SpaceX's Lowered Orbit Plans Face Petitions Against
Citing bigger risks of collisions in orbit and stymied use of the 12 GHz band for 5G services, satellite and wireless interests filed petitions Monday with the FCC International Bureau asking it to reject SpaceX plans to relocate 2,824 planned non-geostationary orbit (NGSO) broadband satellites to a lower orbit (see 2004200003). SpaceX didn't comment Tuesday.
Sign up for a free preview to unlock the rest of this article
Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
Satellite operators noted what they said were excessively high failure rates for SpaceX Starlink satellites. At 2%-3%, it's multiple times higher than the company told the FCC it would be, Viasat said. "At this rate hundreds, if not thousands, of Starlink satellites can be expected to become uncontrollable orbital debris that remain a source of collision risk for many years." Investigate the failure rate and "ensure ... vigorous oversight" over Starlink, conditioning approval on achieving and verifying appropriate reliability and collision probability metrics, it said. Also citing what it said were failure rate issues, OneWeb said SpaceX needs to clarify how it proposes to modify the uplink power levels from its Ka-band gateway earth stations so OneWeb can then analyze the potential impacts on its gateway uplink operations in the Ka band.
Amazon's Kuiper said 1,200 SpaceX satellites plus 784 of its own at a 590 kilometer altitude will mean an average of 509 daily conjunction events when two satellites are less than a kilometer apart, more than an order of magnitude increase from what Kuiper had expected based on existing orbital debris. Kuiper said the FCC, once it has resolved space safety concerns, should only consider the SpaceX constellation as part of the 2020 NGSO fixed satellite service processing round.
Kepler agreed with SpaceX that coordination agreements are the best way to handle physical and frequency coordination, saying SpaceX keeps changing its constellation plans, making it difficult to make meaningful progress in assessing and concluding an agreement. If it doesn't reject the SpaceX application outright, the FCC needs to be sure the proposed redesign makes the SpaceX system fundamentally different from what was previously authorized, thus requiring that the system be treated as newly filed and incorporated into the Ku/Ka-band processing round that closed in May, SES/O3b petitioned.
SpaceX's planned modifications would preclude many of the 5G services multichannel video distribution and data services anticipate operating in the 12.2-12.7 GHz band, wrote the Computer & Communications Industry Association and Incompas. They said the FCC should undertake an NPRM on the future of the 12 GHz band, based on a tentative conclusion the band can be used for two-way, fixed and mobile 5G wireless broadband services. DirecTV said the FCC should require SpaceX to show it's complying with internationally recognized equivalent power-flux density limits and fix any interference to direct broadcast satellite receivers on notification. It said the commission also should assess the effect of SpaceX's proposed modified operations on the aggregate interference environment.
SpaceX got some qualified support from Spire. It said since SpaceX assured it will protect the operations of other satellite operators, the license modification should be granted only with a condition requiring it complies with its promises to coordinate operations of its satellites in good faith with current satellite operators and current and future applicants proposing to operate in the 400-600 kilometer altitude range. SpaceX and Telesat said they are discussing their respective applications to modify NGSO systems as part of their good-faith coordination.