DISH Wants Starlink To Cease Operations In Case Of Unfavorable FCC Decisions

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In its latest filing with the Federal Communications Commission (FCC), DISH Corporation has laid down a set of conditions which it believes that the regulatory body should add to SpaceX's authorization for operating the latter's Starlink satellite-based internet service. The company's comments follow an earlier analysis submitted to the FCC in March, when it presented a study conducted by a third-party consultant to prove to the Commission that Starlink would create network interference with DISH's user equipment. Both the Starlink terminals and DISH's equipment use the 12GHz band to communicate with satellites. SpaceX has previously stated to the FCC that it will operate its equipment using parameters that will not create interference.

DISH Asks FCC To Modify SpaceX's Starlink License To Reflect Third-Party Study, Future Rules

The company's comments were filed with the FCC on Tuesday, and they are concerned with several petitions currently pending with the body. These include a request by the FCC made to companies using the 12GHz band to submit their suggestions for new rules governing the spectrum. They also include a petition by SpaceX under the umbrella of Starlink Services LLC to grant it the status of a telecommunications carrier, and a petition to authorize SpaceX to operate user terminals onboard ships and other vehicles.

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DISH believes that since SpaceX has not officially replied to its updated third-party analysis, which uses implied real-world scenarios to demonstrate that SpaceX would violate certain Starlink operating parameters that it has submitted to the FCC, the budding telecommunications carrier should be required to make bonafide commitments to DISH in the form of codified updates to SpaceX's current authorizations from the FCC.

The company's argument against Starlink revolves around the number of co-frequency satellite beams that SpaceX will use to cover geographical units. SpaceX has highlighted to the FCC that it plans to use a single beam per area. DISH's third-party analyst believes that using a single beam is unrealistic - and in his latest study, he has highlighted that even if SpaceX uses a single beam, it might cause interference to DISH's systems.

In its latest filings with the FCC, DISH states that it has used real-world parameters instead of the ones provided by SpaceX to the FCC to show that Starlink would create interference with DISH terminals despite a Nco of 1. Image: DISH Exparte Filing on March 18, 2021 in FCC dockets IBFS File No. SAT-MOD20200417-00037; Expanding Flexible Use of the 12.2-12.7 GHz Band, WT Docket No. 20-443

Specifically, DISH wants the FCC to add two new conditions to SpaceX's license. The company believes that when it comes to the chances that Starlink might create interference with DISH terminals, the FCC cannot "afford to get this wrong, and at a minimum should preserve the ability to intervene and order immediate cessation of SpaceX’s operations if violations occur."

As a result, DISH believes that the FCC should modify the license by requiring SpaceX to use only one satellite beam per frequency, modify its operations to protect DISH customers should the FCC decide to change its interference calculation criteria and provide more proprietary information to DISH (DISH's current analysis have been conducted using confidential information from SpaceX).

Additionally, DISH also requests the FCC to modify the SpaceX license to require the company to cease Starlink operations in case the Commission chooses to rule against SpaceX in the 12GHz rulemaking proceeding, Starlink Services LLC's request for authorization to operate as a telecommunications carrier and SpaceX's request to operate user terminals on vehicles.

The third-party studies which it uses as the basis of the claims use different assumptions than those which SpaceX has stated to the FCC. A portion of DISH's analysis which conforms with SpaceX's claims shows that no interference to DISH terminals will take place from Starlink communications, but the company believes that the scenario under which this applies is not applicable to real-world usage conditions.

The author has no position in any of the stocks mentioned. NewAgeAds LLC has a disclosure and ethics policy.
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