of views were expressed but no real consensus emerged although a number of participants expressed the view the charges being produced were disproportionate to the costs and the salaries of the staff. Some participants objected to a flat fee as it did not take into consideration the size of a filing and would therefore require more categories: a point made at the previous meeting of the Group. Some participants favoured a cap, although one administration objected to this approach based on the objections raised on the flat fee and proposed -5- a reduced rate above a certain number of units. The Bureau was requested to provide some additional information on a flat fee and the cap/reduced rate with examples of application. [Further work is required in order to give advice to Council] 6 Modifications to Decision 482 (modified C2002) The external auditor’s report to Council (document C02/102 and its addendum) identified issues relating to the principle of one free publication per year and per Member State (see §§21, 51, 83, 84, Recommendations 16 and 17) and to the follow-up procedure/interest on arrears (see §§19, 26, 27, Recommendation 3). In addition, the Bureau expressed concerns that the three times limit for modifications to networks originally received prior to the 7th November 1998 was too large now that the “page methodology” was no longer used. Concerns were also expressed on the cancellation of all or part of a filing at a point in time after the Bureau has started the examination of the network but prior to the publication date when the invoice can be issued. In the case of a complete cancellation, the Bureau does not recover the costs of its work but has decided that there will be no charge. In the case of a partial cancellation, the Bureau may have to re-examine other networks with respect to the cancelled frequency assignments and therefore the Bureau have treated this case as a modification that will be processed in the order of the date of receipt. For the case where partial cancellation of a network is submitted prior to the Bureau starting the examination of the original coordination request, there will be no charge for the cancelled frequency assignments. Discussions recognised there was a fundamental dilemma in addressing the issue of the lost of income for the cancelled networks where work had commenced: on one side the Bureau was not achieving the recovery of its costs; but, to charge for the cancellation of a network would be to penalise that administration for freeing up spectrum. Charging in these circumstances was therefore not seen to be promoting efficient use of the radio spectrum and possibly contrary to the spirit of Article 44 of the Constitution. The same view was taken with regard to charges incurred for processing API’s that are not followed by a coordination request within the time period specified in No. 9.5D of the Radio Regulations. [The Group needs to make a recommendation to Council to affirm or change this approach.] Further discussions considered the changes arising from the PP-02’s revision of Resolution 88 and a series of amendments were agreed to Decision 482 (see Annex 4) although Thailand reserved its position with regard to the modifications to decides 7. In addition, it was agreed that text would be included in this report relating to the charges incurred for cancelling part of a satellite network filing. Administrations may cancel (withdraw) satellite network filings awaiting or under processing by the Bureau. In the case of satellite networks for which a notice has been received prior to 1 January 2002, if the cancellation is received before the date of publication, no charges shall apply. In the case of satellite networks for which a notice is received on or after 1 January 2002, subsequent cancellation will not remove the obligation to pay the flat fee component (payable following receipt of the notice) however, no charges will apply for the variable component (if any) providing the cancellation is received before the date of the publication of the related special section. In the case of requests to cancel specific beams or specific frequency assignments from a filing (e.g., some Administrations have requested the deletion of some specific frequency assignments from a filing for the reason that these frequencies are covered by no. 9.11A, so as to change the category of the filing from 3 to 2, which has considerably lower charges) that partial cancellation will be treated as a modification (MOD). Footnote 5 to decides 4 of Decision 482 (modified 2002) will be applied to determine whether or not the modification should be subject to a cost recovery charge. -6- ANNEX 1 Recommendations From Report to the Special Session of Council-02 2.1 Decision 482 charging methodology It is recommended that the application of Decision 482 (modified) methodology, as provisionally adopted by Council-02, be extended to Council-03. However, due to concerns over the application of this methodology and the effort required by all parties for its maintenance, the special session of Council is also recommended to approve a Decision to enable the ad-hoc Group on Cost Recovery to study: the application of charges based on a calculation of “Units” as established in Decision 482 (modified) but with a prescribed maximum number of units for each category of filings; and, an alternative methodology to result in an appropriate “flat fee” structure of cost recovery charges in order to remove the complexity of calculation involved in the current scheme. Annex 1 contains a draft Decision extending the provisional implementation of Decision 482 (modified) until the 2003 Session of Council and proposed new terms of reference for the ad-hoc Group on Cost Recovery established at the 2002 Session of Council (Decision 510). 