We propose to allow aircraft station licensees to provide airborne commercial mobile services as part of their aircraft station license under Part 87 of the Commission’s rules and seek comment on alternative authorization methodologies. Under any airborne authorization scheme, Airborne Access Systems would be required to manage in-flight mobile use. Mobile communications services controlled by authorized Airborne Access Systems would be permitted across all commercial mobile spectrum bands at altitudes above 3,048 meters (10,000 feet). These authorizations would cover only in-cabin operations. Moreover, any authorization method would require an agreement with separately authorized satellite or air-to-ground backhaul links to transmit mobile data from the aircraft to terrestrial networks.
Part 87 Authorization Methodology Part 87 Aircraft License Modification We propose to revise Part 87 of the Commission’s rules to permit mobile communications services on aircraft as one element of an aircraft station license and seek comment on this proposal, as well as alternative authorization frameworks. Part 87 of the Commission’s rules governs the authorization and use of radio services onboard aircraft, between aircraft, and between air and ground stations for aircraft travelling domestically and U.S. aircraft travelling to international destinations (including international waters).40Unless exempted, airlines must obtain an aircraft station license to cover any radio equipment or services other than certain two-way VHF, radar, or emergency locator services.41 Under certain conditions, two or more aircraft having a common owner or operator may be issued a single fleet license to cover all aircraft stations in a given fleet.42 We seek comment on how this proposal would work with FAA’s established airframe dependent equipment certification procedures.
Authorizing the proposed use in this manner would allow airlines and other commercial aircraft operators to install and operate Airborne Access Systems as part of their existing aircraft station or fleet licenses.43 Aircraft station licensees would be required to file for a modification of their existing aircraft station or fleet licenses on FCC Form 605 to include the newly designated airborne mobile communications authorization.44 To the extent that an aircraft operator does not have an aircraft station license, that aircraft operator would, under this proposal, be required to apply for an aircraft station license in order to operate an Airborne Access System. Licensees would be permitted to contract with third parties to install and operate Airborne Access System aboard licensed aircraft.45 However, aircraft station licensees would retain sole responsibility for ensuring that such equipment is installed and operated in accordance with all applicable rules.
The airborne radio environment is interference-sensitive and must be closely controlled by aircraft station licensees to ensure stable operation of mission critical equipment, the safety of aircraft passengers and crew, and compliance with all applicable rules and regulations. Aircraft station licensees currently manage this unique environment for a wide variety of radio services in accordance with FCC and FAA rules.46 As such, they may be well positioned to ensure that Airborne Access Systems are properly operated and integrated into the existing device ecosystem. Indeed, regardless of the authorization scheme we select, no Airborne Access System could be installed and operated without the permission, supervision, and control of aircraft station licensees.47 In addition, modifying existing aircraft fleet or station licenses to include proposed airborne mobile communications use should not impose significant administrative burdens on applicants or the Commission. Finally, this proposal is roughly analogous to the successful authorization regimes adopted by other administrations in recent years.48
We propose to retain the current licensing assignment methods applicable to Part 87 aircraft station licenses. Although we propose to permit licensees to provide a new service offering, the underlying functions of aircraft station licenses remains the same. Under this proposal, existing aircraft station licensees seeking to provide mobile communications services on aircraft could request a modification of their current authorizations to permit operation of an Airborne Access System, and applicants for new aircraft station authorizations could indicate on their applications their intention to provide mobile communications services on aircraft. We seek comment on whether such license modifications must be placed on public notice for thirty days pursuant to Section 309 of the Communications Act.49 We seek comment on this proposed authorization approach, as well as the alternative authorization mechanisms listed below, and on what changes, if any, may need to be made to the table of allocations to reflect this licensing regime.50
We acknowledge that, with respect to the NCU transmissions and the communications between the picocell and the consumer mobile devices, the Airborne Access System proposed here would operate on spectrum licensed to mobile service providers for terrestrial wireless use. However, we do not propose to modify the existing rights of commercial mobile licensees or otherwise impede their ability to provide mobile services within their license areas. Under our proposal, aircraft operators should be able to offer access to wireless services to the limited confines of the in-cabin environment in a safe and effective manner – and thereby extend broadband service to an otherwise difficult-to-serve market segment – while protecting incumbent terrestrial licensees from harmful interference and without infringing upon incumbents’ existing operations. We seek comment on this proposal, including potential impacts it may have on the existing rights of terrestrial mobile licensees.
