Before the

FEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554

)
In the Matter of )
)
SINGLE NETWORK FUTURE: SUPPLEMENTAL ) GN Docket No. 23-65
)
COVERAGE FROM SPACE
)
)
SPACE INNOVATION ) SB Docket No. 22-271
)

PETITION FOR RECONSIDERATION OF

SPACE EXPLORATION HOLDINGS, LLC

William M. Wiltshire David Goldman

Paul Caritj Vice President of Satellite Policy

HWG LLP Jameson Dempsey

1919 M Street, N.W. Director, Satellite Policy
Suite 800
Washington, DC 20036 SPACE EXPLORATION TECHNOLOGIES CORP.
202-730-1300 tel 1155 F Street, N.W.
202-730-1301 fax Suite 475
Washington, DC 20004
Counsel to SpaceX 202-649-2700 tel
202-649-2701 fax

May 30, 2024

 TABLE OF CONTENTS

SUMMARY .................................................................................................................................... 1
INTRODUCTION .......................................................................................................................... 4
DISCUSSION ............................................................................................................................... 11
I. ADOPTING BAND-SPECIFIC OUT-OF-BAND PFD LIMITS THAT ACHIEVE A COMMON
INTERFERENCE THRESHOLD WOULD BETTER ALIGN WITH FUNDAMENTAL PHYSICS
AND REALISTIC INTERFERENCE ASSUMPTIONS THAN A ONE-SIZE-FITS-ALL PFD
LIMIT .................................................................................................................................11
II. ADOPTING BAND-SPECIFIC OUT-OF-BAND PFD LIMITS THAT ACHIEVE A COMMON
INTERFERENCE THRESHOLD WOULD BETTER SERVE CONSUMERS AND FACILITATE
FUTURE SCS INNOVATION THAN A ONE-SIZE-FITS-ALL PFD LIMIT.............................16
CONCLUSION ............................................................................................................................. 20

i
 Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

)
In the Matter of )
)
SINGLE NETWORK FUTURE: SUPPLEMENTAL ) GN Docket No. 23-65
COVERAGE FROM SPACE )
)
)
SPACE INNOVATION ) SB Docket No. 22-271
)

PETITION FOR RECONSIDERATION OF

SPACE EXPLORATION HOLDINGS, LLC

SUMMARY

SpaceX appreciates the Commission’s leadership in adopting a flexible regulatory

framework for supplemental coverage from space (“SCS”) that will enable ubiquitous mobile

coverage for consumers and first responders and will set a strong example for other countries to

follow. 1 SpaceX supports nearly all of the Commission’s recent SCS Order and looks forward to

launching commercial direct-to-cellular service in the United States this fall.

But to best achieve the Chairwoman’s vision of a Single Network Future, the Commission

should reconsider a single number in the SCS Order—namely, the one-size-fits-all aggregate out-

of-band power flux-density (“PFD”) limit of -120 dBW/m2/MHz that it adopted in the new Section

25.202(k)(1) for all supplemental coverage operations regardless of frequency band. 2 If the

Commission decides to retain an aggregate limit, adopting band-specific limits that efficiently and

transparently achieve the accepted ITU interference protection threshold for terrestrial networks

1
See Single Network Future: Supplemental Coverage from Space, FCC 24-28 (rel. Mar. 15, 2024) (“SCS Order”).
2
See id. ¶ 205.

1
of -6 dB interference-to-noise ratio (“I/N”) would better achieve the Commission’s goals of

ensuring better service, broader coverage, and more choices for consumers. By making this simple

adjustment to the SCS Order, the Commission can potentially bring an order of magnitude better

service to consumers who use supplemental coverage from space in higher frequencies, without

causing any risk of harmful interference to terrestrial services in adjacent bands.

Adopting band-specific out-of-band PFD limits would have key advantages over a single-

limit approach. For example, adopting band-specific limits would align with fundamental physics

and sound engineering practice by recognizing the outsized role that frequency plays when

calculating appropriate PFD levels to meet a given interference protection criterion. In fact, with

all else equal, frequency alone causes a 10 dB difference in required PFD levels between operations

at 600 MHz and operations at 2 GHz to meet the same I/N threshold. That means that operations

at 600 MHz require power levels ten times lower than operations at 2 GHz to meet the same -6 dB

I/N that is sufficient to protect terrestrial end user handsets. But by adopting a single PFD limit

of -120 dBW/m2/MHz regardless of frequency, the SCS Order essentially flips the calculation:

requiring SCS operators at 2 GHz to suppress their PFD ten times below what the applicable -6

dB I/N interference threshold would require, while allowing operators at 600 MHz to meet that

single PFD limit while exceeding the applicable -6 dB I/N threshold. Reconsidering the single

out-of-band PFD limit and replacing it with band-specific limits that consider the role of frequency

and other reasonable assumptions would address this imbalance.

