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Spectrum

SpaceX, Engineers Clash over Whether 12 GigaHertz Band Can Be Shared with 5G Operators

Competing submissions to the FCC show the friction over valuable mid-band spectrum.

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SpaceX head Elon Musk

August 10, 2021 – Research commissioned by RS Access showing the mid-band 12 GHz spectrum, a band used by satellite service providers, can be shared with 5G operations has elicited a scathing rebuke by SpaceX — and the engineering firm behind the study is responding in kind.

The FCC is currently studying the possible sharing of the band between satellite providers and mobile wireless carriers for 5G. Broadband Breakfast held a panel discussion in July, which included arguments for and against the spectrum’s flexible use. RS Access’ V. Noah Campbell mentioned the technical study in question during the session, by RKF Engineering Solutions, LLC.

In a filing to the Federal Communications Commission last week, however, SpaceX alleges RKF’s technical study is a “fatally flawed” analysis that washes over the interference consequences that will allegedly happen if the spectrum is shared with 5G operations.

To address interference concerns, the engineering study drew three main conclusions: low-earth orbit satellite user terminals, which SpaceX’s Starlink fleet uses, can reject 5G signals; technology used by mobile wireless networks will direct energy toward handsets, not satellite terminals; and 5G networks will be used largely in higher population areas, whereas Starlink will focus on low-density, largely rural, areas. It also said that without coordination, interference possibilities will affect less than one percent of next-generation satellite operator terminals.

But SpaceX said these conclusions assume that the 5G build-out will only occur in urban areas and limit the next-generation satellite service providers from operating in those areas. The company said while Starlink is “designed to optimize for rural areas initially, it will provide service in urban areas.” It also claims that there will be interference suffered by the satellite terminals on the ground to cause disruptions in service, and ultimately, thousands of customers could be impacted.

SpaceX notes that the $900 million it won in December from the FCC’s $9.2-billion Rural Digital Opportunity Fund – which is currently being reassessed due to complaints of possible overbuilding – backs the fact that urban coverage is part of its agenda.

The company said it has over half a million back orders in its first six months of beta testing its Starlink service with only a third of its LEO fleet deployed (it has over 1,400 satellites launched). It also said it has applied to increase the number of licensed user terminals to 5 million.

RKF engineering firm responds

But RKF said in a filing to the FCC on August 9 that SpaceX misread the study to “find harmful interference where none may exist.” It said the study finds that a 5G network with zero coordination among users of the spectrum would impact fewer than one percent of next-generation satellite terminals. With coordination, such possible interference incidences would be reduced even further, it adds.

RKF, founded in 2001 and known by the last name initials of its founders Phil Rubin, Ted Kaplan, and Jeff Freedman, said this is the only engineering study of its kind in the FCC docket and no company has refuted it.

Other complaints in the Tuesday filing include RKF’s claim that its study did not say that the 5G build-out will only occur in urban areas, noting that the study surveyed less populated areas and found that demand is greatest in more densely populated areas. It also said its study does not preclude SpaceX from operating in any part of the country. It added that SpaceX operations in urban areas with 5G networks is “still readily achievable.”

“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,” David Marshack, chief operating officer of RKF, said in a statement to Broadband Breakfast.

“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.

“The engineering analysis clearly shows that coexistence between satellite and terrestrial 5G in the 12 GHz band is highly feasible,” the statement added. “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.”

Dish Network — the beneficiary of mobile wireless assets from the T-Mobile-Sprint merger and which is using said assets to develop its 5G network – said in a January filing that it hopes the commission would find a way to open the band for 5G use.

Since the other satellite-using C-band spectrum has already concluded its auction, the supply of critical mid-band spectrum for 5G is diminishing. Last month, RS Access filed a study by Roberson and Associates with the FCC claiming that the 12 GHz spectrum is “highly favorable for 5G, resembles lower-mid band frequencies, and can rapidly accelerate 5G deployment nationwide.”

Managing Editor Ahmad Hathout has spent the last half-decade reporting on the Canadian telecommunications and media industries for leading publications. He started the scoop-driven news site downup.io to make Canadian telecom news more accessible and digestible. Follow him on Twitter @ackmet.

Spectrum

FCC Seeking Comments on Licensed Spectrum Allocation for Unmanned Aircraft

Amazon began launch of drone deliveries in two U.S. cities late last month.

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Screenshot of Amazon Drone via Amazon

WASHINGTON, January 4, 2023 – More than two years after its urging, the Federal Communications Commission said Wednesday that it is seeking comment on crafting rules for opening up the lower 5 Gigahertz spectrum band to unmanned aircraft systems, days after Amazon Prime Air began deliveries in two cities using drone technology.

The commission is seeking comments on providing these operators with access to licensed spectrum in the 5030-5091 MHz band for “safety-critical” wireless communications, on whether the commission’s rules on flexible-use spectrum bands are adequate to ensure “co-existence” of ground mobile operations and unmanned aircraft system use, and on a proposal to require such operators to get a license to communicate with air traffic control and other aircraft.

Currently, such unmanned systems operate primarily under unlicensed and low-power wireless communications rules or experimental licenses, according to the FCC. “Given the important current and potential uses for these systems, the Commission will consider ways to improve the reliability of their operations,” the commission said in a release.

“It is past time that we assess the availability of wireless communications resources for the increasingly important remote-piloted aircraft activity we rely on today,” added Chairwoman Jessica Rosenworcel in the release. “The FCC must ensure that our spectrum rules meet the current – and future – spectrum needs of evolving technologies such as unmanned aircraft systems, which can be critical to disaster recovery, first responder rescue efforts, and wildfire management.”

