Author Topic: Starlink : New FCC and ITU Filings  (Read 344071 times)

Offline OceanCat

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Re: Starlink : New FCC and ITU Filings
« Reply #660 on: 05/25/2024 02:23 am »
SpaceX is asking FCC to apply the same conditions in Gen2 authorization to other constellations, so far they have filed request against Kuiper V band and AST SpaceMobile constellation.

The 5 conditions they asked FCC to require other constellations to meet are:
• file semi-annual reports on collision avoidance maneuvers and satellite disposal, including
any difficulties or failures related thereto;
• apply a new performance-based method for assessing disposal failures that accounts for
both the number of failed satellites and their entire passive decay time;
• communicate and collaborate with NASA to promote space safety and sustainability;
• take all possible steps to assess and mitigate collision risk after receiving a conjunction
warning from the 19th Space Defense Squadron or other source; and
• coordinate with NSF to reach a mutually acceptable agreement to mitigate the impact of
its satellites on optical ground-based astronomy, with associated annual reporting
requirements.

SpaceX had a follow up meeting with the FCC to highlight how inconsistently the FCC applied the requested conditions.


Online gongora

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Re: Starlink : New FCC and ITU Filings
« Reply #661 on: 07/04/2024 12:27 am »
More permits for testing Starlink on F9 second stage on flights from Vandy and Florida
1276-EX-ST-2024
1277-EX-ST-2024

Offline OceanCat

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Re: Starlink : New FCC and ITU Filings
« Reply #662 on: 07/21/2024 06:39 pm »
SpaceX comments on milestone extension requests.

Quote
...
SpaceX’s upcoming V-band milestone modification application, along with pending requests
from other operators, provide an opportunity for the full Commission to reaffirm
these policies and set a consistent baseline for all operators (footnote: SpaceX does not expect
to meet its deployment milestone for its V-band license. Therefore, SpaceX expects to file
a modification application in which it states its strong preference, consistent with the policies
underlying the Commission’s milestone framework, to have any yet-undeployed satellites
deferred to a subsequent V-band processing round.)
...
The full Commission must address pending and future deployment milestone extension
requests because they raise novel facts and issues and lack clear precedent and guidelines.
...
For example, in its
opposition to Telesat’s extension request, Amazon has bent over backwards to parse factors in a
transparent effort to harm Telesat’s potential customers while anticipating factors that might
support Amazon’s own milestone modification application due to its foreseeable and
unexceptional delays in deploying its own system. Amazon has confusingly identified COVID as
a valid justification for extension in its view, even years after the pandemic’s main brunt, but only
with respect to COVID-related supply chain issues and personnel shortages, and not with respect
to Telesat’s unforeseeable contract issues. Similarly, Amazon attempts to discount Telesat’s
efforts to avoid delays, make investments, and progress toward meeting buildout milestones,
seeking to knock Telesat’s 2016 processing round system out of competition, while setting itself
up to invoke the very same factors in its favor when Amazon ultimately files its own milestone
modification application.
...
Pending requests for deployment milestone modifications such as the one SpaceX will file
shortly present the Commission with an obligation and an opportunity. Requests in these
applications to extend milestone dates cannot be addressed on delegated authority because they
involve novel facts and issues and lack outstanding Commission precedents and guidelines on
which to rely, particularly in view of the receding COVID-19 pandemic and recent major updates
to the Commission’s NGSO spectrum sharing framework. More broadly, the Commission has the
opportunity to reaffirm clear policies and guidance for NGSO operators that fail to meet their
deployment milestones but nevertheless seek to continue deploying satellites to serve consumers.
Specifically, the Commission should declare that any deployment milestone extension request is a
modification application to defer the undeployed portion of an authorized system to a subsequent
NGSO processing round, allowing an actual, limited extension of the milestone date only under
truly rare and exceptional circumstances. Doing so will provide a consistent means to address
pending—and future—extension requests that preserves the integrity of the processing round
framework while avoiding the arbitrary line-drawing and disparate treatment that attends case-bycase
review divorced from the consequences to other systems that share spectrum with the requester.
« Last Edit: 07/21/2024 08:59 pm by OceanCat »

