Promote Direct-to-Device Innovation

Agenda Items 1.13 and 1.14 both address the need for additional spectrum to support satellite direct-to-device (D2D) services, but they do so through two distinct regulatory frameworks. D2D services enable satellites to connect directly to mobile devices, including smartphones, vehicles, and internet-of-things (IoT) devices, virtually anywhere in the world. Today, these services primarily support texting and basic data applications, but they are expected to provide increasingly robust broadband connectivity in the coming years. Such capabilities could deliver significant benefits to consumers in rural and remote areas, as well as in places where terrestrial mobile coverage is weak or unavailable. Enterprise applications include connectivity for vehicle fleets, ships, drones, robots, and other connected devices.

Despite its promise, D2D remains constrained by two related challenges. First, satellite operators generally lack authorization to operate in most spectrum bands assigned to terrestrial mobile networks, known internationally as international mobile telecommunications (IMT) bands. Second, the amount of spectrum allocated to the mobile satellite service (MSS)—particularly spectrum suitable for communicating directly with handheld devices—remains limited both in the United States and globally.

The United States should strongly support both Agenda Item 1.13 and Agenda Item 1.14. Together, they offer a pathway to greater capacity, innovation, and potentially ubiquitous mobile connectivity.

Agenda Item 1.13 examines whether satellite operators should be authorized to provide D2D connectivity in spectrum bands already used for terrestrial mobile services.

The FCC pioneered this approach in 2024 when it authorized satellite D2D operations in certain exclusively licensed terrestrial mobile bands under a framework known as Supplemental Coverage from Space (SCS). Agenda Item 1.13 would establish a similar concept internationally by considering secondary MSS allocations in selected IMT bands.

Under the FCC’s framework, satellite operators partner with terrestrial mobile carriers to extend coverage into areas where conventional cellular networks are unavailable.⁷⁴ T-Mobile and Starlink, for example, have partnered to provide T-Satellite, a direct-to-cell service that supports texting, messaging, location sharing, and other basic functions in areas without cellular coverage.⁷⁵ AT&T and Verizon have formed similar partnerships with AST SpaceMobile.⁷⁶ Most recently, the three major U.S. mobile carriers announced a joint venture to coordinate their D2D efforts.⁷⁷

While promising, SCS remains constrained by its secondary status. Satellite operators may provide service only with the consent of the terrestrial license holder and generally only in areas lacking terrestrial coverage.⁷⁸ D2D operations must also protect neighboring terrestrial networks, including those operating across national borders. These requirements can limit the availability of service in border regions where multiple operators use the same frequencies.⁷⁹

Agenda Item 1.13 would effectively create a comparable framework at the international level. ITU Working Party 4C has been tasked with studying possible MSS allocations in IMT bands between 694/698 MHz and 2.7 GHz as well as the technical, operational, and regulatory issues necessary to support direct satellite-to-device connectivity without disrupting existing terrestrial services.⁸⁰

The potential benefits are substantial. D2D services can improve network resilience, close coverage gaps, and provide connectivity in locations where terrestrial networks remain uneconomic or impractical to deploy. Other countries are already moving in this direction. Australia’s Universal Outdoor Mobile Obligation incorporates satellite-enabled D2D connectivity as part of its coverage strategy, and Telstra has partnered with SpaceX to provide satellite messaging services.⁸¹ In 2025, Canada adopted its own supplemental mobile coverage framework, allowing satellite operations on a secondary, noninterference basis in certain mobile bands.⁸²

The United States should strongly support broader D2D authorizations. At the same time, it should oppose technical restrictions that would unnecessarily limit the usefulness of these services.

One concern involves a proposed interference-to-noise (I/N) protection threshold of -6 dB at national borders. As with the outdated assumptions underlying the current EPFD limits that limit NGSO operations in bands shared with legacy GSO systems (discussed above), this proposal risks imposing excessively conservative restrictions. In regions with many closely spaced borders, such as Central America and West Africa, the proposed threshold will make it difficult for satellite operators to provide D2D service at usable power levels. The resulting exclusion zones could leave substantial populations without service.

Similar concerns arise from assumptions used to derive aggregate power-flux density limits for D2D transmissions. Some proposals rely on highly conservative assumptions regarding handset antenna gain, body loss, polarization loss, and related factors.⁸³ In practice, these assumptions could make the resulting limits even more restrictive than the underlying -6 dB I/N threshold.

The United States should continue to support expanded D2D authorizations across IMT bands while resisting technical criteria so restrictive that they undermine the very services the ITU seeks to encourage.

Agenda Item 1.14 advances a related but distinct objective: expanding the amount of spectrum allocated to the mobile satellite service, allowing satellite operators to provide D2D connectivity as a primary service rather than a secondary one. Globalstar’s partnership with Apple illustrates this model. Using MSS spectrum, Globalstar enables texting and related satellite capabilities on newer iPhone models at any location, including very rural and remote areas.

Although both SCS and MSS-based D2D services connect satellites directly to mobile devices, they serve different purposes. Under the SCS model, satellites extend the reach of terrestrial mobile networks and remain dependent on partnerships with terrestrial carriers. Under the MSS model, satellite operators control both the service and the spectrum they use. As a result, MSS operators can offer service across broader geographic areas, support a wider variety of devices, develop new applications, and potentially compete directly with terrestrial providers. MSS spectrum can support not only smartphones but also vehicles, ships, trains, drones, robots, and a wide range of enterprise IoT applications.

In the United States, MSS spectrum is concentrated in a small number of bands, including the so-called “Big LEO” allocations and the 2 GHz MSS bands.⁸⁴ Access to these frequencies is limited, and a small number of incumbent operators hold exclusive licenses. As demand for D2D services has grown, so has competition for this spectrum. SpaceX, for example, petitioned for access to portions of MSS spectrum currently assigned to incumbents.⁸⁵ Incumbent operators argued that additional sharing would create harmful interference, while proponents of expanded access contended that modern technologies could enable coexistence and that portions of the spectrum remain underutilized. The debate ultimately ended with the FCC’s Space Bureau declining to open those bands to new entrants in April 2026.⁸⁶

Recent transactions highlight the market’s assessment of MSS spectrum’s value. SpaceX agreed to pay $19.6 billion for 65 megahertz of EchoStar spectrum authorized for MSS/D2D services, while Amazon’s Project Kuiper agreed to acquire Globalstar and its MSS assets for $11.6 billion. These transactions suggest that demand for MSS spectrum substantially exceeds current supply.

Even successful services such as Apple and Globalstar’s partnership remain constrained by limited spectrum resources. Significantly more MSS spectrum would be required to support richer satellite capabilities on consumer devices or to enable robust competition among providers.

As debate over additional MSS allocations moves to the international stage, the United States should strongly support efforts to identify new MSS spectrum bands that can be allocated globally or regionally for D2D services.

The United States should also support studies examining greater spectrum sharing among MSS operators and applications. For example, consumer handset services may be able to share spectrum with maritime services or certain IoT applications. With the exception of some low-band MSS allocations, most satellite spectrum is coordinated and shared among multiple users. Future allocations should be guided by technical feasibility and consumer demand rather than by the interests of incumbent license holders.

Demand for MSS spectrum is growing rapidly. The ITU should ensure that spectrum policy evolves accordingly.