Before the

FEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554

In the Matter of )
)
Filings of SpaceX and T-Mobile Requesting to ) GN Docket No. 23-135
Establish Supplemental Coverage from Space )
)
Space Exploration Holdings, LLC Application ) IBFS File No. SAT-MOD-20230207-
Accepted for Filing 00021

COMMENTS OF AT&T

Michael P. Goggin
Jessica B. Lyons
David J. Chorzempa

AT&T SERVICES, INC.

1120 20th Street, N.W.
May 18, 2023 Washington, D.C. 20036
(202) 457-2055
 TABLE OF CONTENTS

I. INTRODUCTION AND SUMMARY..............................................................................1

II. THE APPLICANTS EITHER FAIL TO REQUEST OR FAIL TO JUSTIFY

ALL RELEVANT WAIVERS NECESSARY TO PERMIT THE
REQUESTED SCS SERVICE. .........................................................................................4

A. The Request For Waiver Of The U.S. Table of Frequency Allocations Is

Inadequate. ...............................................................................................................4

B. Other Necessary Waiver Requests Are Missing. .....................................................5

III. APPLICANTS’ TECHNICAL SHOWINGS ARE INSUFFICIENT. ..........................8

IV. CONCLUSION ................................................................................................................12

ii
 Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of )
)
Filings of SpaceX and T-Mobile Requesting to ) GN Docket No. 23-135
Establish Supplemental Coverage from Space )
)
Space Exploration Holdings, LLC Application ) IBFS File No. SAT-MOD-20230207-
Accepted for Filing 00021

COMMENTS OF AT&T

AT&T Services, Inc., on behalf of itself and its affiliates (collectively, “AT&T”), submits

these comments in response to the Federal Communications Commission’s (“Commission” or

“FCC”) Public Notice seeking comment on filings by Space Exploration Holdings, LLC

(“SpaceX”) and T-Mobile USA Inc. (“T-Mobile”) (collectively “Applicants”) jointly requesting

authority to deploy supplemental coverage from space (“SCS”) to supplement T-Mobile’s

terrestrial network using SpaceX satellites. 1 In particular, the Applicants seek authority to

deploy SCS services utilizing T-Mobile’s Broadband PCS G Block spectrum. AT&T has an

interest in this proceeding as an adjacent licensee holder of Broadband PCS C Block spectrum.

I. INTRODUCTION AND SUMMARY.

As AT&T and others explained in the ongoing SCS proceeding, it is paramount that SCS

operations do not jeopardize or inhibit the delivery of terrestrial wireless services. 2 Mobile

1
Space Bureau and Wireless Telecommunications Bureau Seek Comment on Filings of SpaceX and
T-Mobile Requesting to Establish Supplemental Coverage from Space, Public Notice, GN Docket No. 23-
135, IBFS File No. SAT-MOD-20230207-00021, Call Sign 3069, DA 23-338 (Apr. 18, 2023).
2
See, e.g., Comments of AT&T, GN Docket No. 23-65, IB Docket No. 22-271, at 2-3, 5-7 (filed
May 12, 2023) (“AT&T Comments”); Comments of Verizon, GN Docket No. 23-65, IB Docket No. 22-
271, at 6-7 (filed May 12, 2023) (“Verizon Comments”); Comments of Apple, GN Docket No. 23-65, IB
broadband networks today are essential to American life. Americans rely on wireless

connectivity to access telehealth platforms, educational resources, important government

services, and more. Developing advanced mobile broadband networks has also fostered

innovation and driven dramatic economic growth. In evaluating potential SCS deployments, the

Commission must prioritize protecting these foundational terrestrial networks.

The best path forward for SCS is a waiver-based approach that vests the Wireless

Telecommunications Bureau (“WTB”) with sole authority to permit SCS operations in terrestrial

mobile frequencies. 3 Such an approach allows the FCC to ensure that applicants meet the high

standard required for waiver and that SCS operations will not present any risk to terrestrial

wireless operations of all licensees, including collaborating carriers. 4 Terrestrial services are

inherently more robust than limited SCS service offerings. Allowing SCS operations to interfere

with or replace existing co-channel terrestrial services would thus degrade service quality and

reliability for American consumers and contravene the public interest. 5 To ensure that terrestrial

deployments are properly protected, the WTB should serve as the sole gatekeeper for permitting

operations in terrestrial frequencies.