2.2 Time survey It is recommended that the 2001 time survey be used as the basis for setting the Decision 482 (modified) charging schedule. Noting concerns of the ad-hoc Group on the way the 2001 time survey was conducted, it is further recommended that a new time survey be conducted based on recording time on a daily or, at most, weekly basis to be completed in time for the report to be considered by the ad-hoc Group identified in § 2.1 above. In addition, future time surveys should be made available to all members and should identify the participants. 2.3 Cost allocation It is recommended that the ad-hoc Group review and provide recommendations, as appropriate, on the cost attribution to activities associated with the processing of satellite network filings in accordance with Resolution 88 (Minneapolis, 1998) or, any modification thereof arising from the Plenipotentiary Conference, 2002. Consideration should also be given to clarifying the meaning of the term “actual costs” in Resolution 91 (Minneapolis, 1998) as it relates to satellite network filings; currently it is not clear if this term relates to the total costs of the ITU or the unit cost of providing the service. 2.4 Extension of cost recovery It is recommended that cost recovery be extended, in principle, to include other work associated with processing satellite network filings and also other aspects of the Space Services Departments activities, subject to clarification of the details of the reallocated costs. Inclusion of these new activities will require modification of Resolution 88 (Minneapolis, 1998) at the Plenipotentiary Conference. It is also recommended that the costs arising from theses activities should not be taken into account by the ITU when setting the fee schedule until the issues noted in § 2.1, § 2.2 and § 2.3 are resolved. -7- ANNEX 2 NEW TIME SURVEY The former time survey, the results of which were presented at the last meeting of the ad hoc group on cost recovery for satellite network filings (July 2002), was criticized especially for the way it was carried out. The ad hoc group therefore expressed its concern as to whether the results of the survey could be deemed accurate and recommended that a new time survey should be conducted in a more objective and efficient way. The group was of the view that the implementation and the characteristics of a new time survey should take account of the following expected goals: 1. to identify, among all the activities performed by the BR, the proportion of those currently subject to cost recovery, so that the share of budget dedicated to cost recovery activities in the ITU-R can be known and therefore recovered. Furthermore, it would be useful to know the respective proportions of each category currently subject to cost recovery. 2. to evaluate the relative shares of each one of the activities performed by the BR and not subject to cost recovery. It is considered crucial that the time survey should provide as much detailed and relevant information as possible, especially regarding the activities not currently subject to cost recovery but likely to be, since it is essential that all relevant figures be available when some new activities are proposed or recommended to be subject to cost recovery, in order to appreciate the impact of such extension. Given these two main objectives, the group proposed that the new time survey should be carried out according to the following characteristics: - Each day, each staff member would indicate all the activities carried out during the day together with the time spent on each of these activities. The duration of time would be expressed in hours and tenths of hour. - The possible activities would be chosen among a rather extended pre-defined set of denominations. This set would include the processing of satellite network filings but without a priori mention of whether the filing is subject to cost recovery, since only the analysis of the results subsequent to the compilation of the data would take account of such aspect. - An appropriate software would be used to collect automatically the raw information provided by the BR staff members and also to concatenate the data so as to show the global time spent on each of the activities within each department. Such a software tool should be available easily. Whether the SAP software, already available within the ITU, could be used to collect the information relating to the time survey, would need to be examined. List of activities relevant to the time survey: - processing of a satellite network filing, together with mention of the name of the filing: o advance publication information for networks subject to coordination o advance publication information for networks not subject to coordination o request for coordination (together with the category of charge) o