DirecTV: 'Widespread' Interference in Opening 12 GHz Band; RS Access: Danger 'Minimal'
DirecTV added to the list of analyses said to show a mobile allocation in the 12.2-12.7 GHz band will cause harmful interference. Even factoring in a variety of assumptions favoring a terrestrial mobile system, the data shows high-power terrestrial operations in the band will result in "significant and widespread harmful interference," DirecTV said in a docket 20-443 filing Monday that included a commissioned study done by satellite consultancy Savid.
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SpaceX's own analysis warning of dire effects to satellite operators using the 12 Ghz band (see 2206220042) is based on "several significantly misleading and unsupportable assumptions," RS Access said Monday. Citing an analysis its consultant, RKF Engineering, did of SpaceX's analysis, RS Access said SpaceX's simulation cherry-picked the Las Vegas partial economic area because it has an atypical interference environment making it "especially inhospitable" to radio coexistence. It said the modeling ignored that SpaceX's Starlink terminals can operate in the 12 GHz band and assumed a ridiculously large number of 5G base stations. Recalculating based on proper assumptions accounts for about 90% of the difference between SpaceX findings and RKF's, it said. "The technical showings, properly analyzed, therefore converge to the conclusion that the effect of 5G deployment on [satellite] exceedance in the 12 GHz band is minimal," it said. SpaceX didn't comment.
DirecTV said the Savid analysis doesn't reflect overlapping interference from adjacent base stations and used the most lenient equivalent power flux density limits in the FCCs rules on protecting DBS from an interference threshold. Despite those assumptions, it said, Savid's analysis found a likelihood of 50% to 70% that DirecTV receivers in suburban or urban areas would get interference from a base station.
DBS, being a one-way service, "cannot afford to lose packets to interference," DirecTV said. Broadband delivery is a two-way communications and can replace lost packets, but DBS lost packets meaning screens freezing, it said. It said other DBS interference analyses in the record "are outdated or irrelevant, and ... do not accurately reflect the characteristics of either a ubiquitous, modern, high-power terrestrial mobile service or DIRECTV’s DBS service." DirecTV urged the FCC to close the 12 GHz proceeding "and give incumbent satellite operators in the band the certainty they need."
The RKF reconciliation study, "like the others Coalition members have previously submitted into the docket, is based on sound science and data that clearly demonstrates coexistence is feasible among two-way terrestrial, mobile 5G, and [satellite] users without significant harmful interference," the 5Gfor12GHz Coalition emailed. "We ... are confident that the data and science, including this new filing, will provide the Commission with the evidence it needs to confirm that opening up this critical spectrum for 5G is not only possible but in the public interest," it said.