A new paper concluding no mitigation steps Starlink takes short of launching significantly fewer satellites can prevent its light pollution effects on astronomy is more proof that SpaceX's proposed second-generation constellation needs environmental review under the National Environmental Policy Act and Section 1.1307 of the FCC’s rules, Viasat told the International Bureau Monday. SpaceX didn't comment.
Tariff classification rulings
Numerous satellite operators agree systems authorized in earlier processing rounds should be protected from later-round systems, but there's little common ground beyond that, per docket 21-456 reply comments Tuesday. The FCC got pushback in the proceeding against sunsetting interference protections given to earlier round systems (see 2203280029). With big disagreements on many issues raised in the NPRM, the FCC should move with "extreme caution," Boeing said. It said support was widespread for band splitting only among systems authorized as part of the same application processing round. It said Viasat arguments that the band-splitting approach would encourage launch of an excessive number of NGSOs don't jibe with the fact most proposed constellation sizes "are reasonably related to their target customer markets and throughput capacity." Viasat repeated that instead of band splitting, the FCC should look at angle splitting during in-line events and to expand the proceeding scope to cover interrelated NGSO issues. Kepler saw "some merit" in Viasat's argument that not evaluating NGSO spectrum sharing rules in a single proceeding could undermine the goals of the 21-456 proceeding. Kepler said there's no overall consensus on how to protect early systems from later-round ones. Beyond protecting earlier-round systems, the FCC should require operational systems share beam pointing and satellite selection data and avoid subjective metrics such as “spectral efficiency,” OneWeb said. The lack of comments about spectral efficiency is "deafening," and reinforces the concern that many operators aren't planning to develop systems designed to share spectrum, SpaceX said. It said there's little agreement on methodology for establishing a quantifiable level of protection that later-round systems must give earlier systems. Intelsat called for keeping the case-by-case treatment of later-round systems, saying doing otherwise would encourage earlier-round grantees to build inflexible NGSO systems. The biggest broadband connectivity impediments are availability of affordable service and digital literacy, not speed of available services, Satellite Industry Association said. It urged "technology inclusive" policies.
The sustainability of outer space is threatened by the debris threat from low earth orbit mega constellations, increasing aluminum in the upper atmosphere from satellite re-entries, and orbital congestion, Inmarsat CEO Rajeev Suri said Tuesday at the Royal Aeronautical Engineering Conference, in prepared remarks. "If these mega-constellations gave us immediate access to something we do not have today, or that we can't get in less risky ways, they might be worth considering," he said. "But, they do not, and I do not think it makes me a Luddite to say let’s understand more now rather than regret things later." He added "there is a role for LEO constellations," and said a "small and highly targeted LEO satellite constellation" will be part of Inmarsat's planned Orchestra mesh network of satellite and terrestrial 5G capabilities.
A preliminary analysis of equivalent power flux density data from SpaceX shows multiple instances of its proposed second-generation system exceeding equivalent power flux density limits, Viasat told the FCC International Bureau Monday. It said it used the same methodology as SpaceX, separately evaluating the 18 smaller tranches of second-gen satellites instead of the Starlink system as a whole. The FCC "cannot accept SpaceX’s claimed EPFD compliance at face value" or approve the expanded Starlink system before meaningful EPFD analysis by the commission and ITU, it said. SpaceX didn't comment Tuesday.
Plaintiffs in two securities suits against space launch company Astra Space asked the U.S. District Court in Brooklyn to consolidate the suits, per a stipulation Tuesday in docket 1:22-cv-00737. Seeking class-action status, both suits allege Astra oversold its launch capabilities when it went public in 2021.
Earth observation company Planet is seeking FCC OK to supplement its non-geostationary orbit earth imaging constellation with up to 32 of its next-generation Pelican satellites. In an International Bureau application last week, it said the first Pelican is slated for an early 2023 launch. It said Pelicans will replace its existing SkySat fleet of satellites as the SkySats reach their end of life.
NASA hired six commercial satellite communications companies to develop and demonstrate near earth space communication services that could be used to support future agency missions. It said Wednesday it has been looking at the feasibility of using commercial satcom as it works to decommission its near-earth satellites. Five-year Communications Services Project agreements totaling $278.5 million were signed with Inmarsat, Kuiper, SES, SpaceX, Telesat and Viasat. NASA said it anticipates seeking multiple long-term contracts for near earth services by 2030.
OneWeb's proposed amendment to its U.S. market access grant (see 2101130002) is facing some pushback from other satellite operators. OneWeb's plans for a complex multistage rollout continues its general effort "to push the burden of coordination completely to other operators despite the harm this burden shifting does to those operators’ customers," SpaceX told the FCC International Bureau this week. It said any FCC consideration of the application needs to hold off until OneWeb provides necessary information missing in its application, such as how the two phases would interact and an updated and complete analysis of the interference its proposed modification would cause to other non-geostationary orbit (NGSO) systems. Amazon's Kuiper said the FCC typically would look at plans like OneWeb's -- adding 6,372 satellites in Phase 2 -- as a newly filed application and handle it as part of the 2020 processing round instead of the 2016 processing round. The phased rollout is designed to avoid that issue and keep its 2016 processing round status for its already authorized satellites, and the FCC should clarify the processing round status of OneWeb's phased modifications, and put the same rules and conditions on it that it imposed on other NGSO fixed satellite service licensees, it said. SES/O3b urged the FCC to require OneWeb to submit materials confirming its NGSO system will comply with ITU equivalent powerflux density limits to ensure that geostationary orbit satellite networks and their customers get interference protection. "There are limits to the extent to which LEO can be populated in a safe and sustainable manner," Viasat said, asking the FCC to limit the aggregate collision risk of the expanded OneWeb constellation. Viasat also said the agency should ensure any expansion of OneWeb's presence in space doesn't undermine low earth orbit satellite operations' sustainability or limit the ability of other satellite operators to share spectrum.
Telesat expects to put up as many as 2,020 satellites during a 15-year span for its planned low earth orbit broadband constellation, it told the FCC International Bureau this week. Phase 1 of the constellation would be 298 satellites, with 1,671 in Phase 2, plus spares and replacements, it said. The satellites' design life would be 11 years, including a 10-year service life and six months for orbit lowering, Telsat said. It said it expects a “favorable” or “qualified favorable” finding by the ITU Radiocommunication Bureau on compliance with applicable equivalent power flux density limits.
Space interests applauded the White House announcement Monday that the U.S. committed to not doing direct-ascent anti-satellite missile testing and is urging other nations to make similar promises. The U.S. "is demonstrating leadership at the international level," the Secure World Foundation said. "As productive discussions in multilateral fora continue on norms and principles for responsible behavior in space, this new U.S. policy sends a clear message about U.S. commitment to ensuring the long-term sustainability of outer space." The announcement demonstrates "continued American leadership in establishing responsible norms of behavior in space," LeoLabs tweeted. "Working with international partners and commercial companies, the US has an opportunity to foster a safe space environment and protect the critical services that space-based resources provide to humanity, like global communications and essential climate data," emailed Planet Labs, which urged the U.S. earlier this month to lead an international effort against such weaponry (see 2204150007).