Offline RedLineTrain

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Re: Starlink : New FCC and ITU Filings
« Reply #663 on: 07/26/2024 03:28 pm »
Yes, this is unfolding as expected.  SpaceX's argument might be right, but it is complicated.  It's good for them to point out that Amazon is talking out of both sides of its mouth (while doing a bit of the same itself, albeit to a much lesser degree).

It seems likely that the FCC will give a one or two-year COVID extension to everybody and indicate that any additional extensions will be very rare -- presumed denial.  The FCC probably will want Kuiper to launch its full constellation, so that might mean a two-year extension.  Telesat will also have an equal extension, but that would effectively mean that its constellation will go to the third round.

We also have the full 30,000 Starlink Gen2 satellite approval coming up in a year or two.  It looks like SpaceX will be able to hit all the milestones on that even without an extension, but the FCC wouldn't want to be seen as approving second round additions while kicking others to the third round.
« Last Edit: 07/26/2024 03:49 pm by RedLineTrain »

Offline OceanCat

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Re: Starlink : New FCC and ITU Filings
« Reply #664 on: 08/14/2024 09:14 am »
SAT-MOD-20240813-00183

Quote
SpaceX herein applies to modify its first processing round V-band space station
authorization so it may continue to launch V-band-capable satellites
...
To date, SpaceX has launched 1,052 Gen2 satellites with V-band capabilities and expects
to have launched a total of approximately 1,530 by the milestone date. At its current rate of satellite
launches, SpaceX would deploy half of its originally authorized V-band system of 11,943 satellites
by October 2026 if allowed to continue launching under the proposed modification after November
19, 2024.
...
Specifically, here, SpaceX requests that the
Commission modify the authorization for its V-band system as follows:

1. SpaceX’s first V-band NGSO processing round system shall include only the number
of V-band payloads on Gen2 satellites that SpaceX has launched on or before
November 19, 2024;

2. SpaceX may deploy additional V-band payloads on Gen2 satellites, up to 7500
satellites as authorized, after November 19, 2024, but those satellites will be considered
part of the second V-band NGSO processing round; and

3. The deployment of those additional V-band payloads on Gen2 satellites will be subject
to new milestone requirements in accordance with Section 25.161(b) based on the date
that the first second-round V-band NGSO system of another operator was authorized.
...
SpaceX is the only Commission-authorized NGSO operator to have deployed
any satellites with V-band capabilities and may be the only first-processing-round V-band system
that will ever deploy. The Commission authorized six other V-band NGSO satellite systems in
the same processing round as SpaceX. It declared one authorization null and void (Audacy),
and three other operators (Boeing, O3b, and Telesat) have surrendered their authorizations.
A fifth operator (Theia) is involved in bankruptcy proceedings. And the sixth operator (Viasat)
announced it has “no plans to deploy its own LEO constellation” and to SpaceX’s knowledge
has not launched any V-band satellites into its authorized MEO orbits. A second V-band
processing round is currently pending, but only two applications have been accepted for filing
(one of which was recently granted).
...

Offline RedLineTrain

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Re: Starlink : New FCC and ITU Filings
« Reply #665 on: 08/14/2024 03:00 pm »
SAT-MOD-20240813-00183

Quote
SpaceX herein applies to modify its first processing round V-band space station
authorization so it may continue to launch V-band-capable satellites
...
To date, SpaceX has launched 1,052 Gen2 satellites with V-band capabilities and expects
to have launched a total of approximately 1,530 by the milestone date. At its current rate of satellite
launches, SpaceX would deploy half of its originally authorized V-band system of 11,943 satellites
by October 2026 if allowed to continue launching under the proposed modification after November
19, 2024.
...
Specifically, here, SpaceX requests that the
Commission modify the authorization for its V-band system as follows:

