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Satellite Operators and Broadband Entrants Vie for Primacy as FCC Debates the 12 GigaHertz Band

Will the 12 GHz band be opened for 5G uses or remain exclusively for satellite services?



Visualization of spectrum from the Australian Department of Infrastructure

July 13, 2021—There is a battle raging in the heart of the atmosphere. And no, it’s not the current heatwave. It’s the wireless radio frequencies known as the 12 GigaHertz (GHz) spectrum.

Join the Broadband Breakfast Live Online event, “Spectrum for 5G, LEOs and the Future of the 12 GigaHertz (GHz) Band,” on Wednesday, July 14, 2021. You can also PARTICIPATE in the current Broadband Breakfast Live Online event. REGISTER HERE.

The 12GHz band is the name commonly used to identify a 500 megahertz swath of frequencies that stretch across the lower end of the so-called K band, between 12.2 GHz and 12.7 GHz.

The band has primarily been used for downlink satellite communications—most notably by the International Space Station, SpaceX, and Dish. But now the band has emerged as a flashpoint in the debate over 5G services versus satellite technologies.

Proponents of spectrum sharing believe now is the time to open 12 GHz up for more intensive broadband uses. But some satellite services are very much opposed. And the Federal Communications Commission is currently considering the arguments.

Spectrum sharing: Will it also work with satellite services?

Spectrum policy primarily uses two methods of allocating bandwidth. A band can either be designated for shared use or exclusive use.

Some entities would like to see the 12 GHz band opened up to greater shared uses. Others want it limited for exclusive use.

Bands can also either be licensed or unlicensed, but the terms are not mutually exclusive. Communications companies are often opposed to shared uses. These companies prefer to utilize an exclusive rights model, in which they approach the airwaves from the perspective of a property owner with complete control over their domain.

One notable exception to this is Dish Wireless.

Dish’s direct broadcast satellite service has been the primary incumbent in the 12 GHz band for years. Representatives from Dish have stated that they welcome the improved competition because they believe sharing the 12GHz band would yield as companies continue to build-out their 5G networks.

A battle of the billionaires

It’s also important to frame Dish’s argument in a broader context. Billionaires Elon Musk, Jeff Bezos, and Richard Branson are embroiled in a war to establish primacy of the satellite internet market. SpaceX’s Starlink, Amazon’s Project Kuiper, and Virgin’s Virgin Orbit are all trying to carve out their own corner of the market for satellite internet.

The 12 GHz band represents important real estate which they could leverage to improve their coverage.

In a response to Dish’s comments before the FCC, SpaceX argued on July 7 that Dish’s shared use model would interfere with incumbent satellite services—an assertion that Dish has pushed back against in the past.

SpaceX accused Dish of amassing “the world’s largest storehouse of unused spectrum” and accused them of only being capable of delivering empty promised. The reply also stated that Dish is attempting to kick operation next-generation satellites out of the 12GHz band—which would not be a precondition for spectrum sharing.

OneWeb and RS Access also weigh in

“The loudest proponents for introducing terrestrial mobile into the 12 GHz band are a handful of parties whose business plans have proved fruitless for nearly two decades, led by two who now see an opportunity for a financial windfall,” said Eric Graham, director of government and regulatory engagement for OneWeb, a satellite broaband provider, referring to Dish and RS Access.

“Arguments in support of introducing a terrestrial mobile allocation into a spectrum band with comparatively poor terrestrial propagation characteristics ignore the fact that such an allocation would only serve consumers who currently have many terrestrial mobile options in the areas where they live, work, and play,” Graham said.

But In a March 2021 ex parte filing with the FCC, RS Access slammed some of the satellite companies, including SpaceX, stating that the Musk’s company only seeks “maximal flexibility for itself, no matter the encumbrances or detriments to other operators.”

Eric Graham of OneWeb, V. Noah Campbell of RS Access, Jeffrey Blum of DISH

The filing also pointed out that the 500 megahertz is only worth three percent of SpaceX’s more than 15 gigahertz of exclusive use. RS Access asserted that improving flexibility “is not a zero-sum choice between satellite and terrestrial operations.” It pointed out that there are few other options for viable mid-band spectrum for license flexible use, and that new innovations are making shared use more efficient.

