BREAKING - 12d after @SpaceX's @FCC modification request for Starlink Gen1 to provide direct-to-handset service using @tmobile@dish's AWS-4 band (https://licensing.fcc.gov/myibfs/download.do?attachment_key=16760354) SpaceX files another license request challenging @globalstar's exclusive spectrum:https://licensing.fcc.gov/myibfs/download.do?attachment_key=16935258[1/4]Apart from the 2020-2025MHz band SpaceX seeks to use the 1610-1617.775 MHz & 2483.5-2500 MHz bands which @globalstar uses for the #iPhone14 sat service, considers "key assets" (https://globalstar.com/Globalstar/media/Globalstar/Downloads/Spectrum/GlobalstarOverviewPresentation.pdf) & promotes to be co-utilized on the ground for small cells (Band 53).[2/4]SpaceX says "Globalstar, has enjoyed exclusive access to portions of the 1.6/2.4 GHz bands, even though the Commission did not provide Globalstar with perpetual exclusive use of the bands", believes "cutting-edge innovations" will ensure they don't cause intereference.[3/4]The application was filed 6-SEP-22, the day before the $AAPL + $GSAT deal was announced with the #iPhone14 premiere. This is the 2nd party after @KeplerComms challenging @globalstar's spectrum (http://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SATPDR2021122400204&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Number - check "other filings" for Globalstar's opposition).P.S.: "SpaceX has not yet submitted system information for ITU publication. SpaceX will submit this information at the appropriate time to the Commission for filing through the U.S. [...]source: https://licensing.fcc.gov/myibfs/download.do?attachment_key=16935259[5/4]
SpaceX application to provide mobile satellite service in the 1610-1617.775 MHz uplink Earth-to-space, the 2020-2025 MHz uplink Earth-to-space, and the 2483.5-2500 MHz downlink space-to-Earth band.They propose to add this to Gen1 as hosted payload.
The lastest modification adds the 1.6GHz and 2.4GHz to the already requested 2.0GHz filing that was done recently.
Following up on the recent Court of Appeal decision on the Gen1 constellation, the Natural Resources Defense Council and International Dark Sky Association filed an opposition to the Gen2 constellation.The thrust of the filing is that a categorical exclusion from NEPA (the environmental assessment law) is unlawful.
Update: SpaceX filed a request to the FCC, asking to appeal the FCC's RDOF decision and saying the denial issued last month "is flawed as a matter of both law and policy."
Wowhttps://twitter.com/Megaconstellati/status/1567614524060061698QuoteBREAKING - 12d after @SpaceX's @FCC modification request for Starlink Gen1 to provide direct-to-handset service using @tmobile@dish's AWS-4 band (https://licensing.fcc.gov/myibfs/download.do?attachment_key=16760354) SpaceX files another license request challenging @globalstar's exclusive spectrum:https://licensing.fcc.gov/myibfs/download.do?attachment_key=16935258[1/4]Apart from the 2020-2025MHz band SpaceX seeks to use the 1610-1617.775 MHz & 2483.5-2500 MHz bands which @globalstar uses for the #iPhone14 sat service, considers "key assets" (https://globalstar.com/Globalstar/media/Globalstar/Downloads/Spectrum/GlobalstarOverviewPresentation.pdf) & promotes to be co-utilized on the ground for small cells (Band 53).[2/4]SpaceX says "Globalstar, has enjoyed exclusive access to portions of the 1.6/2.4 GHz bands, even though the Commission did not provide Globalstar with perpetual exclusive use of the bands", believes "cutting-edge innovations" will ensure they don't cause intereference.[3/4]The application was filed 6-SEP-22, the day before the $AAPL + $GSAT deal was announced with the #iPhone14 premiere. This is the 2nd party after @KeplerComms challenging @globalstar's spectrum (http://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SATPDR2021122400204&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Number - check "other filings" for Globalstar's opposition).P.S.: "SpaceX has not yet submitted system information for ITU publication. SpaceX will submit this information at the appropriate time to the Commission for filing through the U.S. [...]source: https://licensing.fcc.gov/myibfs/download.do?attachment_key=16935259[5/4]FCC filing: SpaceX application to provide mobile satellite service in the 1610-1617.775 MHz uplink Earth-to-space, the 2020-2025 MHz uplink Earth-to-space, and the 2483.5-2500 MHz downlink space-to-Earth band.They propose to add this to Gen1 as hosted payload.
