Connect Europe views on the Commission Regulation Proposal on 2GHz MSS Satellite

Connect Europe welcomes the opportunity to comment on the European Commission’s proposal for a Regulation establishing a Union-level procedure for the authorisation of systems providing mobile satellite services using the harmonised 2 GHz frequency band and repealing Decision No 626/2008/EC. 

The proposal aims to establish an EU-level comparative procedure for selecting holders of rights of use in the 2 GHz MSS band and authorising them under common Union conditions across all Member States. Connect Europe supports the overall objective of improving legal certainty, reducing fragmentation, promoting pan-European services and enabling innovative satellite connectivity, including Direct-to-Device services. 

The proposal correctly recognises that satellite connectivity can play an important complementary role to terrestrial connectivity in extending outdoor coverage [1], ce, and enabling connectivity in remote, underserved or crisis-affected areas. 

The proposal correctly puts at the core Europe’s sovereignty, which Connect Europe strongly appreciates. In particular, the proposal aims to strengthen the EU’s competitiveness and strategic autonomy and promote satellite D2D technologies within the new space ecosystem with the view to reinforcing the Union’s industrial and scientific capacities, enhancing connectivity services for end-users and consolidating Europe’s strategic autonomy, including resilient supply chains. Connect Europe welcomes this approach and supports the design proposed by the European Commission with capacity reserved for secure communications, commercial new EU entrants and commercial entrants. 

At the same time, the Regulation should be clarified on some aspects to ensure that the new framework develops in a way that is competitively neutral and fully coherent with existing terrestrial mobile networks. In particular, Connect Europe believes that the interactions with, and the role of European telecom operators, could be further clarified, as terrestrial mobile networks provide the foundation for Europe’s connectivity, emergency communications, digital services and the future 5G/6G ecosystem. In particular, Connect Europe recommends that the final Regulation should: 

• Preserve the principle of complementarity of satellite D2D communications networks with respect to terrestrial mobile communications networks and provide precise details on how this principle shall apply. 

• Guarantee coexistence with terrestrial mobile networks, including through mandatory technical studies, clear interference-prevention obligations, transparent coordination mechanisms, robust interference resolution mechanisms and alignment with relevant international and 3GPP standards, protecting existing and future terrestrial mobile deployments from harmful interference from satellite connectivity. Satellite D2D networks should operate on a non-interference basis with respect to in-band and adjacent-band services. 

• Ensure competitive neutrality between satellite and terrestrial operators, so that MSS and D2D services complement, rather than distort, the European mobile market, through the application of the principle of "same service, same rules", as comparable services will be offered to end users. 

• Include specific safeguards for the first secure MSS/hybrid licence, ensuring that any reliance on terrestrial infrastructure remains strictly ancillary to the satellite component and is limited to the non-commercial use of any spare capacity available after secure governmental, crisis-management, public-safety and critical-infrastructure needs have been fully met. 

• Confirm pro-competitive and partnership-related provisions, and further detail the rules aimed at avoiding exclusivity agreements for undertakings with strong dominance in satellite communications markets. 

[1] D2D services alone will not be able to provide high-performance mobile connectivity, especially indoors.