Space Ref by Keith Cowing 7/26/2022
Letter from SpaceX to FCC: Dell Firm Agrees with SpaceX, OneWeb, and DirecTV on 12 Ghz
The firm paid by Michael Dell’s private trust fund to reach the opposite result, states: “Starlink terminals within the 5G coverage area typically suffered an exceedance”. Attached is a response filed today with the FCC by SpaceX on how—despite its unrealistic and misleading assumptions—the firm paid by Michael Dell’s private trust fund to reach the opposite result, agrees with the three separate studies by SpaceX, OneWeb, and DirecTV filed with the FCC each showing that existing users of the 12 GHz spectrum band will be detrimentally impacted and experience extensive harmful interference if Dish Network’s petition to hoard the 12 GHz spectrum band is granted, and the approximately 100,000 Americans from all 50 states across the country who have submitted letters to the FCC asking them to take action.
July 26, 2022
BY ELECTRONIC FILING
Marlene H. Dortch
Secretary
Federal Communications Commission 45 L Street, N.E.
Washington, DC 20554
Re: WT Docket No. 20-443; GN Docket No. 17-183 Dear Ms. Dortch:
The technical record in this proceeding is now unanimous—high-powered terrestrial operations in the 12.2-12.7 GHz band would effectively eliminate service for Americans that depend on satellite services using the band. This technical conclusion is not even in dispute. Moreover, given the MVDDS licensees’ frequent refrain that they plan to operate in a footprint that overlaps with satellite services and compete for the same customers,1 it seems the harm MVDDS licensees would cause to consumers of satellite services is not a bug in the rule changes they are demanding, but an anticompetitive feature.
“Starlink terminals within the 5G coverage area typically suffered an exceedance.”
The definitive conclusion above does not come from SpaceX or from the dozens of diverse organizations that have opposed MVDDS licensees’ attempt to change the rules to give themselves a windfall. Nor does it come from the nearly one hundred thousand Americans that pleaded with the Commission to protect their broadband service. Rather, that technical conclusion comes from RKF Engineering Solutions, LLC (“RKF”),2 the consultants paid by Michael Dell’s private trust fund to reach the opposite result. 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. 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.3
But while RKF’s clients paid it to mislead the Commission and the public about the harm they intend to cause SpaceX’s customers, the 12 GHz Band is in reality heavily used by many services in addition to SpaceX. In fact, separate studies by OneWeb and DIRECTV show definitively that changing the rules on behalf of Dell’s trust fund and DISH would not just harm
Americans using SpaceX’s services, but would also harm millions of Americans who depend on the 12 GHz Band for competing broadband services and direct-to-consumer satellite television.4 These technical showings have not been disputed.
In rejecting DISH’s initial petition to deny satellite customers services that use the 12 GHz Band, the Commission explicitly stated that it would add new rights to the band only if it could do so “without causing harmful interference to incumbent licensees.”5 Having concluded that a 12 GHz terrestrial system will interfere with satellite services operating in the same area, RKF attempts to pivot to a new question that is at odds with the Commission’s threshold for action— RKF claims that the service areas for the new terrestrial service will somehow be geographically distinct from the already ubiquitous satellite operations.
But this, too, is an easy issue to resolve in favor of existing users of the band. Terrestrial proponents uniformly envision on the record a ubiquitous terrestrial deployment,6 specifically extending to rural areas and other underserved portions of the country where RKF would relegate satellite operators.7 SpaceX is already providing service to hundreds of thousands American customers located in urban, suburban, and rural areas. And DIRECTV has millions of subscribers spread across all areas of the United States. Accordingly, based on this proceeding’s record, the Commission can conclude only that a new terrestrial service and existing satellite services in the 12 GHz band will have substantial overlap, and therefore new terrestrial transmitters will cause harmful interference to receivers used by existing and future satellite customers.
More:
https://spaceref.com/space-commerce/letter-from-spacex-to-fcc-dell-firm-agrees-with-spacex-oneweb-and-directv-on-12-ghz/
