INTERNATIONAL TELECOMMUNICATION UNION
AD HOC GROUP ON COST RECOVERY
FOR SATELLITE NETWORK FILINGS
Document INFO/2
15 October 2003
Original: English
GENEVA, 20 – 23 OCTOBER 2003
Information Document by the Radiocommunication Bureau
Time Study and Initial Indications
1. Purpose of the Time Study
In order to check if the current cost recovery categories are still appropriate, as requested
by the ITU Council, a Time Study was initiated in the autumn of 2001. The following was set as the
goals of the study: (i) to collect data concerning time that is needed for treatment of individual
filings, (ii) to analyze the data collected and try to find what represents an appropriate measure of
complexity and size of filings that can be related to time necessary for treatment and (iii) to
establish ratios between different complexity categories and relation to the size of filings. The
purpose was to establish ratios between different categories of cases within Coordination, Plans
and Notification so that the appropriate portion of the overall cost can be properly assigned to
particular categories to set the cost recovery fee structure. The goal thus was not to establish
absolute time for treatment, but rather time ratios between different categories. In view of the
above goals, during the design phase that took about three months, it was decided to conduct the
study for Coordination, Notification and Plans filings, only in SSD and only for the complement of
staff who are directly involved in the treatment of filings (those whose “fingerprints” are on
Coordination and Plans Special Sections and Parts-IS, -IIS and –IIIS of the BR-IFIC). It was felt
that study concentrated only on the core activity would give better insight into reasons for
differences in treatment time and make it possible to establish categories of filings for cost
recovery purposes and relative weights among them. There are, of course, many other associated,
inseparable and indispensable activities, such as management of various activity teams, handling,
archiving and dispatching of physical folders and correspondence, CR/D processing, 9.5D
processing, 9.41/9.42 processing, 11.44.1 processing, regulatory assistance, general divisional
and departmental support and management, etc, the costs of which need to be recovered.
At different stages of treatment of filings different individuals, teams or Divisions of SSD are
involved. The processing of Coordination, Plans and Notification submissions (see companion
document for details of processing) was divided into 25 individual tasks according to the workflow.
Every staff member performing those tasks was requested to record the time taken for his/her
task(s) relevant to a particular filing. For this purpose, a time sheet to be filled in traveled with the
physical filing folder. Guidelines for filling the time sheet, that also contained the list of tasks, were
issued to all staff involved. Upon completion of the processing, SPR Division captured data from
the time sheet into a database. A sample Time Sheet and the Guidelines are shown in Annex 1.
2. Description of Tasks
Tasks as defined for the purpose of this time study are not exactly the same for
Coordination, Notification and Plans. Tables 1 and 2 describe relevant tasks separately for
Coordination and Notification, and Plans, respectively.
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Table 1
Description of Tasks for Coordination and Notification
No.
1
2
3
4
5
6
7
8
9
Task
Name
Contents of the task
Coordination
Notification
Transfer the received electronic file, to server M:\BRSSD\….
Registration
Open the zip file. Run Fix-Things. Print the files.
As-received
Prepare the folder. Give ID number. Scan letters and annexes. Transfer mdb files
publication
from M:\BRSSD\ to M:\BRSSD\BACKLOG\
Enter validation request data in SNTrack, include frequency information to check that
Pre-validation
frequencies notified are covered by an appropriate API Special Section.
If they are not, check Coordination Special Section.
For an Earth Station, check if notified frequencies are
covered by its satellite’s frequency bands.
For a Radioastronomy station, check that the notified
frequency bands are allocated to this service, according
to Table of Allocation (Article 5) and split if necessary.
Run Validation program against mdb file to check if there are fatal or any other errors
that may require further information from the Administration.
Manually check the notice to verify that it is receivable under No. 9.5D and that the
Date of Bringing into Use is within the 3/7/9 year limit. Also manually check AP4 data
which is not at present checked by the Validation program (Non-GSO networks in
particular, but not exclusively)
For re-submissions, check that it is received within 6
months from the date of return of notice.
Check that all necessary graphical data has been provided by the Administration
Send acknowledgement of receipt fax to the Administration; include items where
clarification or additional information is required from the Administration.
Prepare instructions for the Data Capture group on modifications to be made to the
coordination request while importing the mdb file into the SNS. This normally
Notice
concerns modifications as a result of correspondence between the Administration and
preparation
the Bureau.
Update SNTrack to indicate that coordination/notification request file has been passed
to SNS Capture team for their treatment.
Analyse the type of network and complexity of treatment required. Dispatch the work
Data capture by priority and complexity and carry out the changes to the data. Register in SNTrack
before/after treatment (status 05).
Special modifications required by SSC (to help
examimation) which imply using SpaceCap,
Sdamd, Gcor, Split, Clone and other tools
Where all graphical data necessary has been provided by the Administration, prepare
the GIMS cover page giving instructions to the GIMS Capture Group about the data to
GIMS
be captured by them.
preparation
Update SNTrack to indicate that coordination/notification request file has been passed
to GIMS Capture team for their treatment
Capture GIMS information. Verify graphical information for coordination/notification
requests. Verify contours and Service Areas for their completeness and correctness.
GIMS capture
Capture and verify graphical information for Plan networks.
Classify the folders and keep them updated.
Run CFEX program to mainly ensure that MOD notices are correctly matched with
their targets (networks to be modified) and to set the necessary finding required flags.
Check that CFEX has run correctly, then run Validation program. Print out validation
Validation
results, analyse them and, if necessary, correct the SNS before re-running CFEX and
Validation programs, until satisfied that the request is complete. If still not complete or
correct, find the reason and write to the Administration for clarification or additional
information. Update SNTrack to indicate that validation has been completed.
After the final check by supervisor that the notice is complete, pass it to status 10 in
SNS. Run PCOM program, which basically checks SNS data against graphical data to
PCOM and
see that no diagrams are missing in GIMS. If PCOM finds no problem, it passes the
Completeness transaction to Status 20. If this is not successful, investigate the reason and either
modify SNS or notify GIMS Capture team of any necessary action. Update SNTrack.
Pass the file for printing and filing – it is now ready for examination by SSC.
2/31
Table 1 (Cont…)
No.