To this end, AT&T and AST & Science, LLC (“AST”) have submitted several FCC

Forms 608 to the WTB notifying the Commission that they have entered into a spectrum

manager leasing arrangement pursuant to which AT&T will lease certain spectrum to AST for

Docket No. 22-271, at 8-9 (filed May 12, 2023) (“Apple Comments”) Comments of CTIA, GN Docket
No. 23-65, IB Docket No. 22-271, at 3-4 (filed May 12, 2023) (“CTIA Comments”).
3
See AT&T Comments at 3, 9-12; Verizon Comments at 5, 7; CTIA Comments at 3, 5-6, 9.
4
See Verizon Comments at 4.
5
See id. at 8.

2
the provision of SCS services. 6 AST also has a Part 25 application currently pending before the

Commission for its planned space constellation’s V-Band gateway links and will file a

corresponding request for authorization (including all necessary waivers) to enable a payload

capable of transmitting on the terrestrial frequencies. 7 Consistent with these comments, AT&T

and AST intend to provide the demonstrations necessary to show that they will not cause

interference to any authorized terrestrial systems. 8 AST has already made significant progress

on this front, recently completing the first-ever space-based voice call directly to an unmodified

smartphone from the Midland, Texas area to Rakuten in Japan. 9 AST’s testing with its

BlueWalker 3 satellite commenced in early 2023 pursuant to experimental authority and remains

ongoing in cooperation with AT&T, Rakuten, and Vodafone. 10

Here, SpaceX seeks to modify its second-generation non-geostationary orbit Fixed-

Satellite Service system (“Gen 2 system”) to authorize the deployment and operation of an SCS

payload in the United States using Broadband PCS G Block frequencies currently licensed on a

near-nationwide basis to T-Mobile. SpaceX and T-Mobile also have submitted an FCC Form

608 notifying the Commission that they have executed a spectrum manager leasing arrangement

6
See ULS File Nos. 0010538493 (lead), 0010538588, 0010538610, 0010538635, 0010538647,
0010538661, 0010538682.
7
See AST & Science, LLC, Application for Satellite Space Station Authorizations, IBFS File Nos.
SAT-PDR-20200413-00034, SAT-APL-20200727-00088, SAT-APL-20201028-00126.
8
Indeed, commenters agree that SCS applicants should be required to show that that their planned
deployments will not interfere with any authorized terrestrial systems. See, e.g., CTIA Comments at 3;
Apple Comments at 9; Comments of Sirius XM Radio Inc., GN Docket No. 23-65, IB Docket No. 22-
271, at 7-8 (filed May 12, 2023) (“Sirius Comments”).
9
See AST SpaceMobile Makes History in Cellular Connectivity, Completing the First-Ever Space-
Based Voice Call Using Everyday Unmodified Smartphones (April 25, 2023), https://astscience.
com/2023/04/25/ast-spacemobile-makes-history-in-cellular-connectivity-completing-the-firstever-
space-based-voice-call-using-everyday-unmodified-smartphones/ (last visited May 7, 2023).
10
See Experimental Call Sign WL2XRE; Comments of AST SpaceMobile, Inc., GN Docket No.
23-65, IB Docket No. 22-271, at 18 (May 12, 2023).

3
permitting SpaceX’s use of the frequencies. To date, it does not appear that SpaceX and T-

Mobile have begun testing any SCS deployments.

The FCC’s rules do not permit SpaceX’s proposed use of T-Mobile’s terrestrial spectrum,

and Applicants fail to even request—much less justify—rule waivers that would be necessary to

authorize their proposed SCS authorizations. More broadly, the Applicants’ technical showings

are woefully insufficient regarding the risk of harmful interference posed by their planned SCS

deployments. SpaceX and T-Mobile’s applications fall far short of meeting the threshold for

waiver and cannot be granted in their current state.

II. THE APPLICANTS EITHER FAIL TO REQUEST OR FAIL TO JUSTIFY ALL

RELEVANT WAIVERS NECESSARY TO PERMIT THE REQUESTED SCS
SERVICE.

The FCC’s rules do not permit SpaceX’s proposed use of T-Mobile’s broadband PCS G

Block spectrum and would require waiver of the U.S. Table of Frequency Allocations (“ToFA”),

Part 24 technical and operational rules, and the Commission’s leasing rules. Here, Applicants

have not met the waiver standard for the ToFA and have failed to even request waiver of the

relevant Part 24 and secondary market rules.

A. The Request For Waiver Of The U.S. Table of Frequency Allocations Is

Inadequate.