Alternative Authorization Methods We also seek comment on alternative authorization methods. For completeness, we describe several alternatives below, although we acknowledge that some of these methods may suffer from deficiencies that make them less desirable in a public interest analysis. We also request comment on other approaches that are not enumerated below. We encourage commenters to provide details on how any authorization regime, including the Part 87 authorization method described above, would work in practice (including the relationship with other licensees or services authorized in the same frequency bands), how it would further the various public interest goals enumerated in this Notice, and its relative costs and benefits.
Non-Exclusive License. One alternative authorization method would establish an Airborne Access System Service pursuant to which applicants could file for non-exclusive licenses to provide airborne mobile services. Eligibility for such licenses would be limited to applicants with appropriate commercial agreements with aircraft operators to operate such systems on specific aircraft. Would such an authorization system provide additional benefits to the public or to aircraft station licensees? Under this alternative authorization scheme, would the airlines retain sufficient control over the in-cabin environment to ensure that services are provided safely and effectively? Are there any additional eligibility conditions that should be required of licensees under this authorization method?
Secondary Markets. Another option would authorize operation of an Airborne Access System pursuant to spectrum lease agreements with mobile wireless service providers. We observe that for any given flight, an aircraft is likely to fly above license areas for many different licensees. Moreover, the licensees implicated will likely vary throughout the course of the flight. The Commission has issued thousands of geographic mobile licenses.51 Would this authorization method be administrable in practice? How would the Commission ensure that a leasing arrangement involves the necessary parties? Would it require the cooperation of every mobile wireless service provider? Would the use of a leasing framework introduce market efficiencies or inefficiencies not present in other authorization models? Under this alternative, how would the Commission determine the boundaries of mobile licenses along a flight path and at various altitudes, especially considering the curvature of the earth?
Auctioned Sky Licenses. Alternately, should the Commission create nationwide or geographic “sky licenses” and allow eligible applicants to bid on these licenses via auction? Would such an authorization system provide unique benefits to the public or to aircraft station licensees? How would the Commission determine the geographic boundaries of such licenses and the proper number of licensees for each geographic area? How would such a licensing construct affect the ability of airlines to manage their in-cabin environment? Would such an authorization method create “artificial” limitations on market-based agreements between airlines and Airborne Access System providers?
Unlicensed Use or License-by-Rule. Should the Commission authorize unlicensed use of an Airborne Access System pursuant to our Part 15 rules? Alternatively, would a license-by-rule approach be appropriate? Both methods appear, on first consideration, to raise significant issues with respect to providing airlines sufficient ability to manage mobile access in flight and to mitigate potential harmful interference into terrestrial networks. Do commenters agree? How would such authorization mechanisms work in practice? Would they require revisions to existing rule parts? Would these methodologies offer appropriate Commission oversight of the mobile communications services being proposed?
Commenters that advocate an alternative authorization methodology should support their arguments with detailed technical and legal analyses. Commenters should also address how the issues raised in Sections III.C.2. and 3. below would apply for any alternative authorization scheme.
Scope of the Authorization
To facilitate the widespread use of airborne mobile data services, we propose to authorize aircraft station licensees to operate Airborne Access Systems that encompass all domestic commercial mobile spectrum bands. Most broadband capable mobile devices are capable of accessing multiple commercial mobile spectrum bands which vary by device and mobile service provider. We tentatively conclude that permitting Airborne Access Systems to operate across all such bands would provide greater access to broadband data for the travelling public, and is consistent with the Commission’s longstanding policy of technological neutrality. However, our proposal does not require a compliant Airborne Access System to cover all commercial mobile spectrum bands or wireless technologies.52 We seek comments on our proposal to not require Airborne Access Systems to cover all commercial mobile spectrum bands, including on whether this approach may increase the risk of harmful interference to terrestrial networks.