10
11
12
13
14
15
16
Task
Name
Assistance
Restructure of
Notices
Network
Summary
Examination 1
Contents of the task
Coordination
Notification
Assist administrations in correcting their submissions
Do splitting of groups, beams, etc. as needed
(Considered under tasks 5, 8 or 17)
due to different provisions and findings.
Not yet implemented. Cost recovery
(Not Applicable)
summary is included in CR/C.
Familiarize with, study and understand the request,
first-submission, ADD, MOD, 11.32A request,
in particular MODs;
resubmission with or without 11.32A/11.41
request;
decide on the treatment of MOD and other assignments and their date of recognition
(2D-date) and compliance with other regulatory dates, compile list of frequencies with
assigned bandwidths, classes of station and service areas. For each assignment
establish: compliance with ToFA and applicable footnotes, applicable form(s) of
coordination, applicability of PFD, EIRP and other limits; using the available software
tools or manually (in particular for Non-GSO cases) check compliance with those
limits; decide on its finding (9.35/11.31). Identify and mark splits necessary to adjust
groups of frequency assignments to findings and the applicable form(s) of
coordination; mark unfavourable groups of frequency assignments;
request SPR to split groups and enter
unfavourable findings
When examination under No.11.32 is
required, the coordination and notification
characteristics are compared, analysed and
coordination requirement from existing
After splits were done and
special sections (CR/C , CR/D, AR14/D,
unfavourable findings were entered by RES33/D etc.,) identified for each group or
SPR and using the available software new coordination requirement established
tools and applicable criteria, establish and splits identified. For earth stations
coordination requirements with
coordination requirements is established
Examination 2
affected network lists (9.36), do it partly from the coordination contours. The
manually for Non-GSO and create
coordination completed by the administration
database results, verify the accuracy
is compared with the coordination identified
and adjust results if necessary, merge and findings established. When the
all results into one mdb file.
coordination is not completed case is posted
for 11.32A examination if so requested by the
administration. The results of analysis is
captured in text file with reasons and findings
in excel file used by SPR for findings capture.
Prepare document for approval, show Prepare document for approval by the
each assigned frequency against its
Weekly Meeting, showing findings for each
assigned bandwidth, class of station,
group of frequency assignments with
applicable forms of coordination and
reasons, to approve recording in the MIFR or
finding, explain reasons for
return of the notices to the administration.
unfavourable or conditions for
After approval, SPR enters the assignments
Document for
favourable finding; summarize
to the network to MIFR and publishes the
approval
coordination requirements for each
PART II-S or returns the notices to the
form of coordination; explain MODs;
administration those unfavourable
enter any other necessary information. assignments published in PART III-S (tasks
After approval, pass coordination
17, 18 and 22). Advise to the administration
requirements file to SPR for entry into (indication of appropriate action) is included
SNS.
as part of the examination results.
Examination
Control appropriateness and accuracy of work done under tasks 13, 14 and 15
control
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Table 1 (Cont…)
No.
17
18
19
20
21
22
23
24
25
Task
Name
Contents of the task
Coordination
Notification
Using FINDCAP and SPLITGROUP /SMOVE
Enter findings, favourable or
software, split groups by frequency, class of
unfavourable, date of protections and
Finding
station and/or emission, as necessary. Capture any remarks using FINDCAP
capture
unfavourable and favourable findings and date software.
of protection. Print TSUM of the network.
Prepare findings document.
Prepare administration’s notes. Prepare BR
Check if any revision of findings is
Preparation of Notes. Check GIMS diagrams. Scan diagrams needed after the approval meeting.
Publication
for Non-GSO networks. Check coordination
Publication of Part II-S/III-S is
requirements.
generated by software.
Check the publication document
where there may be a problem with
Verification
NA
the transaction to go through the
automatic update process.
Completion of the networks: Using FINDCAP /GIBC/
/SPACEPUB software, transfer coordination
Only necessary where there
requirements from mdb files to SNS, change status,
Final
may be a problem with the
update CR/C and IFIC Nos, print draft CR/C, make final
Verification
transaction to go through the
verification of findings, BR’s and administrations’
automatic update process.
Notes. Prepare and verify the final version of the CR/C
Special Sections for publication in IFIC-CD.
Update of
A series of computer program that is run every two weeks.
database
Info to admins
Preparation of letters and notice summary for
& corresp.
notices which received an unfavourable finding.
Includes all aspects of treatment of an API notice:
registration, entry in SNTRACK, manual pre-validation
and validation, notice preparation, data capture,
restructuring of the notice, if required, PCOM,
API
NA
preparation of the approval document, preparation of
the publication, entry of the Special Section number,
verification of the IFIC CD-ROM, update of the
database, information to the administration.
For API: check the maximum possible extension, if
Change to
necessary capture the target if it is not in SNS, prepare
Date of
(with the 2c date wizard) the MOD transaction and
Publication in Part II
Bringing into then, as for API, publish it as an API MOD.
For CR: Modification, based on the API MOD, is done
Use
automatically by a software tool during the Update
Others
(To be used and explained on a case-by-case basis)
4/31
Table 2
Description of Tasks for submissions under Article 4 of Appendices 30 and 30A
Detailed Task in the Time
Sheet
Description of task group
01 Registration
02 As-received publication
05 Data capture
- Creation of physical folder for the submission
- Registration of the submission in the BR tracking database
- Preparation of the submission for as received publication
- Data capture of the submission
- Data comparison and verification of captured data
03 Pre-validation
08 Validation
09 PCOM and
Completeness
Data validation and completeness excluding the relevant correspondence.
06 GIMS preparation
07 GIMS capture
GIMS validation and data capture.
10 Assistance
22 Info. to adm. & corresp
Correspondence and information to administrations including inquiries for
missing/incomplete data in the submission.
13 Examination 1
14 Examination 2
15 Prep. Doc. for approval
16 Examination control
- Regulatory examination with respect to compliance with the provisions of
Apendices 30 and 30A
- Technical examinations for extracting list of affected administrations/networks
under § 4.1.1/4.2.1 of Article 4 of Appendices 30 and 30A
- Establishment of coordination requirement in the case of Part B request
(category 8)
- Preparation of a document containing list of affected administrations and
networks and/or Bureau’s notes for approval at Weekly Meeting
- Transfer of technical examination results into the SPS (Space Plans
Systems) database
- Data capture of IFIC information in the SPS database
18 Preparation of
Publication
19 Verification
20 Final Verification
21 Update of database
- Preparation of the draft Special Section containing network characteristics
and lists of affected administrations/networks from the SPS database
- Verification and insertion of the Bureau’s notes in the Special Section
- Preparation of the SPS database for the IFIC
3. Data Collected
Data collection has been going on for about two years by now. During that time, about 1200
coordination special sections (CR/C) have been published, about 150 submissions under
Appendices 30 and 30A have been treated and more than 200 requests for recording of space
stations in MIFR as well as more than 400 requests for recording of earth stations have bean
processed. Through the time study this made it possible to collect a real wealth of data. Table 3
summarizes the amount of data collected.