Adopting band-specific limits tied to a -6 dB I/N threshold would also better achieve the

Commission’s stated goals in establishing out-of-band limits in the SCS Order. For example, this

change would more closely align the adopted limits to those the Commission proposed in the

NPRM, which themselves differ depending on frequency. It also would align with the

2
Commission’s acknowledgment in the NPRM that more restrictive limits in the Commission’s

mobile terrestrial rules reflect a specific problem in those terrestrial networks—the “near-far”

problem—that does not apply in the SCS context. Specifically, while a terrestrial operator may

have one or more high-powered base stations in close physical proximity to an adjacent-band cell

phone that make it hard for the cell phone to receive signals from its intended operator’s base

station, a transmitting satellite will always be hundreds of kilometers or more away from that cell

phone.

Improving the SCS Order through out-of-band limits tied to a single interference threshold

of -6 dB I/N rather than a single PFD limit would also enhance choices for consumers by allowing

operators using different frequencies to scale the out-of-band limits with the applicable -6 dB I/N

threshold for terrestrial networks, rather than arbitrarily suppressing some operations but not

others. A band-specific approach would also be more technically achievable, insofar as no satellite

operator has claimed that it can meet a -120 dBW/m2/MHz limit.

Band-specific PFD limits tied to the -6 dB I/N threshold would also provide clarity to all

stakeholders—while still protecting terrestrial operations—by making clear the specific

assumptions that underlie those limits. The SCS Order states that the Commission used realistic

rather than worst-case assumptions, but the order does not explain what those assumptions are or

why they are reasonable. Operators are therefore unable to understand how the Commission

reached a single PFD limit or whether it considered the disparate impact that such a limit has for

consumers that will rely on service from operations in different frequency bands. By adopting

limits using the fundamental physics equations that relate PFD to the applicable -6 dB I/N

threshold, along with generally accepted user equipment parameters, the Commission can provide

more certainty to operators, and to the people that will ultimately rely on these services.

3
 Using band-specific limits will better achieve the broader public interest goals of the Single

Network Future by efficiently protecting terrestrial users while unlocking the tremendous promise

of supplemental coverage from space to connect people and first responders everywhere. Band-

specific out-of-band emissions limits will enable future innovation in SCS that can provide even

more robust supplemental mobile capabilities even in the most remote corners of the country and

during emergencies. And the Commission can more readily scale this band-specific approach to

new frequency bands outside of the initial bands included in the SCS Order, particularly in mid-

band spectrum. By making this small update to its SCS Order, the Commission has the opportunity

to set a strong example for other administrations of how to set technical limits based on sound

assumptions, which in turn promote the deployment of supplemental coverage abroad.

Accordingly, pursuant to Section 1.429 of the Commission’s rules, 3 SpaceX seeks reconsideration

solely of the PFD limit in new Section 25.202(k)(1).

INTRODUCTION

The Commission initiated its rulemaking proceeding for supplemental coverage from space

in 2023 to lead the way in developing rules that would enable mobile network operators to leverage

satellite-based capabilities to extend the reach of their exclusively licensed mobile spectrum

holdings into areas where terrestrial networks either do not exist or have been rendered inoperable

by emergencies. 4 The Chairwoman explained that by swiftly adopting flexible rules, the

Commission would set a strong foundation for a “Single Network Future” that seamlessly

interweaves terrestrial and satellite capabilities into a ubiquitous mobile experience for American

consumers, enterprises, and first responders. But more broadly, the Chairwoman intended for

3
See 47 C.F.R. § 1.429.
4
See Single Network Future: Supplemental Coverage from Space, 38 FCC Rcd. 2790, ¶ 1 (2023) (“NPRM”).

4
these rules to serve as a model for other countries around the world to follow—rules that not only

would enable U.S.-licensed satellite operators to bring supplemental coverage to international

markets, but also would bring the benefits of the Single Network Future everywhere. 5

The NPRM sought comment on a wide array of legal and technical proposals in an effort

to weave together two distinct regulatory regimes in its rules—the flexible use rules for terrestrial

operations that allow rapid innovation within the broad contours of a license and the command-

and-control rules for satellite operations that involve detailed applications and open-ended reviews

for almost every change to a satellite system. Marrying these two very different regulatory cultures

was no easy task, as the NPRM reflected, but as a general matter the Commission wisely sought to

defer to existing terrestrial rules and secondary market policies as a baseline rather than graft a

duplicative satellite ruleset onto these novel and nascent operations.