1. SpaceX’s first V-band NGSO processing round system shall include only the number
of V-band payloads on Gen2 satellites that SpaceX has launched on or before
November 19, 2024;

2. SpaceX may deploy additional V-band payloads on Gen2 satellites, up to 7500
satellites as authorized, after November 19, 2024, but those satellites will be considered
part of the second V-band NGSO processing round; and

3. The deployment of those additional V-band payloads on Gen2 satellites will be subject
to new milestone requirements in accordance with Section 25.161(b) based on the date
that the first second-round V-band NGSO system of another operator was authorized.
...
SpaceX is the only Commission-authorized NGSO operator to have deployed
any satellites with V-band capabilities and may be the only first-processing-round V-band system
that will ever deploy. The Commission authorized six other V-band NGSO satellite systems in
the same processing round as SpaceX. It declared one authorization null and void (Audacy),
and three other operators (Boeing, O3b, and Telesat) have surrendered their authorizations.
A fifth operator (Theia) is involved in bankruptcy proceedings. And the sixth operator (Viasat)
announced it has “no plans to deploy its own LEO constellation” and to SpaceX’s knowledge
has not launched any V-band satellites into its authorized MEO orbits. A second V-band
processing round is currently pending, but only two applications have been accepted for filing
(one of which was recently granted).
...

Interesting and potentially significant curveball.  It doesn't appear to be an extension request after all.  Rather, it's a request to push unlaunched satellites to a later processing round.  I don't think anybody but SpaceX (and potentially the FCC) would like this precedent because of the impacts on the more heavily used Ku- and Ka-bands.

I still think that the FCC may add a year or two to deadlines in order to account for Covid.  It is easily portrayed as an exceptional occurrence.  Hard to argue against it.  However, it will be interesting to see if the FCC is tempted by SpaceX's proposal.  It seems possible that the FCC will combine the two approaches:  a one or two-year extension and thereafter pushing unlaunched satellites to a later round.
« Last Edit: 08/14/2024 03:08 pm by RedLineTrain »

Offline GreenShrike

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Re: Starlink : New FCC and ITU Filings
« Reply #666 on: 08/14/2024 04:34 pm »
SAT-MOD-20240813-00183

Quote
SpaceX herein applies to modify its first processing round V-band space station
authorization so it may continue to launch V-band-capable satellites
...
To date, SpaceX has launched 1,052 Gen2 satellites with V-band capabilities and expects
to have launched a total of approximately 1,530 by the milestone date. At its current rate of satellite
launches, SpaceX would deploy half of its originally authorized V-band system of 11,943 satellites
by October 2026 if allowed to continue launching under the proposed modification after November
19, 2024.
...

Interesting and potentially significant curveball.  It doesn't appear to be an extension request after all.  Rather, it's a request to push unlaunched satellites to a later processing round.  I don't think anybody but SpaceX (and potentially the FCC) would like this precedent because of the impacts on the more heavily used Ku- and Ka-bands.

I still think that the FCC may add a year or two to deadlines in order to account for Covid.  It is easily portrayed as an exceptional occurrence.  Hard to argue against it.  However, it will be interesting to see if the FCC is tempted by SpaceX's proposal.  It seems possible that the FCC will combine the two approaches:  a one or two-year extension and thereafter pushing unlaunched satellites to a later round.

Note that I read this thread because of amusing SpaceX snark about other filings, not because I actually understand FCC business, so forgive me if this seems simplistic or obvious.

I may be wrong, but I understand (or I think I do, from the above), that SpaceX has until October this year to launch half of its ~12k V-band constellation, that from their estimates will only hit ~1.5k by the deadline, and that at their current deployment rate will hit the half-constellation milestone in October 2026 -- i.e. two years late.