Table 3 – Size of Data Collected
Number of networks for which time data are available for a range of tasks
Data Preparation
Tasks
1-7
8-9 10-12
Coordination
250-300 600
0
Plans - Part A
Plans - Part B
Notification - SS 100-200
80
20
Notification – ES 100-200 150
30
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Examination
13-16
1200
140
12
230
430
Publication
17-19
20-24
150-250
0-100
100-230
300-400
50
50
While this represents a gold mine of useful data, data collected is not perfect. For example,
collection of data concerning coordination publication tasks stopped after about six months due to
a misunderstanding as to whether publication was under cost recovery or not. Despite this, the
collected publication data exhibit relatively narrow spread of time and might thus be usable.
Coordination processing backlog, which was at its peak when data collection started, also acted on
data collection. At that moment, large portion of coordination backlog was awaiting examination,
i.e. large number of coordination requests had by then already passed data preparation phase, in
particular the early stages of that phase (tasks 1-7). Therefore, the number of networks for which
data is available for tasks 1-7 is much smaller than the number of published CR/C special sections.
Also, there seems to have been a misunderstanding of the scope of some of these tasks and these
data may need further analysis and possibly a correction before they can be used. Figures 1 and 2
show more specific, per task, histograms of data points available for Coordination and Notification.
Figure 1 resembles the effect of coordination backlog on data collection – fewer data points for
early stages of processing, with sample size growing for subsequent, later stages of processing.
Number of Notices (Coordination Requests)
1400
1200
Number of notices
1000
800
600
400
200
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
21
22
23
24
25
Task number
Figure 1
Data collected for Coordination Requests
Number of Notices (Notifications Space Station)
300
Number of notices
250
200
150
100
50
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Task number
Figure 2
Data collected for Notification of Space Stations
6/31
Raw data available, before any correction, indicate that examination time dominates. The
first analysis for coordination and notification was therefore done only for examination phase, i.e.
for tasks 13-16. To increase sample size, in particular for tasks 1-7 (and for publication phase for
which data collection was resumed), data collection will continue till the spring 2004 session of the
Council.
4. Preliminary Indications from Data Collected
4.1 Coordination Requests
This initial data analysis was done using data in the overall SSD database as well as in the
database of SSC. The two databases are complementary. Overall database contains data about
current cost recovery category for each processed network, while SSC database contains data
about forms of coordination applicable to each processed network as well as its number of cost
recovery units. Processed networks in the two databases are the same, except that SSC database
is slightly larger as it also contains data about networks that were fully examined but were then
withdrawn by their administrations just before publication. These are valid data points for
examination and they increase the sample size.
For reference purposes, the current cost recovery categories for coordination are shown in
Table 4 below.
Table 4
Current Cost Recovery Categories for Coordination
Category
2
3
4
5
6
Description
CR/C - GSO under 9.7 ± 9.11 ± 9.21
CR/C - GSO under 9.7 and 9.11A
CR/C - Non-GSO under 9.11A
CR/C - Small
CR/C - Non-GSO under 9.21
Table 4 testifies that current cost recovery categories for coordination are related to forms
of coordination applicable to a coordination request. The nature of that relation was judged to be
appropriate at the time when categories were established. In the meantime, there has been
considerable development in the overall software support of treatment, in particular examination, of
coordination requests. Intuitively, some relation between the applicable forms of coordination, as
an expression of complexity of a coordination request, and time for treatment should be expected.
The problem is to find what now, after those developments took place, might be a representative
relation.
For this purpose, an exhaustive list of all Individual Forms of Coordination (IFoC) that exist
in Article 9 of Radio Regulations, Appendices and Resolutions, was made. These IFoCs are
indicated by lower case letters a to n in Table 5 below. Their number is large, 13 (without RS84).
Some of them apply only to GSO networks (9.7, RS33#3, A30#7.1, A30A#7.1 and 9.13), others
only to Non-GSO networks (9.12 and 9.12A) and are thus mutually exclusive, while yet others
apply to both GSO and Non-GSO networks (9.11, RS33#2.1, 9.14, 9.21/A, 9.21/B and 9.21/C).
From this, the theoretical maximum number of IFoCs for a single very complex network is 11.
Then, an initial analysis was made to find the average relative processing time for cases
with different number of applicable IFoCs, i.e. average for cases with any single (among a to m in
Table 5) applicable IFoC, average for cases with any combination 2 applicable IFoCs (any two out
of a to m in Table 5), etc. This first analysis yielded the curve in Figure 3. Time values are
normalized to the average examination time for networks to which only one IFoC is applicable.
7/31
Table 5
Forms of Coordination, IFoC and FoC
Individual Form of
Coordination (IFoC)
a
9.7
b
RS33#3
c
A30#7.1
d
A30A#7.1
e
9.11
f
RS33#2.1
g
9.12
h
9.12A
I
9.13
j
9.14, RS77
k
9.21/A
l
9.21/B
m
9.21/C
RS84
n
Forms of Coordination (FoC)
A
9.7, RS33#3
B
A30#7.1, A30A#7.1
C
9.11, RS33#2.1
D
9.11A (9.12, 9.12A, 9.13, 9.14), RS77
E
9.21 (9.21/A, 9.21/B, 9.21/C)
Ignored, suppressed by WRC-03
Tasks 13, 14, 15, 16
IFOC:
(9.7), (AP30#7.1), (AP30A#7.1),
(RS33#3), (9.11), (9.12), (9.12A), (9.13),
(9.14/RS77), (9.21/A), (9.21/B), (9.21/C),
(RS33#2.1)
7
Relative Average Time (to IFOC = 1)
6
5
4
3
2
1
0
0
1
2
3
4
5
6
7
8
9
Individual Forms of Coordination
Figure 3
Average relative examination time for cases with different number of
applicable Individual Forms of Coordination (IFoC)
Figure 3 reveals a monotonically increasing average relative treatment time with increasing
number of applicable IFoCs. This gave the first support for the approach taken.