Rather than consider a comprehensive regime that would apply to all potential frequency

bands, the Commission proposed to take an incremental approach that focused at first on a small

number of mobile frequency bands in which a single terrestrial licensee holds an exclusive license

covering one of several geographically independent areas (“GIA”) (i.e., CONUS, Hawaii, Alaska,

and Puerto Rico). These bands included 600 MHz (614-652 MHz and 663-698 MHz), 700 MHz

(698-769 MHz, 775 MHz-799 MHz, and 805-806 MHz), 800 MHz (824-849 MHz and 869-894

MHz), Broadband PCS (1850-1915 MHz and 1930-1995 MHz), and AWS-H Block (1915-1920

MHz and 1995-2000 MHz). 6 The previous year, SpaceX had submitted a space station license

application to provide supplemental coverage from space throughout the United States in

5
See id., Statement of Chairwoman Rosenworcel.
6
See NPRM ¶¶ 18-23.

5
partnership with T-Mobile, using T-Mobile’s exclusively licensed PCS G Block spectrum. 7 Other

bands proposed in the NPRM reflected similar applications to provide supplemental coverage from

space.

Among other technical proposals, the Commission proposed to apply the existing per-

transmitter terrestrial out-of-band emissions limits found in Parts 22, 24, and 27 of the

Commission’s rules to supplemental coverage operations—i.e., those limits the Commission had

“deemed necessary to protect adjacent operations in the relevant bands of operation.” 8 To codify

this approach, the Commission proposed a new Section 25.202(k)(1) as follows:

Out of band emission limits. Space station downlink emissions on spectrum

allocated for mobile-satellite service and used in providing SCS shall meet the out-
of-band emission limits applicable to the terrestrial base stations of its terrestrial
partner, as set forth in parts 22, 24, or 27 of this chapter (e.g., §§ 22.917, 24.238,
27.53), respectively. 9

The NPRM did not at any point seek comment on or propose to adopt an aggregate out-of-band

emissions limit.

The Part 22, 24, and 27 per-transmitter out-of-band limits have two central features. First,

these rule parts cover a wide range of frequency bands, including 600 MHz to2.2 GHz initially

identified for SCS, and the Commission appropriately applies more restrictive out-of-band limits

to lower frequency bands than it does to higher frequency bands. This difference reflects the fact

that transmitters using lower frequencies must operate at lower power levels than those using

higher frequencies to avoid causing harmful interference to other terrestrial users. These different

7
See Application for Modification of Authorization for the SpaceX Gen2 NGSO Satellite System to Add a Direct-
to-Cellular System, ICFS File No. SAT-MOD-20230207-00021, at 9-13 (Feb. 7, 2023).
8
NPRM ¶ 117.
9
Id., Appendix A (proposed Section 25.202(k)(1)).

6
limits carry over to the Commission’s cross-border agreements, which similarly adopt different

terrestrial out-of-band emission limits in different frequency bands.

Second, the out-of-band emissions limits in Parts 22, 24, and 27 are also expressly designed

to account for the so-called “near-far” interference problem. 10 This situation arises when a

sensitive user handset is physically close to one or more interfering out-of-band terrestrial base

stations, but far from the handset’s intended in-band base station. Due to the way that terrestrial

networks are designed—with many high-powered base stations in relative proximity—the

distances involved generally are relatively short, requiring tight emissions masks on each terrestrial

base station antenna to prevent harmful out-of-band interference. A similar problem does not exist

between satellite transmitters and adjacent band terrestrial mobile receivers because a satellite will

always be hundreds or thousands of kilometers away from an out-of-band handset on the ground,

as well as hundreds or thousands of kilometers away from that handset’s intended base station.

Thus, as the Commission recognized, the near-far problem does not exist for supplemental

coverage transmissions from space, 11 and the near-far solution of tight emissions masks around a

satellite antenna is not necessary from a technical perspective to protect out-of-band handsets on

the ground from harmful interference.

