SpaceX License Mod Includes Near-Hit Reports, Accepting Interference
SpaceX's license modification approval, released Tuesday, has conditions including requirements it coordinate with radio astronomy observatories and regularly report close passes in orbit involving, in addition to restrictions on how it uses the 12 GHz band. These was as expected (see 2104260044). Some critics of the license mod saw good news in the terms.
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Commissioners approved it unanimously. No commissioners issued statements. SpaceX didn't comment.
The altitude cap and condition that SpaceX accept additional interference stemming from its redesign "is a positive outcome," an Amazon spokesperson said: "These conditions address our primary concerns regarding space safety and interference."
Viasat said it's "pleased the Commission confirmed that Starlink satellites must be reliable and safe, and also recognized the need to assess the cumulative (aggregate) collision risk presented by the entire Starlink constellation." But it said it doubts other nations "will follow the FCC’s approach to providing near-exclusive use of limited LEO orbits and spectrum that, by necessity, must be shared by multiple LEO systems." It's disappointed the FCC didn't embrace arguments for a National Environmental Policy Act review of SpaceX plans.
The order saying SpaceX "proceeds at its own risk" on its use of the 12.2-12.7 GHz band and what may happen in the 12 GHz rulemaking shows how seriously the agency is looking at the possibility of opening the band to terrestrial mobile use, RS Access CEO Noah Campbell told us.
Allowing SpaceX to lower 2,814 planned non-geostationary orbit (NGSO) satellites from a 1,100-1,300 km range to 540-570 km means better broadband service for remote, underserved areas, the redesign doesn't present an interference problem, and the lower altitude will help with orbital debris mitigation, the FCC said. It said the approval comes "under the existing satellite precedent and licensing framework" and doesn't look at SpaceX's ability to meet Rural Digital Opportunity Fund obligations.
The conditions include having to coordinate operations in the 10.7-11.7 GHz band with radio astronomy observatories, capping its satellites' orbits at 580 km, and limiting its use of the 19.7-20.2 GHz band to one beam per satellite per area. The FCC said the Starlink constellation has to accept any additional interference stemming from the modification from constellations authorized in the 2016 NGSO processing round. It said SpaceX also has to accept additional interference from Amazon's Kuiper constellation into its Ka-band uplinks stemming from the modification.
The agency required a semiannual report, due every Jan. 1 and July 1, about the number of conjunction events over the previous six months, including the number that required some action, like maneuvering or coordination with another operator. Separately, SpaceX must report if there are three or more satellite disposal failures in any 12-month period, including the assessed cause of the failure and remedial actions for each of the disposal failures.
The agency rejected arguments raised by numerous critics that SpaceX's redesign should be treated as part of the 2020 NGSO processing round instead of the 2016 one. Since potential increases in interference are offset by diminished interference overall, the modification doesn't need to be treated as a newly filed application, the FCC said.
The regulator rejected arguments for environmental assessments of SpaceX's constellation, noting its work to lessen effects of its constellation on astronomy. The FCC "will continue to monitor this situation and SpaceX’s efforts to achieve its commitments in this record." The agency said questions about whether SpaceX's antenna for its Ka-band gateway transmissions is out of compliance with its authorization are outside the scope of the license mod proceeding. It said use of parabolic antennas on SpaceX satellites wouldn't cause significant interference problems. Some operators had raised red flags about SpaceX moving from phased array to parabolic antennas without notifying the agency (see 2103300024).