While this gives an indication that relation between IFoCs and relative average time exists,
individual forms of coordination (IFoCs) are not necessarily the best measure of complexity. In
Radio Regulations some groups of IFoCs fall under one lead provision and those IFoCs that
belong to the same lead provision almost always go together, e.g. 9.11A invokes 9.12 and 9.12A
and 9.14 for Non-GSO networks or 9.13 and 9.14 for GSO networks. Also, some pairs of IFoCs act
practically as a single provision, e.g. 9.7 and RS33#3, 9.11 and RS33#2.1. Therefore, Forms of
Coordination (FoC), indicated by capital letters A to E in Table 5, are more naturally related to
Radio Regulations. These FoCs were then used in the second step of the exercise. Here, IFoCs
A30#7.1 and A30A#7.1 are also take as one FoC due to the simplicity of attaching them to
8/31
assignments of a network. Average relative times for different number of applicable FoC are shown
in Figure 4.
Tasks 13, 14, 15, 16
9
Relative Average Time (to FOC = 1)
8
FOC:
(9.7/RS33#3), (AP30#7.1/AP30A#7.1),
(9.11/RS33#2.1),
(9.12/9.12A/9.13/9.14/RS77), (9.21/A/B/C)
NB. If < 1 then 1
7
6
5
4
3
2
1
0
0
1
2
3
4
5
6
Forms of Coordination
Figure 4
Average relative examination time for cases with different number of
applicable Forms of Coordination (FoC)
This also shows monotonic increase of relative examination time with increasing number of
applicable FoCs. Cases to which 5 FoCs apply are extremely rare. In more than 1000 coordination
requests studied there were only 4 such cases. Frequency of occurrence of different number of
IFoCs and FoCs is shown in Table 6 below.
Table 6
Frequency of occurrence of different number of applicable IFoCs and FoCs
Number of Networks (=number of data points)
Individual Forms of Forms of Coordination Forms of Coordination
Coordination (IFoC)
(FoC) - Up to 5
(FoC) - Up to 4 (4=4&5)
1
456
470
470
2
279
474
474
3
340
312
312
4
134
33
37
5
26
4
6
34
7
15
8
9
Total
1293
1293
1293
Finally, the same exercise was done for up to four applicable FoCs, where case 4 actually
combined 4 and 5 applicable FoCs. Relative average examination time for this is given in Figure 5.
Again, it shows monotonic increase of average relative time with increasing number of FoCs.
9/31
Tasks 13, 14, 15, 16
4
FOC:
(9.7/RS33#3), (AP30#7.1/AP30A#7.1),
(9.11/RS33#2.1),
(9.12/9.12A/9.13/9.14/RS77), (9.21/A/B/C)
NB. If < 1 then 1 and if > 4 then 4
Relative Average Time (to FOC = 1)
3.5
3
2.5
2
1.5
1
0.5
0
0
1
2
3
4
5
Forms of Coordination
Figure 5
Average relative examination time for up to 4 different
applicable forms of coordination (FoC)
This indicates that new cost recovery categories might be related to the number of forms of
coordination (FoC) applicable to a particular coordination request. Such an approach would more
intimately relate the complexity of coordination requests to the Radio Regulations. Possible new
cost recovery categories are shown in Table 7.
Table 7
Possible New Cost Recovery Categories for Coordination Requests
New Category
1
2
3
4
(5)
Number Forms of Coordination
(FoC)
1
2
3
4 (,5)
(5)
After this, the relation of examination time with size of the coordination request was studied.
Current cost recovery units were used as the measure of size. They are well related to what under
Radio Regulations constitute an assignment and an assignment is actually the subject of
examination and overall processing. Figures 6 to 9 are scattergrams of data points, i.e. relative
time versus number of units, for cases of 1, 2, 3 and 4 applicable FoCs, respectively. Best-fit lines
are also included in these Figures.
10/31
Tasks 13, 14, 15, 16 (FOC = 1)
16.0
12.0
10.0
8.0
6.0
4.0
y = 3E-05x + 0.9481
2.0
0.0
0
5000
10000
15000
20000
25000
30000
35000
40000
Units
Figure 6
Scattergram and-best fit line for one applicable FoC
Tasks 13, 14, 15, 16 (FOC = 2)
18.0
16.0
Relative Total Time (to Average Time for FOC = 1)
Relative Total Time (to Average Time for FOC = 1)
14.0
14.0
12.0
10.0
8.0
6.0
4.0
y = 4E-05x + 1.4625
2.0
0.0
0
5000
10000
15000
20000
25000
Units
Figure 7
Scattergram and best-fit line for 2 applicable FoCs
11/31
30000
35000
Tasks 13, 14, 15, 16 (FOC = 3)
Relative Total Time (to Average Time for FOC = 1)
12.0
10.0
8.0
6.0
4.0
y = 1E-05x + 1.525
2.0
0.0
0
5000
10000
15000
20000
25000
30000
35000
40000
45000
50000
Units
Figure 8
Scattergram and best-fit line for 3 applicable FoCs
Tasks 13, 14, 15, 16 (FOC = 4)
Relative Total Time (to Average Time for FOC = 1)
14.0
12.0
10.0
y = 0.0001x + 2.8091
8.0
6.0
4.0
2.0
0.0
0
10000
20000
30000
40000
50000
Units
Figure 9
Scattergram and best-fit line for 4 (4 and 5 combined) applicable FoCs
12/31
60000
18.0
Relative Total Time (to Average Time for FOC = 1)
16.0
14.0
12.0
10.0
4 FOC Provns
8.0
6.0
4.0
2 FOC Provns
3 FOC Provns
2.0
1 FOC Provn
0.0
0
10000
20000
30000
40000
50000
60000
Units
Figure 10
Best-fit lines for 1 to 4 applicable FoCs
Figure 10 shows that the ratio of relative examination time, expressed by the best-fit lines,
between the simplest and smallest case (one applicable FoC, number of units close to zero) and
the most complex and very large case (4 or 5 applicable FoCs, number of units about 50000) is
about 1:8. If processing time is good indicator of costs involved (which it should be) this indicates
that the ratio of cost recovery fees for all coordination requests should be restricted to about 1:8.