The NPRM did not propose any band-agnostic technical limits, acknowledging that “any

interference analysis must be band-specific.” 12 With respect to cross-border out-of-band

emissions, the Commission cited agreements with Canada and Mexico that apply different limits

10
See, e.g., Service Rules for the 698-746, 747-762, and 777-792 MHz Bands, 22 FCC Rcd. 15289, ¶ 263 n.606
(2007) (discussing near-far problem).
11
See NPRM ¶ 118 (“We also acknowledge that the interference metrics are different for satellite transmissions
insofar as near-far interference caused by the proximity of an adjacent band device to a terrestrial base station is
not present in SCS.”).
12
Id. ¶ 133 (emphasis added).

7
at different frequencies. 13 Accordingly, the NPRM proposed to adopt band-specific terrestrial

technical rules to supplemental coverage operations in each relevant frequency band. As relevant

here, the Commission proposed to extend the existing Part 22, 24, and 27 out-of-band emissions

limits to supplemental coverage operations as a convenient extension of the existing rules, but also

noted that operators should retain flexibility to meet higher limits. 14

While SpaceX initially supported the approach of applying underlying terrestrial rules, it

later explained that those terrestrial limits were significantly more conservative than necessary to

protect terrestrial out-of-band handsets from supplemental coverage satellite transmissions, since

supplemental coverage transmissions would fall well below the noise floor of an out-of-band

handset by the time they reached the ground. 15 As such, SpaceX suggested that the Commission

could adequately protect terrestrial operations using the existing Part 25 per-satellite out-of-band

emissions mask that applies to all satellite systems, including those adjacent to terrestrial systems.

Just two weeks before the Commission issued its Circulation Draft, AT&T submitted a

letter suggesting that -107.5 dBW/m2/MHz was the appropriate PFD corresponding to the UE

noise floor to assess out-of-band limits adjacent to the PCS G block, and requested that the

Commission assess out-of-band interference in the aggregate. 16 AT&T further argued that the

appropriate analysis should include a user equipment gain of 0 dBi and a 9 dB noise figure,

reflecting 3GPP recommended values. 17 Even though a 0 dBi gain is not achievable in practice,

13
See id. ¶ 132 n.280.
14
See id. ¶ 117.
15
See Comments of Space Exploration Holdings, LLC, GN Docket No. 23-65, SB Docket No. 22-271, at 18-20
(May 12, 2023); Reply Comments of Space Exploration Holdings, LLC, GN Docket No. 23-65, SB Docket No.
22-271, at ii (June 12, 2023); Letter from Jameson Dempsey to Marlene H. Dortch, GN Docket No 23-65, SB
Docket No. 22-271 (Aug. 25, 2023).
16
See Letter from Michael P. Goggin to Marlene H. Dortch, GN Docket No. 23-65, SB Docket No. 22-271, ICFS
File No. SAT-MOD-20230207-00021 (Feb. 7, 2024).
17
See id. at 3 & n.9.

8
SpaceX nevertheless relied on AT&T’s assumptions to conduct an analysis of SpaceX’s direct-to-

cellular system. That analysis showed that SpaceX expected to be able to meet a PFD of -120

dBW/m2/MHz for a single satellite. 18 At no point did SpaceX suggest that it could meet an

aggregate limit of -120 dBW/m2/MHz, or that such a limit should be the rule for all operators and

frequencies. Moreover, no other supplemental coverage operator provided—or has since

provided—an aggregate out-of-band emissions analysis in the record to suggest that it could meet

-120 dBW/m2/MHz. Consequently, no party had adequate notice that the Commission was

considering an aggregate out-of-band limit, particularly one that would apply across all frequency

bands.

Because no party—including AT&T—had suggested that the Commission adopt an across-

the-board aggregate PFD limit, it was a surprise when the Commission proposed to adopt an

aggregate out-of-band emissions limit of -120 dBW/m2/MHz across all supplemental coverage

operations in all frequency bands. 19 In response to the Circulation Draft, SpaceX expeditiously

sought meetings with Bureau staff to raise concerns about the -120 dBW/m2/MHz out-of-band

limit and suggest that the Commission should either defer consideration of appropriate limits to a

further notice or adopt a limit based on the record, which suggested that the appropriate limit was

closer to -113.5 dBW/m2/MHz, if not higher, for the PCS G Block. 20 T-Mobile joined SpaceX in

explaining that the Commission had not provided sufficient notice and that additional study was

18
See Letter from David Goldman to Marlene H. Dortch, GN Docket No. 23-65, SB Docket No. 22-271, Attachment
A at 2 (Feb. 13, 2024) (“SpaceX OOBE Analysis”).
19
See Single Network Future: Supplemental Coverage from Space, FCC-CIRC2403-03, ¶ 205 (Feb. 22, 2024)
(“Circulation Draft”).
20
See Letter from David Goldman to Marlene H. Dortch, GN Docket No. 23-65, SB Docket No. 22-271 (Feb. 28,
2024).

