Engineering Firm Fires Back at SpaceX Criticism

RKF Engineering Solutions LLC has fired back at criticism leveled by Space Exploration Holdings LLC (SpaceX) with a technical analysis done by RKF Engineering that concluded that 99% of non-geostationary fixed-satellite (NGSO FSS) operators wouldn’t experience harmful interference from terrestrial 5G mobile operations in the 12.2-12.7 gigahertz band, and the impact on remaining users could be mitigated.

The technical analysis was submitted by RS Access LLC in initial comments it filed in the FCC’s 12.2-12.7 GHz band proceeding in May (TR Daily, May 10).

In reply comments filed in July (TR Daily, July 8), SpaceX argued that “the fatal defects of the technical ‘study’ are glaring at first glance. RS Access’s advocacy piece makes every assumption in favor of RS Access and implies an extremely limited deployment (though declares it a ‘robust deployment’) that still shows massive interference to next-generation satellite users.”

In a filing submitted yesterday in WT docket 20-443 and in a statement, RKF Engineering said it was taking the rare step of drafting a submission to defend itself.

“SpaceX’s inexplicable response to our rigorous, data-driven engineering study on coexistence in the 12 GHz band is so egregiously inaccurate that we as a firm felt it needed a direct response,” said a statement by David Marshack, RKF Engineering’s managing director and chief operating officer. “Though our firm has often been called on to perform analyses in Commission proceedings, rarely has our firm engaged directly in the FCC docket on its own behalf. But in multiple Commission filings, SpaceX has impugned RKF’s integrity with baseless allegations and brazen misrepresentations that have made engaging on the record necessary.

“RKF stands behind its work and will not tolerate bad-faith actors who have gone well beyond the bounds of zealous advocacy and professional decorum,” he added. “The engineering analysis clearly shows that coexistence between satellite and terrestrial 5G in the 12 GHz band is highly feasible. Any claim to the contrary is a misunderstanding of our findings which show that a 5G network with zero coordination would impact fewer than one percent of NGSO terminals. As a respected firm that has assisted the FCC in many spectrum proceedings, we look forward to engaging with good-faith actors who seek to bring the Commission’s 12 GHz rulemaking to a successful conclusion.”

In the FCC filing, Mr. Marshack complained, among other things, that SpaceX (1) “misreads our study to find harmful interference where none may exist”; (2) “ignores our study’s detailed siting discussion and falsely claims our study ‘assumes a 12 GHz 5G buildout will occur only in urban areas’”; (3) “criticizes RKF for assuming, consistent with all publicly available information, that Starlink would focus on less densely populated areas”; (4) “continues to talk around Starlink’s well-known technical limitations, claiming that it will provide service to tens of millions more customers than analysts’ long-term, ‘most aggressive’ expectations”; and (5) “says RKF should have assumed more Starlink user terminals, even though that would not have changed the results.”