For comparison purposes, current cost recovery fees for coordination were normalized to
the flat fee of the current Category 2. This is shown in figures 11 and 12. Figure 11 covers manly
the flat portion of fees (small number of units) while Figure 12 covers the mid portion up to about
1500 units. These Figures indicate a ratio of fees of the order of up to about 80. If one extends
these curves up to 50000 units the ratios become much, much greater and go into thousands (see
Table 8).
Table 8
Ratio of Current Cost Recovery Fees for Coordination
Current Category
Recovery Category
1
2
3
4
5
6
Flat Fee
Reference
1
Ratio for
50 000 units
1312
45
143
553
2527
1027
As a further check, for cases studied, scattergrams and best-fit lines relevant to the current
coordination cost recovery Categories 2 to 6 were also produced. They are shown in Figures 13,
14, 15, 16 and 17. These Figures indicate that even for the current cost recovery categories,
dependence on the size of coordination submission is generally much weaker than what results
from the current cost recovery fees.
13/31
Relative Fees (to Category 2 Flat Fee)
4
Category 3
3.5
3
Category
1
2
3
4
5
6
2.5
2
1.5
Description
API
Coord request under Art 9 (ex 9.11A)
Coord request under Art 9 (incl 9.11A)
Coord request under 9.11A (NGSO)
Small coord request (ex MSS/FSS/BSS)
NGSO coord (9.21 only)
Flat fee per
filing (in
CHF)
1300
5600
21000
7100
5900
4900
No of units Add charge
covered by per excess
flat fee
unit
6
147
1103
5
1170
16
137
62
12
288
10
115
Category 4
Category 5
1
Category 2
Category 6
0.5
Category 1
0
0
2
4
6
8
10
12
14
16
18
20
Units
Figure 11
Current relative cost recovery fees for coordination – flat fee portion
90
Category
1
2
3
4
5
6
80
Relative Fees (to Category 2 Flat Fee)
70
Description
API
Coord request under Art 9 (ex 9.11A)
Coord request under Art 9 (incl 9.11A)
Coord request under 9.11A (NGSO)
Small coord request (ex MSS/FSS/BSS)
NGSO coord (9.21 only)
Flat fee per
filing (in
CHF)
1300
5600
21000
7100
5900
4900
No of units Add charge
covered by per excess
flat fee
unit
6
147
1103
5
1170
16
137
62
12
288
10
115
Category 5
60
50
Category 1
40
Category 6
30
20
Category 4
10
Category 3
Category 2
0
0
200
400
600
800
1000
1200
1400
Units
Figure 12
Current relative cost recovery fees for coordination – up to 1500 units
14/31
1600
Category 2: Coordination Request under Art 9 (excl. 9.11A)
Relative Total Time for Tasks 13 - 16 (to Average Time for FOC = 1)
16
14
12
10
8
6
4
y = 3E-05x + 1.1472
2
0
0
5000
10000
15000
20000
25000
30000
35000
40000
45000
50000
Units
Figure 13
Scattergram and best-fit line relevant to the current cost recovery Category 2
Category 3: Coordination Request under Art 9 (incl. 9.11A)
Relative Total Time for Tasks 13 - 16 (to Average Time for FOC = 1)
14
12
10
8
6
y = 6E-05x + 1.4854
4
2
0
0
10000
20000
30000
40000
50000
Units
Figure 14
Scattergram and best-fit line relevant to the current cost recovery Category 3
15/31
60000
Category 4: Coordination Request under 9.11A (NGSO)
Relative Total Time for Tasks 13 - 16 (to Average Time for FOC = 1)
4
y = 6E-05x + 1.472
3.5
3
2.5
2
1.5
1
0.5
0
0
5000
10000
15000
20000
25000
30000
35000
40000
Units
Figure 15
Scattergram and best-fit line relevant to the current cost recovery Category 4
Category 5: Small Coordination Request (excl. FSS/MSS/BSS)
Relative Total Time for Tasks 13 - 16 (to Average Time for FOC = 1)
1.8
1.6
1.4
1.2
y = 0.0012x + 0.6804
1
0.8
0.6
0.4
0.2
0
0
50
100
150
200
250
Units
Figure 16
Scattergram and best-fit line relevant to the current cost recovery Category 5
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Category 6: NGSO Coordination Request (9.21 only)
Relative Total Time for Tasks 13 - 16 (to Average Time for FOC = 1)
18
y = 0.0069x + 3.4893
16
14
12
10
8
6
4
2
0
0
200
400
600
800
1000
1200
1400
1600
1800
2000
Units
Figure 17
Scattergram and best-fit line relevant to the current cost recovery Category 6
17/31
4.2. Preliminary Indications from Data Collected for the submissions under Article 4 of
Appendices 30 and 30A
No data was available for task no. 1 which was not yet started during the period under
study. Moreover, since all notices under study were received before the commencement of time
sheet recording, no data was available for task no. 2. It is expected that these two tasks require a
constant small amount of timing irrespective of the notice characteristics.
4.2.1. Category 7: Part A Special Section
Analysis of the captured data shows no meaningful relationship with the time spend for the
examination and publication phases and the cost recovery units.
Figures 18 and19 illustrate relationship between the relative time (compared to the average
value of the total time spent for notices of the corresponding sub-category of Special Section, i.e.
AP30/E/, AP30A/E/ and AP30-30A/E/) spent for the data preparation phase versus number of units
and groups respectively. In order to exclude the effect of exceptional cases, 2 samples having very
high value of relative time to data preparation phase have not been considered in this analysis.
Figure 18 shows that relation between the number of units using the formula for the
category 7 in Annex A to Decision 482 of the Council (Doc. C02/68) and the relative time is not
considerable. On the other hand from Figure 19 it could be noted that there is more significant
correlation between the number of groups in the SNS/SPS database and the relative time (a
difference of 0.46 between the start-point and end-point of the trend line in Figure 19 vis-à-vis 0.33
in Figure P1).
