Microsoft’s Guns Blazing Starlink Support Can Deal Michael Dell’s RS Access Serious Blow

Microsoft's explanatory diagram for Azure Space and MDC shows that the company intends to use satellites operating in three different orbits for connecting the remote datacenter with its and its partners' ground facilities. SpaceX's Starlink satellites orbit in Low Earth Orbit, due to lower latency and easy de-orbiting. Image: Microsoft Corporation

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In a meeting with Federal Communications Commission (FCC) representatives earlier this month, members of Microsoft Corporation shared their support for Space Exploration Technologies Corp.'s (SpaceX) Starlink satellite internet network. Starlink and other non-geostationary fixed-satellite services (NGSO FSS) providers are at odds with terrestrial 5G operators such as Michael Dell's RS Access LLC and dish-based service (DBS) providers such as DBS over rules for governing the 12GHz spectrum. The FCC is currently evaluating input from all stakeholders in the spectrum to accommodate demand from all sides. Microsoft's meeting came after it submitted detailed comments in support of the satellite companies early last month.

Microsoft Highlights Key Reasons Why Starlink Should Retain Access To The 12GHz Frequency Band

The fight between the satellite and terrestrial providers resulted from a 2016 rulemaing petition submitted to the FCC by multi-video data distribution service (MVDDS) companies that sought greater access to the 12GHz spectrum. Back then, they argued that a lack of development in the space by satellite companies and spectrum sharing between MVDDS and NGSO FSS providers being impossible necessitated that the FCC grant the former greater leeway and protections for the spectrum.

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The Commission ruled on this petition earlier this year when it opened the floor for comments from all parties to help it decide on the new rules. Since then, RS Access has submitted a study detailing how spectrum sharing is possible due to new technologies. SpaceX and other NGSO providers' request to the FCC to extend the deadline to reply to this study has been accepted.

Microsoft's Modular Datacenter (MDC) will use SpaceX's Starlink satellites to connect with ground stations. Image: Microsoft Corporation

Microsoft, which has partnered up with Starlink to bring data center internet coverage to remote and polar U.S. regions, submitted detailed comments to the FCC at the start of May. These comments expressed unflinching support for Starlink and contained arguments which SpaceX is yet to present before the FCC.

Microsoft argued that if the FCC shaped the spectrum rules to favor the MVDDS providers, it would be a backward step towards making broadband-level internet available to remote American regions. It argued that the satellite companies have already started to provide consumers with internet coverage, and any unfavorable changes would nip this progress right in the bud.

It also highlighted that if the Commission introduces new protections for terrestrial users, then the very nature of satellite terminals, which receive weak signals from hundreds of miles in the sky, will require significant restrictions for MVDDS use. These restrictions, believes Microsoft, will hamper both MVDDS and satellite coverage and, as a result, provide no benefit to the American consumer.

As the company's senior director for Government and Regulatory Affairs, Ms. Paula Boyd outlined:

The 12 GHz band is not a good candidate for terrestrial broadband access due to the significant environmental attenuation at these frequencies. NGSO FSS broadband providers, however, can use the 12 GHz band to transmit from space to Earth, meaning that attenuation due to buildings, foliage, and other environmental factors are greatly reduced. And satellite licensees do not require the extensive local supporting infrastructure of terrestrial 5G networks—they can transmit directly from space to rural communities. This allows 12 GHz satellite licensees to provide connectivity in places that are hard to reach by terrestrial providers.

The Quectel AG15 Module featuring Qualcomm's 9150 C-V2X application-specific integrated circuit. The 9150 features ARM's Cortex A7 cores clocked at 1.7GHz and the chip is fabricated on the 14nm node.

Spectrum Deharmonization Will Limit Public Interest Served Through 12GHz 5G Use Argues Microsoft

Additionally, and more importantly, the Redmond, Washington-based software giant pointed out that even if the Commission did grant concessions to the MVDDS providers to use the 12GHz band for 5G use, the lack of international harmonization would deter optimal usage. Ms. Boyd pointed out that this lack will deter companies (such as Qualcomm) from developing chipsets and semiconductor which utilize the 12GHz band for terrestrial use.

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According to the Microsoft executive:

The costs of adding support for a new band cause both chip and device manufacturers to strive for global scale. The lack of internationally harmonized rules for a 12 GHz terrestrial service will likely deter manufacturers from making such investments.

. . . .Given these factors, a manufacturer would be taking a major risk by investing to build semiconductors and devices that would only work on a single mobile operator’s network—especially when that operator has no track record of deploying meaningful mobile service.

The presence of international harmonization has been a driving factor for Qualcomm to develop technologies to support Cellular Vehicle-to-Vehicle (CV2X) deployment, as highlighted by the company's senior vice president for Spectrum Strategy and Technology Policy, Mr. Dean Brenner, in an exclusive interview with Wccftech.

During the conversation, Mr. Brenner highlighted that:

Second point is, actually believe it or not, in China they are using the upper 20MHz for C-V2X of the 5.9GHz band. That matches up perfectly, it’s the same 20MHz that’s part of the 30MHz that the FCC is allocating here for C-V2X in the United States. So when you’re rolling out a new technology harmonization of the spectrum, having the spectrum be allocated similarly around the world is very helpful, it reduces costs, it allows economies of scale to be achieved. So you know the fact that the United States is on the cusp here of allocating the upper 30 and the upper 30 matches up with the 20 that China is using is a very very positive development for C-V2X. The harmonization means that we can keep the costs down. So it’s always harmonization in the spectrum is a very very good thing for us and for consumers.

A summary of technological changes in satellite systems which now make spectrum sharing feasible according to RS Access. Image: Comments of RS Access 5.7.21 Filed in FCC Docket 20-441

Finally, Ms. Boyd also argued that changing the rules in favor of the MVDDS providers will go against Section 303(y) of the 1934 Communications Act, which requires the FCC to ensure that spectrum flexibility rules do not "deter investment in communications services and systems or technology development"

She added that not only new rules favoring 12GHz terrestrial use are "unlikely to succeed commercially and unlikely to contribute significantly to closing the digital divide," but that they will also deter telecommunications investment as companies will be wary of changing rules.

Microsoft's comments also bemoan the lack of new evidence by the MVDDS companies showing how satellite and terrestrial coexistence is possible in the 12GHz band. Since they were posted, RS Access shared a detailed study with the FCC highlighting technological developments that make sharing possible.

However, the study did not outline how the current rules limiting MVDDS transmit power to 0 dBm/MHz (24 dBm/14 MHz) will allow terrestrial users to serve their customers and avoid interference with NGSO providers. All eyes are now on Starlink's rebuttal, as the FCC's comment reply deadline will expire at the end of the first week of July.

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