GSOA Response to Ofcom Consultation on D2D in Mobile Spectrum Bands

GSOA broadly agrees with Ofcom’s assessment of the potential business models for Direct-to-Device (D2D) services, particularly the emphasis on partnerships between Mobile Network Operators (MNOs) and satellite operators to deliver seamless connectivity. The wholesale-retail model, where satellite operators provide capacity to MNOs for integration into consumer offerings, is a pragmatic approach that aligns with existing market structures and ensures interoperability. At the same time use of terrestrial MS spectrum for satellite services introduces additional technical complexities and operational risks, which need a careful study while ensuring the protect incumbent services (in band and in adjacent bands).
GSOA agrees with Ofcom that D2D can also be provided in Mobile Satellite Service (MSS) bands, and there is an existing authorisation framework in place for these services.