In order to exclude the effect of exceptional cases, 5 samples having very low or very high
value of total relative time have not been considered in the corresponding analysis. Figures 20-22
illustrate relationship between the relative total time spent for all three phases versus some
parameters. It could be noted that more significant correlation exists between the total relative time
and the number of groups compared to that of cost recovery units. In Figure 22 an alternative
parameter instead of number of groups is shown which is the combination of beams, channels,
type of polarization and types of earth station antenna. The correlation between this parameter and
the total relative time (the range of 0.29 compared with 0.22 for the no. of groups) is comparable to
that of number of groups. However, this is an independent parameter that could be extracted from
the network characteristics even before data capture. Moreover, it includes the number of
assignments which has an impact on the size of the network.
The calculated cost based on the Council’s Decisions 482 and 513 (Documents C03/68
and C03/88 respectively) relative to the flat fee (15800) and the relative total time of the Part A
samples (category 7) are illustrated in Figure 23. It could be noted that the current calculated cost
does not have a meaningful correlation with respect to the total time spent for each network.
Moreover, the ratio between the maximum and minimum calculated cost recovery fee is about 15
which is much greater than the ratio between the maximum and minimum relative total time which
is about 5.
4.2.2. Preliminary Conclusion
Initial results of these studies indicate that there is no remarkable correlation between the
processing time of the category 7 of notices and the cost recovery units. The number of groups or
combination of beams, channels, type of polarization and types of earth station antenna may be
more suitable for prediction of the processing time within the SNP division. However, there are
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some other factors, such as those listed below, that could not be quantified but may have
significant impact on the processing time:
- accuracy and consistency of the notices submitted on paper;
- proper communication between administration and the Bureau, specially at the level of
technical experts;
- exceptional cases which require upgrading technical examination software;
- application of the new provisions to some notices such as grouping concept contained in
Resolution 548 [COM6/4] (WRC-03) which increase the processing time;
- etc.
It is therefore expected that even with a large number of samples, it will not be possible to predict
the relevant processing time with sufficient precision only from the network characteristics of the
notice.
Since complete data sheet only for 12 samples were available for Part B processing (category 8),
statistical analysis were not considered useful for this category. In general, any alternative
modelling of the size of a Part A notice could be also used for Part B. However, the constant and
coefficient factor of such formula might be different according to the estimated average cost for this
category.
Figures 24 and 25 show the calculated cost recovery fee relative to the flat fee of each
AP30/30A sub-category based on the Council’s Decisions 482 and 513 versus the units. The range
of units used in these Figures is about the same range of Part A samples (units up to 48640). From
these Figures it could be noted that the ratios between the maximum and minimum calculated cost
recovery fees are about 15 and 30 for categories 7 and 8 respectively for the range of units
appearing in the samples under study. These ratios seem to be far from reality taking into account
the ratio of relative times.
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Figure 18
Data Prep. Relative Time vs
Cost Recovery Units
2.0
y = 7E-06x + 0.6143
1.8
Relative Time
1.6
1.4
1.2
1.0
0.8
0.6
0.4
0.2
0.0
0
10000
20000
30000
40000
50000
Cost Recovery Units
60000
Relative time
Relative Time Trend
Linear (Relative Time Trend)
Figure 19
Data Prep. Relative Time vs
No. of Groups
2.0
y = 0.0073x + 0.5675
1.8
1.6
Relative Time
1.4
1.2
1.0
0.8
0.6
0.4
0.2
0.0
0
10
20
30
40
No. of Groups
50
60
70
Relative time
Relative Time Trend
Linear (Relative Time Trend)
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Figure 20
Relative total time vs Cost Recovery Units
2.50
y = 2E-06x + 0.95
Relative Total time
2.00
1.50
1.00
0.50
0.00
0
10000
20000
30000
40000
50000
60000
Total Relative Time
Cost Recovery Units
Trend Line
Linear (Trend Line)
Figure 21
Relative total time vs No. of Groups
2.50
y = 0.0034x + 0.9217
Relative Total time
2.00
1.50
1.00
0.50
0.00
0
10
20
30
40
No. of groups
50
60
70
Total Relative Time
Trend Line
Linear (Trend Line)
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Figure 22
Relative total time vs combination of beams, channels, polarization and
e.s. antenna types
2.50
y = 0.0005x + 0.9098
Relative Total time
2.00
1.50
1.00
0.50
0.00
0
100
200
300
400
500
combination of beams, channels, polarization
and e.s. antenna types
600
700
Total Relative Time
Trend Line
Linear (Trend Line)
Figure 23
16
4.0
14
3.5
12
3.0
10
2.5
8
2.0
6
1.5
4
1.0
2
0.5
0
0.0
Sam ples sorted on total relative tim e
Relative Cost
Relative Total Time
22/31
Relative Total Time
Relative Cost
Relative Cost based on the Units vs Relative Total Time
(Part A)
Figure 24
Relative Cost vs Units
9.0
8.0
7.0
5.0
4.0
3.0
2.0
1.0
0.0
0
2000
4000
6000
8000
10000
Cost Recovery Units
Cost Cat. 7.1
Cost Cat. 8.1
Cost Cat. 8.2
Cost Cat. 7.2
Figure 25
Relative Cost vs Units
35.0
30.0
25.0
Relative Cost
Relative Cost
6.0
20.0
15.0
10.0
5.0
0.0
10000
15000
20000
25000
30000
35000
Cost Recovery Units
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40000
45000
50000
Cost Cat. 7.1
Cost Cat. 8.1
Cost Cat. 8.2
Cost Cat. 7.2
4.3. Preliminary Indications from Data Collected for Notification Submissions
(Non-planned services)
Concerning processing of notification submissions, indications in this section are based on analysis
of examination tasks 13, 14, 15 and 16. Indications are preliminary due to that and also due to the
still early stage of analysis and absence of previous cost recovery experience in this area.
4.3.a The Time Study planned in the autumn of 2001 did not envisage collection of data about
the characteristics of notification filings that might affect the processing time. Therefore, for the
purpose of this analysis, data were subsequently generated on the number of applicable forms of
coordination for each case, whether the notification submission covered only one or multiple
coordination special sections, and whether notified characteristics were the same as or differed
from coordination data. From experience, the above and in particular the dissimilarity between
coordination and notification data and coverage of several coordination special sections (the
original plus several modifications), were felt to considerably affect the processing time. Tables N1
and N2 show how the forms of coordination (provisions) were grouped for this purpose and how
the complexity factor was defined.
