SCS GIA Limits Facing Satellite, Terrestrial Opposition
The FCC's proposal to limit mobile supplemental coverage from space (SCS) operations to co-channel licenses held by one party in geographically independent areas (GIA) is getting pushback from some satellite and terrestrial interests, per NPRM reply comments in docket 23-65 Tuesday. There was wireless and satellite disagreement on whether a waiver system suffices or if the agency needs SCS rules. The SCS NPRM was adopted 4-0 in March (see 2303160009) and the wireless industry argued in initial comments SCS rules are premature (see 2305150007).
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The GIA limit isn't needed to mitigate the possibility of interference, since phased array antennas and geolocation fencing will let SCS operators serve smaller geographic footprints belonging to their terrestrial partners, AST SpaceMobile said. It asked the FCC to apply its secondary market spectrum lease rules to SCS services and reject restrictions on foreign-flagged systems serving the U.S. It urged allocating the 800 MHz band for SCS operations, given the compatibility of the band's cellular geographic service area licensing scheme with SCS operations.
Satellite use of terrestrial spectrum operations should require the consent of a terrestrial licensee, with the SCS applicant having to make technical showings of coexistence, CTIA said. It said "arbitrary, pre-determined minimum geographic deployment requirements" on SCS deployments in the form of GIA limits could preclude transactions and investments in new infrastructure.
Geographic limits should be the purview of the contractual arrangement between the SCS provider and the relevant terrestrial license holder, as long as they show they won't cause interference to adjacent channel or area licensees, said Lynk Global. Alaskan ISP OptimERA said that approach would keep out competition by small carriers. Others opposing GIA restrictions included T-Mobile and Kepler.
SCS activities should fall within the FCC's flexible use licensing regime and secondary market policies instead of its "outdated and overly prescriptive command-and-control framework for satellite services," said SpaceX. It urged the FCC to allow SCS across all flexible use bands. T-Mobile said the satellite and terrestrial parties should be allowed to develop the SCS agreements themselves, without the FCC dictating how they coordinate their operations, as long as there's a requirement the satellite operators in an SCS arrangement show there's no harmful interference to adjacent-channel and adjacent-area licensees.
Warning of "severe consequences" for approving SCS bands without considering band plans in other nations, Omnispace said this could destroy U.S. spectrum leadership globally. It urged instead "an international, consensus-driven allocation approach." The agency's proposed SCS framework "will introduce co-channel, space-to-space interference to duly authorized satellite systems in contravention of ... international treaty obligations," it said. It warned of SCS deployments being precluded in many U.S. terrestrial bands because of conflicts between U.S. terrestrial uplink bands aligning with other countries' terrestrial downlink bands.
Rather than a waiver-based approval approach, the FCC needs a "more enduring and stable" rules-based framework allowing geostationary and non-geostationary orbit operators to offer SCS service, Satellite Industry Association said. Licensing should be by the Space Bureau, it said. A rules-based approach guarantees use of objective, predetermined qualifications, "rather than subjective, case-by-case assessments," said Lynk, but until the rules are adopted, the agency should use waivers for applicants.
The agency's existing rules and policies, with tailored waivers, "are well-equipped to process SCS applications," Verizon said, opposing a new SCS regulatory regime. It said the FCC should make clear SCS offerings don't count toward terrestrial buildout obligations of wireless providers. Verizon said any SCS allocation would "undermine the supplemental, non-interfering nature of SCS use." AT&T urged a waiver-based approach overseen by the Wireless Bureau.
Before SCS rules, the FCC needs to do more band-specific interference studies, Kepler said. It said the agency needs to consider how transferrable technical measures it adopts are to other nations looking to put in place similar frameworks and submit a proposal for an SCS agenda item for the 2027 World Radiocommunication Conference.
The SCS proceeding neglected to talk about 911 and emergency notification system SCS use cases, said Boulder, Colorado's Emergency Telephone Service Authority. It said SCS could play a big role in continuity of service when unprotected wireless service areas lose coverage due to fiber cuts, hurricanes or other natural disasters. It said the FCC should mandate delivery of SCS emergency texts and calls to public safety answering points through the 911 system where possible. Lynk said the agency should undertake a Further NPRM or separate proceeding about 911 and wireless emergency alert delivery via satellite networks.
With direct-to-device service using mobile satellite service spectrum being distinctly different from SCS, the FCC should beware of adopting rules that give SCS operators unfair competitive advantage over MSS operators supporting direct-to-device operations, Globalstar said. The NPRM already proposes exclusive use by SCS operators of big swash of terrestrially allocated spectrum and operations at notably higher power levels, it said.