9
warranted to develop reasonable limits.21 And the only party to submit additional technical data

in the record—Verizon—explained that out-of-band limits must take into account the frequency

involved. 22 Unfortunately, because Verizon did not submit its letter after the start of the

Commission’s Sunshine period, it did not give any party an opportunity to comment on its analysis.

When the Commission ultimately adopted the SCS Order, it doubled down on its aggregate

-120 dBW/m2/MHz limit. The Commission justified its decision based on eleventh-hour

comments from AT&T, Verizon, and DISH suggesting that “variability in receiver gain and noise

values in the same or different bands should be considered for interference protection.” 23 Although

the Commission generally stated that it was relying on “reasonable assumptions regarding state-

of-the-art technology in currently deployed terrestrial networks and accordingly ha[d] not used any

worst-case assumptions,” 24 the SCS Order did not provide any of those technical assumptions or

explain why those assumptions were correct. Nor did the SCS Order analyze the relationship

between its single PFD limit and the generally accepted ITU -6 dB I/N interference threshold for

the protection of terrestrial networks for the bands at issue. And apart from claiming that a single

limit would be “simple,” the order did not justify the consequence of that limit: requiring higher-

frequency operations to suppress their emissions by as much as ten times below the -6 dB I/N

threshold while allowing lower-frequency operations to exceed it.

21
See Letter from Steve B. Sharkey to Marlene H. Dortch, GN Docket No. 23-65, et al., at 3 (Mar. 5, 2024); Letter
from Steve B. Sharkey to Marlene H. Dortch, GN Docket No. 23-65, et al., at 3 (Mar. 6, 2024).
22
See Letter from Rachael Bender to Marlene H. Dortch, GN Docket NO. 23-65, SB Docket No. 22-271, at 2 (Mar.
8, 2024) (“the calculation of equivalent PFD appears to be based on three specific assumptions that do not apply
to scenarios at the lower frequency end of the bands included in the Draft SCS Order”).
23
SCS Order ¶ 206.
24
Id. ¶ 204.

10
 DISCUSSION

Reconsidering the one-size-fits-all aggregate out-of-band emissions limit adopted by the

Commission would address several errors and omissions in the SCS Order. Adopting band-

specific PFD limits would appropriately recognize that PFD limits are—and should always be—

dependent on the specific frequency at issue. As such, adopting band-specific limits would

promote efficient spectrum management reflecting “the realities of interference, drawn from basic

physics” and clear, realistic assumptions about terrestrial user equipment parameters. 25 And above

all, band-specific out-of-band limits would best achieve the goals of the SCS Order to establish

equitable, technologically feasible limits that enable ubiquitous mobile connectivity for consumers

and set a strong example for other countries to follow. 26

I. ADOPTING BAND-SPECIFIC OUT-OF-BAND PFD LIMITS THAT ACHIEVE A COMMON

INTERFERENCE THRESHOLD WOULD BETTER ALIGN WITH FUNDAMENTAL PHYSICS
AND REALISTIC INTERFERENCE ASSUMPTIONS THAN A ONE-SIZE-FITS-ALL PFD LIMIT

The one-size-fits-all aggregate out-of-band emissions limit of -120 dBW/m2/MHz in the

SCS Order represents a material error that overlooks the fundamental nature of PFD limits and

how they relate to applicable interference thresholds. To correct this error, the Commission should

replace the one-size-fits-all limit with a framework and associated limits that efficiently reflect the

established -6 dB I/N interference threshold in different frequency bands, just as the PFD limits

applicable to terrestrial operations do today. Doing so will promote more efficient sharing between

terrestrial and supplemental coverage operations without arbitrarily constraining higher-frequency

supplemental coverage operations at the expense of consumers and first responders.

25
See Principles for Promoting Efficient Use of Spectrum and Opportunities for New Services, 38 FCC Rcd. 3682,
¶ 3 (2023).
26
See SCS Order ¶ 205.