requests for modification of the space service plans and Lists: Appendices 30/S30 (Parts A and B), 30A/S30A (Parts A and B) and 30B/S30B. o notification (there might be a need to distinguish between several categories, as for coordination requests) o Resolution 49 -8- o Resolution 46/D o Checking of networks under Resolution 51 o CR/D o invoicing relating to cost recovery process o suppression of networks o updates of the Master Register o suspension of notices under No. 11.49 o management of dates of bringing into use o extension of period of validity o provisional recordings under No. 11.47 - publication in the Space BR IFIC CD ROM - review of a BR finding or decision, in accordance with Article 14 - service documents, in accordance with Article 20 (IFL) - activities related to software engineering, together with the name of the project: o specification, o development / updating o validation - mandatory assistance to administrations required by the RR (e.g. No. 9.60) - general assistance to administrations (excludes the previous item) - preparation of Rules of Procedure - preparation and attendance at ITU and non-ITU meetings (together with the name of the meeting) - management - preparation and publication of SNL - publications other than BR IFIC - training received by the BR staff - training provided by the BR staff to ITU staff - seminars and training provided by the BR staff to administrations - other activities (holidays, sick leave…) The group was of the view that priority should be given to a proper implementation of the new time survey through an appropriate software tool, even if no results can be made available at the 2003 session of Council. The group also agreed upon that the new time survey should be conducted at least within the SSD and IAP departments. The group eventually noted that conducting this new time survey may be somehow connected to the general audit performed in the ITU by the Group of Specialists established by PP-02 Decision COM6/1. -9- ANNEX 3 Radiocommunication Bureau Space Department Activities Agreed In Principle For Inclusion Within Cost Recovery Charges Subject To Clarification Of The Reallocated Costs Table 1 BR Activities not currently covered by cost recovery for which a separate invoice will be issued Notifications (and Ap 30B not covered by special sections) Table 2 Other ongoing BR Activities not currently covered by cost recovery to be included in invoiced charges for coordination or notification Publication in the Space BRIFIC CDROM of special sections including publications for coordination requests and advanced publications Changes to the date of bringing into use Updates to Master Register Provisional recordings under 11.47 Suspension of notices under 11.49 Preparation and publication of Space network list Preparation and publication of Res. 46/D Checking and publication of Due diligence information under Res. 49 Checking of Expiry of networks under Res. 4 and extension of Period of Validity Checking of networks under Res. 51 Suppression of networks Mandatory assistance to administrations under Article 9 of the Radio Regulations (e.g. No. 9.60) [Article 14 – review of a BR finding or decision] Article 20 – Service documents (IFL) [Development and maintenance of BR Space Web page] [Support given to IAP Department for software development] [Space Workshops] - 10 - ANNEX 4 DRAFT DECISION 482 (Rev. 2003) Implementation of cost recovery for satellite network filings The Council, considering a) Resolution 88 of the Plenipotentiary Conference (Rev. Marrakesh, 2002), on the implementation of cost recovery for satellite network filings; b) Resolution 91 of the Plenipotentiary Conference (Minneapolis, 1998), on cost recovery for some products and services of ITU; c) Council Resolution 1113, on cost recovery for the processing by the Radiocommunication Bureau of space notifications; d) Document C99/68 reporting on the Council Working Group on implementation of cost recovery for satellite network filings; e) Document C99/47 on cost recovery for some ITU products and services, recognizing that the Plenipotentiary Conference (Minneapolis, 1998), by Resolution 88, resolved: • that cost recovery for satellite network filings shall be implemented as soon as possible consistent with the general principles for cost recovery adopted in Resolution 91 (Minneapolis, 1998); • that all filings for the production of the special sections of the Weekly Circular for space radiocommunication services concerning advance publication, and their associated requests for coordination or agreement (Article 11, Article 14 plus Resolutions 33 and 46, or Article S9 of the Radio Regulations) and requests for modification of the space service plans contained in Appendices 30/S30, 30A/S30A and 30B/S30B to the Radio Regulations, received by the Radiocommunication Bureau after 7 November 1998, shall be subject to the application of cost recovery using the methodology to be adopted according to Resolution 88, further recognizing the practical experience of the Radiocommunication Bureau in implementing cost recovery filing charges and the methodology as reported to Council 2001 in accordance with Council Decision 482, decides 1 that satellite network filings identified under recognizing above received by the Radiocommunication Bureau after 7 November 1998 shall be subject to charges as set out in Annex A to this decision; - 11 - 2 that the above charges for each satellite network2 filing communicated to the Radiocommunication Bureau, shall be composed of: a) a flat fee3 indicated in Annex A for each category 4, b) an additional charge for the satellite network filing for which the number of [units], when published, exceeds the number of [units]4 covered by the flat fee; 3 that for satellite network filings received by the Bureau after 31 December 2001, the flat fee component shall be paid, in accordance with decides 9, following receipt of the filing by the Radiocommunication Bureau. 