Dueling series of facts and technical data

Back in December of 2020, Chairman and CEO of Dell Technologies Inc. Michael Dell appealed to FCC Commissioner Nathan Simington to advocate for the use of open radio access networks in domestic 5G networks, their utility in bridging the digital divide, and the opening of the 12 GHz band for 5G use.

The decision to open the 12 GHz band may well come down to technical data: Whether Dish and its allies can provide data that will convince the FCC that opening the band to greater sharing will not interfere with incumbent usage.

For SpaceX and other entities that would prefer to see it remain closed, they will likely have to demonstrate how their services will be irredeemably impacted by other carriers operating within the band.

Join the Broadband Breakfast Live Online event, “Spectrum for 5G, LEOs and the Future of the 12 GigaHertz (GHz) Band,” on Wednesday, July 14, 2021. Panelists include Eric Graham of OneWeb, V. Noah Campbell of RS Access and Jeffrey Blum of DISH. You can also PARTICIPATE in the current Broadband Breakfast Live Online event. REGISTER HERE.


FCC GOP Commissioner Endorses Satellite Streamlining Bill

The Satellite and Telecommunications Streamlining Act would ease FCC permitting for the rapidly growing satellite industry.



Screenshot of FCC Commissioner Nathan Simington in 2021

WASHINGTON, December 12, 2022 – As Congress scrambles to negotiate an end-of-year omnibus, Federal Communications Commission Commissioner Nathan Simington on Thursday touted technical potential of satellite broadband and endorsed a bill that would streamline satellite permitting.

The bipartisan Satellite and Telecommunications Streamlining Act, introduced Thursday with the Secure Space Act, would ease the FCC’s permitting process for the rapidly growing satellite industry. It’s companion bill bars the agency from authorizing non-geostationary satellites from entities that also offer products found on the “covered list,” which identifies equipment and services that pose “unacceptable” risks to national security.

“American companies are leading the way in the space economy revolution, and Congress has recognized that we must act quickly to secure America’s role as the home to the most innovative new companies in the emerging launch and satellite sectors,” said Simington, an outspoken proponent of satellite broadband, in a statement. “There is an insatiable hunger for low-latency, high-bandwidth broadband connections in every corner of the U.S. that satellite broadband providers are racing to feed,” he added.

The junior Republican-appointed commissioner in September criticized the FCC’s revocation of a $885 million, Rural Digital Opportunity Fund award to satellite-broadband provider Starlink. Commissioner Brendan Carr also criticized the flip-flop. At the end of September, Simington, Carr, and their colleagues unanimously adopted an order that required the removal of satellite debris from space, and in November, Chairwoman Jessica Rosenworcel announced the inception of a dedicated space bureau at the agency.

Outside the FCC, many experts say current satellite broadband is technologically incapable of providing reliable broadband, an assessment echoed by the National Telecommunications and Information Administration in its guidelines for the $42.45 billion Broadband Equity, Access, and Deployment fund.

Will bipartisan broadband bills beat the buzzer?

The Broadband Grant Tax Treatment Act, a bill that would make non-taxable broadband grants from the BEAD program and the American Rescue Plan Act, may yet become law by year’s end, spokespeople for Sen. Mark Warner, D-Va., and Rep. Mike Kelly, R-Penn., told Broadband Breakfast Monday.

And if the bill isn’t passed this month, the spokespeople said, each legislator plans to advance it in the 118th Congress.

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LEO Technology Could Connect the Unconnected, Although Capacity Questions Remain

Unlike geostationary satellites, LEOs offer a connection that can support real-time communication.



Screenshot of Internet Society Director of Online Content Dan York

WASHINGTON, December 2, 2022 — Low earth orbit satellites have the potential to provide life-changing connectivity for rural and underserved users if they can overcome issues of affordability and sustainability, according to Dan York, director of online content for the Internet Society.

Speaking at a Friday event hosted by the Gigabit Libraries Network, York explained that LEO technology can help to not only connect the two billion people worldwide who are unserved but also improve connectivity for the underserved.

Traditional geostationary satellites can provide some connectivity, but the high latency prevents uses like video calling or online gaming. LEOs offer a low-latency, high-speed connection that supports real-time communication.

In addition to being an interim solution while fiber buildout takes place, LEOs can provide redundancy during disasters and other outages, said Don Means, director of the Gigabit Libraries Network.

