Dish, which earlier this year completed an acquisition of bankrupt satellite mobile operator TerreStar, asked the FCC to transfer TerreStar's frequency licenses to a Dish subsidiary and to allow Dish to use the spectrum to build a broadband wireless network that it could then use to offer standalone cellular services.

Combined with spectrum Dish acquired in a separate deal to buy DBSD North America, the satellite provider wants to build a network using LTE, the technology of choice for most of the nationwide mobile phone operators, it wrote.

But it needs special permission from the FCC to offer standalone cellular service--as opposed to a service that is integrated with satellite service--and says it is crucial that it be allowed to do so.

"The requirement to make every device dual-mode severely limits a provider's ability to enter into arrangements with multiple device and equipment manufacturers, thereby limiting consumer choice and severely impairing the business case economics," Dish wrote.

The company also argued that customers want the choice of a smaller, lighter device with long battery life. Adding satellite capabilities to devices makes them heavier and reduces battery life. "Today, a mobile voice and data provider's ability to attract customers depends in large measure on its ability to provide its customers with the types of devices that best suit their needs," it wrote.