4 that the flat fee shall be regarded as a basic charge for a satellite network filing regardless of whether it is a new notice or a modification to a notice5 .For modifications to a notice in Category 1 of Annex A, the additional charge will apply but no additional flat fee component will be charged. 5 that each Member State shall be entitled to the publication of special sections for one satellite network each year without the charges referred to above. Each Member State may determine which network shall benefit from the free entitlement. Modifications to the publications of that network will be published with no charge up to the limit established for excess charges indicated in Annex A which was in force at the time of the original publication; 6 that nomination of the free entitlement for the calendar year of reception by the Bureau of a filing shall be made by the Member State no later than the end of that calendar year5bis. 7 that for any network for which the API was received prior to 7 November 1998, there will be no cost-recovery charges for the first coordination request referring to that API, regardless as to when it is received by the Radiocommunication Bureau. Modifications to these networks communicated to the Radiocommunication Bureau after 7 November 1998, shall be subject to a charge in accordance with decides 2 above. 7bis there will be no cost recovery charges for any request for modification to a plan received prior to 7 November 1998. Any request for modification to a plan for publication in either Part A or Part B received after 7th November 1998 shall be subject to a charge in accordance with decides 2 above. 8 that Annexes A (Schedule of processing charges) and B (Methodology) to this decision should be reviewed periodically by the Council; 9 that the payment of charges specified in Annex A shall be made on the basis of an invoice sent to the notifying administration or, at the request of that administration, to the satellite network operator in question within a period of a maximum of six months after issue of the invoice. An invoice for the flat fee component shall be issued upon receipt of the filing by the Radiocommunication Bureau and, for the additional charge (if any), after the publication of the relevant special section. Administrations shall be invoiced according to the flat fee charges in force ____________________ 2 In accordance with Nos. 1.111 and 1.112 and Appendix 4 of the Radio Regulations, a satellite network consists of one geostationary satellite, or one or more non-geostationary satellites, and one or more cooperating earth stations. 3 The methodology for the calculation of the flat fee and the additional charge is described in Annex B. 4 The fee per frequency unit shall not be understood as a tax imposed on spectrum users. It is used here as a driver for the calculation of cost recovery relating to publication of satellite systems. 4 The definition of the [unit] for each category is found in Annex A. 5 The charge for a modification, where applicable, is based on [units] in respect of those elements (e.g. assigned frequencies, classes of stations, number of emissions) affected by the modification submitted. There will be no charge for modifications which do not result in further technical or regulatory examination by the Radiocommunication Bureau. 5bis The free entitlement cannot be applied to a filing cancelled for non-payment. - 12 - at the date of receipt of the filing or the additional charge (if any) in force at the date of publication of their respective networks. In the event a satellite network filing is cancelled after payment of the flat fee component, this flat fee component is not refundable. If a filing is cancelled as a consequence of non-payment, the corresponding invoice(s) shall be deemed uncollectable; 10 that publication of special sections for the amateur-satellite service shall be exempt from any charges, instructs the Director of the Radiocommunication Bureau to submit an annual report to the Council on the implementation of this decision, including analyses of: a) the cost of the different steps of the procedures; b) the impact of the electronic submission of information; c) enhancement in quality of service, including, among others, reduction of the backlog; and d) the costs of validating filings and requesting corrective action thereto, invites the External Auditor to prepare, in accordance with Article 31 of the Financial Regulations, and to submit to the Council an annual report containing a financial and management audit of the processing costs incurred by ITU in the selected cost categories identified in Annex B and, the charges collected.