Gary Zhou 
SpaceX added its support for expanding the use of the 12.7-13.25 GHz Band for mobile broadband in a new filing with the Federal Communications Commission (FCC) on Tuesday. The company noted that although it was already licensed to use the band for uplink operations, it submitted its comment in support of the Notice of Inquiry that the FCC will consider other productive uses of in the U.S.
“SpaceX’s support of this NOI is consistent with its general encouragement of sharing spectrum—when technically feasible—to enable competition and ensure all spectrum is put to its highest and best use. In fact, SpaceX shares all of the spectrum it is licensed to use, both with competing next-generation satellite systems and with other technologies and Federal users. And more broadly, SpaceX encourages the Commission to continue to explore ways to put all spectrum to its highest and best use, including in true mid-band spectrum such as the long-dormant satellite allocation in the AWS-4 frequencies,” SpaceX said.
SpaceX noted that spectrum sharing only benefits Americans when it accounts for the different technologies sharing the band and those operating in adjacent bands.
“Hence, the Commission is wisely moving forward in this proceeding by only exploring possible additional uses that are consistent with the existing uses in this and adjacent bands,” it said.
“This 12.7 GHz Band is currently more lightly used than adjacent bands, such as the 12.2-12.7 GHz band (“12 GHz Band”). While the Commission should certainly account for existing uses in the 12.7 GHz Band and consider methods to either protect those uses or relocate them, such an approach initially appears more tenable in this band than forcing new services that are incompatible with existing services into other more intensively used bands.”
SpaceX noted that adding incompatible technologies in the adjacent 12 GHz band would “result in massive harm to Americans.”
“Consumers throughout the United States rely heavily on satellite downlink operations in the 12 GHz Band for their everyday personal and business broadband needs using highly sensitive user terminals. In this context, the high-power uses proposed in that band will blow out service for millions of Americans only to unjustly enrich notorious spectrum speculators with no benefits for American consumers. Unlike the insurmountable technical challenges in the 12 GHz Band,5 the 12.7 GHz Band is used differently and may be more conducive to sharing, with appropriate rules to protect American consumers using adjacent bands,” it said.