In its request for waiver of the ToFA, SpaceX baldly asserts that it plans to operate on an

“unprotected, non-interference basis.” 11 This barebones assertion fails to offer the compelling

showing needed to justify waiver. “An applicant for waiver faces a high hurdle even at the

starting gate,” 12 and “must support its waiver request with a compelling showing.” 13 Waiver is

11
See Waiver Requests, IBFS File No. SAT-MOD-20230207-00021, at 4 (“Waiver Requests”); see
also Technical Attachment A, Technical Informa to Supplement Schedule S (“Technical Narrative”),
IBFS File No. SAT-MOD-20230207-00021, at 5 (purporting to “certify” no interference).
12
WAIT Radio v. FCC, 418 F.2d 1153, 1157 (D.C. Cir. 1969).

4
only appropriate if it is shown that the underlying purpose of the rule would be frustrated by

application of the rule; that the waiver is in the public interest; that application of the rule would

be inequitable or unduly burdensome; or that the applicant has no reasonable alternative to the

waiver requested. 14 The Commission historically has taken an even more exacting approach to

requests for waiver of the ToFA. Indeed, the Commission has made clear that waiver of the

ToFA is only appropriate “when there is little potential for interference into any service

authorized under the [ToFA].” 15

Applicants do not meet that burden here. The Commission should reject SpaceX’s

request to simply take it at its word that it will not cause interference. 16 As commenters have

made clear, the Commission must ensure above all else that SCS operations do not jeopardize the

delivery of terrestrial services that enhance Americans’ lives and fuel economic growth. 17 The

FCC thus should not grant the applications unless and until SpaceX provides sufficient technical

showings demonstrating that terrestrial licensees—including T-Mobile itself—will be protected

from harmful interference.

B. Other Necessary Waiver Requests Are Missing.

Applicants failed to request waiver of the Commission’s leasing rules, which prohibit

lessees from using spectrum that is allocated for terrestrial mobile use for satellite services. 18

13
Amend. of Section 73.202(b), Table of Allotments, FM Broad. Stations, Memorandum Opinion
and Order, 29 FCC Rcd 907, 911, ¶ 12 (2014).
14
47 C.F.R. § 1.925(b).
15
Fugro-Chance, Inc., Order, 10 FCC Rcd 2860, ¶ 2 (1995).
16
See, e.g., Viasat, Inc., Order and Declaratory Ruling, 35 FCC Rcd 5416, ¶ 22 (2020) (denying
waiver where applicant “has not provided the demonstration that there is little potential for interference”).
17
See, e.g., Apple Comments at 8-9; Verizon Comments at 9-10; CTIA Comments at 2-4.
18
Waiver Requests at 1 (limiting waiver requests to “Section 2.106 and certain subsections of
Section 25 of the Commission’s rules.”).

5
The FCC’s secondary market rules incorporate the use restrictions applicable to the underlying

license. In other words, if the underlying licensed spectrum is restricted to certain services, those

“use restrictions apply to the spectrum lessee as well.” 19 Where, as here, the Applicants propose

to deploy novel SCS services in spectrum licensed for exclusive, terrestrial use, waiver of the

leasing rules should be required.

Likewise, while SpaceX’s proposed operations appear inconsistent with several of the

Commission’s Part 24 technical or operational rules, Applicants have not sought their waiver.

SCS operations do not fit neatly within Part 24 requirements. Applicants thus must do more than

state that its SCS deployments will be capable of complying with the Part 24 rules and instead

provide explanation or technical analysis that would justify waiver. 20 For example:

• Equipment Authorization. Section 24.51 provides that “each transmitter utilized for
operation . . . must be of a type that has been authorized by the Commission under its
certification procedure for use in this part.” This seems to include all transmitters—
user and base station—and could be interpreted to require SpaceX’s space stations to
be type certified. This may not be practical in the SCS context, and a waiver should
be required.

• Calculation of height above average terrain (“HAAT”). HAAT information is

required to comply with certain other Part 24 rules (such as Section 24.232).
Providing HAAT information for a non-geostationary satellite orbit (“NGSO”)
constellation does not make sense. Specifically, subsection (e) states that the
“[p]osition location of the antenna site shall be determined to an accuracy of no less
than +/- 5 meters in both the horizontal (latitude and longitude) and vertical (ground
elevation) dimensions,” which is not possible for an NGSO constellation.
Accordingly, a waiver of this rule likely should be required.