Because it involves flying machines, the rules implicate the Federal Aviation Administration, and because it possibly implicates federal spectrum, it brings in the National Telecommunications and Information Administration, which governs the federal use of spectrum.

“Accordingly, a whole-of-government approach is needed to ensure that this proceeding addresses the relevant concerns and issues within the responsibility of each stakeholder agency and that our efforts in this area work in complement with those of our federal partners to support and promote the safe and productive operation of UAS,” the FCC said in its notice of proposed rulemaking.

The support for wireless communications with UAS in the 5030-5091 MHz band is not new. In 2020, the FCC released a report – mandated by Congress in the FAA Reauthorization Act of 2018 – that found that “alternative frequencies licensed under flexible-use service rules are a promising option for UAS communications,” and that the commission “begin a rulemaking to develop service and licensing rules enabling UAS use of that band.”

The request for comments come after Amazon, which began deliveries of packages using drones in California and Texas last week, asked the FCC in November to allow near-ground level drones to utilize the 60-64 GHz band to facilitate safe operations of the drone.

Amazon had asked the commission to adopt a new perspective on drones, saying a “drone package delivery operating near ground level operates much more like a last-mile delivery truck than a cargo plane.”

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Spectrum

As Debate Over 12 GigaHertz Persist, Satellite Companies Jockey for Nearby Spectrum

The inquiry considers how the spectrum band could be expanded to include mobile broadband services to decrease interference.

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Photo of Eric Graham, OneWeb executive

WASHINGTON, December 26, 2022 – Satellite service provider OneWeb is in support of the Federal Communications Commission’s proposal to open up crucial middle-band spectrum in the 12.7-13.25 GigaHertz (GHz) band for mobile wireless use, given the outstanding fight between satellite and terrestrial service providers over the lower portion of the 12 GHz band.

The FCC has released a notice of inquiry inviting input on how the 12.7-13.25 GHz band could be expanded to include mobile broadband services to decrease interference in the heavily populated 12 GHz band.

The 12.7 GHz band in the United States is primarily allocated to Fixed Service, Fixed Satellite Service, and Mobile Service with limited federal use. The notice of inquiry acknowledges that the need for mobile broadband access for Americans continues to grow “unabated,” necessitating the expansion into more frequency ranges.

The inquiry states that the 12.7 band is “ideal” for the commission to consider as it is already allocated for mobile services on a primary basis domestically, and it appears to be lightly used.

OneWeb, formerly known as WorldVu, is in support of expanding the 12.7 band as it says it reduces congestion on the adjacent 12 GHz band, which has historically hosted fixed satellite systems.

“[It] offers terrestrial operators the requested bandwidth of mid-band spectrum with the same beneficial propagation characteristics present in the 12 GHz band, but with substantially less disruption to incumbent satellite operations and associated harm to American consumers,” read its comment.

The inquiry recognizes that there are alternative, and likely superior, solutions for providing additional mid- band spectrum than by creating new allocations in the heavily used 12 GHz band, continued OneWeb in its comment.

For years, OneWeb claimed, certain 12 GHz terrestrial licensees have demonstrated no regard for “unacceptable” interference they could cause to incumbent satellite operations making intensive use of the 12 GHz band.

Inquiry comes at time when debate over flexible use of the 12 GHz has raged

There has been considerable debate on whether 5G operations can be shared on the 12 GHz spectrum with satellite service providers. Executives at OneWeb argued at a Broadband Breakfast Live Online event that mobile use of the 12 GHz band would “wipe out” the relatively weak satellite signals.

A study published in 2021 by consultancy RKF Engineering Solutions, however, found that the coexistence of 5G and satellite operations in the 12 GHz band was readily achievable, with less than 1 percent of satellite operations being interrupted by terrestrial broadband.

Satellite broadband service provider Starlink  refuted the study , claiming that it is a “fatally flawed” analysis that washes over the interference consequences that will allegedly happen if spectrum is shared with 5G operations. According to Starlink, the study assumes that 5G build-out will only occur in urban areas and disregards the interference suffered by satellite terminals on the ground.

Pressure on the FCC continues to increase as industry advocacy group 5G for 12 GHz Coalition with its 36 members argues for the inclusion of the next generation wireless technology into the expansion of the 12 GHz band.

Backlash against expanding into 12.7 GHz Band 

Other satellite companies, however, are skeptical of the expansion into the 12.7 band that the NOI proposes.

Canada-based satellite provider  Kepler Communications told the commission that increased terrestrial use of the 12.7 GHz band may be unworkable as it raises the risk of interference to the adjacent 12 GHz band.

IntelSat, a multinational satellite service provider, said the 12.7 GHz band shares more technical characteristics with millimeter wave frequencies, which have limited utility for terrestrial mobile broadband, than true mid-band frequencies in the 3 – 6 GHz range. It claimed that the band would not be suitable for mobile broadband uses and would simply interfere with the “highly valuable” fixed satellite services operations currently using the band.

Eutelsat satellite network urged the commission to adopt rules that expand satellite access to the 12.7 GHz band rather than introducing potentially interfering mobile broadband operations in its comments.

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12 Days of Broadband

High Demand for Spectrum Necessitates Increased Cooperation and New Sharing Programs

The FCC licensed a significant amount of the limited available spectrum before its authority to do was set to expire.

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Graphic courtesy of TechHive

From the 12 Days of Broadband:

No matter the year, issues of radiofrequency spectrum is an important topic because of the crucial importance of wireless transmission in modern internet connectivity.

The year 2022 saw many carve-outs of the already limited unlicensed spectrum to tackle growing demand for connections and to relieve congestions on existing frequencies.

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