Table N1
Grouping of Forms of Coordination (Provisions)
Grouped Forms of Coordination (Provisions)
9.7
RR33#3
RR1060
A30#7.1
A30A#7.1
9.11
RS33#2
9.11A (9.12, 9.12A, 9.13, 9.14)
RS46
RS77
9.21 (9.21/A, 9.21/B, 9.21/C)
AR14
11.32A
11.41
RR1544
9.15
9.17
9.17A
A
B
C
D
E
F
G
Table N2
Definition of Complexity Factor
Complexity
Factor
Notified Data Same as
Coordination Data ?
1
2
3
4
Yes
No
Yes
No
Notification covers 1 or
more than 1 Coordination
Special Section ?
1
1
Multiple
Multiple
4.3.b The processing of Notices for recording in the MIFR has the following features that are
different from those of coordination requests processing.
4.3.b.1 When an unfavourable finding is established for a Notification case, the case is returned to
the administration. The notice may be resubmitted within the stipulated regulatory time limit and
this is considered as part of the notification process, as illustrated in the diagram below.
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NOTIFICATION PROCESS
Submission of
Notices under Article 11
Returned under
11.37
Returned under 11.36
No Resubmission Possible
Resubmission with or without request
for 11.32A examination
Return under 11.38
Resubmission and publication under 11.41
The notification process ends with the resubmission and recording and hence it is appropriate to
consider a cost recovery scheme to take into account this and other regulatory actions by the
Bureau, explained in paragraphs 4.3.b.2 and 4.3.b.3.
4.3.b.2 The assignments recorded in the MIFR need certain continued regulatory activities as given
in RR provisions Nos.11.47, 11.44, 14.1, 11.49, 11.50, etc.
4.3.b.3 Notices for Earth stations are submitted to the Bureau after bilateral coordination between
the administrations operating earth station and those having terrestrial stations. Therefore, the
assistance given to Administrations during coordination of an earth station is treated as part of the
Notification activity for recording of the earth stations in the MIFR and accordingly the cost
recovery should cover it.
4.3.1 Processing of Notices for Earth Station
Study of large number of earth station examinations shows that time needed for treatment
of earth stations is quite consistent since the size variation is not significant. Therefore, a flat cost
recovery fee per case seems possible and reasonable for notification of earth stations.
4.3.2 Processing of Notices for Non-GSO space stations that are not subject to coordination
For the cases analyzed, the spread of network size is from 1 to 195 cost recovery units.
Since the regression line shows a variation between 1 and 1.4 of the relative time for the entire
observed range of size, a cost recovery approach based on flat fee per case may be possible.
25/31
Relative Total Time(to
Average Time)
Notification Tasks 13-16
NGSO cases
3.5
3
2.5
2
1.5
y = 0.002x + 1.0006
1
0.5
0
0
50
100
150
200
250
No of Units
Figure N1
4.3.3 Processing of Notices for GSO and Non-GSO space stations which are subject to
coordination
The study of GSO (all forms of coordination) and Non-GSO space stations (under
No.9.11A) shows that the time of examination of a notification submission for a space station is
dependent on the number of units (existing cost recovery unit), number of applicable forms of
coordination, number of coordination special sections covered by the submission and on similarity
(or dissimilarity) between notification and coordination data (Figures N1 and N2).
Relative Total Time(to
Average Time)
Notification Tasks 13-16 GSO cases
8.00
7.00
6.00
5.00
4.00
3.00
2.00
1.00
0.00
y = 8E-05x + 1.0009
0
2000
4000
6000
8000
No of Units
Figure N2
26/31
10000
12000
14000
Relative Total Time(to
Average Time)
Notification Tasks 13-16 GSO cases with one
Provision
4
3.5
3
2.5
2
1.5
1
0.5
0
y = 0.0001x + 1.0001
0
2000
4000
6000
8000
10000
12000
14000
No of Units
Figure N3
Relative Total Time(to
Averagae Time for
Prov=1)
Notification Tasks 13-16
GSO cases with
Provisions >1
12
10
8
6
y = 0.0004x + 2.2593
4
2
0
0
1000
2000
3000
4000
5000
6000
7000
No of Units
Figure N4
From the scattergrams and regression lines in Figure N3 and N4 it can be seen that the
time needed for the processing (present Table is computed only for Tasks 13 -16) depends on the
number of units and the number of applicable forms of coordination (indicated as number of
provisions in the related Figures). The predicted relative time for cases with one provision (see
paragraph 4 for grouping of provisions) shows a ratio of 1 to 2.5 compared to the reference,
depending on the number of units. The relative time required for examination of cases with multiple
procedures is seen to have a ratio of 2 to 4.2 from the regression line calculated above. Data so far
collected indicate that there exists a relation between time and the number of provisions
(procedures) and the number of units to be examined.
From the scattergrams and regression lines in Figure N5 and N6 it can be seen that the
time needed for the processing (only for Tasks 13 -16) also depends on the number of units and
the Complexity Factor defined in paragraph 4 above. From the regression line it can be seen that
the predicted relative time required for cases with a Complexity Factor 1 shows a ratio of 1 to 2.75
depending on the number of units. The relative time required for examination of cases with
Complexity Factors 2, 3 or 4 taken together is seen to have a ratio of 2.25 – 4.4 predicted by the
regression line for number of units of up to 7000. Therefore, it is appropriate to consider that the
notification examination involving cases covering multiple coordination special sections and where
there is difference between the coordinated and the notified characteristics is almost like doing
both the job of coordination examination and the notification examination at the same time. This
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difference between the coordination and notification examination and other factors indicated in
paragraph1 above indicate that cost recovery fees for notification should be higher than those for
coordination. On the other hand, this will obviate the need for separate charging of resubmissions,
which is integral part of the notification process as explained in paragraph 2.1 above.
Relative Total Time(to
Average Time)
Notification Tasks 13-16 GSO Complexity Factor 1
3.50
3.00
y = 0.0001x + 1
2.50
2.00
1.50
1.00
0.50
0.00
0
2000
4000
6000
8000
10000
12000
14000
No of Units
Figure N5
Relative Total Time (to
Average Time for Comp
Fact 1)
Notification Tasks13-16 GSO cases with
Complexity Factor 2,3,4
14.00
12.00
10.00
8.00
6.00
y = 0.0004x + 2.492
4.00
2.00
0.00
0
1000
2000
3000
4000
5000
6000
7000
No of Units
Figure N6
4.3.4
Processing of Notices for GSO space stations where examination under Nos.11.32A
and 11.41 is requested
The number of cases that are being submitted under the provisions of 11.32A and 11.41
are steadily increasing since there is a need for administrations to submit the notices before the
expiry of 9- or 7-year regulatory period. Examination under No.11.32A will depend on the number
of administrations (actually on the number of satellite networks) with which coordination has not
been completed and on the availability of sophisticated C/I calculation software for batch
examination processing. With the currently available tool, examination is now undertaken only with
respect to one specific network and hence there is no other data available as of now. However, the
work involved in this activity will be reassessed for the next review of the cost recovery when other
data becomes available. However, it is possible to assume that the time taken would be more than
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that of the normal 11.32 examination depending on the number of satellites involved and the stage
of software development.