But if the FCC just hands out essentially blanket 2-year extensions because of COVID-related inconvenience, that would mean that SpaceX could squeak by and hit that half-constellation milestone, right?

And then they'd retain Round 1 (which is just about priority in using the RF bands?) privileges for the entire constellation (assuming they complete the second half of the constellation on time)?
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Online DanClemmensen

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Re: Starlink : New FCC and ITU Filings
« Reply #667 on: 08/14/2024 04:53 pm »
How does SpaceX intend to use V-band? It's a poor choice for space-to-ground and ground-to space compared to Ku or even Ka, However, I then learned that Starlink currently has a really annoying problem: if you do not have a good view of the sky in the pole-ward direction, you cannot use Starlink now. That's because The GEO satellites have priority for Ka and Ku, so you cannot in general transmit from the ground in the equator-ward direction and Starlink satellites cannot transmit toward the ground from the equator-ward direction. But Starlink would have priority in the V-band, so it can be used in all directions. My daughter has a cabin in the Sierras on a south-facing slope. This is not just theoretical for me.

Online gongora

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Re: Starlink : New FCC and ITU Filings
« Reply #668 on: 08/14/2024 06:33 pm »
Right now for Starlink only Ku is used for the consumer terminals, everything else is used for gateway communications.

Offline RedLineTrain

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Re: Starlink : New FCC and ITU Filings
« Reply #669 on: 08/14/2024 09:44 pm »
I may be wrong, but I understand (or I think I do, from the above), that SpaceX has until October this year to launch half of its ~12k V-band constellation, that from their estimates will only hit ~1.5k by the deadline, and that at their current deployment rate will hit the half-constellation milestone in October 2026 -- i.e. two years late.

But if the FCC just hands out essentially blanket 2-year extensions because of COVID-related inconvenience, that would mean that SpaceX could squeak by and hit that half-constellation milestone, right?

And then they'd retain Round 1 (which is just about priority in using the RF bands?) privileges for the entire constellation (assuming they complete the second half of the constellation on time)?

Yes, most of that is true.  NB:  V-band currently is 7,500 satellites rather than 12,000 satellites.

Because the V-band is largely unused, the value to SpaceX of having all of its V-band payloads in the first round of V-band is much less than setting a favorable precedent on the second and third rounds of the Ku- and Ka-bands.
« Last Edit: 08/14/2024 09:45 pm by RedLineTrain »

Offline OceanCat

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Re: Starlink : New FCC and ITU Filings
« Reply #670 on: 08/16/2024 02:34 pm »
SES-LIC-INTR2024-05590

Quote
SpaceX Services seeks authority for a new V-band gateway earth station.

The only thing that slightly surprised me is the number of antennas that is unusually low -- 1. As far as I recall even early temporary Ku gateways had 4 antennas and Ka gateways had 8 antennas off the start.

V-band capable satellites should support higher total throughput. Shall we call them v2-mini-max?

Online gongora

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Re: Starlink : New FCC and ITU Filings
« Reply #671 on: 08/16/2024 02:41 pm »
Single antenna in Redmond = test site?

Ka- and E-band share an antenna, right?  Does V-band also use that antenna, or something else?

Offline OceanCat

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Re: Starlink : New FCC and ITU Filings
« Reply #672 on: 08/16/2024 03:19 pm »
Yeah, probably a test site but the antenna is a typical parabolic antenna and it's not typical for SpaceX to make small steps.

Yes, Ka- and E-band share an antenna (see the table in a random Ka&E-band gateway application filed in January) but V-band is not shared according to the table in the application. So I assume it's more simple. Of course it's just an assumption. Maybe they are testing a quantum amplifier.

Online gongora

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Re: Starlink : New FCC and ITU Filings
« Reply #673 on: 08/16/2024 05:52 pm »
For the antenna sharing I was wondering more on the satellite side.

