Support Grows for SpaceX License Mod Conditions; Approval Seen Looming
A growing number of parties suggested technical conditions for any FCC approval of SpaceX's pending license modification to allow a lower orbit for more than 2,800 proposed satellites (see 2004200003), reflecting a sense that some think agency OK will be forthcoming, we're told. A lawyer involved in the proceeding said approval could come as soon as the end of the month. The commission and SpaceX didn't comment Tuesday.
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Viasat, OneWeb and Hughes joined Dish Network (see 2104070041) and RS Access (see 2104120003) in suggesting conditions in recent days. Another lawyer involved in the proceeding said it's too early to tell how the FCC might look at the condition suggestions. He said the level of filing activity suggests the agency is trying to move something forward. He said whether an approval is challenged later in court could depend on conditions.
Any agency approval of the license mod should be conditioned on 19.7-20.2 GHz downlinks being on a secondary basis to geostationary orbit fixed satellite service operations, Hughes said in an International Bureau filing Monday. It said SpaceX also should have to receive a favorable or “qualified favorable” compliance with ITU equivalent power flux density limits for its complete system. In meetings with International Bureau Chief Tom Sullivan and an aide to Commissioner Brendan Carr, OneWeb representatives said the modification should be processed in the 2020 non-geostationary orbit processing round, and SpaceX should be required to choose satellites that avoid in-line interference events with OneWeb in the Ku and Ka band over the continental U.S. and to closely coordinate avoidance events with other operators, rather than relying just on its automated system.
Viasat suggested a variety of conditions, including that SpaceX be required to limit its aggregate collision risk and release enough details into the record to facilitate spectrum sharing in the Ka and Ku bands. It said SpaceX should be required to maintain an orbital tolerance of plus or minus 2.5 km at each nominal altitude at which it wants to operate, so other NGSO systems can share access to the 510-600 km range.
Viasat, which has been actively lobbying against the mod, also ramped up its challenges, especially on sharing spectrum and orbital space, in four additional, separate filings Monday. A recent SpaceX Starlink satellite's close call in orbit, with SpaceX supposedly turning off its automated collision avoidance system, "raises significant questions" about the efficacy of that system and SpaceX's claims that it can mitigate the collision risks of its proposed NGSO system, Viasat said, criticizing the lack of information SpaceX submitted into the record that can be used to calculate total residual collision risk. Viasat separately said the FCC needs to facilitate shared use of the bands by requiring SpaceX to release details such as the number of beams on each satellite, the number of channels per beam, the number of co-frequency reuses per satellite, and satellite and earth station antenna masks.
SpaceX's request to operate at nominal 540, 550, 560 and 570 km altitudes, with tolerances of give or take 30 km, would give it "excessively wide" tolerances that would let SpaceX "'wander' across a large portion of the physical space in low-earth orbit," Viasat said. And it said that due to the number of maneuverability-related failures SpaceX satellites have had, the company should have to divulge to the FCC more data about the number of satellites that experienced failure at or below injection altitude and about failures experienced by its earlier-generation satellites.