So much for the “win-win-win” scenario that Dish Network envisioned for the 12 GHz band. Dish and fellow MVDDS licensee RS Access have argued that the 12 GHz band can be used by both satellite players like SpaceX’s Starlink and by companies like Dish that want to use it for 5G, all for the public’s benefit.
SpaceX on Tuesday submitted its own analysis of the effect of terrestrial mobile deployment on non-geostationary orbit fixed satellite service (NGSO FSS) downlink operations. The upshot: The SpaceX study shows terrestrial mobile service would cause harmful interference to SpaceX’s Starlink terminals in the 12.2-12.7 GHz band more than 77% of the time, resulting in full outages 74% of the time.
Although entities like RS Access note that SpaceX has access to plenty of other spectrum to accomplish its broadband mission, SpaceX insists that the 12 GHz band has become one of the most important and intensely used spectrum bands for Americans who depend on satellite services. In fact, SpaceX said it depends on the 12 GHz band for the workhorse frequencies in critical downlink services to serve Americans “in every corner of the nation.”
In the past, Dish and its allies have pointed out the lack of technical studies submitted by SpaceX and Starlink in the 12 GHz proceeding, where the FCC is studying what to do with the spectrum. So it’s notable that SpaceX conducted its own study, which it says uses the same methodology as a study RKF Engineering Solutions did on behalf of RS Access. However, SpaceX also said the RKF study was “riddled with errors” and faulty assumptions.
SpaceX plugged its own calculations into a study, which uses the same Monte Carlo methodology as RKF while “adjusting some of the most egregious errors,” the company said. SpaceX’s study shows the aforementioned percentage of time that interference from terrestrial mobile service would degrade service to SpaceX’s Starlink terminals operating in the 12 GHz band.
“This analysis verifies what should be intuitive – that a high-power terrestrial network would blow out anyone using the high-sensitivity equipment satellite consumers must use to receive signals that comply with commission and international power restrictions on satellite downlink transmissions,” SpaceX told the commission.
SpaceX also brought up Dish’s recent 5G launch but complained that it “has not yet submitted any information to corroborate” the claim that it has met its initial 5G milestone deployment.
“Even aside from their meritless technical claims, neither Dish nor RS Access can make a case that remotely justifies commission complicity in their attempted spectrum arbitrage,” SpaceX wrote in its June 21 filing. “As has been widely documented, Dish has never lived up to its repeated promises to deploy a new terrestrial networking using the exclusive licenses already stored up in its warehouses – the commission simply cannot gift more spectrum to any operator with this track record of broken promises and stranded consumers. For over a decade, Dish has promised and failed to timely deploy a network using its licenses in the 700 MHz, AWS-4, AWS H Block, AWS-3 and 600 MHz.”
SpaceX would like the FCC to drop the 12 GHz proceeding, but Dish and RS Access have been urging the FCC for years to change the rules so that their MVDDS licenses can be used for two-way 5G services.
In April 2021, the FCC granted a license modification for SpaceX, but it made a point of saying it was conditional on future actions at the commission, “including but not limited to the 12 GHz proceeding,” and therefore “SpaceX proceeds at its own risk” in terms of what it does in the 12 GHz band.
The 5G for 12 GHz Coalition, which is comprised of more than 30 members, including Dish and RS Access, released the following statement Tuesday: “We understand that SpaceX has – after 18 months and both a robust comment and reply period – just filed its own in-house technical submission to the 12 GHz proceeding. Our engineers and technical experts are reviewing the filing in depth and remain committed to working in good faith with the FCC and stakeholders to ensure that the American public is able to reap the immense benefits of 5G services in this band.”