SpaceX Fed Up With DISH’s “Desperate” Arguments Against Starlink

Space Exploration Technologies Corp.'s (SpaceX) director of satellite policy David Goldman has lambasted DISH Corporation's opposition to his company's Starlink satellite internet service. SpaceX's third modification to Starlink and its use of the 12GHz spectrum band for the service's user terminals have received strong criticism from DISH, who believes that the modification will hamper its coverage and the spectrum use will create interference with DISH terminals in the same area should SpaceX not operate its systems according to parameters submitted to the Federal Communications Commission (FCC) and the International Telecommunications Union (ITU).

DISH Has Been Unable To Find Any Problems With Starlink Over The Course Of A Year States SpaceX

Mr. Goldman's latest comments came in response to DISH's claim that his company is being evasive in response to a detailed Starlink interference analysis submitted by DISH earlier this year. This analysis, conducted by a third-party consultant employed by DISH, states that if SpaceX were to violate certain parameters of Starlink, then the network will create interference with DISH user terminals.

DISH believes that SpaceX will use more than one frequency beam per channel per satellite to connect with its user terminals, which will increase the interference footprint of the devices. SpaceX, on the other hand, has submitted data with ITU and FCC with a Nco (number of beams per satellite) value of 1.

In its analysis, DISH showed that if SpaceX were to stick with its submitted parameters, then Starlink would not interfere with the DISH terminals. However, the company characterized such a parameter as impractical for real-world scenarios that involve multiple users owing to the limited bandwidth capacity of a single beam.

DISH believes that SpaceX's claim that it "simply will not operate as DISH and its paid consultant hypothesize. Instead, it will comply with the terms of its license.” fail to explicitly state that SpaceX will only use one beam per channel per geographic area. The company's executive vice president of external and legislative affairs Mr. Jeffrey Blum believes that

SpaceX fails to clarify whether the possibility is real, whether in fact, it has such a plan, and whether it will operate consistently with that parameter. And, even if it were to finally say that it will do so, what would it mean to operate “consistent with” a Nco of 1?

An excerpt from DISH's report showing interference levels that would exceed the beeping for more than 10% of the time for dishes of varying sizes. According to Telecom, "this is a useful metric as this is the time percentage that roughly corresponds to a long-term event, i.e., the EPFD levels exceeded for more than 10% of the time may cause link margin reduction in the GSO link and can be used to estimate the link availability reduction due to NGSO interference." The 'Baseline' case represents an Eco of 1. Image: DISH Ex Parte Presentation, IBFS File No. SAT- MOD20200417-00037; Call Signs: S2983 and S3018; Expanding Flexible Use of the 12.2-12.7 GHz Band, WT Docket No. 20-443 submitted on February 16, 2021

In response to this, Mr. Goldman believes that DISH's arguments are intended to deprive customers of a new service from access. He also highlights to the FCC that DISH's latest filings show that the company has found no problems with Starlink and that:

Astonishingly, DISH repeatedly claims that SpaceX has not stated for the record how it transmits to a given point on the Earth just days after SpaceX stated on the record that the data SpaceX provided to DISH "actually reflects the way SpaceX operates its system." But having already paid for its flawed technical analysis, DISH cannot take yes for an answer.

In its latest filings with the FCC, DISH states that it has used real-world parameters instead of the ones provided by SpaceX to the FCC to show that Starlink would create interference with DISH terminals despite a Nco of 1. Image: DISH Exparte Filing on March 18, 2021 in FCC dockets IBFS File No. SAT-MOD20200417-00037; Expanding Flexible Use of the 12.2-12.7 GHz Band, WT Docket No. 20-443

DISH also built on its earlier analysis in a new FCC filing by showing that instead of determining the worst-case interference events, if real-world events were to be simulated, then even a Nco of 1 will end up interfering with some of its user terminals.

Mr. Goldman believes that this new analysis is at odds with the existing internationally established approach and it factors in assumptions not present in current evaluation frameworks.

DISH's full new report was filed at the FCC yesterday and in it, its expert explains how "this real-world information is superior to the simulation parameters embedded in the software used by the Radiocommunication Bureau."

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