Space Exploration Technologies Corp.'s (SpaceX) satellite internet service Starlink will not completely rule out providing coverage in urban areas, even though it is designed to optimize service in rural and underserved areas, according to comments submitted by the company's director of Satellite Policy, Mr. David Goldman to the Federal Communications Commission earlier this month. The submission summarized SpaceX's response to a lengthy study commissioned by RS Access, LLC., which had claimed that the 12GHz spectrum could be shared between multichannel video data distribution service (MVDDS) providers non-geostationary fixed-satellite service (NGSO FSS) providers such as Starlink.
In his latest presentation, the SpaceX executive outlined to the Commission that his internet service can scale up operations to provider converge to 30 million Americans who currently completely lack internet coverage or are undeserved. He also criticized RS's study by stating that it makes overly restricting assumptions about satellite internet, 'cherry-picks' information and uses data unrepresentative of real-world performance.
Starlink Alleges That MVDDS Licensees Are 'Spectrum Hoarders' That Do Not Provide Useful Consumer Service
Mr. Goldman's remarks came in the form of a presentation brought up during a meeting with Commission officials at the start of this month. In this presentation, the SpaceX executive turned his guns on a study submitted by RS Access and conducted by RKF Engineering Solutions. The study had aimed to prove that multichannel video data distribution (MVDDS) service providers and non-geostationary fixed-satellite service (NGSO FSS) providers could use the 12GHz spectrum band without significantly affecting each others' services.
The study had intended to counter an earlier one submitted years back by DISH Corporation, which claimed that the satellite companies could not coexist in the 12GHz band with others. However, Mr. Goldman believes that it is flawed in several areas, as it relies on cherry-picked data, a false rural-urban divide, inaccurate assumptions and end up describing significant interference to the satellite internet users from the MVDDS providers.
GN 17-183 on August 03, 2021
One assumption used in the RKF study was that even if Starlink employed 2.5 million user terminals, the interference from the MVDDS 5G providers would be minimal because the satellite terminals would serve rural areas, and the 5G terminals would be located in urban areas.
In his detailed rebuttal to the study, SpaceX's Goldman countered the assumption by stating that:
Of the 2.5 million user terminals sited by the model (an inaccurately low projection), only 14,600 of them are placed in “metropolitan” Rural Digital Opportunity Fund areas, with the remainder in “non-metropolitan” and rural areas where the study and RS Access, DISH, and the other MVDDS Licensees acknowledge they would never intend to deploy.7 That is, the study assumes that 99.4% of NGSO FSS user terminals will be deployed in such rural areas. This simply does not reflect reality. Although SpaceX’s Starlink system will bring service to the millions of Americans who are presently unserved and underserved by existing broadband options, including in the rural areas that the MVDDS Licensees apparently would have no intention of serving—if they even could or would build out any type of service, which is itself a dubious proposition given their history—SpaceX is authorized to provide, and is providing, a competitive broadband service throughout the United States, which will certainly overlap with any theoretical terrestrial buildout. In fact, a large proportion of SpaceX’s existing Starlink orders come from urban locations.
Additionally, in his presentation, Mr. Goldman also stated that Starlink could scale up service to provide internet connectivity to unserved and underserved Americans. According to him, roughly 30 million people across the United States lack access to adequate internet coverage, and "Starlink's architecture can scale to support America's unserved and underserved population, rural, suburban, and urban."
Other arguments against the RKF study highlight how it uses incorrect elevation angles for the Starlink user terminals. It incorrectly argues that 80% of the user terminals will be installed at ground levels and does not provide adequate details about the 5G MVDDS operating parameters.
Furthermore, he also lambasted an economic study submitted by The Brattle Group alongside RKF's technical study. This study claimed that opening the 12GHz band for 5G use could provide economic benefits worth $1 trillion. In response, the SpaceX executive commented:
Simply put, RS Access’s economic study can only reach its laughably over-the-top conclusions by making the precise opposite assumptions of those made in the RKF Study. RS Access and the other MVDDS Licensees must therefore make clear on the record whether they plan to sell their spectrum to others that will build 1) a large-scale nationwide 5G network in rural and remote areas or 2) a small-scale supplemental capacity network for people already served in dense urban environments. If RS Access plans the first, its technical study—even as flawed as it is— demonstrates it will cause widespread interference to broadband users across the country. But if it’s the second, the economic study shows the minimal benefits are outweighed by the extraordinary costs.
Starlink is currently gearing up to launch the second batch of its first phase of Starlink satellites. The first phase will consist of roughly 4,400 spacecraft - the bulk of which will be at lower inclinations.
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