SpaceX is taking another stab at quashing Dish’s attempts to use the 12 GHz band for 5G, this time submitting a technical analysis by the third-party engineering firm of Savid LLC that it says validates SpaceX’s own previous study and underscores the notion that Dish’s plans would undermine satellite services in the band.

The Savid analysis leaves “no doubt that giving Dish and Dell’s personal trust fund a windfall in the 12 GHz band would effectively end service to Americans who already depend on the band,” SpaceX told the FCC in an October 4 filing.

“In fact, Savid’s analysis ‘revealed some conservative assumptions’ in SpaceX’s study, concluding that not only was SpaceX’s study more accurate than the submission by RKF, but that SpaceX may have underestimated the likelihood of interference and potential harm to Starlink services,” wrote David Goldman, senior director of Satellite Policy at SpaceX.

SpaceX describes it as a “spectrum grab” on the part of Dish and urged the commission to end the proceeding and remove the “cloud hovering over millions of Americans who depend on the satellite services provided in this band.”

It’s been a long simmering battle between SpaceX and the Dish camp, which includes RS Access, a firm tied to Dell Technologies founder Michael Dell. The fight reached new heights over the summer after SpaceX urged Starlink fans to send comments to the FCC. The 5G for 12 GHz Coalition called it a “misinformation campaign” and pointed the finger at SpaceX founder Elon Musk for what they called “disingenuous” tactics.

In its latest filing, SpaceX says the Dell family trust “tried to move the goal posts” once again by claiming that only a third party could truly analyze the harm Dish would cause. To address that point, SpaceX said it engaged the independent engineering consulting firm of Savid to evaluate both SpaceX’s previous study, submitted in June, and criticisms by Dish and Dell.

Savid is the same satellite and space systems consulting firm that DirecTV in July cited as the source of a study that showed mobile operations in the 12 GHz band would cause extensive harmful interference to DirecTV receivers.  

SpaceX provided a copy of the Savid study to the FCC and said the record is definitive that unavoidable interference would be caused by high-power transmitters in the 12 GHz band if Dish were allowed to use it for 5G. That would be “devastating for millions of American consumers who depend on the satellite services in the band,” SpaceX told the commission.

Dish’s response

Of course, Dish sticks by its argument that coexistence in the band is possible. 

“SpaceX’s latest submission follows the company’s familiar pattern: making exaggerated claims in service of trapping 500 MHz of 5G-ready spectrum. It is no surprise that today’s filing from SpaceX includes a flawed technical analysis that purports – unsuccessfully – to rebut the multiple studies submitted to the FCC from the best experts in the field that have concluded that co-existence is eminently possible,” said Jeff Blum, EVP, External and Legislative Affairs at Dish, in a statement provided to Fierce.

“We urge the FCC to move forward to unleash this critical mid-band spectrum for 5G use,” Blum added.

Middle ground?

Based on a quick review of the analysis, analyst Tim Farrar of TMF Associates said the truth almost certainly lies somewhere between the Dish/Dell position that there is an “extremely low risk” of harmful interference and the SpaceX position that there will be disastrous interference to the vast majority of terminals.

He also noted that it’s important to remember that not all Starlink terminals will be operating in this part of the spectrum at any given time, since it represents only 25% of the downlink band.

“The value of this spectrum for terrestrial remains to be seen,” he said, as everyone is struggling to find compelling use cases for 5G beyond fixed wireless access (FWA) and that will be needed to justify widespread deployment of higher frequencies. Millimeter wave, for example, seems very much on the back burner at the moment, he said. On the other hand, “the FCC is finding it ever more challenging to refill the spectrum pipeline as all the potential bands that could be repurposed for 5G have difficult trade-offs and knotty interference problems,” he said.

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