SpaceX, Dish Continue Clashing Over 12 GHz

The updated RKF Engineering Solutions study on opening the 12 GHz band for 5G (see 2205200038) "tinkers at the margins .... yet perpetuates most of the flaws of its original report" and introduces new ones aimed at masking interference issues, SpaceX said Monday in docket 20-443. Problems include modeling a terrestrial deployment covering only 10% of the population in each license area and assuming the entire 10.7-12.7 GHz band is available for SpaceX downlinks. It said there's no reason to think any of the parameters in RKF's modeling reflect the mobile service the FCC has been asked to create in the band. SpaceX hasn't submitted any engineering declaration on engineering studies that show higher-power terrestrial operations in the 12 Ghz band can coexist with non-geostationary orbit operations there, Dish Network said. It said SpaceX is seemingly ignoring likely problems with its own proposed second-generation constellation while it raises red flags about the 12 GHz band.