On Friday, TechFreedom filed comments in response to the Federal Communications Commission’s (FCC) Notice of Proposed Rulemaking (NPRM) looking to establish rules to allow Supplemental Coverage from Space (SCS) on terrestrial frequencies. In crafting these new rules, the FCC should be guided by two words: Innovation and Interference.
“This proceeding paves the way for a new era in space communications based on innovation and interference tolerance,” said James E. Dunstan, TechFreedom’s General Counsel. “For the first time, space assets can help close the digital divide. With the right rules, the FCC can usher in a world where space-based and Earth-based systems can coexist and supplement each other in an interference-tolerated system. But the FCC must reward innovation, not further entrench incumbents with rules that give them all the negotiating power.”
“The FCC should reward innovators, not incumbents,” Dunstan continued. “The FCC’s proposal would reward incumbent terrestrial licensees rather than the innovators who pioneered these technologies. This sends the wrong message to those seeking innovative approaches to space communications. It would paralyze new efforts to develop such technologies. The Commission should revisit whether some form of a Pioneer’s Preference could help reward the space communications innovators.”
“The FCC should only grant SCS authorizations to U.S. licensees,” Dunstan concluded. “Whatever wisdom there may have been for an ‘open skies’ policy allowing foreign licensees access to U.S. markets, such a policy is not applicable here. The extensive coordination and integration SCS will require with terrestrial systems supports licensing U.S. entities only. Moreover, the FCC’s ‘open skies’ policies have led to a flight offshore to seek licenses from jurisdictions that have neither expertise nor inclination to protect the public interest or our outer space treaty obligations. This flight has included many U.S. companies, who have found ‘flag of convenience’ jurisdictions that will license their operations far quicker and more cheaply than can the FCC. Entertaining market access petitions for SCS will further exacerbate this flight.”
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Find this release on our website, and share it on Twitter, Bluesky, and Mastodon. We can be reached for comment at media@techfreedom.org. Read our related work, including:
- Our comments to the NTIA on development of a National Spectrum Strategy (Apr. 17, 2023)
- Our comments to the FCC on expediting initial processing of satellite and earth station applications (Mar. 3, 2023)
- Our comments to the FCC on prevention and elimination of digital discrimination (Feb. 22, 2023)
- Our comments to the FCC on In-Space Servicing, Assembly, and Manufacturing (ISAM) (Oct. 31, 2022)
- Our comments to the FCC on receiver performance in spectrum management (June 27, 2022)
- Our comments to the FCC on revising spectrum sharing rules (Apr. 25, 2022)
- Our comments to the NTIA on the Broadband Equity, Access and Deployment (BEAD) program (Feb. 4, 2022)
- Our comments to the FCC on modernizing and expanding access to the 70/80/90 GHz bands (Dec. 2, 2021)
- Our reply comments to the FCC on expanding flexible use of the 12.2-12.7 GHz band (Jul. 7, 2021)
- The FCC, 2.5 GHz Spectrum, and the Tribal Priority Window: Something Positive Amid the COVID-19 Pandemic Techdirt (Dec. 9, 2020)
- The FCC and Spectrum Policy: Sometimes It Hz So Bad Townhall (Nov. 16, 2020)
- Our comments to the FCC urging them not to adopt an NPRM to reallocate the 12 GHz spectrum (Oct. 8, 2020)
About TechFreedom: TechFreedom is a nonprofit, nonpartisan technology policy think tank. We work to chart a path forward for policymakers towards a bright future where technology enhances freedom, and freedom enhances technology.