SpaceX Wants FCC To Reject Starlink 12GHz Spectrum Sharing Petition

Ramish Zafar
SpaceX Starlink Cluster
A cluster of 60 SpaceX Starlink satellites before launch on January 29, 2020. The launch, believed to have cost SpaceX $50 million, was the company's third launch of an operational batch of Starlink satellites. (Image Credit: SpaceX)

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A major point of contention between astronautic launch services provider and equipment manufacturer Space Exploration Technologies Corp. (SpaceX) and providers of MVDDS fixed, terrestrial-based television and internet service providers is the latter's demand that the Federal Communications Commission (FCC) open up the 12GHz mid-band frequency spectrum to allow the latter to deliver 5G-based services.

The Commission has reserved this band for operators of non-geostationary satellite service operators (NGSO) for providing non-terrestrial services to customers in the United States. A coalition of MVDDS service providers filed a petition with the FCC back in 2016 (before SpaceX formally launched the Starlink internet constellation) requesting the body to change its rules to allow them to provide two-way mobile broadband services in the 12.2GHz - 12.7GHz spectrum and either remove or designate as secondary the NGSO fixed-satellite service (FSS) spectrum allocation.

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The coalition formulated the latter assertion on primarily two premises, and SpaceX, through its latest filing with the FCC has argued that the Commission reject the MVDDS petition due to the facts that not only are the premises invalid but that they remain unsupported by latest filing activity by other operators and entities.

Bottom of the SpaceX Starlink WiFi router. The image comes from the label locations diagram for the FCC filing. (Image Source: FCC)

SpaceX Asserts That 2016 MVDDS Petition For Stripping NGSO FSS Provider Access To 12GHz Mid-Band Spectrum Is Unsupported By Recent Filings

The MVDDS coalition's argument rests on facts that 1) The NGSO FSS allocation of the 12GHz band is unused, with virtually no operator presence in the area, and to ensure that broadband services are provided effectively 2) within the 500Mhz of the band quoted above, new rules should not provide NGSO FSS operators with any interference protection in the form of power output limitations and other means.

Given that the petition for rulemaking with the Commission was filed in 2016, the coalition was right to argue that the spectrum was at the time underutilized. Since then, however, SpaceX has been the primary entity that has consistently launched its satellites that intend to make use of the frequencies that are present in the spectrum – a fact that the company has consistently reiterated to the FCC, both in today's and in earlier filings.

However, today's letter to Ms. Marlene Dortch, Secretary to the FCC by David Goldman Director of Satellite policy at SpaceX is one of a kind. This is due to the fact that it outright asks the Commission to reject the MVDDS rulemaking; an occurrence that is absent from the company's previous correspondence with the regulatory body.

The Falcon 9 booster vertical on the launchpad prior to SpaceX's Starlink launch on June 13 this year. This booster has previously launched the Dragon spacecraft to the International Space Station. (Image Credit: SpaceX)

In the letter, Mr. Goldman once again reiterates SpaceX's claim that it has invested a sizeable amount in deploying the Starlink internet satellite constellation and that the company has plans for more launches in the future that are set in stone. The executive also uses recent filings with the FCC on the matter to boast the veracity of his claims and refute the second premise on which the MVDDS petition rests on.

Mr. Goldman uses filings by Federated Wireless, WeLink, Public Knowledge and others to prove to the Commission that the MVDDS proposal of not providing NGSO FSS operators any interference protection in the band that they were initially granted preferential access to is unwarranted. The executive achieves this by stating that the filings by the aforementioned bodies either do not restate or confirm this assertion, or those such as the one filed by Public Interest Groups earlier this month outrightly state that spectrum rights for the satellite service providers need to be preserved for any such proposal to be effective.

Quoting silence in recent filings about the viability of spectrum sharing between 5G services providers and NGSO FSS service providers, Mr. Goldman argues that any such proposal will end up harming consumers by cutting consumer capacity in half, and as a result causing significant throughput drops in 50 states that are sufficient to reclassify the internet services from being dubbed as 'broadband'.

Schematics of the SpaceX Starlink router as filed with the Federal Communications Commission. The image above represents the company's instructions for Wistron NeWeb Corp. for manufacturing the router. The nine line items under 'Notes' provide Wistron with details for the router, with instructions 5 and 8 dealing with the router's painting. (Image Source: Federal Communications Commission)

Company States That Quality Drops, Lack of Support By Recent Filings Primary Reasons For Dropping 2016 MVDDS Petition

Finally,  the executive's last line of argumentation states that the use of the 12GHz spectrum for 5G is unsuitable due to propagation characteristics – a claim that SpaceX has made in several prior filings with the FCC.

Subsequently, by quoting the facts that the MVDDS petition's arguments are either violated as in the case of no spectrum usage by NGSO FSS operators or are not supported by recent filings with the Commission as in the case of protecting the rights of satellite operators and in the case of spectrum sharing between terrestrial and non-terrestrial service providers, SpaceX argues that the FCC has no reasons to move ahead with the petition.

Both the company and the Commission are currently engaging on multiple fronts when it comes to the internet constellation. The FCC has already rejected SpaceX's request to provide the company with funds under the Rural Digital Opportunity Fund for providing low-latency internet access to rural Americans, arguing that the company's plans for Starlink are un-deployed and therefore "experimental". SpaceX, for its part, is moving ahead with full steam as it continues to deploy satellites and develop products such as Starlink ground stations and routers (details of which are shared above).

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