If SpaceX was provided a license to share Globalstars spectrum. Then Globalstar "could be viewed" to be in default of these requirements.
Given Globalstar’s priority position at1610-1617.775 MHz/2483.5-2500 MHz, existing critical services depending on the spectrum, andvery established regulatory precedent to protect such incumbent services, any other operatorseeking to use this spectrum would need to successfully complete coordination with bothGlobalstar’s U.S.-filed HIBLEO-4 system and French-filed HIBLEO-X system (including currentand future satellites for these systems). Based on the scant data provided to date, SpaceX has notdemonstrated that a successful coordination between Globalstar and SpaceX is possible or thatharmful interference would not be expected from SpaceX’s operations to Globalstar’s MSSnetwork. In particular, SpaceX has not provided any actual interference analysis to substantiate itsclaims about “modern communication technologies, sophisticated phased-arrays, and advancedbeam scheduling protocols inherent in its 1.6/2.4 GHz MSS system” that will prevent harmfulinterference with Globalstar’s systems. Vague statements provide no basis for Commission action,5especially when harmful interference could upend the safety-of-life services that Globalstarprovides to consumers and inflict irreparable harm on Globalstar’s MSS business.
Plans to use a part of Ku-band for 5G networks in the United States could disrupt Starlink broadband services even more than SpaceX previously estimated, the company said Oct. 4 as it released interference analysis from a third party.SpaceX said the analysis validates its in-house study in June, when it warned Starlink would be unusable for most Americans if a 5G high-power mobile service is allowed to operate with 12 GHz band frequencies across the United States.The analysis from engineering consulting firm Savid also shows “SpaceX may have underestimated the likelihood of interference and potential harm to Starlink services,” SpaceX senior director of satellite policy David Goldman wrote to the Federal Communications Commission.
Similarly, two independent studies that the European Space Agency (“ESA”) commissioned in 2019—the ATISPADE and ARA studies—show that satellite reentry has a “negligible” effect on the environment.18The ATISPADE study looked at the effect of reentering satellites on the ozone layer. It found that, in the worst case analyzed, the additional yearly ozone reduction was “negligible when compared to the impact of anthropogenic activities,” only between 0.0006% and 0.0008% of global annual ozone loss.19 While the worst case used in the study assumed an average of 450 tons worth of satellites reentering every year and a peak of 650 tons per year,20 the fundamental conclusion—that the impact to the ozone is “negligible” compared to other sources—remains valid even when extrapolating to one order of magnitude more mass per year, as Viasat aggressively assumes would occur.21But Viasat presents no justification for its allegations that these extremely aggressive scenarios will come to pass. Indeed, one leading study raises questions about Viasat’s fundamental premise, finding that the chemical reactions that take place during meteorite reentry do not create alumina at all, even though meteorites contain aluminum.22 In fact, no alumina has ever been detected using rocket-borne spectrometry specifically looking for all aluminum species precipitated by reentering meteorites.The ESA-commissioned ARA study undercuts Viasat’s overblown claims—parroted by NRDC/IDA and others—about the climate effects of the Gen2 satellites. The study found the climate effects of satellite reentry to be minute compared to other man-made sources. For instance, in the worst-case scenario, the annual impact of satellite reentry was 290,000 times less than the annual impact of the aviation sector and 650,000 times less than the annual impact of the road transportation sector.23 Again, even when extrapolated to an order of magnitude greater than the worst case evaluated in the ARA study, the effect would remain negligible relative to other man-made sources. Similarly, assuming the extremely aggressive reentry figures that Viasat touts, the annual impact of reentering Gen2 satellites on Earth’s albedo—the fraction of solar radiation that is reflected away from Earth—will be negligible compared to natural sources (i.e., just 0.005% of the amount of mineral dust created annually through naturally occurring dust storms from the Sahara Desert alone).24
SpaceX remains committed to leading the way on space sustainability, andrecognizes that further dialogue with the scientific community on this issue would be valuable.For instance, the U.S. Government Accountability Office hypothesized that additional “observational data” on the release of alumina from satellite reentry could help the scientificcommunity better quantify emissions and develop “more accurate atmospheric modeling studies.”To that end, SpaceX commits to work with the scientific community to explore methods to collectobservational data on the formation of alumina from satellite reentry. SpaceX will implementreasonable methods that are discovered to the extent practicable and will report findings from thesemeasurements to the Commission.
