Coalition Blasts SpaceX’s 12 GHz Technical Analysis

The 5Gfor12GHz Coalition today blasted as a “political document” a recently filed technical analysis by Space Exploration Holdings LLC (SpaceX) that predicted that its Starlink broadband terminals would experience harmful interference more than 77% of the time, causing full outages 74% of the time, if the 12.2-12.7 gigahertz band was used for 5G terrestrial services (TR Daily, June 21).

SpaceX said it used the same methodology as that employed by RKF Engineering Solutions LLC for a study last year and an update on that analysis in May, but SpaceX said it used “assumptions that reflect reality and [correct] several of the most glaring errors. Even still, SpaceX still left a number of RKF’s assumptions that are unrealistically favorable for its MVDDS client, such as completely ignoring that the band is in fact shared among multiple satellite operators.”

The RKF analyses were done for RS Access LLC, which is among a number of entities urging the FCC to open the 12.2-12.7 GHz band up to 5G terrestrial use. The updated study predicted only a small chance that 5G terrestrial services would cause harmful interference to non-geostationary fixed-satellite service (NGSO FSS) operations in the 12.2-12.7 GHz band (TR Daily, May 20). The earlier RKF study released last year concluded that more than 99% of NGSO operations wouldn’t experience harmful interference from 5G operations in the 12 GHz band (TR Daily, May 7, 2021).

In a statement released today, the coalition said the RKF analyses “demonstrate not only that coexistence is feasible in the band, with 99.85% of NGSOs experiencing no risk of harmful interference alongside 5G, but the substantial societal, economic and geopolitical benefits of unleashing more critical mid-band spectrum for two-way terrestrial services. After failing to submit any expert technical input during the public comment and reply comment periods in the proceeding, Starlink has only now submitted a self-produced political document in the guise of a technical analysis. This ‘study,’ which was not produced by an independent expert, is both scientifically and logically flawed,” the coalition added.

The coalition added that “[i]n contrast to the nationwide simulation submitted by RKF, Starlink attempts to imply nationwide conclusions based on results it generated from a single cherry-picked partial economic area (PEA): Las Vegas, NV. This PEA’s largest population center is a 141-square mile city that sprawls across the arid Las Vegas Valley. Given its unique topology and morphology, Las Vegas is among the most unfavorable geographies to analyze for co-existence (nearly ten times as unfavorable for 5G/satellite coexistence as the national average).”

“Within the Las Vegas assumptions, Starlink grossly distorts the 5G network configuration to create interference with NGSO terminals,” the coalition added. “For example, Starlink assumes a massive and unprecedented over-deployment of 5G towers that exceeds any realistic network build-out. If the assumptions SpaceX uses in Las Vegas are extrapolated nationwide, they would necessitate the deployment of over 600,000 macro 12 GHz sites across the country. This is wholly unrealistic, as leading nationwide carrier AT&T currently uses only 67,000 macrocells to provide coverage across the entire country to its 81 million subscribers, and with its entire portfolio of spectrum spanning 600 MHz-39 GHz. This assumption alone decimates the scientific and engineering credibility of Starlink’s purported study.”

“Starlink also said that a stunning 54 percent of its satellite user terminals in Las Vegas would operate in urban and suburban areas—a deployment model so contrary to Starlink’s network architecture and stated business model that the company appears to have had to slash the number of terminals it intends to deploy in Las Vegas simply to avoid physical capacity constraints inherent in its network design and operating parameters,” according to the coalition. “Starlink has publicly stated that its service will serve a limited number of customers in high-density areas and is really targeted for sparsely populated regions[.]”

“In addition to this manipulated filing, Starlink has initiated a public misinformation campaign by falsely telling customers and the public that coexistence is not possible in the band among Starlink and 5G services—despite nationwide data proving otherwise,” the coalition complained. “This tactic, which is commonly used by [SpaceX Chief Executive Officer] Elon Musk, is not only disingenuous, but it promulgates an anti-5G narrative that is harmful to American consumers who deserve greater competition, connectivity options and innovation. It also stands to threaten America’s global leadership in the 5G and technology sector as other countries outpace the nation in delivering next-generation services.”

The coalition said that it and its 35 members “remain committed to working with the FCC and stakeholders to reach a win-win solution for the American people. We will continue to pursue the facts that prove coexistence is possible in the band and advance the public interest.”

SpaceX has asked customers to write to the FCC and Congress in response to SpaceX’s argument that permitting terrestrial broadband services in the 12 GHz band would cause harmful interference to the Starlink system (TR Daily, June 29). As a result, more than 95,000 comments have been filed in the FCC’s 12 GHz band docket.