• Frequency Restriction. Section 24.229 provides that the PCS G Block “shall be used
for base station transmissions.” 21 Base stations, in turn, are defined as “land

19
See, e.g., 47 C.F.R. § 1.9020(d)(3).
20
See Verizon Comments at 4 (arguing that SCS applicants should be required to provide a
demonstration that the deployment “will comply with terrestrial protection rules for the relevant rule part”
and “requests for appropriate waivers”).
21
47 C.F.R. § 24.229(c).

6
 station[s] in the land mobile service.” 22 Since SpaceX proposes using these
frequencies for satellite transmissions, a waiver should be required.

• Power and antenna height limits. Section 24.232(a)(2)-(3) limit base stations with an
emission bandwidth greater than 1 MHz (SpaceX is proposing channels of 1.4 to 5
MHz) to 1640 Watts/MHz Effective Isotropic Radiated Power (“EIRP”) with antenna
height less than 300 meters HAAT. For HAAT greater than 300 meters, the EIRP is
limited to a greater extent, i.e., 160 Watts/MHz for HAAT up to 2000 meters.
Although subsection (b) permits larger EIRP densities and greater tower heights in
lower-population counties, SpaceX’s transmissions will obviously occur at much
greater heights and will be at up to 585 kW/MHz EIRP. These levels would likely
greatly exceed the rule’s limits, and thus a waiver should be required.

• Interference Protection.

o Section 24.237(a) of the rules requires coordination with “co-channel or

adjacent channel incumbent fixed microwave licensees.” SpaceX does not
appear to contemplate this requirement in its application materials. It should
either articulate its plan for compliance or request a waiver of the rule.

o Section 24.237(d) requires an “engineering analysis to assure that the

proposed facilities will not cause interference to existing [Private Operational
Fixed Point-to-Point Microwave] stations.” 23 Section 24.237(g) and
Appendix I to Subpart E of section 24 provide a detailed calculation
methodology for evaluating this interference. AT&T acknowledges that these
coordination distances are a function of base station antenna height and that
there is no methodology for determining the correct coordination distance for
space station transmitters. Nonetheless, Applicants still completely ignore
these requirements, and waiver should be required.

• Maintenance of Station Location Information. Section 24.815 states that licensees

“must maintain a current list of all station locations, which must describe the
transmitting antenna site by its geographical coordinates and also by conventional
reference to street number, landmark, or the equivalent. All such coordinates shall be
specified in terms of degrees, minutes, and seconds to the nearest second of latitude
and longitude.” This rule may be impossible to comply with in the satellite context
and thus, a waiver should be required.

22
47 C.F.R. § 24.5.
23
47 C.F.R. § 24.237(d).

7
 Applicants should be required to request waivers of these rules, as well as any others that

the Commission believes are applicable, and to demonstrate that the requests meet the

Commission’s rigorous waiver standards.

III. APPLICANTS’ TECHNICAL SHOWINGS ARE INSUFFICIENT.

Applicants’ technical showings fall short on multiple fronts. SpaceX baldly asserts that

its proposed service “presents no potential for interference into Commission authorized service

within the PCS G Block,” and it says little about the potential for interference to other authorized

services in adjacent bands. 24 The Commission should seek clarification from SpaceX regarding

how it will ensure that its service will not cause interference to other authorized terrestrial

services, including T-Mobile’s own operations in the PCS G Block. 25 Indeed, as T-Mobile itself

has cautioned, SCS operators must “demonstrate that they will cause no more harmful

interference than a terrestrial licensee using the same spectrum.” 26

As AT&T explained in its SCS comments, “even where there is only one licensee in a

proposed SCS band, the underlying terrestrial licensee and its SCS collaborator should be

required to show that the proposed SCS deployments would not interfere with or supplant

existing terrestrial services in the band.” 27 Protecting terrestrial operations is paramount, and T-

Mobile’s PCS G Block co-channel operations should take precedence over the proposed SCS

24
Waiver Requests at 4.
25
See Verizon Comments at 9 (“The SCS partners’ application to transmit on the terrestrial wireless
licensee’s frequencies should clearly demonstrate that the proposed SCS operations will not interfere with
existing terrestrial in-band and adjacent band services, including by demonstrating compliance with
existing market area boundary limits and OOBE limits.”). As T-Mobile itself has advised in the SCS
proceeding, an SCS applicant “must also be required to establish that it would not cause harmful
interference” and should demonstrate “that its use of the spectrum would be no different than a terrestrial
licensee in an adjacent band or adjacent area.” Comments of T-Mobile USA, Inc., GN Docket No. 23-65,
IB Docket No. 22-271, at 5 (filed May 12, 2023) (“T-Mobile Comments”).
26
T-Mobile Comments at 7.
27
AT&T Comments at 8.

