SpaceX Presses FCC On Importance Of Spectrum Sharing Rules & 12GHz Band
As SpaceX continues to build its network of Starlink satellites aimed at providing broadband internet coverage all over the United States and the globe, it's also dealing with the Federal Communications Commission (FCC) and a consortium of Multichannel Video and Data Distribution Service (MVDDS) providers to ensure access to 500MHz of the 12.2 - 12.7GHz spectrum for the satellite network. Additionally, the company is leading the charge with a proposal to the Commission requesting it to clear up ambiguities in its spectrum sharing rules for Non-Geostationary orbit (NGSO) Fixed-Satellite Service (FSS) satellites for balancing the needs of older and newer licensees and determining fair metrics for evaluating provider performance.
To that end, SpaceX's David Goldman who heads satellite policy at the company called upon the Commission's representatives early last week, with the meeting being disclosed on the public record at the week's tail-end.
SpaceX Reiterates Spectrum Sharing Rule Modification Suggestions & Importance Of 12.2 GHz - 12.7GHz Spectrum For Starlink To FCC
Judging by the details made public in a filing to the FCC's dockets RM-11768 and RM-11855, the primary topic on SpaceX's agenda in its latest calls with the four Commissioners' offices was the need to modify the FCC's rules that allow for spectrum sharing amongst the aforementioned satellite service providers. These rules (47 CFR Part 25 – SATELLITE COMMUNICATIONS - Subpart C - Technical Standards, §261) deal with inter-operator coordination in the event that the frequencies that they have been allotted by the FCC overlap.
SpaceX's proposals (backed by Kuiper Systems, LLC, O3b Limited and Kepler Communications Inc) filed with the FCC at the start of this month suggest that the Commission expedite the modification process to ensure that service providers can confidently make their investment decisions for satellite coverage.
Of the two primary points of contention for these rules that have risen among service providers, the first one is ambiguity regarding a framework to deal with disputes in the case two parties are granted access to a single spectrum, with one party being an older licensee. Proposals to deal with the ambiguity are extensive, and they range from suggestions that allocate more spectrum to an earlier licensee or those that suggest "clumping" together applicants to award all of them equal spectrum sharing status.
SpaceX, on the other hand, has suggested that the FCC amend the rules to provide providers that have gained access to a spectrum via an earlier round interference protection enabled by providers who have gained access via a later round; with the level of interference being specified through standard antenna masks and noise temperatures. SpaceX has also suggested that in the case that same-round operators have conflicts over spectrum usage, the Commission should award preference to the operator with greater spectral efficiency that is evaluated via Mbps-Hertz-km².
This evaluation criterion is the second primary point of contention between providers, and companies apart from SpaceX have suggested different metrics. These include Amazon, who believes that an interference threshold determined by time delays should gauge efficiency and Kepler who believes that bits/Hz is more suited for determining efficiency. SpaceX, however, maintains its ground and counters the proposed evaluation techniques by stating that they lack the standardization necessary for such criteria. In its latest calls with the FCC, the company also modified its suggested criteria by adding the bandwidth used by a service provider to it after suggestions made by Kepler.
Finally, SpaceX also continued to stress to the FCC the importance of the 12.2GHz - 12.7GHz for NGSO satellite providers. The opposition by the MVDDS group towards providing NGSO operators protection for using this spectrum is based on a petition filed in 2016, with the current market scenario reflecting updated ground realities, argues SpaceX. Executives from Dish held meetings with FCC Commissioners last week to discuss this spectrum allocation, as it and others try to convince the Commission about the merits of opening the spectrum to allow 5G-based mobile and fixed broadband deployment.
They claim that the spectrum offers significant propagation advantages over the mmWave spectrum and that a lack of development in the NGSO market is wasting this potential. SpaceX has countered these claims by quoting the number of Starlink satellites that it has deployed. The company has also stated to the FCC that not only does the Starlink network use the 12GHz band for downlink (insinuating that any changes to the procedure will affect the end-user), but that the band's propagation characteristics will force the MVDDS terrestrial suppliers to limit their coverage to urban areas and deny rural Americans with internet coverage in the process.
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