RS Access, one of the firms that holds 12 GHz licenses alongside Dish Network, is behind a new analysis that accuses SpaceX of using erroneous data in its evaluation of how satellite companies can use the adjacent 10.7-11.7 GHz band.
SpaceX and OneWeb are considered non-geostationary orbit fixed satellite service (NGSO FSS) operators, and they contend the 10.7-11.7 GHz band is too encumbered with other users for them to use it for their satellite services. They want to be able to use the 12.2-12.7 GHz band without having to deal with the likes of Dish and/or RS Access.
The problem for the satellite players is Dish and RS Access want to use the 12 GHz band for 5G; entities in their camp include the 5G for 12 GHz Coalition. The 5G for 12 GHz Coalition includes more than 30 members, including Dish, Public Knowledge, Federated Wireless, Airspan, Altiostar, Dell Technologies, Rise Broadband, VMware and the Rural Wireless Association.
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New filing
“SpaceX and other NGSO FSS operators have made unfounded claims about the extent and effect of FS [fixed satellite] and RAS [radio astronomy service] encumbrances on NGSO FSS systems in the 10.7-11.7 GHz band. The claims cannot withstand scrutiny. RKF’s analysis shows that FS sites are far fewer, far less consequential, and much more readily accommodated than SpaceX and its allies now claim,” said David Marshack, managing director and COO at RKF Engineering Solutions, in a letter to the FCC filed Thursday.
One of the claims from SpaceX is the FCC’s database shows more than 880,000 FS links in the 10.7-11.7 GHz band, which would make it extremely crowded. But RKF’s assessment revealed only 69,000 FS call signs authorized to operate in the 10.7-11.7 GHz band.
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“Nothing in the FCC’s publicly available ULS database comes close to supporting SpaceX’s claim that there are 880,000 such paths,” Marshack told the commission. In short, “nothing about the unfounded speculation SpaceX and its allies have injected into the record disturbs the Commission’s well-established conclusion that RAS, RS, and NGSO FSS operations can successfully coexist below 12.2 GHz.”
Under old rules for what’s known as MVDDS uses, Dish holds the lion’s share of 12 GHz licenses in a section of the band that Dish would like to use for 5G deployments. RS Access, which is tied to Dell Technologies founder Michael Dell, is the second largest holder of this spectrum and has been an ally with Dish on this endeavor.
Both are at odds with satellite companies like SpaceX that want the spectrum for deployments of their own. SpaceX, for example, consistently refers to StarLink’s mission to serve underserved Americans with broadband; it accuses Dish and other MVDDS licensees of poor spectrum stewardship.
So far, the issues have been argued before the Federal Communications Commission (FCC) through its comment filing system; the FCC has yet to consider a 12 GHz band proposal in a formal meeting or vote. But as FCC Chairwoman Jessica Rosenworcel was just confirmed by the Senate this past week, the 12 GHz backers are eager for a resolution sooner rather than later.
SpaceX disses Dish
In an October filing, SpaceX accused Dish of “picking fights” with satellite operators so that it can “upset the carefully crafted balance” the commission has struck for the shared 12.2-12.7 GHz band and get exclusive licenses for free to add to its “vast warehouses” of unused spectrum. In the filing, SpaceX referred to an “Astroturf coalition” and Dish’s “highly paid political spokesmen.”
Asked about the accusations at the time, Public Knowledge (PK) Senior VP Harold Feld said Dish sponsors their annual IP3 event, as do companies such as Microsoft, that oppose Dish and support SpaceX in this proceeding. PK also has processes in place to safeguard the independence of its advocacy, he noted.
“We continue to believe that this band presents the opportunity to expand unlicensed and opportunistic sharing and enhance competition in mobile broadband by enhancing Dish’s spectrum holdings for 5G deployment without interfering with SpaceX broadband,” he said, reiterating that any changes to the rules must not cause harmful interference to SpaceX’s terrestrial operations.
The main thing is for the FCC to act in a manner that moves it closer to expanding access to the band, he said, adding that his group favors the commission adopting an order permitting an unlicensed underlay using the same rules adopted for the 6 GHz band last year, with low power indoor use only throughout the band and higher power outdoor use using a database to avoid interfering with SpaceX’s customers. “Neither SpaceX nor any other opponent in this proceeding has submitted engineering evidence to explain why the rules adopted for the 6 GHz band would not adequately protect incumbent operations in the 12 GHz band,” Feld said.
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If the 12 GHz rules were changed so that it can be used for 5G, that could open up more mid-band spectrum opportunities for incumbent U.S. wireless carriers. T-Mobile, for one, has argued for an auction to occur if the 12 GHz band were to be opened up for terrestrial 5G use. Dish and RS Access oppose a new auction, saying the spectrum already was auctioned.
In a recent interview, RS Access CES and co-founder V. Noah Campbell declined to comment on how RS Access might use the spectrum if it were deemed 5G ready. But he’s eager for the FCC to determine how the rules should be updated.
“We’re encouraged by having a permanent chair and we think that Chairwoman Rosenworcel is very interested in bringing spectrum to terrestrial 5G applications,” he told Fierce. “Spectrum is finite,” and with other bands being occupied by federal users, “I think this is a very unique band and it’s a huge opportunity to add a lot of capacity to the U.S. 5G ecosystem.”