8
deployments. The Commission rightly recognizes that “SCS service options initially may be

more limited than a terrestrial licensee’s core service offerings.” 28 SCS is not a substitute for

terrestrial coverage, and SCS operations that interfere with or replace existing co-channel

terrestrial services would degrade service quality and reliability for American consumers and run

counter to the public interest. 29

Here, the Commission must require the Applicants to show that the proposed SCS

deployments will not harm any of T-Mobile’s existing PCS G Block terrestrial network services.

T-Mobile has indicated that it initially built out and placed into operation “over 35,000 sites

across the country utilizing” the PCS G Block spectrum “as part of its nationwide LTE

Network.” 30 With such widespread deployments, T-Mobile appears likely to face one of three

options: (i) confining SCS coverage to only the unserved portions of its licensed areas; (ii)

tolerating interference and service degradation or interruption in areas covered by its terrestrial

network; or (iii) turning down its terrestrial coverage and permitting SCS as a replacement. The

Applicants have not shown here that they have the capability of confining SCS coverage only to

unserved portions of licensed areas, as in Scenario (i). And either of the latter two outcomes

reduce service quality for U.S. consumers, a result that clearly contravenes the public interest.

Consistent with the FCC’s goal in the SCS proceeding, SCS must supplement, not supplant,

terrestrial service offerings. 31

28
Single Network Future: Supplemental Coverage from Space, Notice of Proposed Rulemaking,
GN Docket No. 23-65, IB Docket No. 22-271, FCC 23-22, ¶ 73 (Mar. 17, 2023) (“SCS NPRM”).
29
AT&T Comments at 8; see also Apple Comments at 8-9 (“SCS is not presently able to ensure the
ubiquitous, seamless, consistently reliable, and fully functional mobile coverage provided by terrestrial
networks in the relevant spectrum bands…”); Verizon Comments at 6 (arguing that SCS should only be
enabled “while retaining high service quality among our nation’s 4G and 5G terrestrial networks”).
30
See, e.g., ULS File No. 0007175779 at Exhibit 1.
31
See T-Mobile Comments at i, 6 (emphasizing the supplementary nature of SCS services).

9
 The Commission should require detailed information about SpaceX’s plans to comply

with Part 24’s (1) frequency stability requirements, (2) field strength limits, and (3) out-of-band

emission (“OOBE”) limitations. 32 At a minimum, the Applicants should be required to provide

predictive modeling demonstrating that its deployments will comply with the technical rules and

not cause any harm to terrestrial systems, including T-Mobile’s network. 33 These showings are

necessary both to protect adjacent licensees and to prevent degradation or displacement of T-

Mobile’s own operations. 34

First, the Commission should require information to ensure that SpaceX will comply

with PCS frequency stability requirements with respect to Doppler shifts. Section 24.235 states

that the PCS transmissions must have frequency stability “sufficient to ensure that

the fundamental emission stays within the authorized frequency block.” 35 SpaceX satellite

transmissions will experience frequency shifts of up to 48 kHz due to Doppler caused by

satellites moving at over 7.5 km/sec. As a result, received transmission on Earth’s surface could

be +/- 48 kHz outside of the G Block band, unless SpaceX transmissions have sufficient guard

band to provide nearly 50 kHz of buffer. Although SpaceX asserts that its satellite transmissions

will experience Doppler and be compensated so that the user equipment will be able to receive

32
Consistent with the SCS NPRM, the Commission should also seek clarification on (1) whether
and how the Applicants will comply with the Commission’s 911 requires; (2) whether and how Wireless
Emergency Alerts will be delivered; (3) whether and how T-Mobile’s roaming partners will have access
to SCS services; and (4) how managed access deployments will be affected and accommodated. See SCS
NPRM ¶¶ 83–91 (911 rules), ¶¶ 92–93 (WEA rules), ¶ 108 (roaming).
33
To the extent that any demonstrations purport to be based on probabilistic analysis, the entire
model, including all assumptions and underlying data, should be put on the record before the Commission
so that the FCC and other parties can review and replicate the analysis. Absent this information, the
veracity of the demonstration cannot be verified.
34
See 47 C.F.R. §§ 24.235, 24.236, 24.238.
35
47 C.F.R. § 24.235.

10
satellite transmissions correctly, 36 it should demonstrate that the Doppler shift will not result in

transmissions outside of the band.