We further propose that airborne commercial broadband operations be permitted only at altitudes exceeding 3,048 meters (10,000 feet). The available research suggests that, at those altitudes, there is little to no risk of harmful interference into terrestrial mobile networks from properly managed airborne mobile operations.53 Moreover, this service floor is consistent with the rules established by the EU for airborne GSM mobile use.54 As noted above, we are unaware of any instances of harmful interference from properly managed airborne mobile broadband operations at altitudes above 3,048 meters (10,000 feet) into terrestrial mobile networks. We seek comment on whether the 3,048 meter (10,000 feet) service floor is appropriate for all mobile technologies (e.g., CDMA, GSM,and LTE) and spectrum bands. We also seek comment as to whether we should allow Airborne Access Systems to remain operational below 3,048 meters (10,000 feet), even if mobile communications services are not permitted at that altitude. Could low altitude Airborne Access System use actually help mitigate harmful interference by preventing activated mobile devices from attempting to access terrestrial networks? We encourage commenters to support their arguments with detailed technical studies and analyses for domestic commercial mobile spectrum bands and technologies, including detailed analyses of the costs and benefits of any such proposals.
We tentatively conclude that, if adopted, our proposal to permit the provision of mobile communications services on aircraft-by-aircraft station licensees at altitudes above 3,048 meters (10,000 feet) would promote the public interest by expanding mobile broadband coverage to consumers in an efficient, non-interfering manner. The deployment of Airborne Access Systems aboard commercial aircraft could provide significant public benefits without harming existing terrestrial licensees in the band. Moreover, terrestrial mobile licensees could benefit from this new commercial service offering if they choose to partner with aircraft station licensees on commercial connection agreements. We seek comment on these proposals and conclusions as well as viable alternative models. Commenters should provide detailed legal and technical analyses in support of their proposals, including detailed analyses of the costs and benefits of any such proposals.
Other Authorization and Licensing Issues
Regulatory Status. While aircraft stations authorized under Part 87 are typically considered private mobile radio services,55 we propose to allow aircraft station licensees choosing to offer mobile communications services using an Airborne Access System to specify their regulatory status depending on the service they are providing. The Commission’s current radio service license application requires an applicant for mobile services to identify the regulatory status of the service(s) it intends to provide because service offerings may bear on the applicant’s eligibility to be a licensee, and other statutory and regulatory requirements.56 In applying that model, an applicant is permitted to choose among several regulatory classifications (e.g.,common carrier, non-common carrier, or private, internal communications), or a combination thereof, and prospective airborne mobile licensees may benefit from a similar approach.57 We seek comment on the merits of applying a similar licensing approach to the provision of mobile communications services on aircraft and ask that commenters discuss the costs and benefits of this approach. We also seek comment on whether there are any obligations under a particular classification that should not apply to mobile communications services on aircraft. For example, should an aircraft station licensee that elects a common carrier regulatory status be required to comply with all rules applicable to CMRS licensees under Part 20 of the Commission’s rules given the limited scope of the in-cabin service offering?58
If the Commission permits an aircraft station licensee to choose its regulatory status in this manner, we propose that such licensees must identify their regulatory status on the FCC Form 605.59 We also propose that if a licensee changes the service it offers such that it would be inconsistent with its regulatory status, the licensee must notify the Commission.60 Further, we propose that licensees must file the notice within 30 days of a change made without the need for prior Commission approval. We seek comment on whether a different time period should apply where the change results in the discontinuance, reduction, or impairment of the existing service.61 We seek comment on alternative proposals regarding changes to the regulatory status of a mobile communications services on aircraft provider and the costs and benefits of such proposals.
Given our proposal to allow an aircraft station licensee to choose its regulatory status, we note that all Commission licensees are subject to the provisions of section 310 of the Act.62 Section 310 requires the Commission to review foreign investment in radio station licenses and imposes specific restrictions on who may hold certain types of radio licenses.63 Specifically, section 310(a) of the Act expressly prohibits a foreign government or its representative from holding any radio license.64 Further, section 310(b) places additional restrictions on who can hold a broadcast, common carrier, aeronautical en route and aeronautical fixed radio station license.65 In particular, the foreign ownership restrictions in sections 310(b)(3) and (b)(4)66 may be implicated for those airlines that have foreign ownership – whether governmental or non-governmental – where the airline provider seeks authorization to provide a common carrier service under the rules adopted in this proceeding.67 We therefore tentatively conclude that we should revise FCC Form 605 to require all applicants to answer foreign ownership questions to ensure compliance with section 310. We seek comment on this tentative conclusion.
