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Industry Experts Fight Over Whether Satellite Tech Should Monopolize 12 GigaHertz Band

Benjamin Kahn



Photocollage of V. Noah Campbell of RS Access and Ruth Pritchard-Kelly of WorldVu Satellites Limited by Broadband Breakfast

March 8, 2021—Experts are divided about how the 12 GigaHertz (GHz) spectrum should be utilized in the wake of the historic C Band auction, which would primarily be used by satellite technologies.

Representatives from some of the largest wireless providers quarreled in a lively exchange on March 4 as part of a panel hosted by the Federal Communications Bar Association. While panelists agreed that the 12 GHz band was an invaluable resource, that was about all they could agree on.

The crux of the debate is whether satellite technologies in low-earth orbit require all of the 12 GHz band, or whether there is room for sharing the frequencies.

Noah Campbell, the CEO of RS Access, LLC, said he believes companies like Amazon and SpaceX that utilize non-geostationary satellites – which hover closer to the earth’s service – have a serious role to play in bridging the digital divide.

But he also argued that other services, including mobile and video, require access to the band, and that satellite services should be able to find spectrum for their services in other bands.

Ruth Pritchard-Kelly, senior advisor to for WorldVu Satellites Limited, testily said Campbell “could do with a little history,” and asked him if he had ever worked on a satellite before. Campbell responded that while he had not, his company has engineers who had.

In arguing for satellite exclusivity of the 12 GHz spectrum, Pritchard-Kelly said satellites in orbit cannot simply switch from Ku frequencies to Ka frequencies. She explained that some satellites are designed to remain in orbit for upwards of a decade, and that it is not easy to simply switch bands.

She said arguing that not all the Ku band is being used is like saying, “I’m not using all nine pints of blood in my body—actually the satellites need all 500 megahertz.” She said that is what her company is licensed for, and that is how they have coordinated their satellites to operate.

When Campbell stated that it seemed like Pritchard-Kelly was worked up about the issue, Pritchard-Kelly declared, “I am paid to be worked up about it.”

Pritchard-Kelly said that even though finding and securing bandwidth is an ongoing issue, she is hopeful “the engineers work it out.” She conceded that sharing would only be possible if the engineers are able to find a way to do so without compromising mobility.

Campbell said he would appreciate coordination between their two companies to solve the problem.

“Have your engineers call our engineers—we’re happy to have this discussion with you.”

As a child of American parents working abroad, Reporter Ben Kahn was raised as a third culture kid, growing up in five different countries, including the U.S.. He is a recent graduate of the University of Baltimore, where he majored in Policy, Politics, and International Affairs. He enjoys learning about foreign languages and cultures and can now speak poorly in more than one language.


Experts Investigating Starlink Are Not Convinced that Elon Musk’s Satellite Project Provides Rural Broadband Solution

Benjamin Kahn



Photo of Cartesian Vice President Michael Dargue from February 2015 by Telecom Finance

February 16, 2021—While SpaceX touts Starlink as the answer to the world’s dearth of broadband coverage, experts are not convinced that it will be able to meet increasing demand.

Elon Musk’s SpaceX began launching a constellation of small satellites early in 2018 with the goal of providing affordable satellite broadband coverage to areas around the globe that historically lacked any access to the internet. On February 16, 2021, Space X launched its 19th mission adding to the hundreds of satellites in low orbit.

Cartesian, a U.S.-based technology consulting firm, recently published its final report as part of its “Starlink RDOF Assessment.” According to its findings, even under generous circumstances, Starlink would be unable to provide reliable internet coverage to its consumers.

To be considered for the RDOF bidding process, a company must commit to providing 100 megabits per second download and 20 megabits per second upload speed to consumers.

Michael Dargue, vice president of Cartesian, wanted to be clear that the assessment was based on publicly available information and that the specific technical abilities of the satellites are largely unknown. Dargue stated that the assessment made several assumptions. He spoke at a Tuesday webinar.

First, he stated that the assessment assumed that the satellites could transfer 20 gigabits per second and that each satellite had an effective range of 300,000 square miles. Additionally, he stated that the assessment assumed that the maximum latitude of center of satellite coverage area was 53 degrees. Dargue added that natural features such as mountains and forests were not accounted for in the assessment.

