Phased arrays would be useful in the service link for creating the earth-fixed beams in the earth-fixed cell scenario. I would expect pahsed arrays to be used in a NGSO scenario – like the fast moving LEO scenario where electrically steering beams fast to maintain a fixture on the ground would be advantageous. In a GEO scenario, I would expect a tendency towards large aperture sizes, which could also mean mechanically steered antennas. In any case, a large antenna array will also be advantageous when it comes to the UL link-budget.