5Gfor12GHz Coalition Statement
The 5G for 12GHz Coalition today responded to a Starlink submission recently filed under Federal Communication Commission (FCC) 12GHz proceedings, setting the record straight on the company’s misinformation campaign.
Since the FCC initiated the 12 GHz procedure 18 months ago, the Coalition has worked with top experts, including RKF Engineering Solutions – a preeminent engineering company with decades of experience modeling radio frequency environments in collaboration with major telecommunications companies and global regulators – to submit sound, data-driven technical analysis on file. These studies show not only that in-band coexistence is possible, with 99.85% of NSOs experiencing no risk of harmful interference alongside 5G, but the substantial societal, economic and geopolitical benefits of freeing up more critical midrange spectrum for two-way terrestrial services. After failing to submit expert technical input during the public comment and response comment periods in the proceedings, Starlink has only just submitted a self-produced policy document under the guise of technical analysis. This “study,” which was not conducted by an independent expert, is both scientifically and logically flawed, as demonstrated in part by the following:
- Unlike the national simulation submitted by RKF, Starlink attempts to infer national conclusions based on the results it generated from a single selected Partial Economic Area (PEA): Las Vegas, NV. The largest population center of this PEA is a 141 square mile city that stretches across the arid Las Vegas Valley. Given its unique topology and morphology, Las Vegas is among the most unfavorable geographic areas to analyze for coexistence (nearly ten times more unfavorable to 5G/satellite coexistence than the national average).
- Under the Las Vegas assumptions, Starlink grossly distorts the 5G network configuration to interfere with NGSO endpoints. For example, Starlink assumes a massive and unprecedented over-deployment of 5G towers that exceeds any realistic network build. If the assumptions used by SpaceX in Las Vegas are extrapolated nationwide, they would require more than 600,000 12 GHz macro sites to be deployed across the country. This is totally unrealistic, as the main national carrier AT&T currently only uses 67,000 macrocells to provide nationwide coverage to its 81 million subscribers, and with its entire spectrum portfolio covering 600 MHz to 39 GHz. This assumption alone decimates the scientific and technical credibility of the alleged Starlink study.
- Starlink also said that as many as 54% 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 reduce 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 launched a public disinformation campaign by falsely telling customers and the public that in-band coexistence is not possible between Starlink and 5G services – despite national data proving otherwise. This tactic, commonly used by Elon Musk, is not only misleading, it promulgates an anti-5G narrative that harms American consumers who deserve more competition, connectivity options, and innovation. It also risks threatening America’s global leadership in 5G and technology as other countries outpace the nation in delivering next-generation services.
The 5Gfor12GHz Coalition – and its 35 members who are ready to make full use of the critical 500 MHz of the 12 GHz band – remain committed to working with the FCC and stakeholders to achieve a win-win solution for the American people. We will continue to seek out the facts that prove coexistence is possible in the band and advance the public interest.
The 5G for 12GHz Coalition consists of 35 diverse and prominent public interest groups, trade associations and telecommunications companies, calling on the FCC to act quickly to enable the 12 GHz band to unleash the power of 5G for all Americans . The Coalition is made up of the following members and continues to grow: 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.