Direct-to-Device Recommendation Letter to the FCC

Assistant Secretary for Telecommunications and Information Arielle Roth wrote to Federal Communications Commission Chairman Brendan Carr to request that the FCC seek public comment on new or updated Knowledge Database guidance to ensure protection of the ensure protection of the GPS L1 signal at 1575.42 MHz. "MSS providers with operations near the GPS L1 signal are partnering with user device manufacturers to enable communications with both terrestrial wireless systems and directly with the MSS providers’ satellites. The rapid growth in the development of this MSS D2D capability brings a corresponding increase in the risk of interference to GPS receivers. Following the evaluation of the potential impact of these developments by a special technical committee of the Space-based Position Navigation and Timing Executive Committee, comprised of federal agencies including the Departments of Transportation and War and the National Aeronautics and Space Administration, the National Telecommunications and Information Administration issued a Request for Comment on “the potential impact on the GPS L1 signal at 1575.42 MHz of the increasing deployment of mobile devices capable of operating on satellite systems in the L-band at 1610-1660.5 MHz.” The results of those analyses lead us to request that the Commission seek public comment on KDB guidance to require D2D devices operating in 1610-1660.5 MHz whose out of band emissions exceed -100 dBW/MHz over any 2 millisecond active transmission interval to include the following showings:

1. Ensuring the devices are incapable of operating in satellite mode on an airplane or when there are accessible terrestrial options for service.
2. Ensure that prior to operating in satellite mode the devices display a screen notifying the user of the prohibition of operating the device on an airplane and the risk of interference to nearby GPS operations.