Dargue stated that with these assumptions made, the assessment indicated that 56-57 percent of consumers reliant on Starlink would experience degradations in their broadband service during peak hours (between 6PM and 12AM). Cartesian modeled two scenarios with megabits per second as the independent variable and percent of subscribers that received uncompromised service as the dependent variable.

The first model assumed that during peak hours users were using 20.8 megabits per second, and the second model assumed that peak hour users were using 15.3 megabits per second. These models both found that more than half of users would experience degradation in their service.

Dargue said that because SpaceX plans to use Starlink for military, commercial, and other non-fixed broadband sources (such as “smart” cars), Starlink’s ability to provide sufficient broadband coverage would be even further diminished. The Cartesian assessment estimated that if 50 percent of Starlink’s satellite capacity is dedicated to non-RDOF network users, 95-92 percent of RDOF users would receive insufficient coverage.

Screenshot of the Tuesday webinar

He stated that these issues will only become worse as the number of users and their broadband dependent devices increase, and that there would be a significant capacity shortfall by 2028. Dargue added that because SpaceX’s future business plans for Starlink are always changing the FCC may find it difficult to determine if SpaceX is complying with its contractual obligations.

Late last year, it was announced that SpaceX had secured a sizeable contract with the FCC’s Rural Digital Opportunity Fund. SpaceX’s contract was worth $885.5 million of a total of $9.2 billion that was made available to the fund.

SpaceX’s Starlink will be responsible for providing 640,000 locations with broadband coverage, mostly on the East Coast and northwestern U.S. Almost 88.3% of the locations Starlink will be covering are considered rural, with its five largest regions being Pennsylvania, Virginia, Washington, Mississippi, and Alabama.

Starlink will work by assembling its planned fleet of approximately 12,000 satellites into an overlapping tessellation of coverage to ensure that no region that is ought to be covered is missed.

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Expert Opinion

Gerard Lederer and McKenzie Schnell: FCC Continues to Undercut Local Authority on OTARD

Broadband Breakfast Staff



The authors of this Expert Opinion are Gerard Lederer and McKenzie Schnell

The Federal Communications Commission’s over-the-air reception devices (known as OTARD) rules limit local governments’, homeowner associations’ and condominium boards’ oversight authority over certain antennas and satellite dishes for certain size specifications.

In the Primary Purpose Report and Order released on January 7, the FCC expanded its rules to eliminate the primary purpose test used to justify the deployment of an OTARD. In addition, on January 11, the FCC released an Order pertaining to a City of Chicago ordinance that reaffirmed its 2018 Philadelphia Order by striking down Chicago’s satellite placement and removal ordinance.

In doing so, the FCC kept its perfect record in place: It has never ruled to uphold a single ordinance or private restriction brought before it.

The growth of OTARD rules

Adopted in response to Section 207 of the 1996 Telecommunications Act, the OTARD rules prohibit state, local and private restrictions that unreasonably impair the ability of the users of antennas that are one meter or less in diameter to deploy OTARDs on property under their exclusive use or control and in which the user has ownership or leasehold interest.

Specifically, it applies to those restrictions that (1) unreasonably delay or prevent installation, maintenance or use; (2) unreasonably increase the cost of installation, maintenance or use; or (3) preclude reception of an acceptable quality signal.

Restrictions prohibited by the OTARD rule include lease provisions, restrictions imposed by state or local laws or regulations, private covenants, contract provisions and even homeowner’s association rules. There is an exception, however, to any OTARD rule restrictions necessary for safety and historic preservation purposes.

The original OTARD rule provided protections for devices used to receive video programming signals. But in its 2000 Report and Order, the FCC expanded the rule to include customer-end devices capable of not only receiving fixed wireless signals, but also devices that had transmission capability.

Fixed wireless signals are those wireless signals that are used in the provision of voice, video and data services to a fixed location. In 2004, the FCC issued another Report and Order expanding the rules to protect hub and relay antennas so long as they were installed for the primary purpose to serve the user on whose premises the device is deployed.

Until this recent Primary Purpose Order, one could argue that an OTARD had to have as its primary purpose providing service to the user on whose premises the OTARD is deployed. But the FCC now makes clear that – in fact – the primary purpose for the installation no longer matters.

