As SpaceX recently launched a batch of Starlink satellites, its legal team is busy lobbing a new round of ammunition at those seeking to use the 12 GHz band for 5G.
It’s not clear where this latest round starts and ends. In June, SpaceX enlisted the help of Starlink users in a campaign to show the FCC how much the service means to them. The company successfully rallied the troops – judging by the nearly 100,000 or so comments filed on its behalf in the FCC’s comment system.
Last week, SpaceX held meetings with the two Republican FCC commissioners, Brendan Carr and Nathan Simington, as well as members of their staff. That follows meetings Dish Network executives held with the FCC earlier this month.
On Tuesday, SpaceX representatives held a rare call with media to talk about how disastrous it would be if the 12 GHz band were opened up to 5G. Users also were on hand, and SpaceX representatives said they’re optimistic the proceeding will go their way, according to The Verge.
Where it lands is anyone’s guess at this point. The FCC’s Office of Engineering and Technology (OET) is studying the 12 GHz band in what Chairwoman Jessica Rosenworcel earlier this year described as among the most complex proceedings undertaken at the agency.
‘Misleading efforts’
“The commission should listen to this outcry from across the country and reject the misleading efforts by speculators to line their pockets at the expense of the American people,” wrote David Goldman, senior director of Satellite Policy at SpaceX in a July 22 filing with the FCC.
The "speculators" he’s most likely referring to are Dish Network and RS Access, which want the 12 GHz opened up for 5G, and they have more than 35 other entities joining them in the 5G for 12 GHz Coalition, with wireless internet provider Starry being the latest to join.
SpaceX insists the spectrum band is crucial for its Starlink services. Both sides accuse the other of making misleading statements.
On Tuesday, SpaceX fired its latest shot – one that especially sears RS Access and turns its own words against it. SpaceX describes RS Access as “Michael Dell’s private trust fund” and says an RKF study, commissioned by RS Access, shows 5G would cause interference.
“Despite its recent hand waving, even RKF admits that wherever terrestrial service overlaps with SpaceX’s terminals, interference levels will exceed RKF’s own harmful interference threshold,” Goldman wrote. “RKF’s model shows that for terrestrial base stations and satellite receivers operating in proximity to one another, exceedances can be 50 dB or more.”
According to RS Access, the RKF study concluded that at least 99.85% of Starlink terminals would experience no interference in the 12.2-12.7 GHz band.
To be sure, SpaceX has a lot of beefs with RS Access and the study done by RKF is a big one. SpaceX reiterated this week that new terrestrial services introduced into the band would cause harmful interference to receivers used by existing and future non-geostationary satellite orbit (NGSO) customers.
Up on the rooftop
According to SpaceX, RKF makes the “extraordinary assumption that people do not put their satellite dishes on their roofs where they get better reception. RKF assumes that nearly half (45%) of all NGSO antennas will be deployed at ground level, where ‘clutter’ will attenuate the terrestrial signal and thus reduce interference, but the data that SpaceX has collected on its subscribers show that they overwhelmingly deploy their antennas on rooftops to enhance unobstructed access to satellites, just as Dish’s and DirecTV’s customers do,” Goldman wrote.
He also said that Starlink has customers in urban, suburban and rural areas of the country and that RKF assumes that NGSO subscribers will be located almost exclusively outside of densely populated areas. Interestingly, a good share of Starlink comments submitted to the FCC are from people purporting to be in rural or hard-to-reach areas where terrestrial broadband is hard to come by.
RS Access stands behind its earlier analysis.
“We stand behind our work and are confident in the commission’s ability to analyze the technical record. We are committed to our ongoing engagement with the FCC to conclusively demonstrate that unleashing 12 GHz is a win-win for consumers and American 5G leadership,” said V. Noah Campbell, CEO of RS Access, in a statement provided to Fierce.