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, includingany difficulties or failures related thereto;• apply a new performance-based method for assessing disposal failures that accounts forboth 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 conjunctionwarning from the 19th Space Defense Squadron or other source; and• coordinate with NSF to reach a mutually acceptable agreement to mitigate the impact ofits satellites on optical ground-based astronomy, with associated annual reportingrequirements.
...SpaceX’s upcoming V-band milestone modification application, along with pending requests from other operators, provide an opportunity for the full Commission to reaffirmthese policies and set a consistent baseline for all operators (footnote: SpaceX does not expectto 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 policiesunderlying 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 extensionrequests because they raise novel facts and issues and lack clear precedent and guidelines....For example, in itsopposition to Telesat’s extension request, Amazon has bent over backwards to parse factors in atransparent effort to harm Telesat’s potential customers while anticipating factors that mightsupport Amazon’s own milestone modification application due to its foreseeable andunexceptional delays in deploying its own system. Amazon has confusingly identified COVID asa valid justification for extension in its view, even years after the pandemic’s main brunt, but onlywith respect to COVID-related supply chain issues and personnel shortages, and not with respectto Telesat’s unforeseeable contract issues. Similarly, Amazon attempts to discount Telesat’sefforts 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 itselfup to invoke the very same factors in its favor when Amazon ultimately files its own milestonemodification application....Pending requests for deployment milestone modifications such as the one SpaceX will fileshortly present the Commission with an obligation and an opportunity. Requests in theseapplications to extend milestone dates cannot be addressed on delegated authority because theyinvolve novel facts and issues and lack outstanding Commission precedents and guidelines onwhich to rely, particularly in view of the receding COVID-19 pandemic and recent major updatesto the Commission’s NGSO spectrum sharing framework. More broadly, the Commission has theopportunity to reaffirm clear policies and guidance for NGSO operators that fail to meet theirdeployment milestones but nevertheless seek to continue deploying satellites to serve consumers.Specifically, the Commission should declare that any deployment milestone extension request is amodification application to defer the undeployed portion of an authorized system to a subsequentNGSO processing round, allowing an actual, limited extension of the milestone date only undertruly rare and exceptional circumstances. Doing so will provide a consistent means to addresspending—and future—extension requests that preserves the integrity of the processing roundframework while avoiding the arbitrary line-drawing and disparate treatment that attends case-bycasereview divorced from the consequences to other systems that share spectrum with the requester.
SpaceX herein applies to modify its first processing round V-band space stationauthorization so it may continue to launch V-band-capable satellites...To date, SpaceX has launched 1,052 Gen2 satellites with V-band capabilities and expectsto have launched a total of approximately 1,530 by the milestone date. At its current rate of satellitelaunches, SpaceX would deploy half of its originally authorized V-band system of 11,943 satellitesby October 2026 if allowed to continue launching under the proposed modification after November19, 2024....Specifically, here, SpaceX requests that theCommission modify the authorization for its V-band system as follows:1. SpaceX’s first V-band NGSO processing round system shall include only the numberof V-band payloads on Gen2 satellites that SpaceX has launched on or beforeNovember 19, 2024; 2. SpaceX may deploy additional V-band payloads on Gen2 satellites, up to 7500satellites as authorized, after November 19, 2024, but those satellites will be consideredpart of the second V-band NGSO processing round; and 3. The deployment of those additional V-band payloads on Gen2 satellites will be subjectto new milestone requirements in accordance with Section 25.161(b) based on the datethat the first second-round V-band NGSO system of another operator was authorized....SpaceX is the only Commission-authorized NGSO operator to have deployedany satellites with V-band capabilities and may be the only first-processing-round V-band systemthat will ever deploy. The Commission authorized six other V-band NGSO satellite systems inthe 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 knowledgehas not launched any V-band satellites into its authorized MEO orbits. A second V-bandprocessing round is currently pending, but only two applications have been accepted for filing(one of which was recently granted)....