Connection with Terrestrial Networks. The rules governing connection with terrestrial networks would vary depending on the regulatory classification selected by a given aircraft station licensee. Aircraft station licensees that choose to register as CMRS providers would be subject to applicable Part 20 and common carrier obligations.68 The requirements applicable to a regulatory classification would govern the rights and obligations of licensees’ connections to terrestrial networks. All licensees would be permitted to enter into commercial agreements with terrestrial mobile licensees for connection to their terrestrial wireless networks. We seek comment on the costs and benefits of this approach and any other approaches that may be used to connect mobile communications services on aircraft with terrestrial networks.
Handset Authorization. Section 301 of the Communications Act requires a valid FCC license to operate a radio frequency transmitter, including a wireless handset, aircard, or other mobile broadband device.69 This statutory requirement is reflected in the Commission’s rules, which require either an FCC license or licensee consent to operate a station in the Wireless Radio Services.70 Our proposal grants aircraft station licensees authorization to operate Airborne Access Systems on commercial mobile spectrum bands. As the definition of Wireless Radio Services includes services provided pursuant to Part 87 of the Commission’s rules,71 we conclude that, for purposes of airborne mobile communications services operations, wireless devices can be operated as subscriber equipment under the aircraft station license, consistent with the proposed rules set forth in Appendix A. We seek comment on this tentative conclusion.
Section 333. Section 333 of the Communications Act states that “[n]o person shall willfully or maliciously interfere with or cause interference to any radio communications of any station licensed or authorized by or under this Act….”72 The proposed Airborne Access Systems likely will operate by maintaining transmissions from mobile devices operating on commercial mobile spectrum bands at or near their lowest power level, thereby preventing these devices from attempting to access terrestrial base stations.73 We tentatively conclude that, pursuant to section 1.903 of the Commission’s rules, mobile units would be deemed to be authorized and operated under the aircraft station license. Accordingly, we tentatively conclude that operation of an Airborne Access System to prevent mobile transmissions from affecting terrestrial base stations constitutes a proper network management function and is not the willful or malicious interference at issue in Section 333. We seek comment on these tentative conclusions.
Federal Spectrum. Most of the Airborne Access Systems currently authorized by foreign countries operate, at least partially, in the 1800 MHz band, consistent with international commercial allocation of this band.74 It is conceivable that U.S.-registered aircraft that wish to offer airborne mobile communications services will choose Airborne Access Systems with the technical ability to operate in that band, particularly those aircraft that operate internationally. Included in this band are the frequencies 1755-1850 MHz, which in the United States currently is allocated on an exclusive basis to the United States federal government for fixed and mobile services, including airborne systems.75 We therefore propose requiring airlines (whether U.S.-registered or registered by another administration) operating an Airborne Access System in the 1755-1850 MHz frequency band to turn off the Airborne Access System or otherwise disengage transmission in this band prior to reaching U.S. airspace.76 We seek comment on this proposal, including potential in-flight enforcement issues. We also note that the Commission has proposed to make the 1755-1780 MHz band available for shared federal and non-federal use.77We seek comment on what, if any, impact such shared operations could have on the proposals set forth in this Notice. In addition, we note that other bands are subject to operational limitations that could affect their availability for airborne commercial mobile operations.78 We seek comment on what, if any, impact such operational limitations could have on the proposals set forth in this Notice. Given our proposal to prohibit operations on Federal frequencies, we invite comment as to whether it would be technologically feasible for systems designed for international flights to switch to authorized non-federal frequency bands in United States airspace.
Applicability to Non-U.S.-Registered Aircraft Operating in U.S. Airspace
Non-U.S.-registered aircraft with Airborne Access Systems currently turn off airborne mobile communications services before entering U.S. airspace.79 We seek comment on whether it is in the public interest to allow aircraft authorized by a foreign government to provide mobile communications services to continue operating its Airborne Access System within U.S. airspace and thereby provide uninterrupted airborne mobile communications services to its passengers.
We also seek comment on the appropriate regulatory framework for the operation of Airborne Access Systems on non-U.S.-registered aircraft within U.S. territory. The ability of a foreign entity to use spectrum or operate radio equipment within the United States stems from rights derived from international agreements, or from direct authorization from the United States. Accordingly, in determining how such use may be permitted, we must take several factors into consideration, including the applicability of international agreements to which we are a party.
