SpaceX says that if 12 GHz spectrum is used for terrestrial 5G networks, it could result in outages for its Starlink space-based internet service as much as three-quarters of the time and render the service “unusable for most Americans.”
The company submitted new technical analysis to the Federal Communications Commission this week, saying in an accompanying letter to the commission that its study “verifies what should be intuitive—that a high-power terrestrial network would blow out anyone using the high-sensitivity equipment satellite consumers must use to receive signals that comply with Commission and international power restrictions on satellite downlink transmissions. As a result, vastly fewer Americans could be connected using next-generation satellite services, and those that remain would experience degraded service and regular outages.”
Dish Network wants to be able to use the 12 GHz band for terrestrial 5G services, and has been asking the FCC for permission to do so since 2016. The agency opened an inquiry in early 2021 looking at the feasibility of allowing mobile services in the band, while also protecting incumbents from interference. There are 500 megahertz of spectrum at stake here that are currently used for satellite broadcasting. SpaceX describes the 12.2-12.7 GHz airwaves as its “workhorse frequencies” for Starlink downlink connections.
“If Dish’s lobbying efforts succeed, our study shows that Starlink customers will experience harmful interference more than 77% of the time and total outage of service 74% of the time, rendering Starlink unusable for most Americans,” SpaceX claimed in a statement on Starlnk’s website.
Meanwhile, Dish has pointed to rival analysis from RS Access and RKF Engineering Solutions that it says demonstrates the feasibility of coexistence in the band. In an ex parte filing, RS Access said that that analysis “finds that 5G operations would have no effect on at least 99.85% of NGSO operations in the 12 GHz band” and that because satellite operators have other downlink spectrum available, “the remote … probability of interference specifically at the 12.2-12.7 GHz portion, would likely be unnoticable [sic] to consumers. … The engineering record is now complete with respect to the feasibility of 5G-NGSO coexistence, and the Commission has the opportunity for a win/win whereby the 12 GHz band is unlocked for massive 5G opportunities while allowing for NGSO co-existence,” the company claimed.
Starlink clearly takes issue with this, calling RS Access’ study “technically meritless” and going further, swiping at Dish’s record of not delivering on build-out requirements for its massive spectrum holdings and saying that no more spectrum rules should be changed to accommodate the company. “Dish has never lived up to its repeated promises to deploy a new terrestrial network using the exclusive licenses already stored up in its warehouses—the Commission simply cannot gift any more spectrum to any operator with this track record of broken promises and stranded consumers,” SpaceX said, going on to add that Dish hasn’t even met previous deployment requirements for the 12 GHz band at issue.
Meanwhile, the 5G for 12 GHz Coalition, which includes Dish and other companies, responded to the technical submission by saying that its engineers and technical experts “are reviewing the filing in depth and remain committed to working in good faith with the FCC and stakeholders to ensure that the American public is able to reap the immense benefits of 5G services in this band.”