All hubs are covered by the revised rule, so long as they meet the rest of the OTARD requirements and serve a user on the premises.

Chicago had to wait 9 years for its order

Given the growth of the OTARD rules, it is of little surprise that local agency ordinances have had a hard time keeping up. Philadelphia, Chicago and Boston each adopted OTARD ordinances to address the placement of satellite dishes and a requirement that they be removed for public safety purposes when no longer in use.

Each of these ordinances were challenged by the satellite television industry (complaints were not filed by an individual dish owner), and pursuant to the automatic stay rule. Each of the ordinances was put on hold while the FCC reviewed the matter. Philadelphia had to wait seven years for its decision. Chicago had to wait nine for its decision, and Boston is still waiting for the opportunity to even defend its ordinance nine years after its ordinance had been challenged.

Despite the OTARD rules’ specific preservation of local authority to protect public safety, the FCC has consistently ruled against OTARD ordinances that relied on that reservation of authority, which was ultimately the case for Philadelphia and Chicago ordinance reviews.

In light of this, local authorities might want to consider addressing the placement and removal of satellite dishes under general rules on external placements of devices that exist today in their zoning and or building codes rather than adopting OTARD-specific rules. For instance, are there rules currently in place that address exterior lighting and how it must be deployed to minimize visual clutter? Are there other external deployments that have to be removed if they become inoperable? When and why are stealth deployments required for other exterior attachments and are their requirements for certification of installers?

Is this a guaranteed winning strategy? The answer to that is not clear, but the FCC seems at least to encourage local government to look to their general police powers to enforce OTARD removal, as noted in the January Declaratory Order where it states that “[A] city may have other means under its local police power to address out-of-service satellite dishes that present a safety hazard or encroach into the public area.”

Gerard Lavery Lederer is a Partner in Best Best & Krieger’s Municipal Law practice group in the firm’s Washington office. Gerry advocates for the rights of public and private property owners with respect to issues of law and policy arising from federal and state communications legislation and regulation. He also serves as legislative counsel and lead Washington advocate for TeleCommUnity, a collection of local governments dedicated to ensuring respect for local rights in federal legislative and regulatory activity.

McKenzie Schnell is an Associate in Best Best & Krieger’s Municipal Law practice group in the firm’s Washington office. McKenzie advises clients on broadband, cable, telecommunications service and data privacy matters, including regulatory compliance, transactions and litigation. She represents public agencies and small private entities at all stages of their  communications projects from infrastructure matters to network practices.

This Expert Opinion is a version of a legal alert, republished by permission of the authors.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to [email protected]. The views expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

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Low Earth Orbit Satellites Are Live, and May Compensate for Geosynchronous Broadband Challenges

Samuel Triginelli



February 4, 2021 -With Elon Musk’s SpaceX working on low earth orbit satellites and launching 60 Starlink satellites in a single batch early Thursday morning, prompting continuing discussions about the effectiveness of these low earth orbit investments in improving rural broadband in the United States.

Pisgah Astronomical Research Institute, a non-profit public organization focusing on space, is one resource for information on how low earth orbit satellites work – or don’t work – for broadband.

Geosynchronous satellites are the more common type. They are used at a distance of 36,000 kilometers from earth.

But one key drawback to geosynchronous satellites is latency in services, which delays responses, video conferences and phone calls.

Latency kills the effectiveness of many types of communication, said Lamar Owen, Chief Technologist of PARI.

Low earth orbit satellites were designed to solve these issues, as they orbit the earth at about 1,000 kilometers above the earth. Instead of being stationary relative to the earth, they “move around.” This addresses latency, providing a key advantage against geosynchronous satellites

And they are capable of being seen from earth.

For the user receiving satellite services, possible advantages include no wires attached to households, poles or underground. Futher, there is no need for a central office with power: Merely a satellite terminal, allowing very remote locations to receive an internet connection.

Video streaming and other mass-market applications are reported to function well with LEO service, said Owen. Further research is necessary to study applications in companies and businesses with a high need of connections owing to asymmetric bandwidth.

For a system of low earth orbit satellites to work properly, critical mass with many satellites is required.

Some disadvantages are the signals that are constantly changing connection from satellite to satellite, with durations of 10 minutes each. The satellite moves and reflects sunlight suffers from rain and snow affect infrequencies being used.

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