SAT-MOD-20240813-00183QuoteSpaceX herein applies to modify its first processing round V-band space stationauthorization so it may continue to launch V-band-capable satellites...To date, SpaceX has launched 1,052 Gen2 satellites with V-band capabilities and expectsto have launched a total of approximately 1,530 by the milestone date. At its current rate of satellitelaunches, SpaceX would deploy half of its originally authorized V-band system of 11,943 satellitesby October 2026 if allowed to continue launching under the proposed modification after November19, 2024....Specifically, here, SpaceX requests that theCommission modify the authorization for its V-band system as follows:1. SpaceX’s first V-band NGSO processing round system shall include only the numberof V-band payloads on Gen2 satellites that SpaceX has launched on or beforeNovember 19, 2024; 2. SpaceX may deploy additional V-band payloads on Gen2 satellites, up to 7500satellites as authorized, after November 19, 2024, but those satellites will be consideredpart of the second V-band NGSO processing round; and 3. The deployment of those additional V-band payloads on Gen2 satellites will be subjectto new milestone requirements in accordance with Section 25.161(b) based on the datethat the first second-round V-band NGSO system of another operator was authorized....SpaceX is the only Commission-authorized NGSO operator to have deployedany satellites with V-band capabilities and may be the only first-processing-round V-band systemthat will ever deploy. The Commission authorized six other V-band NGSO satellite systems inthe 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 knowledgehas not launched any V-band satellites into its authorized MEO orbits. A second V-bandprocessing round is currently pending, but only two applications have been accepted for filing(one of which was recently granted)....
Quote from: OceanCat on 08/14/2024 09:14 amSAT-MOD-20240813-00183QuoteSpaceX herein applies to modify its first processing round V-band space stationauthorization so it may continue to launch V-band-capable satellites...To date, SpaceX has launched 1,052 Gen2 satellites with V-band capabilities and expectsto have launched a total of approximately 1,530 by the milestone date. At its current rate of satellitelaunches, SpaceX would deploy half of its originally authorized V-band system of 11,943 satellitesby October 2026 if allowed to continue launching under the proposed modification after November19, 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.
SAT-MOD-20240813-00183QuoteSpaceX herein applies to modify its first processing round V-band space stationauthorization so it may continue to launch V-band-capable satellites...To date, SpaceX has launched 1,052 Gen2 satellites with V-band capabilities and expectsto have launched a total of approximately 1,530 by the milestone date. At its current rate of satellitelaunches, SpaceX would deploy half of its originally authorized V-band system of 11,943 satellitesby October 2026 if allowed to continue launching under the proposed modification after November19, 2024....
SpaceX herein applies to modify its first processing round V-band space stationauthorization so it may continue to launch V-band-capable satellites...To date, SpaceX has launched 1,052 Gen2 satellites with V-band capabilities and expectsto have launched a total of approximately 1,530 by the milestone date. At its current rate of satellitelaunches, SpaceX would deploy half of its originally authorized V-band system of 11,943 satellitesby October 2026 if allowed to continue launching under the proposed modification after November19, 2024....
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)?
SpaceX Services seeks authority for a new V-band gateway earth station.
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 Corporationis DENIED... we disagree with DISH that SpaceX’s use of smaller beams will result in SpaceX violatingCommission and ITU EPFD limits....We continue to condition SpaceX’s authorization on SpaceX communicating with only one satellite beamat a time in the same frequency in the same or overlapping areas....
Swarm seeks expeditious grant of this modification request to allow SpaceX to rapidlybegin integrating these Swarm antennas as payloads on its upgraded Gen1 satellites, scheduled tolaunch in the coming months to begin providing enhanced coverage and broadband connectivityto consumers in Alaska and polar regions around the world.
In accordance with the conditions of its current V-band authorization andSection 25.164(b)(1) of the Commission’s rules, SpaceX notifies the Commission that SpaceXhas not met its milestone requirement to launch 50 percent of the maximum number of proposedspace stations with V-band capabilities, place them in the assigned orbits, and operate them inaccordance with its authorization by November 19, 2024. As of that date, SpaceX had solaunched, placed into orbit, and operated 1,485 space stations with V-band capabilities.
SpaceX formally notified the FCC it hasn't met the first V-band deployment milestone.QuoteIn accordance with the conditions of its current V-band authorization andSection 25.164(b)(1) of the Commission’s rules, SpaceX notifies the Commission that SpaceXhas not met its milestone requirement to launch 50 percent of the maximum number of proposedspace stations with V-band capabilities, place them in the assigned orbits, and operate them inaccordance with its authorization by November 19, 2024. As of that date, SpaceX had solaunched, placed into orbit, and operated 1,485 space stations with V-band capabilities.
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).