Telecom Obligations Are Not Seen as an Urgent SCS Issue
As the FCC mulls a framework for direct-to-handset satellite service, satellite interests told us discussions about service rules are a relatively low priority. Service rules came up in comments last month in the agency's supplemental coverage from space (SCS) framework NPRM (see 2305150007), but many SCS interested parties were silent.
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In the hierarchy of importance, addressing possible interference concerns and license and business arrangements in the NPRM seem far more pressing than wireless operational items like telecom obligations, said a lawyer with satellite clients. A satellite company looking to partner with a wireless operator might take more of a stance that it will just deal with whatever service rules obligations come up, and those obligations are considerably less important than other matters, he said. He said it's possible satellite operators, as they seek waivers of particular spectrum rules, might tack on requests for waivers from particular telecom obligations.
"All existing carriers want to talk about is interference," emailed TechFreedom General Counsel Jim Dunstan. "Once they start talking about 911, then they're conceding what a huge benefit SCS would be (which also highlights how poor cellular coverage is in rugged terrain)." He said SCS backers want to discuss 911 for the opposite reason, but there are "some significant problems" in tying SCS into the 911 infrastructure, especially for early systems that are text-only. He said wireless emergency alerts are unworkable because WEA "counts on some pretty sophisticated geofencing that the satellite guys are probably not able to implement." He said SCS operators also wouldn't want WEA traffic to take up significant bandwidth in their capacity-constrained systems.
Satellite licenses typically have non-common carrier status, and the FCC in the SCS framework NPRM proposes they keep that status when adding SCS service. It asks about whether to extend wireless 911 requirements to the proposed provision of SCS. Mobile satellite service (MSS) providers are exempt from such 911 requirements as supporting basic and enhanced 911 and text-to-911 but are required to support emergency call center service when offering two-way interconnected voice service, the NPRM says. The NPRM asked about extending commercial mobile radio service 911 and E911 rules to the satellite half of SCS satellite/terrestrial partnerships. It also asks about how satellite operators intend to support wireless emergency alerts or whether they "could adversely affect WEA’s reliability and availability or change the nature of a provider’s participation in WEA from in whole to in part if the SCS satellite operators were to not participate in WEA."
In SCS partnerships, most satellite operators will have telcos manage the traditional telecom requirements like 911, or at least try to have them do so, another lawyer with satellite clients said. The satellite's role will be to bounce the communications from one location to another, with the network management to be handled on the ground at the telco's facilities, she said.
A lawyer for a company with SCS plans said SCS via existing satellite spectrum rather than satellite use of terrestrial spectrum already comports with existing MSS regulations. She said 911 and WEA might not be technically feasible when the satellite operator isn't operating an IP network. WEA is an obligation for wireless providers, which satellite operators aren't, she said.