October 13, 2023

BY ELECTRONIC FILING
Marlene H. Dortch
Secretary
Federal Communications Commission
45 L Street, N.E.
Washington, DC 20554

Re: GN Docket No. 23-135, ICFS File No. SAT-STA-20231002-00240, ICFS File
No. SAT-MOD-20230207-00021, Call Sign S3069

Dear Ms. Dortch:

Earlier this year the Commission unanimously determined that rapidly processing direct-
to-cellular applications while it considers long-term rules would serve the public interest by
facilitating testing and deployment of innovative supplemental coverage capabilities for American
consumers. 1 As Chairwoman Rosenworcel has stated, the Commission should “make it easier for
satellite operators collaborating with terrestrial mobile providers to obtain authorization for
converged services” because these services can provide “connectivity suitable for emergency calls
and texts in remote settings where terrestrial networks do not reach.” 2 In furtherance of this strong
public interest, SpaceX recently applied for special temporary authority (“STA”) to accelerate its
deployment by testing its direct-to-cellular payload in conjunction with fast-approaching launches
of its first supplemental coverage satellites. 3 Unfortunately, now that SpaceX is on the cusp of
reaching the Chairwoman’s goals by deploying a system that will finally bring ubiquitous
connectivity across the country, AT&T and DISH-mouthpiece the Rural Wireless Association
(“RWA”) have seemingly coordinated a desperate, 11th-hour campaign to prevent it. In their recent
letters, AT&T and RWA raise a series of baseless procedural claims while offering no substantive
reason to deny the application. 4 The Commission should reject AT&T’s and RWA’s oppositions
and swiftly grant SpaceX’s STA to begin testing a system that can enable emergency connectivity
in otherwise unserved areas.

1
See Single Network Future: Supplemental Coverage from Space, FCC 23-22, ¶ 43 (rel. Mar. 17, 2023).
2
Jessica Rosenworcel, Chairwoman, Keynote Address to Mobile World Congress: “Leadership for Future
Connectivity,” 3-4 (Feb. 27, 2023), https://docs fcc.gov/public/attachments/DOC-391271A1.pdf.
3
See Request for Special Temporary Authority, ICFS File No. SAT-STA-20231002-00240 (Oct. 2, 2023) (“STA
Request”).
4
See Letter from Michael P. Goggin to Marlene H. Dortch, GN Docket No. 23-135 and ICFS File No. SAT-STA-
20231002-00240 (Oct. 10, 2023) (“AT&T Letter”); Letter from Carri Bennet to Marlene H. Dortch, GN Docket
No. 23-135, ICFS File No. SAT-STA-20231002-00240, ICFS File No. SAT-MOD-20230207-00021 (Oct. 12,
2023) (“RWA Letter”).

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Marlene H. Dortch
October 13, 2023
Page 2 of 3

AT&T and RWA appear to confuse their policy preferences for established Commission
rules and procedures. AT&T apparently would prefer all direct-to-cellular activities to run
exclusively through the Wireless Telecommunications Bureau (“WTB”), or otherwise be
processed as experimental proposals by the Office of Engineering and Technology. 5 RWA’s me-
too filing parrots AT&T’s request to process SpaceX’s request through OET. 6 But AT&T and
RWA ignore the clear Commission rules that permit the Space Bureau—in consultation with
WTB—to grant SpaceX’s STA. Section 25.120 of the Commission’s rules permits an operator
with a pending application for regular authority to apply for a 60-day STA, as SpaceX has done
here, and the Commission has regularly approved STAs with underlying applications requesting
waivers. 7 Thus, AT&T is wrong that SpaceX would need to request and receive a litany of
procedural waivers before receiving the STA. 8 Moreover, AT&T’s evident concern with
SpaceX’s request that the Commission “confirm that [SpaceX] is authorized to use the PCS G
Block spectrum licensed to T-Mobile consistent with” the parties’ spectrum manager lease is
misplaced. 9 This request was meant to confirm the limitations of SpaceX’s ability to operate in
the spectrum, not to prejudge its rights to do so. Indeed, the STA request specifically recognizes
“that Commission grant of the STA does not prejudice the Commission’s further consideration of
its direct-to-cell application.” 10

Nor does AT&T or RWA challenge the public interest in granting SpaceX’s STA. In fact,
both letters acknowledge the value in allowing SpaceX to expeditiously test its direct-to-cellular
capabilities. 11 Further, an STA would be technically identical to an experimental license,
presenting no increased risk of harmful interference—indeed, no harmful interference risk at all—
to other spectrum users. The STA request explains that SpaceX would operate only on a non-
interference, non-protected basis pursuant to relevant Part 24 and Part 25 rules and consistent with
its underlying application. And contrary to AT&T’s and RWA’s claims, SpaceX has backed up
this commitment with “robust technical demonstrations” showing that its operations will not cause

5
The Commission may ultimately determine that WTB should process applications for hybrid terrestrial/space
operations such as supplemental coverage from space. That concept finds support in the SCS rulemaking record
among wireless and satellite operators alike, and SpaceX has explained why treating SCS as part of the Mobile
Service would serve the public interest. But the Commission should decide this procedural issue as a part of the
rulemaking, and should not use it as an excuse to delay rapid deployment of services that can benefit consumers
now.
6
See RWA Letter at 1.
7
See, e.g., Grant, ICFS File No. SAT-STA-20211216-00195 (Apr. 28, 2022) (granting an STA during the pendency
of an application requesting waivers of the U.S. Table of Frequency Allocations and other rules); Grant in Part,
ICFS File No. SAT-STA-20171104-00149 (Nov. 16, 2017) (granting an STA during the pendency of an
application requesting waivers of the U.S. Table of Frequency Allocations, station-keeping requirements, and
other rules); Grant, ICFS File No. SAT-STA-20110318-00057 (Mar. 21, 2011) (granting an STA during the
pendency of an application requesting a waiver of the Commission’s orbital debris rules).
8
Even if the rules did require such waiver requests, SpaceX implicitly included them because its STA request relies
on the terms of SpaceX’s underlying application for regular authority. See STA Request at 1 and n.2.
9
See AT&T Letter at 1.
10
STA Request at 2.
11
See AT&T Letter at 1; RWA Letter at 1.

1155 F St NW, Suite 475, Washington, DC 20004 | phone 202.649.2700 | fax 202.649.2701 | spacex.com
Marlene H. Dortch
October 13, 2023
Page 3 of 3

harmful interference to any in-band, out-of-band, or cross-border users. 12 AT&T and RWA have
not even attempted to refute this evidence. Moreover, SpaceX noted in its STA request that “in
the extremely unlikely event that harmful interference” occurs, it “will take all reasonable steps to
eliminate” it, further reducing the risk to existing users. 13 Therefore, no technical reason exists to
deny SpaceX’s request.

SpaceX urges the Commission to dismiss AT&T’s and RWA’s arguments and
expeditiously grant SpaceX’s STA request.

Sincerely,
/s/ David Goldman
David Goldman
Vice President, Satellite Policy

SPACE EXPLORATION TECHNOLOGIES CORP.

12
See, e.g., Letter from David Goldman to Marlene H. Dortch, GN Docket No. 23-135 and ICFS File No. SAT-
MOD-20230207-00021, Attachment B (July 26, 2023) (summarizing non-interference showings).
13
STA Request at 2.

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