11
 Power flux-density limits are—and should always be—dependent on the specific

frequency at issue. The issue comes down to fundamental physics. The appropriate equation to

calculate the interference-to-noise ratio (I/N) is:

I/N = PFD + 10*log10( λ2/4π) + G –10*log10(kTB) – NF – other losses

Where:

o I/N = Interference to Noise Ratio [dB]

o PFD = Power Flux-Density [dBW/m2/MHz]
o λ = wavelength [m]
o G = User equipment (“UE”) antenna gain [dBi]
o G + 10*log10( λ2/4π) is the effective aperture of the UE antenna
o NF = Noise Figure of the UE [dB]
o 10*log10(kTB) = thermal noise, where B is the reference bandwidth used to define
PFD (1 MHz) [dBW/MHz]
o 10*log10(kTB) + NF is the noise floor of the UE

However, the PFD corresponding to the noise floor varies with frequency/wavelength as follows:

PFD corresponding to the noise floor = (10*log10(kTB) + NF) – (10*log10( λ2/4π) + G)

and as a result, the appropriate aggregate PFD level necessary to meet the applicable target I/N

threshold also varies with frequency.

As shown in Table 1 below, using this generally accepted approach built on fundamental

physics and reference standards, higher frequency operations (i.e., shorter wavelengths) permit a

higher PFD to meet the same target I/N threshold as lower frequency operations.

12
since satellites use circular polarization and terrestrial equipment uses linear polarization, but

conservatively does not include other losses such as body loss and atmospheric loss. Subtracting

a further 6 dB—based on the established -6 dB I/N threshold for cellular user equipment in all of

the relevant frequency bands for supplemental coverage and adjacent terrestrial mobile

operations 29—provides a reasonable aggregate PFD level in each band to protect out-of-band

users. Importantly, because the numbers above are represented in decibels, each 3 dB difference

in PFD represents a doubling/halving of power, and a 10 dB difference represents an order of

magnitude difference in power.

Even the limits in the table above likely still over-protect adjacent band terrestrial users

because they do not consider other reasonable losses, including 3-6 dB of additional body loss—a

factor that SpaceX mentioned in its initial analysis and that the Commission has found appropriate

in other mobile contexts. 30 These additional losses would overcome any possible variability in

UE antenna characteristics (e.g., in antenna gain or noise figure) that the Commission identified in

the SCS Order.

The results of this analysis, which combines fundamental radiofrequency equations with

“reasonable assumptions regarding state-of-the-art technology” 31 while conservatively excluding

some reasonable losses, demonstrate the arbitrariness of applying a single out-of-band PFD limit

across a wide range of supplemental coverage frequencies. For example, despite the fact that

operations at -110.5 dBW/m2/MHz at 1.995 GHz are over ten times more powerful than operations

29
See, e.g., Circulation Draft ¶ 205 (deriving PFD using “a single-entry 6 dB I/N interference threshold, typically
used for coexistence analyses”).
30
See, e.g., SpaceX OOBE Analysis at 2-4; Service Rules for Advanced Wireless Services H Block, 28 FCC Rcd.
9483, ¶ 147 (2013) (noting that “in prior Commission analysis, the total losses attributable to head and body losses
have been in the range of as much as 6 to 10 dB for each device”); Amendment of Part 15 of the Commission’s
Rules for Unlicensed Operations in the Television Bands, Repurposed 600 MHz Band, 600 MHz Guard Bands
and Duplex Gap, and Channel 37, 30 FCC Rcd. 9551, ¶ 125 (2015) (conservatively assuming 3 dB body loss).
31
SCS Order ¶ 204.

14
at -120.8 dBW/m2/MHz at 614 MHz, they both meet the -6 dB I/N threshold and would not cause

harmful interference to adjacent band operations. But even though operators at 614 MHz must

operate at lower power levels to achieve the same I/N, the single -120 dBW/m2/MHz PFD limit

adopted in the SCS Order would allow those 600 MHz band operators to exceed the -6 dB I/N

threshold by 0.8 dB while requiring operators in the PCS G Block and AWS-H block to suppress

their emissions by an order of magnitude below the threshold, as shown below in Figure 1.

Figure 1: PFD limits meeting -6 dB I/N at different frequencies compared to the

-120 dBW/m2/MHz rule. Blue dots represent the PFD limit required to meet the
accepted -6 dB I/N. Under the SCS Order, operations at 600 MHz may exceed
the applicable -6 dB I/N threshold while complying with the FCC rule, but
operations between 700 MHz and 2 GHz must suppress their emissions below the
-6 dB I/N threshold, sometimes by over 10 dB, to comply with the rule.

