Supporters of Opening 12 GHz Rebut SpaceX Objections

A 12 GHz spectrum license holder wants the Federal Communications Commission to push ahead with allowing wireless services in the band, contending there is plenty of evidence to rebut opposition from satellite giant SpaceX.

RS Access, which along with other stakeholders has pressed the FCC for well over a year to pass a spectrum-sharing plan for 12 GHz, said Wednesday that it had met with 16 staffers from three branches of the agency to share technical points on why it thinks the sharing plan works.

The FCC continues to study the idea — which would add new services to a swath of 500 megahertz between 12.2 and 12.7 GHz — and has not set out a clear position yet. FCC Chairwoman Jessica Rosenworcel this spring called it one of the agency’s “most complex dockets.”

But Starlink, which is part of SpaceX, has gone all in against the proposal, with Elon Musk’s tech company saying wireless use of the band will likely interfere with signals from non-geostationary satellites, or NGSOs. Other companies, including Dish Network Corp., are aligning with RS Access against SpaceX in an increasingly bitter public policy battle before the commission.

In a filing with the agency, RS Access said Wednesday there was no longer any need to hold back on the spectrum-sharing plan after Monte Carlo simulations — a type of predictability study that factors in risks — showed that advanced wireless signals would not disrupt satellites.

“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 coexistence,” RS Access CEO V. Noah Campbell wrote.

Campbell said the 12 GHz band is well-suited for wireless and that deploying 5G “would deliver meaningful economic and public interest benefits to American consumers without affecting future NGSO services.”

SpaceX representatives did not immediately respond to a request for comment Thursday.

According to the papers filed with the FCC, which included a summary of what its engineers found, RS Access has filed two technical studies based on Monte Carlo simulations of a “robust nationwide” 5G deployment and 2.5 million NGSO terminals. RKF Engineering Solutions LLC conducted the studies.

“NGSO operators — including Starlink — have failed to submit any technical analysis of their own during the 1.5 years this proceeding has been open,” the filing says.

RS Access took note, however, of an assertion by the satellite company that RKF should have used different satellite designs to model their operations, which could show a higher chance of interference.

“To remove any doubt about the feasibility of 5G-NGSO coexistence, and despite serious questions about the claims made by opposing satellite companies, RKF’s new analysis incorporates technical assumptions put forward by Starlink about the nature and operation of NGSO terminals,” the company said.

Even so, RS Access argued that “the assumptions advanced by Starlink are contrary to what publicly available data show about how NGSO systems operate in the real world.”