Second, the Commission should require more detailed showings about SpaceX’s

compliance with out-of-band emission (“OOBE”) limits. The OOBE limits defined in section

24.238 37 are provided to protect adjacent band PCS licensees (e.g., PCS C Block and H Block

licensees), assuming the OOBE are transmitted from PCS base stations (“BS”) and mobile

stations (“MS”). Further, the limits are dependent on the on-channel maximum PCS

transmission power level, which will be significantly different for SpaceX satellite transmissions

than terrestrial PCS BS or MS transmissions.

SpaceX stated in its application that its space station transmissions will abide by this

limit, but there should be a demonstration—even if through a static interference link budget

analysis—that shows that the OOBE from SpaceX satellite transmissions will protect adjacent

band services. Even though space stations will be transmitting at distances much greater than

those from BS/MS, these transmissions will usually be unimpeded by terrain, foliage, buildings,

etc., that would dampen a PCS signal. An interference link budget would provide details to help

confirm that the Section 24.238 OOBE limits are sufficient to protect adjacent-band PCS

licensees.

Third, the Commission should require information to demonstrate SpaceX’s compliance

with field strength limits at edge-of-service area at the border with Canada and Mexico—a

showing that SpaceX’s application makes no attempt to substantiate. Unlike transmissions from

fixed base stations, satellite signal levels will be varying continually due to motion of the

36
Technical Narrative at 4.
37
47 C.F.R. § 24.238.

11
satellite, movement of the satellite spot beam, size of the spot beam, variation of signal from

center to edge of the spot beam, and atmospheric and other propagation conditions. As a result,

the satellite transmission signal level on Earth’s surface at the service area boundary will be

continually changing.

This situation raises a whole host of technical questions that SpaceX does not address.

How will SpaceX ensure that the power level will not exceed a given limit, when taking into

account all of the continuously changing variables above? The power level transmitted by a

given beam will need to be adjusted continually as the satellite moves. How does the satellite

know what the instantaneous signal level is at every point along the boundary, at any point in

time? Will there need to be a “buffer” area between a spot beam and the boundary area to ensure

the limit at the boundary area is met? That boundary area will depend on the size of the spot

beam, the elevation angle to the serving satellite, etc. How is all of this determined? SpaceX’s

frequency reuse plan assigned to its beams—which will depend in part on how many users are

being supported in a given region—will also impact compliance. SpaceX must provide a

technical description of how it will manage these issues. In particular, using dynamic

simulations to provide signal levels across various beam sizes as satellites are in motion (and

handing off between each other) would provide greater confidence in any analysis provided here.

IV. CONCLUSION

AT&T supports the Commission continuing a case-by-case waiver approach to SCS

operations. But the application in this proceeding falls far short of the waiver standard and raises

questions that require further technical analysis and clarification. The applications should not be

granted unless and until SpaceX and T-Mobile are able to make the required showings.

12
 Respectfully submitted,

By: Michael P. Goggin

Michael P. Goggin
Jessica B. Lyons
David J. Chorzempa

AT&T SERVICES INC.

May 18, 2023 1120 20th Street, N.W.
Washington, D.C. 20036
(202) 457-2055

13
 AFFIDAVIT OF MICHAEL P. GOGGIN
I, Michael P. Goggin, pursuant to 47 C.F.R. § 25.154(a)(4), hereby declare under penalty
of perjury:
1. I am employed by AT&T Services, Inc. as an Assistant Vice President – Senior
Legal Counsel.
2. I am qualified to speak on behalf of AT&T Services, Inc.
3. I have reviewed the preceding Comments, and the factual statements therein are
complete and accurate to the best of my knowledge, information, and belief.

/s/ Michael P. Goggin

Michael P. Goggin
Assistant Vice President – Senior Legal Counsel
AT&T Services, Inc.

Date: May 18, 2023

 CERTIFICATE OF SERVICE

I, Kim Riddick, certify that, on this 18th of May 2023, I have served a copy of the foregoing

pleading by U.S. Mail upon the following:

William M. Wiltshire David Goldman

HARRIS, WILTSHIRE & GRANNIS LLP Director of Satellite Policy
1919 M Street, N.W. SPACE EXPLORATION TECHNOLOGIES CORP.
Suite 800 1155 F Street, N.W.
Washington, DC 20036 Suite 475
Counsel to SpaceX Washington, DC 20004

Steve B. Sharkey
Vice President, Government Affairs
Technology and Engineering Policy
T-MOBILE USA, INC.
601 Pennsylvania Ave.
Washington, DC 20004

/s/ Kim Riddick

Kim Riddick