Yet the SCS Order does not evaluate its limit against the accepted -6 dB I/N limit, explain the

disparity in treatment, or justify its decision to permit some SCS operators to exceed established

ITU interference thresholds while requiring others to severely degrade their operations by an order

of magnitude below the level necessary to protect adjacent-band users. Moreover, no supplemental

15
 coverage operator stated—at any point in the proceeding—that it could meet a -120 dBW/m2/MHz

aggregate limit for any of the frequencies at issue in the SCS Order, and the Commission never

sought comment on whether such a limit was achievable, much less appropriate. Nor does the SCS

Order explain whether or how it considered the “near-far” problem with respect to the limit it

adopted, a problem that largely drives the need for more restrictive out-of-band limits between

nearby terrestrial systems but—as the Commission acknowledges—does not apply in the context

of a satellite downlinking from hundreds of kilometers away. 32 To the extent that the SCS Order

adopted its single out-of-band limit based on an interference problem that does not exist in the

supplemental coverage context, it fails to identify, explain, or justify that decision.

II. ADOPTING BAND-SPECIFIC OUT-OF-BAND PFD LIMITS THAT ACHIEVE A COMMON

INTERFERENCE THRESHOLD WOULD BETTER SERVE CONSUMERS AND FACILITATE
FUTURE SCS INNOVATION THAN A ONE-SIZE-FITS-ALL PFD LIMIT

Reconsidering the Commission’s one-size-fits-all aggregate out-of-band emissions limit

and substituting band-specific out-of-band limits that achieve the accepted ITU -6 dB I/N threshold

to protect terrestrial networks not only would align the SCS Order with fundamental physics

principles and engineering best practices, it also would better achieve the core goals of the SCS

Order and the stated intent of the Commission’s out-of-band limits to create a simple, clear

framework for out-of-band emissions that is equitable and technologically feasible.

Adopting a framework with associated band-specific out-of-band limits would be more

“equitable” and “technologically feasible” than an across-the-board PFD limit of -120

dBW/m2/MHz. While the SCS Order asserts that an across-the-board limit would be “equitable”

and “technologically feasible,” 33 unfortunately neither the record nor sound engineering practice

32
SCS Order ¶ 118.
33
Id. ¶ 205.

16
supports that conclusion. As demonstrated in the preceding section, an across-the-board -120

dBW/m2/MHz PFD limit is inequitable because it arbitrarily punishes higher-frequency operators

by making them reduce their power by more than an order of magnitude below the -6 dB I/N

threshold, while permitting lower-frequency operators to exceed that interference threshold. From

a practical perspective, adopting a -120 dBW/m2/MHz will effectively foreclose supplemental

coverage operations in mid-band spectrum, including in the PCS G Block that is the subject of the

SpaceX/T-Mobile arrangement, and in higher mid-band frequencies that operators may seek to use

to provide supplemental coverage. Moreover, an across-the-board limit would unfairly permit

supplemental coverage systems using lower frequency bands to operate at higher power levels than

accepted interference metrics would otherwise allow. Ultimately, an across-the-board aggregate

out-of-band PFD limit would needlessly take away options from consumers and harm competition,

potentially leading to higher prices and poorer services, including during emergencies and natural

disasters when people need them most.

Adopting band-specific PFD limits based on clear technical assumptions would provide

greater “clarity for stakeholders” than a single arbitrary limit imposed without providing any

underlying assumptions. As shown in the preceding section, determining the appropriate

aggregate PFD value to protect adjacent band terrestrial operations from supplemental coverage

involves a straightforward analysis using a single formula and a small set of variables. This

straightforward, evidence-based analysis using clear assumptions reveals that conservative

aggregate PFD values should have scaled from -120.8 dBW/m2/MHz at 600 MHz to -110.5

dBW/m2/MHz in the AWS-H Block.

And yet, the SCS Order does not provide clarity for stakeholders because it did not state

the specific methodology it used for its analysis, any of the values it used for the inputs to that

17
analysis, or the basis for those assumptions or why they were reasonable. Nor does it explain how

it reached a limit an order of magnitude more restrictive than necessary to meet the -6 dB I/N

threshold using “reasonable assumptions” that did not “use[] any worst-case assumptions.”34

Unfortunately, the fact that the aggregate out-of-band emission limit in the SCS Order is so much

more restrictive than necessary to protect services adjacent to the PCS G Block and AWS-H block

while allowing lower-frequency operators to exceed accepted interference thresholds suggests that

the analysis may not have been based on the realistic assumptions found in the record, or on the

Commission’s rules, ITU Recommendations, 3GPP standards, or manufacturer specifications.

