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'There's Not an In-Between'

SpaceX Rejects Idea of Conditions to Tackle 12 GHz Sharing Concerns

No technical conditions exist that could ameliorate worries about harmful interference expected to come from opening the 12 Ghz band to terrestrial use, SpaceX Satellite Policy Senior Director David Goldman told reporters Tuesday. Satellite operators' already-heavy use of the band means employing highly sensitive receivers and low power levels, and given 5G advocates' suggested high-power mobile service, "there is not an in-between on that," Goldman said.

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Goldman said there has been no suggestion in the docket of any compromise power levels on terrestrial service that could address interference concerns. He said if Dish Network thought such a viable compromise existed, it would have been put forward.

Multichannel video and data distribution service (MVDDS) licensees have already suggested conditions, RS Access CEO Noah Campbell said in an interview. "The science on this already is very clear," he said. He said the commissioned studies by RKF Engineering (see 2205200038) “have very specifically designed technical parameters." Those studies show a full-power 5G mobile service operating at internationally accepted standards, creating "very, very, very limited issues" in two channels of spectrum, he said. That shouldn't be an issue considering SpaceX has access to more than 10,000 MHz elsewhere, he said. He said there is no need for additional coordination with non-geostationary orbit satellite operators, nor have NGSO interests put forward any suggested conditions. "The science on this already is very clear," he said.

If the FCC does opt to open the 12 GHz band, "there is no easy fix" for its fixed satellite service operations, Goldman said. "This isn't a situation where there's a software patch." He said SpaceX was "optimistic" the FCC would opt not to modify the band's usage but didn't have an idea on timing of when the agency might decide.

Those RKF studies show the MVDDS licensees plan to operate in a footprint overlapping with satellite services and to compete for the same customers, SpaceX said in a filing Tuesday to be posted in docket 20-443. That in turn points to the interference being "not a bug in the rule changes they are demanding, but an anticompetitive feature." It said RKF tries to obfuscate that with a variety of unrealistic assumptions, such as that sizable numbers of SpaceX's Starlink dishes will be deployed at ground level, reducing interference, when the vast majority get mounted on roofs.

Goldman's comments came as SpaceX hosted a call with media featuring a variety of Starlink users. Colby Hall, executive director of eastern Kentucky economic development organization Sharing Our Appalachian Region, said a pilot program installing 30 Starlink dishes in Bell County, with a 38% poverty rate, "by all accounts [has] been wildly successful" in bringing telehealth access. He said the group is looking at another pilot in a similarly distressed county in the next four to six weeks.

Dish's 12 GHz plans are a "prime example of crony capitalism" and should be rejected, policy experts said in the docket Tuesday. The signatories included American Consumer Institute CEO Steve Pociask, Americans for Tax Reform President Grover Norquist, China Tech Threat founder Roslyn Layton and Competitive Enterprise Institute Research Fellow Ryan Nabil. The 12 GHz band and other bands suitable for mobile wireless "should not just be given away to any of the incumbent users in that band."