The United States is a signatory to the Convention on International Civil Aviation (Chicago Convention), which provides a mechanism for recognizing foreign licenses.80 Under the Chicago Convention, aircraft registered to a member country may use radio transmitter equipment over another country’s territory provided that the transmitter is licensed by the country that registered the aircraft and that said use is in compliance with the regulations of the country over which the aircraft is flying.81 The Chicago Convention also provides that licenses issued by member nations must be equal to or above the minimum standards adopted by the International Civil Aviation Organization (ICAO).82 As we interpret the Chicago Convention, foreign-registered aircraft do not currently have authority to operate an Airborne Access System within U.S. airspace as such use is not currently permitted under the Commission’s rules.
Further, to the extent the Commission adopts rules to permit mobile communications services on aircraft, a non-U.S.-registered carrier may operate an Airborne Access System that complies with such rules. Moreover, we are not aware that ICAO has adopted or intends to adopt standards and recommended practices for the operation of Airborne Access System pursuant to the Chicago Convention.83 We therefore tentatively conclude that the Chicago Convention is not an independent source of authorization for foreign airlines to operate an Airborne Access System within U.S. airspace. It also does not appear that other agreements offer a means by which the United States may recognize the authority of a foreign-registered aircraft to operate an Airborne Access System. We also are not aware of any bilateral agreements between the United States and any other administrations that would serve as a mechanism for allowing foreign-registered aircraft to operate an Airborne Access System over U.S. airspace.
In light of these considerations, we tentatively conclude that current agreements do not provide non-U.S.-registered carriers independent authorization to operate Airborne Access Systems in U.S. airspace. We seek comment on these tentative conclusions. Commenters believing otherwise should identify the applicable agreement(s) and legal authority under which we may permit such operation. We also request comment on any other mechanisms that might allow for recognition of an Airborne Access System authorization issued by another administration.
Assuming that there are no international agreements permitting foreign-registered aircraft to operate an Airborne Access System within U.S. airspace, we seek comment as to whether the Commission should directly authorize such use on the same terms that would apply to Airborne Access System operation onboard domestic aircraft. Specifically, operators of foreign-registered aircraft would be permitted to apply for an aircraft station license under Part 87 for the purpose of providing access to airborne mobile communications services to passengers while within U.S. airspace.84 We seek comment on this proposal, as well as on any alternative licensing approaches. Commenters should discuss the costs and benefits of this or any alternative proposal. We note that applications for such authorizations would be subject to the foreign ownership provisions of sections 310(a) and (b) of the Act, just as they apply to operators of U.S.-registered aircraft.85
Service below 3,048 meters (10,000 feet)
As noted previously, the proposed 3,048 meter (10,000 feet) altitude floor for airborne mobile communications services would minimize the risk of harmful interference with terrestrial networks and is consistent with FAA regulations and international practices. However, there may be circumstances where mobile communications services on aircraft operating below 3,048 meters (10,000 feet) would be in the public interest and would not cause harmful interference. We seek comment as to whether there are circumstances in which mobile communications services on aircraft would not raise the concerns set forth above (e.g.,in low flying, slow moving aircraft) and whether the 3,048 meter (10,000 feet) altitude limit and/or Airborne Access System requirement would be necessary in such cases. For instance, certain providers of critical public services routinely operate aircraft at altitudes below 3,048 meters (10,000 feet) and may have a need for mobile communications services at these altitudes. These operators include medical evacuation, police departments, news organizations, and public safety entities. Could these use cases be accommodated within the proposed rules? What would the appropriate regulatory and technical parameters be for the use of mobile communications services on aircraft by these and other, similarly situated entities?
While we propose to authorize service only above 3,048 meters (10,000 feet) for all commercial aircraft, we also seek comment generally on the technical viability, safety, and legality of mobile communications services on aircraft below 3,048 meters (10,000 feet) (or other reasonable altitude limit adopted in this proceeding) for specific purposes on certain types of aircraft. Would operations below 3,048 meters (10,000 feet) be technically viable? Should Airborne Access Systems be permitted to remain in operation at altitudes below 3,048 meters (10,000 feet)? Would such low altitude operations help to mitigate the potential for harmful interference from mobile devices into terrestrial mobile networks? If allowed, would such operations require the permission of terrestrial CMRS licensees? We emphasize that nothing in this proposal should be read to contradict the FAA’s authority to determine the proper conditions for operation of PEDs on aircraft.
