Thread by @Steved24661

The Starlink disinformation war is in full swing. A quick thread on what is actually going on at the FCC and an explanation why STARLINK -- not Verizon or AT&T -- is actually the legacy player trying to catch up to innovation...

$asts

https://twitter.com/MarioNawfal/status/1824535260920717797

I'll start with a brief reminder that I am not an FCC lawyer and none of what I am saying constitutes legal or financial advice. I'm merely a lawyer conducting my own research, which is something you should do as well. My opinions are my own.

$asts

With that said, the whole spat between SpaceX, Verizon, and AT&T concerns the FCC's newly adopted Supplemental Coverage from Space (SCS) rule. The SCS rule authorizes satellite operators to use MNOs spectrum to create hybrid satellite-terrestrial networks.

$asts

These hybrid networks allow direct to device satellite connectivity, which in turn provides "ubiquitous network connectivity, including in 'dead zones' and other hard-to-reach areas." In other words, the SCS rule sets up the framework for a single network future $asts

But the rule notes that use of terrestrial networks must be done without harmful interference to other terrestrial networks. The rule thus sets a OOBE PFD limit of −120 dBW/m2/MHz at 1.5. SpaceX's problems lie in this requirement. $asts

Indeed, SpaceX recently filed a request for waiver of these OOBE PFD limits, stating that it could comply with the limits "for a single satellite," but that the limit was "not practically achievable on an aggregate basis" (ie, SpaceX's constellation cannot comply with the limit)

So SpaceX requested that the FCC waive the OOBE PFD limits to a less restrictive level. SpaceX claims that the less restrictive limits will not cause harmful interference and are necessary to serve the public interest by allowing SpaceX to provide SCS coverage. $asts

Enter Verizon, AT&T and others who argue that SpaceX has not met the "good cause" standard for a waiver. To secure a waiver, SpaceX must show that strict compliance with the SCS rule is inconsistent with the public interest. $asts

ATT & V argue that the requested waiver does not meet this standard because it directly contradicts the limit in the SCS rule and would cause harmful interference to terrestrial networks. In fact, AT&T notes that the waiver would cause an 18% reduction in D/L throughput. $asts

Admittedly, AT&T and Verizon are not disinterested actors here. They both have recently partnered with AST Spacemobile to provide a satellite mobile broadband service to their customers. The difference is that $asts CAN comply with the OOBE PFD limits while Starlink cannot.

Whether SpaceX's request is successful is now in the FCC's hands. In the past, they have been successful with waiver requests concerning network interference (see e.g., Viasat v. SpaceX and International Dark Sky v. FCC). But those cases seem to be distinguishable...

In Viasat v. SpaceX, the FCC waived the FCC rule that SpaceX obtain a favorable interference finding from the ITU before SpaceX could begin providing commercial service. The FCC waived the req. because SpaceX had performed its own analysis showing it could comply...

and because the ITU was severely backlogged. Viasat appealed. The U.S. Court of Appeals for D.C. Circuit upheld the decision, finding that good cause existed because delay can be a basis to waive an agency requirement. $asts

Moreover, in International Dark Sky v. FCC, the FCC granted a similar "interim waiver" which allowed SpaceX to proceed with its constellation while it waited for the ITU to certify that it complied with power limitations. On appeal, the Court found that the waiver was not...

inconsistent with regulations because the waiver required SpaceX to still receive a favorable finding from the ITU and the waiver would help avoid the harm of long delays. So, according to the Court, the FCC's decision to grant a waiver was reasonable.

Both these cases, however, appear to be distinguishable to me as a lay, non-fcc observer. For the SCS waiver, SpaceX has admitted it CANNOT comply and is requesting a waiver that is directly INCONSISTENT with the rule. This is not a procedural waiver like the other cases. $asts

The public interest analysis will be interesting. In the past, SpaceX was the only game in town who could offer rural broadband. Now, $ASTS can offer broadband while also complying with the SCS rule. I don't know how the FCC can justify a waiver in this instance.

Finally, if you want information about why $asts is technologically better than starlink in basically every single way, check out the amazing DD done by @thekookreport attached to this tweet.

https://twitter.com/thekookreport/status/1797396586907250783

@thekookreport Apologies, I posted the wrong picture to the Viasat v SpaceX case discussion above. The correct picture of the excerpt from the Court’s opinion is attached to this tweet.

And here are some more threads comparing $asts and starlink and explaining why $asts is the superior technology. Courtesy of @CatSE___ApeX___ !

https://twitter.com/catse___apex___/status/1824735941006598156