Offline OceanCat

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Re: Starlink : New FCC and ITU Filings
« Reply #674 on: 08/17/2024 01:47 am »
I haven't seen any info regarding gateway antenna sharing on the satellite side. My guess is as good as yours.

Meanwhile the FCC today approved the application to upgrade gen1 satellites filed in Feb 2023.

Quote
SpaceX proposes to deploy larger satellites with two potential form factors as its upgraded first generation
satellites — one to be deployed on the Falcon 9 launch vehicle and one to be deployed on the Starship launch vehicle.
...
SpaceX states that it is scaling the size of its beams and the corresponding spot size to enable the most
efficient use of spectrum and increase network capacity.
...
The Petition for Additional Information, Additional Conditions, or Denial of DISH Network Corporation
is DENIED... we disagree with DISH that SpaceX’s use of smaller beams will result in SpaceX violating
Commission and ITU EPFD limits.
...
We continue to condition SpaceX’s authorization on SpaceX communicating with only one satellite beam
at a time in the same frequency in the same or overlapping areas.
...

Offline OceanCat

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Re: Starlink : New FCC and ITU Filings
« Reply #675 on: 08/22/2024 05:58 am »
News related to Gen1 upgrade launch schedule. SpaceX filed an application to authorize VHF beacons on gen1 satellites similar to the VHF beacons on gen2 satellites and stated that it wants to launch them soon:

Quote
Swarm seeks expeditious grant of this modification request to allow SpaceX to rapidly
begin integrating these Swarm antennas as payloads on its upgraded Gen1 satellites, scheduled to
launch in the coming months to begin providing enhanced coverage and broadband connectivity
to consumers in Alaska and polar regions around the world.

In shell 2 (inclination 70°) 15 out of 36 planes are totally empty. In shell 3 (inclination 97.6°) 5 out 10 planes are empty, each can have 43 satellites. All together SpaceX can do up to 25 launches to fill up shells 2 and 3.

SpaceX has been filing STAs extensions like the one attached due to low polar satellite count, asking to operate as low as 10 degrees above horizon in polar regions. The full constellation is supposed to operate 25 degrees above horizon.

Offline OceanCat

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Re: Starlink : New FCC and ITU Filings
« Reply #676 on: 12/05/2024 06:37 am »
SpaceX formally notified the FCC it hasn't met the first V-band deployment milestone.

Quote
In accordance with the conditions of its current V-band authorization and
Section 25.164(b)(1) of the Commission’s rules, SpaceX notifies the Commission that SpaceX
has not met its milestone requirement to launch 50 percent of the maximum number of proposed
space stations with V-band capabilities, place them in the assigned orbits, and operate them in
accordance with its authorization by November 19, 2024.  As of that date, SpaceX had so
launched, placed into orbit, and operated 1,485 space stations with V-band capabilities.

Offline scr00chy

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Re: Starlink : New FCC and ITU Filings
« Reply #677 on: 12/05/2024 10:40 am »
SpaceX formally notified the FCC it hasn't met the first V-band deployment milestone.

Quote
In accordance with the conditions of its current V-band authorization and
Section 25.164(b)(1) of the Commission’s rules, SpaceX notifies the Commission that SpaceX
has not met its milestone requirement to launch 50 percent of the maximum number of proposed
space stations with V-band capabilities, place them in the assigned orbits, and operate them in
accordance with its authorization by November 19, 2024.  As of that date, SpaceX had so
launched, placed into orbit, and operated 1,485 space stations with V-band capabilities.

Relevant from previous filings:

Quote
Failure to meet the milestone requirements of 47 CFR § 25.164(b) may result in SpaceX's authorization being reduced to the number of satellites with V-band capability in use at the milestone date. Failure to comply with the milestone requirements of 47 CFR § 25.164(b) will also result in forfeiture of SpaceX's surety bond. By December 16, 2028, SpaceX must either demonstrate compliance with this milestone requirement or notify the Commission in writing that the requirement was not met. 47 CFR § 25.164(f).

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