Innovation, Science and Economic Development Canada

Engineering, Planning and Standards Branch

Senior Director, Space Services and International
6th Floor, East Tower
235 Queen Street
Ottawa ON K1A 0H5

25 October 2024

Via email: satelliteplanning-planificationsatellite@ised-isde.gc.ca

Re: Reply Comments on Consultation on Supplemental Mobile Coverage by Satellite

SpaceX is pleased to provide reply comments in support of the Innovation, Science and Economic
Development (ISED) Canada and its leadership in furthering the Canadian framework for Supplemental
Mobile Coverage by Satellite (“SMCS”).

Satellite direct-to-cell services promise a safer and more connected future where the peace-of-mind of a
simple text to a loved one or a call for help is delivered reliably. For the thousands of Canadians living in
and travelling through Canada’s vast and diverse terrain, satellite direct-to-cell will be a game-changer in
expanding seamless connectivity, even in areas outside of reach of existing mobile coverage. This
technology will also strengthen the already robust and critical mobile infrastructure in major cities and
towns during crises such as natural disasters and states of emergency.

Innovative commercial partnerships between the mobile industry and technology providers streamline
the development and deployment of satellite direct-to-cell capabilities to mobile subscribers at an
unprecedented pace, while fostering the advancement of direct-to-cell technologies in a still nascent but
burgeoning industry.

For the first time, Starlink Direct to Cell will enable subscribers to seamlessly access satellite direct-to-cell
capabilities using their everyday phones, without requiring specialized hardware or cost-prohibitive
devices. These capabilities are arriving quickly.

SpaceX’s comments to ISED just last month highlight the deployment tempo of Starlink Direct to Cell with
its mobile partners—in lockstep with Canadian stakeholders—accelerating the domestic regulatory
provisions for SMCS. Since then, Starlink Direct to Cell was tested in the most exigent of circumstances—
to support public safety during the historic and devastating hurricanes in the Southeastern United States
earlier this month.

While still in the testing phase of the service, within hours of the U.S. FCC’s grant of emergency
authorization, SpaceX and its U.S. mobile partner, T-Mobile, rapidly mobilized and activated Starlink Direct
to Cell to deliver a best-effort service for communities in the paths of Hurricanes Helene and Milton. The
service provided emergency alerts for all phones on all mobile carriers in the affected areas and activated
free basic SMS messaging, including text to 911 capabilities for T-Mobile subscribers.

The positive impact to affected communities was immediate. In just one day, over 27,000 mobile devices
connected to Direct to Cell satellites. In the coming days, over 250,000 texts were sent through Direct to
Cell—connecting loved ones, family members, and disaster relief services. Direct to Cell is still delivering
thousands of messages while damaged terrestrial telecommunications infrastructure is restored. The
swiftness with which the U.S. FCC acted to enable this service was instrumental to its success.

In response to this emergency, Direct to Cell technologies demonstrated how SMCS can support
communities and critical public services during natural disasters. Of equal significance, the rapid
mobilization of government agencies and private sector service providers are a reminder that efficient
and flexible regulatory arrangements have the power to enable cutting-edge and life-saving technologies
in times of crisis.

SpaceX looks forward to working closely with ISED in the coming months as the SMCS framework is
finalized and provides the following brief comments for consideration:

Re: Future bands of consideration in the SMCS:

Q4 “ ISED is seeking comments on other considerations it should take into account when
identifying frequency bands where the proposed SMCS framework will be applied. “
Q6 “ ISED is seeking comments on any other bands that are used for commercial mobile services
for which the SMCS framework should be applied. “

As a general matter, SMCS is intended to supplement and augment terrestrial mobile networks. Returning
to first principles, the goal of SMCS should be to eventually enable SMCS in any terrestrial mobile band
where operators and providers are able to deploy service to benefit mobile subscribers.

Accordingly, at a national level, SpaceX encourages ISED to look toward developing a consistent and
efficient process to enable SMCS services in additional mobile bands. This proposition will realize two key
mandates — first, ensuring today’s satellite direct-to-cell services are expediently and thoughtfully rolled
out to consumers quickly, and second, developing a blueprint of policy considerations and best practices
to rapidly enable future iterations of satellite direct-to-cell, including in future bands.

SpaceX respectfully proposes that ISED consider adopting a positive rights-based doctrine in the
consideration of future SMCS bands, taking a posture to allow the deployment of SMCS in a band and
enable the swift delivery of consumer services unless there is real and substantive evidence that doing so
would cause harmful interference to incumbent users.
Re: Technical limits and appropriate power-flux-density limits:

• Q22: Technical requirements to be applied to commercial mobile user equipment for SMCS: ISED is
seeking comments on its proposal that existing technical requirements in the relevant SRSP and
RSS in each frequency band would be sufficient for UE for SMCS.
• Q27: Cross-border coexistence: ISED is seeking comments on its proposal to apply existing cross
border rules, as defined in the applicable TRAA, and on whether other technical considerations
must be taken into account to ensure protection of cross-border terrestrial operations.

SpaceX applauds ISED and Canadian stakeholders, such as the Radio Advisory Board of Canada, for taking
an empirical and evidence-based approach to propose band-specific technical limits in the SMCS
consistent with ISED’s existing Standard Radio System Plans (“SRSPs”). By adopting band-specific limits,
ISED will align the SMCS framework with fundamental physics by recognizing that frequency is a
determinative factor in calculating appropriate power-flux density levels. SpaceX further agrees with the
RABC’s proposal to base protection criteria in Canada upon an I/N of -6 dB, widely accepted as an
adequate protection criterion for terrestrial mobile services.

However, while SpaceX generally can support the RABC’s proposal to define two protection criteria for
the lower versus higher bands for the initial SCMS framework and the limited subset of SMCS bands under
consideration, SpaceX encourages ISED to clearly outline and define consideration criteria and procedure
to revise and update protection limits in the SMCS for a new band. This would streamline the addition of
future SMCS bands and realistically account for the practical situation in any given band, including the
type of technology service proposed and the status of deployed adjacent band services in any given band.
For example, appropriate protection criteria should also take into consideration polarization losses (of
conservatively ~ 3 dB) to account for the losses between the circular polarization of satellite transmissions
and the linear polarization of mobile antennas.

Noting the fierce competitive environment of satellite direct-to-cell services, SpaceX strongly supports
ISED’s practice, as adopted in its SRSPs, in applying evidence-based approaches to defining technical limits.
By leaving little to subjectivity or commercially driven motivations, ISED will develop a sensible approach
to interference management for SMCS that balances the deployment of innovative new services with the
protection of incumbent services from harmful interference. Such measures will also pay dividends to
future-proofing the SMCS framework as further bands are considered and SMCS technologies evolve.

As ISED looks to formalize the SMCS framework in the coming months, SpaceX encourages ISED to
evaluate and consider requirements in close consultation with prospective SMCS providers and their
mobile partners to consider the feasibility of such requirements with early satellite direct-to-cell
deployments.
SpaceX is excited by ISED’s progress in developing an enduring SMCS framework that will rapidly enable
the delivery of the transformative benefits of satellite direct-to-cell to Canadian subscribers.

Thank you,

Brett Tarnutzer
Satellite Policy Director
SpaceX

Contact: Brett Tarnutzer Satellite Policy Director

Sharon Zhang Senior Satellite Policy Manager