Astronautic Launches Equipment Service Provider and Manufacturer Space Exploration Technologies Corp. (SpaceX) is currently full steam ahead with its plans to deploy the Starlink constellation of satellites. These satellites allow the company to generate revenue by providing Internet access to consumers in the United States.
At the heart of Starlink are the operating frequencies for the satellites and their ground receivers that SpaceX must share with other entities. In particular, the 12.2 GHz – 12.7 GHz band caused friction between SpaceX and other non-MVDDS (Multichannel Video and Data Distribution) telecommunications service providers, which have opposed the efforts of the MVDDS coalition.
These discussions took a new turn when SpaceX asked the Federal Communications Commission (FCC) earlier this year to have the company lower its operating altitude for the Starlink satellites currently in orbit. The MVDDS coalition argued that the runway cut made it infeasible for 5G terrestrial operations over the 12GHz band.
To this end, the FCC Commissioner, Mr. Brendan Carr, and other members met with SpaceX officials last week to discuss the implications of restricting access to the 12 GHz spectrum for Starlink.
SpaceX jeopardizes significant investment investment in production if 12GHz spectrum access is taken away from using Starlink satellites
In a letter Sent to the Secretary of the Commission, Ms. Marlene Dortch, on the same day that the meeting between FCC and SpaceX representatives took place, Noah Campbell had argued on behalf of RS Access LLC that SpaceX would have little to lose if the Commission had access to limit the 12 GHz band. Mr. Campbell argued that access to the band represented only 3.6% of the total spectrum that SpaceX can use, and that the changes the company proposed would significantly change the Starlink specifications the company initially described to the Commission .
In particular, RS Access stated to the FCC that by changing the elevation angles of the user station of its Starlink user terminals, SpaceX would not only limit terrestrial 5G services, but the change would also cause interference issues with the network itself.
In response to these and other points, SpaceX stated to the FCC that the MVDDS coalition currently has no terrestrial 5G operations that will cause interference with a change in the Starlink specification. At the meeting, the company claimed that it is the coalition’s responsibility to protect non-geostationary fixed satellite service (NGSO FSS) operators of satellite services from interference caused by their terrestrial 5G services, as emphasized by e-CFR (Electronic Code or Federal Regulations).
The company’s Ex Parte filing with the FCC reveals important details for the network. According to SpaceX, it has invested $ 70 million in the production of Starlink consumer terminals and is currently producing 120 Starlink satellites per month. The consumer terminals are used by users to connect to the satellites, and the frequencies they will use for their downlink are similar for the MVDDS coalition’s planned 5G terrestrial networks.
SpaceX addressed the coalition’s allegations about the negative effects of changing the Starlink height and angles on terrestrial 5G via interference, and told Commission representatives that the evidence submitted to the FCC has lower altitudes, does not affect on the terrestrial cover. The change also addresses the FCC’s main concern about Starlink’s latency options, as SpaceX believes the lower altitude will improve consumer latency.
SpaceX cites 12-year gap since FCC’s purchase of 12 GHz spectrum rights as reason to maintain Starlink access to 12 GHz spectrum
Finally, as it reinforces the story against the coexistence of MVDDS and NGSO FSS usage on the 12 GHz spectrum, SpaceX pointed out that the argument that a shift in Starlink’s operational parameters co-exists. with terrestrial services, which contradicts the MVDDS coalition has previously claimed for the FCC.
In other words, according to the company, the coalition’s argument that the Starlink elevation and slope changes make it coexistent comes along with the assumption that the absence of such changes makes this possible.
As SpaceX LLC advisor Paul Caritj puts it in the Ex Parte filing,
“Some parties recognize the implausibility of their earlier proposal and are now suggesting that the additional rights of 12 GHz MVDDS licensees would somehow be consistent with sharing the band with existing NGSO operations. However, technical analyzes submitted by the MVDSS licensees themselves contradict this claim and conclude that MVDDS operators cannot obtain increased rights without interference with existing NGSO licensees. “
The conditions for coexistence, as emphasized by RS Access (were mentioned,
“To coexist with terrestrial services, NGSO ground stations must maintain a minimum elevation angle high enough above the horizon to avoid receiving harmful interference from terrestrial operations. A low minimum elevation angle on an NGSO receiver increases antenna gain and makes the NGSO receiver more vulnerable to interference from terrestrial sources The proposed change to SpaceX does just that: SpaceX would make its user terminals more vulnerable to future terrestrial operations by dramatically reducing their minimum elevation angles to the horizon. prospective 5G licensees in the The 12 GHz band would be virtually nowhere to place their base stations without tripping over SpaceX’s sensitive receivers Approval of the SpaceX modification would eliminate the co-primary nature of terrestrial services, SpaceX exclusive give dominion over the sacrifice entire band and American 5G leadership for an unproven business plan. “
The discussions between company representatives and the FCC come as smartphone manufacturers and network equipment vendors brace themselves for the rollout of 5G cellular and non-cellular services. SpaceX’s ability to successfully demonstrate commercial operations with the FCC could put an end to speculation for the 12 GHz spectrum.