SIA to FCC: Reject Rural LECs’ Bid to Cut Out Satellites
Since the FCC has decided a satellite roof-top dish is part of a telecommunications network, the commission should deny a petition for declaratory ruling seeking reversal of a satellite operator’s eligible telecommunications carrier (ETC) designation in Texas, the Satellite Industry Association (SIA) said Friday. In March, rural local exchange carriers (RLECs) asked the agency to junk the Texas Public Utility Commission’s grant of ETC status to a Globalstar reseller, DialToneServices (DTS). Only ETCs can get universal-service subsidies.
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DTS owns no facilities, the rural carriers said in justifying their positions. But satellite earth stations are as critical to a communications network as the local loop, SIA told the FCC. “A communications satellite network requires at least two earth stations (to communicate with each other) and at least one satellite (to relay the communications),” said SIA.
The FCC should refuse to accept the RLECs’ equation of a satellite dish with a analog phone, SIA said. “In wireline parlance, the satellite earth stations is the local loop… A wireline network begins and ends with the local loop that transmits and routes the communications, just as the satellite network begins and ends with the satellite earth station that transmits and routes the communications.” Just as when a wire to a home is cut the wireline network is damaged and the home cannot make or receive calls, satellite dish failure disrupts the network, it said. Do not “institutionalize a bias toward terrestrial technology,” urged SIA.
The RLECs object to DTS as a reseller being made eligible for universal service subsidies, but SIA said that reselling satellite communications services is needed given the limited number of satellite licenses. “From the earliest days of communications satellites, the industry has consisted of two, potentially separate segments, one focused on launching and operating satellites and another on providing ground equipment and services,” it said.
The FCC should reject the petition as a bid at “a second bite at the apple” because it urges preemption of the Texas designation granted more than a year ago, said SIA. SIA noted that S. 101, a universal service reform bill pending in the Senate, specifically would make “satellite broadband service eligible for universal-service support.”
The DTS application to Texas is the first known instance of a satellite carrier seeking universal service support. It would be wrong to use the episode to deprive satellites of subsidies based on this one fact-specific case, said SIA. “Satellite services are sometimes the only option and are often the most effective option for providing communications services to rural and remote areas,” it said.