Additionally, SpaceX hereby notifies the Commission of its intent, following issuance ofthe Gen2 license, to seek a modification of its V-band authorization to significantly reduce thetotal number of satellites ultimately on orbit. SpaceX plans to request Commission authorizationto (1) harmonize the orbital parameters of those V-band space stations with those requested inSpaceX’s pending second-generation (“Gen2”) application and (2) confirm that these V-bandspace stations will be operated as payloads onboard a subset of SpaceX’s proposed Gen2 satellites,and not as separate spacecraft. This modification will not increase, and may slightly reduce, thenumber of V-band space stations and it will not materially affect any other aspects of the V-bandlicense. SpaceX does not anticipate that this change to its planned V-band operations will alterany material aspect of its pending application to deploy and operate Gen2 space stations in the Ku-, Ka-, and E-bands.
Quote SpaceX remains committed to leading the way on space sustainability, andrecognizes that further dialogue with the scientific community on this issue would be valuable.For instance, the U.S. Government Accountability Office hypothesized that additional “observational data” on the release of alumina from satellite reentry could help the scientificcommunity better quantify emissions and develop “more accurate atmospheric modeling studies.”To that end, SpaceX commits to work with the scientific community to explore methods to collectobservational data on the formation of alumina from satellite reentry. SpaceX will implementreasonable methods that are discovered to the extent practicable and will report findings from thesemeasurements to the Commission.Quote Additionally, SpaceX hereby notifies the Commission of its intent, following issuance ofthe Gen2 license, to seek a modification of its V-band authorization to significantly reduce thetotal number of satellites ultimately on orbit. SpaceX plans to request Commission authorizationto (1) harmonize the orbital parameters of those V-band space stations with those requested inSpaceX’s pending second-generation (“Gen2”) application and (2) confirm that these V-bandspace stations will be operated as payloads onboard a subset of SpaceX’s proposed Gen2 satellites,and not as separate spacecraft. This modification will not increase, and may slightly reduce, thenumber of V-band space stations and it will not materially affect any other aspects of the V-bandlicense. SpaceX does not anticipate that this change to its planned V-band operations will alterany material aspect of its pending application to deploy and operate Gen2 space stations in the Ku-, Ka-, and E-bands.
GAO wants FCC to reexamine its 1986 decision excluding most FCC actions from NEPA, particularly regarding mega-constellations. Wants review of whether they normally do not have significant effects on human env & document their findings. FCC agrees. https://gao.gov/products/gao-23-105005
From FCC's reply it doesn't seem that they plan to change anything at the moment, so probably won't affect Gen2, but worth monitoring.
FCC decision on SpaceX's application for its Gen2 Starlink satellites, with some key conditions."Our actions will allow SpaceX to being deployment of Gen2 Starlink"Highlights mine: https://www.fcc.gov/document/fcc-partially-grants-spacex-gen2-broadband-satellite-applicationfcc.gov/document/fcc-p…
SpaceX may have made an error in informing the FCC that it would soon be requesting that the already-authorized 7,500-satellite V-band constellation be folded into the Gen2 constellation. FCC just took that and said that they weren't going to authorize any more satellites and frequency bands.Also, I believe that SpaceX got an Nco = 1 on Gen2, meaning that the overall Gen1+Gen2 will now have a combined Nco=2. I imagine that SpaceX wanted better than that.