Ofcom has published a summary of responses to its Call for Input on “improving mobile connectivity from the sky and space”, alongside a series of next steps that it intends to take in this area.

We previously commented on the Call for Input here. It sought views on the potential supply of, and the demand for, direct-to-device (“D2D”) services and mobile-satellite services (“MSS”), as well as the associated spectrum needs of these services delivered using satellite or high-altitude platform systems (“HAPS”). The summary of responses is divided in line with the main themes that emerged from the responses that Ofcom received, as follows:

1. D2D in mobile bands

Ofcom notes that although there were a number of expressions of interest in offering D2D services to mass market handsets, operators “appear to be in different phases of development” and, as such, there was limited input on proposed commercial timelines.

Respondents acknowledged the benefits of D2D services, but given the UK’s extensive terrestrial networks the view among many was that the market opportunities for D2D services were limited to playing “a complementary role” by providing coverage to the small percentage of the UK without coverage (estimated to be only 0.3% of the population). That said, in addition to providing connectivity to so-called ‘not-spot’ remote areas, other benefits of D2D services were recognised, including: (1) the improvement of the availability and reliability of emergency services; (2) acting as a back-up where terrestrial networks fail; and (3) possibly to “support government, military and railway use cases and encourage development of innovative applications and use cases”.

As for spectrum requirements for delivering D2D services in mobile bands, Ofcom explains that “there was a consensus that the focus should be on Frequency Division Duplex (FDD) bands as Time Division Duplex (TDD) bands present more complexity and challenge for deployment, though one operator did suggest it could expand services to TDD bands in future phases”.

There was less consensus, however, on the matter of authorisation. Whilst respondents generally “encouraged a technology neutral approach that enables flexibility whilst also preventing harmful interference to incumbent services”, they were split on the timing of a national authorisation in the UK. Some supported a UK authorisation as soon as possible, warning of the consequences of delay, while others argued that Ofcom should wait until a decision is made at WRC-27 “as this would support cross-border harmonisation and could act as a base for national regulation”.

Finally, Ofcom notes that there was a concern among many respondents – particularly MNOs – that the introduction of D2D services will “increase the potential for harmful interference to terrestrial networks and adjacent spectrum services”.

2. D2D and other services using MSS spectrum

Ofcom states that several respondents commented on the benefits associated with D2D services using the MSS spectrum, pointing to examples of existing services using the MSS spectrum. However, there was disagreement about the commercial and technical viability of co-frequency sharing of Mobile MSS bands.

3. Satellite – IoT

There was broad agreement on the potential benefits and market opportunities associated with the use of MSS spectrum (both new and existing) for IoT services. Examples provided included “ubiquitous connectivity in rural locations and maritime regions, continued connectivity when terrestrial networks are disrupted, such as during a natural disaster, and climate monitoring”. It was also noted that MSS spectrum aids in the design of satellites as a more simplified antenna can be used as compared to mobile bands.

Ofcom notes that IoT respondents expressed an interest in 2 GHz MSS spectrum, and some discussed using spectrum sharing and time sharing to enable the most efficient use of the spectrum available. The consensus view was also that spectrum should be made available for those providing satellite IoT services in advance of WRC-27.

Next Steps

In the light of the responses it received, Ofcom has decided to continue its work in this area by separating out three separate strands of enquiry:

1. D2D in mobile bands. Ofcom plans to consult on an authorisation framework in early 2025 “with a view to securing the potential benefits of D2D in mobile bands for UK consumers and businesses and support innovation and investment”. Stakeholders who are planning to launch services in the UK are encouraged to engage with Ofcom early by contacting the relevant team at mobilefromskyandspace@ofcom.org.uk.
2. Future use of the S-Band 2 GHz MSS spectrum and review of the authorisation of spectrum use across MSS bands. Ofcom recognises the “clear interest” in access to this spectrum from those wanting to deploy satellite IoT and D2D services, whilst noting that the existing licences has called for its access to continue after 2027 for its delivery of the European Aviation Network. Ofcom states that it plans to “review the use of this spectrum prior to the expiry of the existing licences in 2027 and welcomes any further information relevant to this”.

Ofcom will also consider changing the current position whereby satellite terminals operating to MSS systems are exempt from licensing to a new “light licence basis to provide greater options for managing the sharing environment between these systems in the future, as deployments continue to grow”. It will also consider whether to authorise additional bands under these light licences and generally review its approach to MSS authorisations in the financial year 2025/26.

3. Provision of satellite IoT services in spectrum used for Short Range Devices. Finally, Ofcom notes that it is “actively engaged in ongoing work in Europe (CEPT, FM44) on a draft ECC Decision on satellite IoT transmissions in the 862-870 MHz Short Range Device bands and will continue to be so”. The ECC Decision is expected to be finalised in July 2025, after which Ofcom will consider whether to implement the recommendation in the UK.

Notable by its absence is any future work on HAPs. Ofcom explains that there were very few responses on this topic which, in its view, suggested “limited interest in commercial deployment of HAPs in the short term”. As a result, it does not intend to progress work in this area at this stage, but can review this in the future if evidence of demand arises, and, in the meantime, welcomes approaches from stakeholders “as and when they are ready to offer services in the UK”.

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