4.3.5
Resubmissions and Other Cases
The process of recording of assignments in the MIFR under provisions like 9.7,
9.11/RES33, 9.11A/RES46 envisages a possibility for resubmission of assignments when the
Bureau returns the notices after publishing unfavourable findings under these provisions. This
allows the administrations an opportunity to note such findings and take appropriate action to
successfully complete coordination procedures and protect their systems. When notices are
returned to administrations, networks data are retained in the database to facilitate processing of
resubmissions. The number of resubmitted cases that were examined during 18 months was about
30 (23 GSO and 6 Non-GSO). The ratio of time spent on the original to resubmission is not
available. But, as can be seen from the flowchart of the process of examination, it is generally
possible for resubmitted cases to be directly sent to the stage of examination of completion of
coordination. Due to this, it is seen that resubmitted notices can be processed relatively quickly
and hence need not be charged separately. As an integral part of notification, resubmissions can
be covered by the cost recovery for the original notification submission.
The following cases also require further study and elaboration, but they do not seem to be
candidates for individual cost recovery:
- Cases to be republished under No. 11.41 after the responsible administration has
requested examination under 11.32A/11.33 that resulted in unfavourable finding;
- Cases accepted by the Bureau for reviewed as a result of ex-Article 14 provisions;
- Cases where the Bureau has to carry out the activities envisaged under Nos.11.47, 11.49,
11.44/11.44.1 (deletion of MIFR recording) and 11.50.
5. SUMMARY
Generally, the initial analysis of data collected indicates relatively weak dependence of
processing time on the size, measured in current cost recovery units, of Coordination, Plans and
Notification submissions. It also indicates a possible re-categorization, for cost recovery purposes,
of coordination requests to express their complexity in a way that seems to be more appropriate for
the current processing and matching better with Radio Regulations. Categorization for Notification
submissions may be different from Coordination to more precisely take into account what actually
represents complexity in notification processing.
These indications are preliminary and data collection and analysis will continue.
29/31
Annex 1
SPACE SERVICES DEPARTMENT
TIME SHEET FOR TREATMENT OF SATELLITE FILINGS
Coordination
Notification
Plans
Geo
ID NUMBER
SATELLITE NAME
EARTH STATION NAME
ADMINISTRATION
COST RECOVERY CATEGORY
TASK
NO.
DATE
TIME SPENT
Hours
INITIALS
Minutes
30/31
REMARKS
Non Geo
GUIDELINES FOR FILLING IN TIME SHEET
The purpose of this time sheet is to enable the Bureau to collate statistics on the time spent on various stages of the
treatment of satellite filings. These statistics will be used for the purpose of cost recovery, and all documents may
be subject to inspection by internal or external auditors.
The recording on the time sheet will apply to the treatment of the following filings : advance publication
(S9, Section I), coordination requests (S9, Section II), and notifications (S11). For the planned space services it is
applicable for fillings under Article 4 of Appendices S30 and S30A and Articles 6 and 7 of Appendix S30B.
1.
Please enter the task number from the list below:
TASKS:
01 Registration
02 As-received publication
03 Pre-validation
10 Assistance
11 Restructure of Notice
12 Network Summary
19 Verification
20 Final Verification
21 Update of database
04 Notice preparation
05 Data capture
13 Examination 1 *
14 Examination 2 *
06 GIMS preparation
15 Prep. Doc. for approval
07 GIMS capture
16 Examination control
22 Info. to adm. & corresp.
23 API
24 Change to date of bringing
into use
25 Others (please specify in
remarks)
08 Validation
09 Pcom and Completeness
17 Finding capture
18 Preparation of Publication
SPR – Data Preparation Phase
SSC – Examination Phase
SPR – Publication Phase
SPR – Data Preparation Phase
SSC – Examination Phase
SPR – Publication Phase
SNP – Data Preparation Phase, Examination Phase, Publication Phase
Coord
Notif
Plans
* Examination 1 – everything related to establishment of findings under S11.31 (compliance with the Table of
Frequency Allocation, with hard PFD and EIRP limits, and the like) and identification of RR provisions involved.
In the case of APS30/S30A it corresponds to all preliminary examination such as compliance with PFD hard limits
of Annex 1 to those Appendices or with EIRP and orbital limitations of Annex 7 to APS30;
* Examination 2 – everything else, basically the establishment of coordination requirements, or examination under
S11.32 or S11.32A. In the case of APS30/S30A/S30B, it corresponds to all examinations required for
establishment of coordination requirements at a first stage (e.g. Part A Special Section publication in the case of
Art. 4 of APS30/S30A), verification of fulfillment of those coordination requirements at the stage of entering the
subject notice into the corresponding Plan/List (e.g. Part B Special Section publication in the case of Art. 4 of
APS30/S30A) and examination required for notification process.
2.
“Date” refers to the date that you start executing the task.
3.
“Time Spent” refers to the total time spent in executing a task, recorded in hours and minutes.
4.
“Initials” refers to the initials of the person who carried out the task.
5.
Assistance is limited to SPR’s action in helping the administrations to correct their submissions and does not
relate to assistance requested by administrations under various RR provisions.
6.
If more than one person is involved (discussion, consultation), the sum of the times all persons involved will
be recorded.
7.
Use of software : preparation for and launching of a program, interpretation, review and use of results will be
recorded against one of the items above, as appropriate : software running time will be recorded against one of
the items only to the extent that during that time it is not possible to do other tasks, e.g. running time is too
short to start something else, PC cannot be used while the program is running, etc.
8.
If the number of tasks exceeds the space provided by the sheet, please attach a new one to this sheet.
9
SPR will capture the sheets into an electronic file
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