Starlink wants competitors to stop wasting FCC time
The Starlink subsidiary of Space Exploration Technologies (SpaceX) has seen interesting changes last week in its struggle to retain the right to use the 12GHz spectrum and to restrict the use of the 12GHz frequency by multi-channel video and data distribution service (MVDDS) providers.By SpaceX Satellite Policy Director David
The Starlink company represented by Goldman rejected the RS supported by Michael Dell
Access’s claim, that is, the Federal Communications Commission (FCC)’s opinion solicitation standard to develop a new 12GHz rule, because it believes that MVDDS should withdraw from this frequency band.
To support its argument, Starlink outlined that a technical study submitted by RS Access was “seriously flawed,” and therefore failed to prove why MVDDS should be able to operate in the 12GHz band.
Goldman’s comments are based on the tough stance in an earlier FCC document submitted at the end of September. He asked the committee to cancel MVDDS’s use of the 12GHz band. Starlink users use this frequency band to receive data from orbiting satellites. In previous documents, the Internet provider emphasized that this is one of the few frequency bands suitable for this purpose.
The latest document submitted by Starlink over the weekend refutes RS Access’s claim that the current FCC’s 12GHz proposed rulemaking notice (NPRM) complies with the Administrative Procedure Act (APA) because NPRM cannot emphasize how sharing between satellites and 5G operators is achieved. of. It believes that the initial argument of DISH Network (another MVDDS license holder) clearly pointed this out, and recent attempts by DISH and RS Access provided little knowledge about this change.
It then turned its gun to the only technical study submitted by RS Access to prove that spectrum sharing is possible due to technological advances. According to Starlink, in order to “reach the unrealistic and favorable conclusions submitted, RS Access was forced to assume certain operating parameters and deployment conditions. But even so, it did not propose any actual rules that require mobile operators to comply with these expectations. “.
Goldman then extended this argument, pointing out that the FCC did not outline in the NPRM that it believes that the level of interference to satellite Internet users in the United States is unacceptable. He criticized DISH for thinking that interference to “tens of thousands” of satellite users is “insignificant.” He outlined that the lack of unacceptable interference standards denied RS Access’s claim that NPRM follows APA.
To further support his point, the executive used RS Access’s statement that the FCC’s separate procedure for the C-band (4GHz-8GHz) 12GHz NPRM complies with the law to prove that the statement in the record is wrong.
The fourth slide of SpaceX’s speech to the FCC at the end of July 2020 emphasized the importance of the 12GHz frequency band to Starlink and discussed the drawbacks of using adjacent spectrum.
In the September letter, Goldman urged the FCC to end the lawsuit without harming the Internet company, citing insufficient technical information in the record. In the letter, he once again criticized the technical research of RS Access and outlined its shortcomings in seven aspects:
In addition to Starlink, the lack of other satellite services and the impact of spectrum sharing on satellite company operations.
Its assumption of deploying constellations was incorrect at the beginning.
There are actually fewer satellite user terminals than in reality.
The elevation angle of the user terminal is higher than in actual use.
Incorrect interference indicators affected the argument.
Even if Starlink and RS Access cannot coordinate, there are assumptions about coordination.
There are limited demonstrations of how satellite and MVDDS systems can coexist.
He also criticized the research boutique MoffettNathanson, saying that he “has no real insight into the operation of the SpaceX NGSO system.”
After actively establishing a constellation with more than 1,600 satellites, Starlink is preparing to launch more satellites in the coming months. It also hopes to use SpaceX’s interstellar spacecraft, a fact that has caused heated controversy in another FCC lawsuit.