Wireless Industry Considers SCS Rules Regime Premature

Waivers from the Wireless Bureau rather than "proscriptive rules and premature modifications to the U.S. Table of Frequency Allocations" would rightly put the onus on SCS applicants to demonstrate that their service will protect terrestrial mobile operations from harmful interference, AT&T said. It said letting SCS deployments count toward terrestrial buildout requirements could create loopholes in spectrum deployment policies. It urged a 911 approach where use of location-based routing would direct SCS 911 calls to the appropriate public safety answering point. It said with initial SCS deployments, only commercial mobile service providers should have to transmit nationwide WEAs, though the agency could revisit this as SCS technology matures. Instead of new rules and unnecessary satellite-specific allocation to terrestrial mobile spectrum bands for SCS, wireless providers would benefit more from FCC guidance on how it will process and review SCS applications, Verizon said, also urging waivers. Leave intact current terrestrial allocations and rely on existing regulatory systems, including spectrum leasing rules and adjacent-band and adjacent-area protection limits, T-Mobile said.

The NPRM's floated rules "would create a regulatory architecture for SCS that is unnecessarily complex and prescriptive," it said, urging instead an approach where terrestrial licensees can allow use of their licensed spectrum by satellite operators on a voluntary basis under commercially agreeable terms and conditions, as long as there's no harmful interference to others. Saying the agency may be acting prematurely, Dish Network and Hughes/EchoStar said in joint comments it first should study interference and coordination issues upfront before authorizing satellite operators to operate in terrestrial spectrum through leasing arrangements. CTIA said the FCC should limit SCS authorization consideration to those that have a terrestrial licensee’s voluntary agreement to use its licensed spectrum to supplement its wireless coverage through SCS.

Requiring an SCS applicant to have a relationship with a mobile network operator before applying for SCS authorization would give established satellite operators an unfair competitive advantage over new entrants, Lynk said. It said geographic limits on service aimed at ensuring no harmful interference to adjacent markets guarantees that only the Big Three wireless carriers will be able to offer SCS to their customers, particularly in the contiguous U.S., it said. Allowing new satellite applicants SCS authority would promote competition and maximize efficient use of spectrum, said AST SpaceMobile. AST said limiting SCS service to wireless spectrum where one party holds all the co-channel licenses across a geographic area means no access to most low- and mid-band spectrum, It also backed allowing SCS service in smaller footprints when geographically adjacent licensees won't face harmful interference. It said the FCC also should let either the terrestrial partner or SCS operator hold authority for handset operation under the FCC’s Part 25 rules.

Allowing SCS operations for only existing Part 25 licensees that have leases with terrestrial commercial mobile radio service (CMRS) operators "narrows the list of potential licensees to a handful of incumbents," Tech Freedom said. It said only U.S. licensees should be eligible for SCS authorizations. Flexible-use spectrum, particularly CMRS bands, "should be the first bands that the FCC looks to in implementing SCS," it said. It backed putting 911 obligations on SCS operations but not wireless emergency alert (WEA) requirements.

Rather than extending terrestrial 911 or wireless emergency alert rules to SCS, the agency should try to promote collaboration with PSAPs and first responders during the feature development process while encouraging more rapid adoption of capabilities such as text-to-911, Apple said. Any steps toward streamlining the blanket earth station licensing process for SCS should also apply to mobile satellite supplemental coverage from space (MSCS) and even more broadly to mobile satellite service, Iridium said. It urged the agency not to adopt E911 and WEA requirements for MSCS, which would use mobile satellite service spectrum rather than terrestrial spectrum. Extending E911 requirements to SCS operators "may be unnecessarily burdensome," Skylo Technologies said. It said an SCS framework should include geostationary orbit (GSO) systems as well as NGSOs in the SCS framework, since "the promise of SCS services" will require use of both. There's no reason to exclude GSO architectures from any SCS framework and have it apply to only non-geostationary orbit, Viasat said. It also opposed requiring an existing Part 25 license or market access grant as a prerequisite to providing SCS. It said that requirement won't guarantee rapid SCS development "and will only needlessly stifle competition by artificially restricting the pool of potential satellite operators that can provide competitive SCS services."

SpaceX and Amazon's Kuiper supported allowing SCS in all flexible-use spectrum. That would encourage competition by including smaller and regional carriers while also avoiding an endless stream of allocation proceedings, SpaceX said. It also advocated for letting NGSO operators apply for a general authorization to launch SCS-capable equipment before obtaining a domestic mobile carrier partner. Kuiper said the agency also should allow SCS anywhere applicants to demonstrate compliance with existing terrestrial service rules and protection requirements. SCS could benefit public safety, but the FCC should do testing of interference risks to public safety communications, the APCO said. It also backed requiring wireless service providers to notify potentially affected public safety licensees before launching SCS services. FirstNet urged allowing use of the 700 MHz Band 14 for SCS, though any use would have to be through a contractual relationship under the FirstNet framework.

Rather than license terrestrial handsets through Part 25 rules, look instead to how handsets are licensed in terrestrial area licensed systems with handsets subject to Part 2 equipment approval and then operating under the terrestrial licensee’s authorization, OneWeb said. It said limiting SCS authorizations to only existing NGSO constellations would "avoid tying up terrestrial licensees in partnerships during the multi-year buildout period for an NGSO constellation." Proposed use of the 600 MHz band for SCS is of particular concern to radio astronomy interests, since Radio Astronomy Service has a co-primary allocation at 608-614 MHz, said the National Academy of Sciences. It said the FCC could consider SCS rules that require avoidance of downlinks into Radio Quiet Zones.