ECiiilS1AR HUGHES~ February 21, 2020

Via E-Mail_and Mail Mr. Adam Lusin Director, Office of International Communications and Information Policy Bureau of Economic and Business Affairs 2201 C Street, NW, Room 4634 Washington, DC 20520 LusinaAW@state.gov and ITAC@state.gov

Subject: Comments of EchoStar/Hughes on US Proposals and Positions for the U.S. Delegation to the 2020 World Telecommunication Standardization Assembly

Dear Mr. Lusin:

Echostar Satellite Systems, LLC (Echostar) and Hughes Network Services, LLC (Hughes) (collectively, Echostar/Hughes) hereby submits its comments in response to the above referenced proceeding.1 The 2020 World Telecommunications Standardization Assembly (WTSA) is an important conference that defines the ongoing work of the International Telecommunications Union Telecommunications Standardization Sector (ITU·T) on the development of telecommunications standards. EchoStar/Hughes has serious concerns about the scope of the ITU·T expanding to address new technologies and issues that are not clearly within its mandate, such as artificial intelligence. Such technologies are more appropriately addressed by other expert bodies Instead, Echostar/Hughes urges the U.S. delegation to work within WTSA to ensure that the ITU·T prioritizes the development of technical recommendations (standards) limited to interconnection and interoperability of international telecommunications networks. We also urge the U.S. delegation to focus on improving ITU·T processes and procedures including transparency.

Background

Echostar/Hughes' U.S. parent company, Echostar Corporation, is a significant global satellite service provider and technology company. Hughes is the largest U.S. satellite broadband operator, with more than 1.4 million customers in North America, one of the world's largest satellite networks, and a substantial US manufacturing presence with a 50% market share in satellite earth station terminals. With the launch of JUPITER 3, Hughes is poised to play an important role in bringing SG to users wherever they are, including rural areas. Echostar is a leading Fixed and Mobile Satellite Services (FSS and MSS) provider developing a global mobile satellite services network to provide 5G, loT, and other new services.

EchoStar/Hughes has a long history of research and development and is taking a leadership role in developing new technologies and bringing them to market. Echostar/Hughes is an active member of all three sectors of the ITU and believe the ITU has a critical role to play in areas such as spectrum management, spectrum development, and telecommunications standards development. However, Echostar/Hughes has concerns about the ITU·T expanding its mandate to develop standards for new technologies that appear to be beyond the scope of its mandate, as they may instead hinder the development of these nascent technologies. Instead, Echostar/Hughes urges the U.S. State Department and the U.S. delegation to refrain from expanding its reach to these technologies unless a reason is given to interfere, the role of the ITU·T is clearly defined, and there is a clear mandate from the ITU 's Member States supporting such action.

185 FR 6526 {Feb. 4, 2020).

EchoStar Corporation

100 Inverness Terrace East• Englewood, CO 80112 • Tel 303.706.4000

mailto:ITAC@state.govmailto:LusinaAW@state.gov

Mr. Adam Lusin February 21, 2020

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Discussion

What overarching vision, objectives and priorities do you believe the U.S. delegation should adopt for WTSA-20 and for U.S. ongoing engagement in the ITU-T? What is the best way for the U.S. delegation to advance and ultimately achieve these objectives and priorities?

The U.S. State Department and the U.S. delegation to WTSA should support the work of the ITU-Ton the development of telecommunications standards on interoperability and interconnection of international telecommunications networks. Recently the ITU-T has begun to expand its reach into other areas, such as artificial intelligence and quantum communications, largely under the guise of providing a forum for discussion through focus groups. The ITU-T and the ITU lack the expertise to act regarding standards for these technologies and may, if they choose to take more active jurisdiction over the development these technologies, impede innovation in these very important areas. Instead, the ITU-T should prioritize development of technical recommendations (standards) limited to interconnection and interoperability of telecommunications networks.

To enable the development of new technologies. it is important that the U.S. delegation work within WTSA to limit further mission creep of the ITU-Tinto areas of new technologies, such as optical communications, quantum communications and artificial intelligence, and beyond. Convening educational •arums, as the ITU-T currently is doing, is an appropriate role of the ITU-T in these areas. but the ITU-T should not stray farther without Member support and should keep its tocus on the important mandate of developing standards limited to interconnection and interoperability of internalional telecommunications networks.

In what areas or subjects do you believe the ITU-T has a role or expertise? What, if any, is the appropriate role for the ITU-Tin developing standards in areas of emerging technologies? How do ITU standards and related standards development activities influence or affect U.S. industry interests in the global digital economy?

T he ITU-T has a clear, delineated expertise In telecommunications that may be exercised ,n international standard setting.2 Areas like setting accounting, tariff principles, interconnection, and roaming for telecommunications systems are appropriate areas of focus of the ITU-T. However, as we saw with past efforts of the ITU-T sector, it is imperative that ITU-T not continue to expand its reach to new technorogies that are best addressed through other bodies. Hosting forums that educate ITU members on such new technologies is an appropriate use of ITU resources.

What are your recommendations for how the ITU-T can best address the needs of developing countries regarding international standards development? Would ITU programs related to development and capacity building be better placed within the ITU Development Sector (/TU-D) or the ITU-T? How might the ITU address regional or developing country needs within its work or in its engagement with other SD0s?

Education and outreach are key areas to ensure that develop,ng countries can engage with and benefit from the ITU-T's work on international standards development. Improving transparency in the ITU's processes and procedures improves the quaUty of engagement and makes the ITU a more inviting and accessible forum for those companies and administrations with less history working with the ITU, which are particularly concentrated the developing world. The ITU-T and ffU-0 have been successful in thek outreach to the developing world, especially through regional meetings and seminars, such as ITU World Telecommunications.

2 The ITU-Tis to "fulfil the purposes of I.he Union relating to telecommunication standa1dizalion" ITU Constitution, Art. 17, Collection of the basic texts of the International Telecommunication Union adopted by the Plenipotentiary Conference,(ITU, 2019)

Mr. Adam Lusln February 21, 2020

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To build on this success, and, recognizing the very limited resources to which some Member States and members (especially in the developing world) have access, it is important that the ITU·T and ITU-0 enable greater access to events and training through remote access. Working together, transparently, as the sectors have done, and enabling greater in-person and remote participation will continue to expand the ability of countries to meet the United Nations Sustainability Goals.3

(~~~ - if~~ A. Manner Senior Vice President, Regulatory Affairs EchoStar/Hughes 11717 Exploration Lane, Germantown, MD 20876, United States (301 ) 428-5893 Jennifer.manner@echostar.com

3 The ITU's Secretary General "affirm[s] its role as a key partner fn development, collaborating with sister United Nations agencies and others to leverage technology to accelerate progress towards the Sustainable Development Goals." Collection of the basic texts of the International Telecommunication Union adopted by the Plenipotentiary Conference, at iv (2019).

The Sustainable Development Goals are contained in United Nations General Assembly Resolution 70/1; https://sustainabledevelopment.un.org/content/documents/21252030%20Agenda%20for%205ustainable%20Dev elopment%20web.pdf

https://sustainabledevelopment.un.org/content/documents/21252030%20Agenda%20for%205ustainable%20Devmailto:Jennifer.manner@echostar.com