York agreed, noting that LEO satellites played an important role in providing connectivity during the aftermath of Hurricane Ian or during wildfires in California.

“Starlink makes it super easy because they can bring one of their trailers into a location, put up a Starlink antenna on the top, bring that connectivity down and then they can share it locally with Wi-Fi access points or cellular access points so people can be able to get that kind of connectivity — first responders, but also people in that local community.”

LEO satellites can provide connectivity even for certain locations that lack a ground station by using inter-satellite lasers, York added.

There are three primary LEO system components. Satellite constellations are made up of hundreds or thousands of satellites, launched into orbit and arranged into “shells” at various altitudes.

User terminals facilitate the transmission and receipt of data to and from the satellites. The antennas are “electronically steerable,” meaning that they can track multiple satellites without physically moving.

The final LEO system component is ground stations, also known as gateways, which are the large antennas and facilities that connect the satellites to the internet.

Advances in rocket technology are driving an increase in LEO satellites, York said. For example, SpaceX is reusing rockets, making launches less expensive. The relatively smaller size of LEO satellites means that they can be mass produced using assembly lines.

However, affordability is still a barrier to widespread adoption, York said. Another challenge is competition with mobile telecom companies for spectrum allocation. ISOC recently released a study discussing these issues and making recommendations for their resolution.

There is also still some uncertainty about the capacity of these connections, York said, pointing to anecdotal reports as well as an Ookla study showing that Starlink’s capacity had decreased in certain areas.

“How much of that is growing pains while Starlink continues to build out the rest of its constellation, versus how much of it might be inherent limitations within the systems?” he asked. “We don’t know. I think we probably won’t know until more of these systems get up and are launched.”

Despite these questions, York was optimistic about the promise of LEO technology: “I think there’s great potential that these systems, as they come online, can truly offer us ways to connect the unconnected.”

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FCC to Establish New Space Bureau, Chairwoman Says

‘The new space age has turned everything we know about how to deliver critical space-based services on its head.’



Photo of FCC Chairwoman Jessica Rosenworcel, via

WASHINGTON, November 3, 2022 — The Federal Communications Commission will add a new space bureau that will modernize regulations and facilitate innovation, Chairwoman Jessica Rosenworcel announced Thursday.

The new bureau is intended to facilitate American leadership in the space economy, boost the Commission’s technical capacity, and foster interagency cooperation, Rosenworcel said, speaking at the National Press Club.

“The new space age has turned everything we know about how to deliver critical space-based services on its head,” Rosenworcel said. “But the organizational structures of the [FCC] have not kept pace,” she added.

The space economy is “on a monumental run” of growth and innovation, the chairwoman argued, and the FCC must remodel itself to facilitate continued growth. Rosenworcel said the commission is currently reviewing 64,000 new satellite applications, and she further noted that 98 percent of all satellites launched in 2021 provided internet connectivity. By the end off 2022, operators will set a new record for satellites launched into orbit, she said.

The FCC will not take on new responsibilities, Rosenworcel said, but the announced restructuring will help the agency “perform[] existing statutory responsibilities better.” In September, Rep. Cathy McMorris Rodgers, R–Wash., warned the FCC against overreaching its statutory mandate and voiced support for robust congressional oversight – a position reiterated by House staffers Wednesday.

“The formation of a dedicated space bureau within the FCC is a positive step for satellite operators and customers across the United States,” said Julie Zoller, head of global regulatory affairs at Amazon’s satellite broadband Project Kuiper, on a panel following Rosenworcel’s announcement.

“An important part of [Rosenworcel’s] space agenda is ensuring that there is a competitive environment in all aspects of that space,” said Umair Javed, the chairwoman’s chief counsel, during the panel. “So we’ve taken action to update our rules on spectrum sharing to make sure that there are opportunities for multiple systems to be successful in low Earth orbit.

“We’ve granted a number of experimental authorizations to companies that are doing really new…things,” Umair continued.

The FCC in September required that low–Earth orbit satellite debris be removed within five years of mission completion, a move Rosenworcel said would clear the way for new innovation.

In August, the FCC revoked an $885 million grant to SpaceX’s Starlink satellite-broadband service. FCC Commissioners Brendan Carr and Nathan Simington criticized the reversal, and Starlink has since appealed it.

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