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'Unlocking the Promise'

Major Carriers Oppose Additional Rules for SCS as Premature

The three major U.S. wireless carriers, AT&T, T-Mobile and Verizon, told the FCC it’s too early for rules on using supplemental coverage from space (SCS) to improve calling to 911. Their message was contained in reply comments posted through Tuesday in docket 23-65. The FCC's SCS framework order approved in March (see 2403140050) included a Further NPRM asking about 911 and radio astronomy issues. Specifically, the FNPRM looks at whether the FCC should mandate location-based routing requirements for SCS emergency communications.

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“Commenters agree that the Commission should not adopt additional restrictions while SCS technology continues to evolve,” AT&T said: Rules “would be premature given the ongoing innovation and development of SCS.” AT&T also opposed additional radio astronomy-related rules (see 2405300044). Commenters agree that the SCS order “properly balanced the protection of [radio astronomy] and space sciences through the Part 25 licensing process with the many public interest benefits SCS offers,” the carrier said.

One key to “unlocking the promise of SCS is to recognize an appropriate regulatory framework and avoid regulation that will unduly burden SCS and hinder its development,” Verizon commented. The provider called for flexibility. Additional restrictions discussed in the FNPRM “would unnecessarily risk undermining the investments that wireless providers and their partner satellite operators are already making in SCS and could stymie progress towards introducing SCS offerings to U.S. consumers,” Verizon said.

Verizon noted it recently announced a partnership with AST SpaceMobile to begin implementing SCS: The service is “in its early stages and the technology and implementation … is constantly evolving.”

T-Mobile said SCS shows “great promise in expanding the reach of emergency communications” but is only “just being introduced.” As the FCC has recognized, “there are meaningful technical differences in the ways emergency calls can be handled by satellite operators and terrestrial providers,” T-Mobile said: “SCS is an emerging service, which means adopting those requirements now would be premature and could hinder its development.”

The Alliance for Telecommunications Industry Solutions also warned against new rules at this time. ATIS said it agrees with the commenters "who acknowledge that the industry is in the best position to examine 911-related issues associated with SCS.”

The FCC “strikes the right balance” on 911 by requiring carriers “to route calls either directly to a public safety answering point using a device’s location information or, in the alternative, to an emergency call center,” said AST SpaceMobile. The rules give carriers flexibility “to determine the best way to route 911 calls while this nascent technology develops,” the company said. On radio astronomy concerns, SpaceMobile said it’s “uniquely well situated to operate harmoniously” with astronomers “given the relatively small size” of its “planned constellation and its use of phased-array antennas that can form and steer precise, narrow downlink beams dynamically to avoid interference.”

Nearly all commenters agree it’s “premature to adopt a more permanent regulatory framework for SCS 911 given the current state of SCS technology and development,” said Intrado, a 911 tech provider. While several partnerships have formed between satellite operators and major carriers, “SCS deployment will take time and face significant commercial, licensing, technical, and operational challenges,” Intrado warned.