AT&T Services, Inc. T: 202.457.

2055
601 New Jersey Ave, NW mg7268@att.com
Suite 650 att.com
Washington, DC 20001

October 10, 2023

By Electronic Filing

Marlene H. Dortch, Secretary

Federal Communications Commission
45 L Street N.E.
Washington, D.C. 20554

Re: GN Docket No. 23-135, Filings of SpaceX and T-Mobile Requesting to Establish
Supplemental Coverage from Space; Space Exploration Holdings, LLC
Application for Special Temporary Authority (“STA”), ICFS File No. SAT-STA-
20231002-00240, Call Sign S3069

Dear Ms. Dortch:

In response to Space Exploration Holdings, LLC (“SpaceX”) and T-Mobile USA Inc. (“T-
Mobile”) jointly requesting authority (the “Applications”) to deploy supplemental coverage from
space (“SCS”), AT&T Services, Inc. (“AT&T”) emphasized that the FCC must require “robust
technical demonstrations showing how they will ensure that SCS deployments will not cause
interference to other authorized terrestrial services.” 1 Thus, AT&T commends SpaceX for
acknowledging the need in the STA to “test its . . . satellites with direct-to-cellular
communications payloads” in T-Mobile’s broadband PCS G Block spectrum.2

However, the Space Bureau (“SB”) cannot and should not “confirm that [SpaceX] is authorized
to use the PCS G Block spectrum licensed to T-Mobile consistent with” the parties’ spectrum
manager lease, as SpaceX requests.3 The Wireless Telecommunications Bureau (“WTB”) should
authorize commercial SCS operations through a waiver-based approach.4 The FCC’s rules do

1
Reply Comments of AT&T Services, Inc., GN Docket No. 23-135, at 5 (filed June 5, 2023).
2
Space Exploration Holdings, LLC, Application for Special Temporary Authority, Call Sign S3069, ICFS
File No. SAT-STA-20231002-00240, at 1 (filed Oct. 2, 2023). Indeed, the Commission should not accept the
underlying spectrum manager lease notification until SpaceX completes its proposed testing and utilized the results
to demonstrate that its SCS operations will not cause harmful interference to co-channel or adjacent operations.
3
Id.
4
See Comments of AT&T Services, Inc., GN Docket No. 23-135, at 2 (filed May 18, 2023); Comments of
AT&T Services, Inc., GN Docket No. 23-65, IB Docket No. 22-271, at 9-11 (filed May 12, 2023); Comments of
Verizon, GN Docket No. 23-65, IB Docket No. 22-271, at 5 (filed May 12, 2023). Indeed, neither the SB nor its
predecessor (the International Bureau) have ever authorized a satellite operator to operate in the United States using
spectrum that is licensed exclusively to a third-party terrestrial operator and it should not do so in the context of this
STA request. The WTB has historically granted terrestrial operating authority because it is best positioned to
administer the Commission’s highly successful exclusive-use licensing framework and to ensure that terrestrial
license rights are adequately protected.
not permit SpaceX’s proposed use of T-Mobile’s spectrum without waiver of the U.S. Table of
Frequency Allocations (“ToFA”), Part 24 technical and operational rules, and the Commission’s
leasing rules.5 The STA contains none of these waiver requests, and the WTB has not yet granted
the necessary waivers that would permit SCS operations in terrestrial mobile frequencies.

SpaceX should not be allowed to bypass the waiver process through the STA request. Instead,
the proper venue to authorize the novel testing SpaceX seeks is through an experimental license
from the Office of Engineering and Technology. This same Part 5 process has already authorized
similar testing for Lynk Global, Inc. and AST&Science LLC as well as ground testing for SpaceX
in LTE Bands 2, 4, and 7 and should be utilized here.6

Respectfully submitted,

/s/ Michael P. Goggin

Michael P. Goggin
AT&T SERVICES, INC.
601 New Jersey Ave., N.W. – Suite 650
Washington, D.C. 20001
(202)457-2055

cc: Roger Noel, Wireless Telecommunications Bureau

Merissa Velez, Space Bureau
Kerry Murray, Space Bureau

6
See ELS File No. 1678-EX-ST-2023 (granted Sept. 27, 2023) (authorizing AST&Science LLC to “test
uplinks from mobile handsets to BW3 NGSO satellite in low-earth orbit”); ELS File No. 1059-EX-CN-2020
(granted May 2, 2022); ELS File No. 0208EX-CM-2022 (granted Feb. 9, 2023); ELS File No. 0931-EX-CN-2020
(granted May 17, 2021) (authorizing Lynk Global to test communications between satellites and mobile operating
stations in the 800 MHz band); ELS File No. 1279-EX-CN-2023 (granted Sept. 26, 2023) (authorizing SpaceX to
conduct limited testing of SCS equipment at its research labs in Sunnyvale, CA and Redmond, WA).

2
 CERTIFICATE OF SERVICE

I hereby certify that on this 10th day of October 2023, a true copy of the foregoing letter

was served via e-mail upon:

William M. Wiltshire David Goldman

Paul Caritj Senior Director of Satellite Policy
HWG LLP SPACE EXPLORATION TECHNOLOGIES
1919 M Street, N.W. CORP.
Suite 800 1155 F Street, NW – Suite 475
Washington, DC 20036 Washington, DC 20004
Counsel to SpaceX David.goldman@spacex.com
wwiltshire@hwglaw.com

/s/ Michael P. Goggin

Michael P. Goggin