Time to Revisit FCC's SCS Framework, SpaceX Says

The FCC's SCS framework requires nationwide licenses, as there were concerns about interference, but that means smaller regional operators get left out, Goldman said, arguing that such interference concerns can be addressed.

Satellite Industry Association President Tom Stroup said major D2D policy challenges to be addressed include determining what bands are most suitable, tackling interference concerns and harmonizing D2D approaches. While nations in the Americas are taking notably different regulatory paths, the region has the potential to shape international norms via a D2D-friendly licensing regime and spectrum availability, he said.

Pascale Dumit, T-Mobile's International Spectrum Policy director, said mobile carriers must be at the forefront of any D2D regulatory approach involving use of terrestrial spectrum. Any such regulatory regime needs to protect carriers’ terrestrial spectrum rights and spectrum investments, she added.

While using terrestrial spectrum means D2D service can be offered pretty much immediately, the longer-term benefit of using mobile satellite service (MSS) spectrum is that terrestrial networks don't have to sacrifice terrestrial capacity, said David Willis, spectrum group director for the U.K. Office of Communications (Ofcom). The political and consumer excitement around D2D needs to be tempered, he said, as today’s technology means that certain service levels are going to be achievable only in sparsely populated areas.

Pointing to SpaceX's purchase of EchoStar MSS spectrum rights, Goldman said relying on terrestrial spectrum for D2D service carries a variety of challenges, including the need to throttle back service near national borders and mobile operator partners that sometimes lack the necessary spectrum.

NTIA Office of Spectrum Management Executive Director Scott Patrick said regulators are excited about the opportunity to make D2D service available quickly, which weighs in favor of terrestrial spectrum use. But there's also a need to accommodate evolving business models, he said.

Nations and States

Operators at the event also laid out the state of their D2D services, while national regulators gave updates on their rules regimes.

Globalstar now supports emergency messaging globally and non-emergency two-way messaging across North America, said Barbee Ponder, the company's vice president of regulatory affairs. It plans to launch 17 satellites over the next year to finish out its existing constellation, he said. Atop that will be a $1.5 billion investment in 48 more satellites and ground infrastructure, he added.

Amy Mehlman, Lynk Global's chief global affairs officer, said it has 53 mobile partners worldwide, even as it looks to acquire Omnispace to give it MSS spectrum access (see 2510240004). She said Lynk's partnership with SES will let it blend services across a multi-orbit infrastructure.

No single D2D spectrum and licensing regime will work everywhere, but satellite operators want to see some consistency, said Isabelle Mauro, director general of the Global Satellite Operators Association. There has never been so much satellite innovation so quickly, necessitating a rethinking of how regulation is done, she said. Her group is in the weeds trying to keep up with the numerous consultations happening in various nations, she added.

Ofcom's Willis said the U.K.’s licensing terms for D2D should be out by Christmas, with service likely available in early 2026. He highlighted the challenge of ensuring that the satellite-delivered service doesn't cause interference issues in nearby nations, as well as possible limits of initial service offerings.

D2D activity in Brazil is happening annoyingly slowly, with major wireless carriers cautious about partnering, said Carlos Baigorri, president of the country's National Telecommunications Agency (Anatel). Despite the "regulatory sandbox” that Brazil set up to incentivize experimentation, the lack of activity has been “quite frustrating” for the regulator, he said. The nation is aggressively trying to cultivate D2D service provision, adopting an “easygoing regulatory framework.” Given its big rural areas, Brazil has bet heavily on satellite as a route to universal connectivity, Baigorri said, noting that its 800,000 Starlink subscribers make it SpaceX’s second-largest market after the U.S. The country has also been very open to licensing other satellite services, from Lynk to Amazon Leo, he said, and China’s Spacesail constellation is also the subject of a licensing proceeding now.

Skylo Technologies getting licensed in Brazil was "a relatively easy process," said Mindel De La Torre, its head of global regulatory affairs. The company, which uses geostationary orbit satellites for D2D service, is seeking licensing in Colombia and incorporation in Argentina and Chile, she noted. Skylo hopes to see other nations adopt an Anatel-like process, where D2D isn't seen as a special service but as an MSS application, De La Torre said, adding that countries that are modifying their regulatory framework just for D2D present a more challenging oversight landscape.

The Canadian regulatory scene is evolving quickly, said Michal Kasprowicz, a DLA Piper technology lawyer in Toronto. The country rolled out a framework for supplemental mobile by satellite, employing unused terrestrial spectrum, early this year.

Trinidad and Tobago's spectrum plan for D2D should be out in January, said Kirk Sookram, deputy chief executive officer of its Telecommunications Authority. The plan is focused on satellite use of the 2 GHz band and will enable D2D service via wholesale delivery as satellite operators use MSS spectrum to extend terrestrial coverage, he said. The plan won't get into D2D services being provided directly to consumers or D2D use of terrestrial spectrum, he added.

Seminar Notebook

The 2 GHz band came up repeatedly during the event. SpaceX had previously sought access to the band (see 2505150002). Asked whether SpaceX still supports 2 GHz sharing now that it's buying EchoStar's 2 GHz license (see 2509080052), Goldman said shared use of the band might be feasible someday, but the FCC has made clear that it's not supporting wider access. A big SpaceX priority is ensuring that handset makers incorporate 2 GHz and other bands it's buying into their products, he said. The AWS-3 spectrum is in devices now and can be used quickly, he added, but AWS-4 use will take longer.

As international forums hammer out global D2D approaches, there needs to be a vision of D2D's and satellite connectivity’s future and whether it’s about openness and international harmonization or closure and protectionism, NTIA Deputy Administrator Adam Cassady said. The agency doesn’t see D2D as an edge case, but a foundational capability of forthcoming networks, he said, arguing that its impact globally may rival the introduction of smartphones.