Adopting band-specific out-of-band emissions limits will allow better coverage and

service during emergencies and natural disasters. When launching this proceeding, the

Chairwoman envisioned a Single Network Future that closed mobile dead zones for consumers

everywhere, including in areas where terrestrial services have not been deployed or where

terrestrial networks been impacted by natural disasters. 35 Adopting efficient band-specific limits

will protect adjacent band networks while ensuring that consumers and first responders can use an

increasingly robust set of features—including texting, voice, web browsing, and more—even in

the most challenging circumstances. Enhanced coverage and service quality will further support

the Commission’s efforts to facilitate emergency 911 calling and texting through direct-to-cellular

networks that can provide a low-latency experience for end users.

An across-the-board, aggregate out-of-band limit, by contrast, will unfortunately

undermine the goal of providing robust coverage during emergencies. As an initial matter, it will

be infeasible for supplemental coverage operators to provide a meaningful service while meeting

34
Id. ¶ 204.
35
See id., Statement of Chairwoman Jessica Rosenworcel at 2.

18
the -120 dBW/m2/MHz limit in higher frequency bands such as the PCS G Block and the AWS-H

Block—limiting the supplemental coverage options for consumers in emergency situations. But

even if operators could provide robust coverage under the aggregate PFD limit in the SCS Order,

meeting such a restrictive limit would require satellite operators either to reduce network coverage

and capacity or to significantly suppress their signals to meet the limit. In either case, that means

less coverage and capacity to connect consumers and first responders during emergencies. Worse,

because these limits will apply even where no adjacent terrestrial networks exist or where those

networks have been damaged by natural disasters, the aggregate limit will needlessly limit the

coverage and quality of direct-to-cellular connectivity even where there is no risk of adjacent-band

interference.

Adopting band-specific PFD limits based on clear assumptions would facilitate future

SCS innovation, including in higher frequency bands. Focusing the Commission’s out-of-band

PFD limits for supplemental coverage from space on meeting the established interference

protection threshold for terrestrial networks—i.e., a -6 dB I/N—will also better accommodate

future innovations that could provide even higher quality services to consumers everywhere. For

example, although SpaceX currently intends to provide text, voice, and web browsing through its

supplemental coverage network, future innovations may permit even more robust supplemental

coverage service and enhanced features. While this improved service will not substitute for

terrestrial mobile networks, it would provide an enhanced source of connectivity where those

networks do not exist. But to achieve these advancements, satellite operators likely will need to

use higher power to provide reliable service. Unfortunately, by setting a limit that will severely

constrain even today’s relatively modest supplemental coverage goals in frequencies above 1 GHz,

the Commission may inadvertently curb future innovation with no offsetting consumer benefit.

19
 Adopting band-specific out-of-band emissions limits will advance U.S. leadership in the

emerging SCS ecosystem by encouraging countries to adopt similarly efficient technical limits.

The SCS Order impressively establishes the United States as a first-mover that sets the template

for other markets in the deployment of supplemental coverage from space. But by adopting an

overly conservative, one-size-fits-all aggregate out-of-band limit without clear assumptions, the

Commission risks setting a precedent that constrains global SCS deployment, particularly for U.S.-

licensed systems. For example, SpaceX has entered into supplemental coverage partnerships

around the world, including in the 2.5 GHz band. If those markets were to follow the

Commission’s lead by adopting a single -120 dBW/m2/MHz out-of-band limit, it would effectively

foreclose operations in that band, requiring operators like SpaceX to turn down their power by

over 10 times more than necessary, ultimately harming consumers. The Commission can set the

right precedent for markets around the world by adopting out-of-band emissions limits based on

reasonable, clearly stated assumptions and tailored to the specific bands at issue.

CONCLUSION

The SCS Order represented an important step toward a 6G Single Network Future. The

Commission can further enhance the promise of this framework for consumers everywhere by

reconsidering its decision to adopt a single, aggregate out-of-band emissions limit of -120

dBW/m2/MHz in Section 25.202(k)(1). If the Commission decides to retain an aggregate limit,

adopting band-specific PFD limits that efficiently and transparently achieve the universally

accepted interference protection threshold of -6 dB I/N would better achieve the Commission’s

goals of ensuring better service, broader coverage, and more choices for consumers.

20
Sincerely,

/s/ David Goldman

David Goldman
Vice President of Satellite Policy

SPACE EXPLORATION TECHNOLOGIES CORP.

1155 F Street, N.W.
Suite 475
Washington, DC 20004
Email: David.Goldman@spacex.com

21