Starlink Aircraft Dish Test Violates FCC Rules Believes Rival

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After Space Exploration Technologies Corp.'s (SpaceX) Starlink satellite internet service applied for a temporary authorization to operate a user dish on an aircraft last month, the company's rival in the 12GHz spectrum band, the Michael Dell backed RS Access, LLC, has requested the Federal Communications Commission (FCC) to either deny the application or grant it after informing Starlink that the permit will be contingent upon future rules set for the 12GHz frequency band.

The latest filing extends the tussle between Non-geostationary Fixed Satellite Service (NGSO FSS) service providers and Multi-channel Video Data Distribution Service (MVDDS) providers over the frequencies that allow the satellite companies' user dishes and the MVDDS providers' consumer equipment to transfer data.

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Starlink's Aircraft Test Authorization Should Include Disclaimer Argues RS Access

In its request, Starlink had outlined to the Commission that it would test the capability to send and receive data from an aircraft through the user dish. These tests will be conducted in Pensacola, Florida and the terminal in question had appeared in an earlier request, ultimately granted, asking the FCC to allow SpaceX to test Starlink in six states.

Now, as Starlink awaits the FCC's decision for the aircraft test, RS Access LLC, which is a company aiming to utilize the 12GHz spectrum for home entertainment and other services, has stated to the Commission that the internet service's Earth Stations In-Motion (ESIM) dishes violate current 12GHz band sharing rules.

In a filing made at the end of last week, the company argues that the ESIMs violate current 12GHz sharing rules, can use other spectrums for their needs, have the potential to "disrupt" current and future services in the band and come before the Commission decides potential new rules for the MVDDS and FSS companies to share the 12GHz spectrum.

Starlink will initially start providing internet coverage onboard the Boeing 737 and Airbus A320, according to SpaceX chief Elon Musk. Image: Jetstar

Additionally, RS also wants the FCC to include in any potential approval a disclaimer of sorts informing Starlink that the authorization does not have any bearing on the Commission's ongoing proceeding for the 12GHz rules.

Providing a sample of the suggested disclaimer, the company wants the Starlink authorization text to include language similar to the following:

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This authorization is subject to modification to bring it into conformance with any rules or policies adopted by the Commission in the future. Accordingly, any investments made toward operations in the bands authorized in this order by SpaceX in the United States assume the risk that operations may be subject to additional conditions or requirements as a result of any future Commission actions. This includes, but is not limited to, any conditions or requirements resulting from any action in the proceedings associated with WTB Docket 20-443.

By doing so, RS Access believes that the FCC will prevent the existing "existing satellite-terrestrial sharing regime" in the 12GHz band from "abuse" and it outlines previous Commission precedents to boost its case.

The 12GHz band is a sore point of contention between the MVDDS and the satellite companies. While the satellite camp argues that any sharing between the two is impossible, pointing out to arguments from the MVDDS camp itself, the former believes that coexistence is possible as it seeks to bolster this claim through new research.

Earlier this year, things came to a head when RS Access submitted a technical study outlining that even if Starlink deployed 2.5 million terminals across the Continental United States, the interference between the dishes and MVDDS equipment would be minimal. In response, SpaceX's head of satellite policy David Golman claimed that the study used selective data, relied on a false rural-urban divide and underestimated the internet service's potential to service more users.

The ESIMs have been mentioned multiple times in Starlink's submissions to the FCC, which request approval for blanket authorizations for the terminals. A filing made in August sought approval for next-generation High Performance (HP) dishes to be used on vehicles of all types and collectively referred to as ESIMs.

It followed an application made in March this year that had sought a blanket license for ESIMs but did not mention the HP variants. The HP user dishes will be capable of operating in extreme temperatures, and they come after several reports of the current dishes malfunctioning in the extreme heatwave that hit several U.S. states earlier this year.