CAGW Files Additional Comments on Use of the 12 GHz Spectrum Band
Agency Comments
June 11, 2021
Via ECFS
Marlene H. Dortch, Esq.
Secretary
Federal Communications Commission
45 L Street, N.E.
Washington, D.C. 20554
RE: Ex Parté Comments on the Petition for Rulemaking to Permit Multichannel Video Distribution and Data Service (MVDDS) Use of the 12.2-12.7 GHz Band for Two-Way Mobile Broadband Service, RM-11768
Dear Ms. Dortch,
On October 22, 2020, Citizens Against Government Waste (CAGW), a private, nonprofit, nonpartisan organization dedicated to educating the American public about waste, fraud, abuse, mismanagement, and inefficiency in government, offered ex parté comments to the Federal Communications Commission (FCC) opposing the petition filed on April 26, 2016,[1] by the 5G Coalition requesting a Rulemaking to Permit MVDDS Use of the 12.2-12.7 GHz Band for Two-Way Mobile Broadband Service, RM-11768.[2] CAGW also joined in a coalition letter regarding this matter on November 17, 2020, which reiterated our concerns over the potential negative impact undertaking a rulemaking in this proceeding would have on the use of satellite broadband service that would aid in bridging the rural digital divide and fostering increased broadband competition.[3]
CAGW believes that deploying broadband in unserved and underserved areas of the country must be conducted in a technology and vendor neutral all-of-the-above approach that utilizes the best technology available to serve a specific region or community, including cable, fiber, mobile broadband, low earth orbit (LEO) satellites, TV white space, wireless, and wireline communications.
As satellite technology continues to evolve to provide faster, more reliable broadband service to rural areas of the country, it is critical that the FCC make every effort to avoid harmful interference that may be caused by increased use of the 12.2-12.7 GHz band for two-way mobile communications. Considering the technological advancements currently being developed and deployed, the FCC must maintain stringent oversight of the band and ensure that incumbent Non-Geostationary Satellite Orbit and Direct Broadcast Service satellite users of the band can continue to deploy satellites that increase communications capabilities that can also be leveraged for satellite-based broadband services to rural communities.
On January 8, 2021, the Microsoft Innovation and Policy Center filed additional comments regarding the petition that demonstrate how the use of satellite-based broadband can “provide broadband connectivity for Americans in unserved and underserved areas. Realizing greater 5G benefits can and should be accomplished in alternative ways without jeopardizing the benefits that derive from satellite space-to-earth operations in the 12 GHz band.”[4] Given the company’s announcement of a new collaboration with satellite companies like SES and SpaceX to help deliver satellite connectivity between field deployed assets and cloud resources across the country, including its new Modular Datacenter, which “can be transported to the field in even the most rugged conditions,” the FCC must ensure that there is no harmful interference with satellite broadband systems.
The technology being used by LEO satellites, like SpaceX’s Starlink and Blue Origin’s Project Kuiper, is continuing to evolve to bring improved access to broadband to rural areas of the country that would otherwise be left behind due to distance or topography.
For these reasons, along with those cited in CAGW’s previous filings, CAGW requests that the FCC to continue to deny the April 26, 2016 petition request of the MVDDS 5G Coalition.
Sincerely,
Thomas A. Schatz
President
Citizens Against Government Waste
[1] MVDDS 5G Coalition, “Petition of MVDDS 5G Coalition for Rulemaking to Permit MVDDS Use of the 12.2-12.7 GHz Band for Two-Way Mobile Broadband Service,” Federal Communications Commission, April 26, 2016, https://ecfsapi.fcc.gov/file/60001692292.pdf.
June 11, 2021
Via ECFS
Marlene H. Dortch, Esq.