Voice Service Onboard Aircraft
In response to the 2004 Airborne Mobile NPRM, commenters raised concerns regarding the use of voice services on airborne aircraft.86 We note that airborne voice service, e.g.,800 MHz Air-Ground Radiotelephone Service, has been available on many airlines for years, although we understand that voice service has been little-used. At the time of the Airborne Mobile NPRM proceeding, commercial wireless was primarily a voice service. Today, commercial mobile services are used much more heavily for data services and Internet access. We appreciate that some people and organizations may continue to have concerns about permitting voice services on aircraft. We also note that international airlines offering airborne mobile voice and data services have not experienced significant problems related to voice.87 Yet, consistent with our review of our technical rules and commitment to technological neutrality, our proposal would create an avenue through which airlines may choose to offer consumers an additional way to access mobile broadband services while in flight.
To be clear, nothing in this proposal would require or ensure the provision of voice service on airplanes. Individual airlines would determine whether this option would, in fact, be available to their passengers. The airlines themselves would be free to choose and manage the types of in-flight data and voice services they provide, subject to applicable FAA and DoT rules or guidelines with respect to safety and etiquette. These considerations notwithstanding, however, we seek comment on whether it is appropriate for the Commission to take concerns regarding the use of voice service into account in this proceeding. Specifically, we seek comment on the operational impacts that may stem from the provision of voice service, and whether the Commission has any role in addressing such effects. We also recognize that the provision of wireless services, including, but not limited to, voice onboard aircraft may require consumer education to ensure that consumers are aware of what FCC rules do and do not permit. We seek comment on the ways that the Commission can help consumers understand our current rules and any rules that the Commission may ultimately adopt in this proceeding.
Agreements with Canada and Mexico
We conclude that any Airborne Access System rules we adopt in this proceeding would limit such operations to U.S. airspace and would require such operations to comply with current and future international agreements with Mexico and Canada. Until such time as any agreements between the United States, Mexico and/or Canada can be agreed to for the proposed airborne mobile communications service, any operations conducted pursuant to rules adopted in this proceeding must not cause harmful interference across the border, and must operate consistent with the terms of the international agreements currently in force. We also note that it may be necessary to modify any rules adopted in this proceeding to codify future agreements with Canada and Mexico regarding the aeronautical use of these bands. We seek comment on these conclusions.
Law Enforcement and Public Safety
While this Notice focuses primarily on the technical parameters and licensing mechanisms by which we may allow airlines to offer mobile wireless services on aircraft, we recognize that our proposals may also raise public safety, law enforcement and national security concerns. We note that wireless service providers are currently obligated to provide assistance to law enforcement agencies with respect to the Communications Assistance for Law Enforcement Act (CALEA).88 Specifically, Congress enacted CALEA in 1994 in order to preserve the ability of law enforcement agencies to conduct electronic surveillance by requiring that telecommunications carriers and manufacturers of telecommunications equipment modify and design their equipment, facilities, and services to ensure that they have necessary surveillance capabilities.89 In addition to telecommunications carriers identified in CALEA and its legislative history,90 the Commission has concluded that facilities-based broadband Internet access providers and providers of interconnected Voice over Internet Protocol (VoIP) service would also be deemed to be “telecommunications carriers” for purposes of applying CALEA.91 Accordingly, we propose that any mobile wireless services offered by Airborne Access System operators would be subject to the provisions of CALEA, regardless of whether such offerings are voice or data services.
Beyond satisfying CALEA obligations, satellite providers,92 ESAA operators,93 as well as 800 MHz Air-Ground licensees94 address specific public safety, law enforcement, and national security concerns through individual negotiations with law enforcement agencies. We anticipate that an entity seeking to provide mobile wireless services through the use of an Airborne Access System would follow the established process and work diligently with law enforcement agencies to address any public safety, law enforcement, and national security concerns through individual negotiations and agreements.
We seek comment on whether there are additional measures that the Commission should take to address in-flight safety and security concerns beyond CALEA obligations and individual agreements among service providers and law enforcement agencies. While we again emphasize that issues of onboard security and safety of flight are matters primarily reserved for the FAA, DoT, and the airlines, there may be measures within our regulatory purview that can be taken to further the Commission’s interests in preserving and promoting public safety and homeland security. We therefore request that commenters identify specific public safety, law enforcement and national security-related concerns that may stem from the Commission’s proposals, and the steps that the Commission could take to address those concerns.