5Gfor12GHz Coalition Statement
The 5Gfor12GHz Coalition today responded to a recently filed Starlink submission into the Federal Communication Commission’s (FCC) 12 GHz proceeding, setting the record straight on the company’s misinformation campaign.
Since the FCC initiated the 12 GHz proceeding 18 months ago, the Coalition has worked with top experts, including RKF Engineering Solutions – a preeminent engineering firm with decades of experience in modeling Radio Frequency environments in collaboration with leading telecommunications companies and global regulators – to submit robust, data-driven technical analyses into the record. These studies demonstrate not only that coexistence is feasible in the band, with 99.85% of NGSOs experiencing no risk of harmful interference alongside 5G, but the substantial societal, economic and geopolitical benefits of unleashing more critical mid-band spectrum for two-way terrestrial services. After failing to submit any expert technical input during the public comment and reply comment periods in the proceeding, Starlink has only now submitted a self-produced political document in the guise of a technical analysis. This “study,” which was not produced by an independent expert, is both scientifically and logically flawed, as demonstrated in part by the following:
- In contrast to the nationwide simulation submitted by RKF, Starlink attempts to imply nationwide conclusions based on results it generated from a single cherry-picked partial economic area (PEA): Las Vegas, NV. This PEA’s largest population center is a 141-square mile city that sprawls across the arid Las Vegas Valley. Given its unique topology and morphology, Las Vegas is among the most unfavorable geographies to analyze for co-existence (nearly ten times as unfavorable for 5G/satellite coexistence as the national average).
- Within the Las Vegas assumptions, Starlink grossly distorts the 5G network configuration to create interference with NGSO terminals. For example, Starlink assumes a massive and unprecedented over-deployment of 5G towers that exceeds any realistic network build-out. If the assumptions SpaceX uses in Las Vegas are extrapolated nationwide, they would necessitate the deployment of over 600,000 macro 12 GHz sites across the country. This is wholly unrealistic, as leading nationwide carrier AT&T currently uses only 67,000 macrocells to provide coverage across the entire country to its 81 million subscribers, and with its entire portfolio of spectrum spanning 600 MHz-39 GHz. This assumption alone decimates the scientific and engineering credibility of Starlink’s purported study.
- Starlink also said that a stunning 54 percent of its satellite user terminals in Las Vegas would operate in urban and suburban areas—a deployment model so contrary to Starlink’s network architecture and stated business model that the company appears to have had to slash the number of terminals it intends to deploy in Las Vegas simply to avoid physical capacity constraints inherent in its network design and operating parameters. Starlink has publicly stated that its service will serve a limited number of customers in high-density areas and is really targeted for sparsely populated regions.
In addition to this manipulated filing, Starlink has initiated a public misinformation campaign by falsely telling customers and the public that coexistence is not possible in the band among Starlink and 5G services – despite nationwide data proving otherwise. This tactic, which is commonly used by Elon Musk, is not only disingenuous, but it promulgates an anti-5G narrative that is harmful to American consumers who deserve greater competition, connectivity options and innovation. It also stands to threaten America’s global leadership in the 5G and technology sector as other countries outpace the nation in delivering next-generation services.
The 5Gfor12GHz Coalition – and its 35 members who stand ready to fully utilize the critical 500 MHz of the 12 GHz band – remain committed to working with the FCC and stakeholders to reach a win-win solution for the American people. We will continue to pursue the facts that prove coexistence is possible in the band and advance the public interest.
The 5Gfor12GHz Coalition consists of 35 diverse and prominent public interest groups, trade associations, and companies in the telecommunications sector, calling on the FCC to act swiftly to allow the 12 GHz band to unlock the power of 5G for all Americans. The Coalition consists of the following members and growing: A Side Technology, Airspan, AtLink, Benton Institute for Broadband and Society, Cambridge Broadband Networks Group, Center for Educational Innovation, Center for Rural Strategies, Ceragon, Computer & Communications Industry Association, DISH, Dell Technologies, Etheric Networks, Federated Wireless, Geolinks, Globtel, Go Long Wireless, Granite, Incompas, MMwave Tech LLC, MVD53, Mavenir, Mixcomm, New America, NextLink, Public Knowledge, RS Access, Resound Networks, Rise Broadband, Rural Wireless Association, Tilson, VM Ware, WeLink, White Cloud, X Lab, Xiber.