Secretary
Federal Communications Commission
45 L Street, N.E.
Washington, D.C. 20554
RE: Ex Parté Comments on the Petition for Rulemaking to Permit Multichannel Video Distribution and Data Service (MVDDS) Use of the 12.2-12.7 GHz Band for Two-Way Mobile Broadband Service, RM-11768
Dear Ms. Dortch,
On October 22, 2020, Citizens Against Government Waste (CAGW), a private, nonprofit, nonpartisan organization dedicated to educating the American public about waste, fraud, abuse, mismanagement, and inefficiency in government, offered ex parté comments to the Federal Communications Commission (FCC) opposing the petition filed on April 26, 2016,[1] by the 5G Coalition requesting a Rulemaking to Permit MVDDS Use of the 12.2-12.7 GHz Band for Two-Way Mobile Broadband Service, RM-11768.[2] CAGW also joined in a coalition letter regarding this matter on November 17, 2020, which reiterated our concerns over the potential negative impact undertaking a rulemaking in this proceeding would have on the use of satellite broadband service that would aid in bridging the rural digital divide and fostering increased broadband competition.[3]
CAGW believes that deploying broadband in unserved and underserved areas of the country must be conducted in a technology and vendor neutral all-of-the-above approach that utilizes the best technology available to serve a specific region or community, including cable, fiber, mobile broadband, low earth orbit (LEO) satellites, TV white space, wireless, and wireline communications.
As satellite technology continues to evolve to provide faster, more reliable broadband service to rural areas of the country, it is critical that the FCC make every effort to avoid harmful interference that may be caused by increased use of the 12.2-12.7 GHz band for two-way mobile communications. Considering the technological advancements currently being developed and deployed, the FCC must maintain stringent oversight of the band and ensure that incumbent Non-Geostationary Satellite Orbit and Direct Broadcast Service satellite users of the band can continue to deploy satellites that increase communications capabilities that can also be leveraged for satellite-based broadband services to rural communities.
On January 8, 2021, the Microsoft Innovation and Policy Center filed additional comments regarding the petition that demonstrate how the use of satellite-based broadband can “provide broadband connectivity for Americans in unserved and underserved areas. Realizing greater 5G benefits can and should be accomplished in alternative ways without jeopardizing the benefits that derive from satellite space-to-earth operations in the 12 GHz band.”[4] Given the company’s announcement of a new collaboration with satellite companies like SES and SpaceX to help deliver satellite connectivity between field deployed assets and cloud resources across the country, including its new Modular Datacenter, which “can be transported to the field in even the most rugged conditions,” the FCC must ensure that there is no harmful interference with satellite broadband systems.
The technology being used by LEO satellites, like SpaceX’s Starlink and Blue Origin’s Project Kuiper, is continuing to evolve to bring improved access to broadband to rural areas of the country that would otherwise be left behind due to distance or topography.
For these reasons, along with those cited in CAGW’s previous filings, CAGW requests that the FCC to continue to deny the April 26, 2016 petition request of the MVDDS 5G Coalition.
Sincerely,
Thomas A. Schatz
President
Citizens Against Government Waste
[1] MVDDS 5G Coalition, “Petition of MVDDS 5G Coalition for Rulemaking to Permit MVDDS Use of the 12.2-12.7 GHz Band for Two-Way Mobile Broadband Service,” Federal Communications Commission, April 26, 2016, https://ecfsapi.fcc.gov/file/60001692292.pdf.
[2] Citizens Against Government Waste, Letter to the Federal Communications Commission, Ex Parté Communication: Multichannel Video Distribution and Data Service (MVDDS) 5G Coalition Petition for Rulemaking to Permit MVDDS Use of the 12.2-12.7 GHz Band for Two-Way Mobile Broadband Service, RM-11768,” October 22, 2020, https://ecfsapi.fcc.gov/file/102256251657/CAGW%20Ex%20Parte%20Letter%20Re%2012%20GHz%20Spectrum%20Petition%20Request%20RM_11768.pdf.
[3] Coalition Letter to the Federal Communications Commission Commissioners, “RE: RM-11768: Petition for Rulemaking to Permit MVDDS Use of the 12.2-12.7 GHz Band for Two-Way Mobile Broadband Service,” November 17, 2020, https://ecfsapi.fcc.gov/file/1117220120360/RM-11768%20Comment%20FCC%20FinaL.pdf.
[4] Microsoft Innovation & Policy Center, Letter to the Federal Communications Commission, “Re: Petition for Rulemaking to Permit MVDDS Use of the 12.2-12.7 GHz Band for Two-Way Mobile Broadband Service, RM-11768,” January 8, 2021, https://ecfsapi.fcc.gov/file/10109098633162/Microsoft%20ex%20parte%208%20January%202021%20RM-11768.pdf.