Kuiper: Can it still meet its launching deadline?

[tssp_art]

In its approval for the Amazon Kuiper constellation, the FCC confirmed deadlines of July 30, 2026 to launch 50% of the constellation and July 20, 2029 to launch the remaining 50%. The 50% deadline is for 1,618 satellites.

In April of 2022 Amazon contracted for 18 launches on the Ariane 6, 12 launches (with option for 15 more) on New Glenn, and 38 launches on Vulcan. None of these vehicles have flown yet.

At the time of placing those orders the Ariane 6 was supposed to fly later that year. There have been several official slips of that date, the last positing a launch in late 2023 but industry sources have ruled out a launch this year and are now expecting it in Q1 2024.

Also at that time, New Glenn was expected to fly later that year but now best estimates place the first flight in late 2024 or early 2025 (although they are contracted with NASA for an August launch of ESCAPADE. I don't see that as being credible with what we've seen to date.)

And of course ULA has most recently delayed Vulcan's inaugural launch for NET Q4 2023.

Part of the payload for that inaugural launch are the first two prototype satellites for the Kuiper network. If Amazon stays with the current plan, the two prototype satellites could be orbited late this year (IMO more likely early next year). If the prototypes function as expected (a big "if") and if no modifications are needed to the production satellite design (another big "if"), and if they have production satellites ready to be launched (yet another big "if"), it's possible that they could start launching production satellites as early as Q1 2024.

Prior to placing that record breaking order for launches, Amazon had contracted for the remaining 9 Atlas Vs from ULA. In its most powerful configuration the Atlas V can lift about 15.5 metric tons to LEO. The production Kuiper satellites are rumored to be ~500Kg (are there more accurate numbers available?) which translates to ~31 satellites per launch. Atlas V launch cadence has not exceeded 7 per year but let's say that ULA is motivated to help (to preserve the order for 38 Vulcan launches) and can get all 9 Atlas Vs launched in 2024, each carrying 31 Kuiper satellites. That's 279 Satellites in orbit by the end of 2024. Ariane 6 has quite a backlog of orders but might get one Kuiper launch in 2024 (possibly 40 satellites). Similarly ULA may get a Kuiper Vulcan launch off next year (maybe 55 satellites). I don't believe that New Glenn will have a Kuiper launch until 2025.

So, very optimistically, Kuiper may have as much as 279+40+55=374 satellites in orbit by the end of 2024. That leaves 19 months until the 50% deadline with 1244 satellites left to launch.

Historically new rockets don't achieve more than a couple of launches per year for their first couple of years. So will there be enough capacity in Ariane 6, Vulcan and New Glenn for the more than 20 launches (combined) needed to get to the 50% mark? Ariane 6 is hoping to eventually get up to 11 launches per year. New Glenn and Vulcan are both completely dependent on Blue Origin's production of BE-4 engines which still haven't ever flown. And there are no more Atlas Vs to be had.

This doesn't look promising, but maybe I'm missing something.

[DanClemmensen]

Part of the payload for that inaugural launch are the first two prototype satellites for the Kuiper network. If Amazon stays with the current plan, the two prototype satellites could be orbited late this year (IMO more likely early next year). If the prototypes function as expected (a big "if") and if no modifications are needed to the production satellite design (another big "if"), and if they have production satellites ready to be launched (yet another big "if"), it's possible that they could start launching production satellites as early as Q1 2024.

Prior to placing that record breaking order for launches, Amazon had contracted for the remaining 9 Atlas Vs from ULA. In its most powerful configuration the Atlas V can lift about 15.5 metric tons to LEO. The production Kuiper satellites are rumored to be ~500Kg (are there more accurate numbers available?) which translates to ~31 satellites per launch. Atlas V launch cadence has not exceeded 7 per year but let's say that ULA is motivated to help (to preserve the order for 38 Vulcan launches) and can get all 9 Atlas Vs launched in 2024, each carrying 31 Kuiper satellites. That's 279 Satellites in orbit by the end of 2024. Ariane 6 has quite a backlog of orders but might get one Kuiper launch in 2024 (possibly 40 satellites). Similarly ULA may get a Kuiper Vulcan launch off next year (maybe 55 satellites). I don't believe that New Glenn will have a Kuiper launch until 2025.

If Amazon/Kuiper is serious about this, they will launch the prototypes on a Atlas in the near future. This would allow them to complete the initial evaluation prior to the first Vulcan. They would then launch the remaining 8 Atlas flights at the best rate ULA can support, and they would be able to shift to Vulcan as soon as it is actually operational. This cost of this approach is high: they basically throw away one of their nine Atlas launches. They could then choose to fly a full-up Vulcan mission on the second Vulcan Centaur flight.

None of this makes sense unless the Kuiper prototypes are actually ready to fly. If in fact a Kuiper schedule slip is hiding behind the Vulcan slip, this trick will not help.

[whitelancer64]

Vulcan will launch 45 Kuiper satellites,

New Glenn will launch 61,

Ariane 6 from 35-40 Kuiper satellites (depends on the use of upgraded boosters, which is planned for later. Initial launches will be with 35 satellites).

Oddly I did not find any articles that mention how many Kuiper sats will be on the Atlas V launches.

[whitelancer64]

*snip*

None of this makes sense unless the Kuiper prototypes are actually ready to fly. If in fact a Kuiper schedule slip is hiding behind the Vulcan slip, this trick will not help.

The two Kuiper test satellites were shipped to the Cape in mid March.

https://www.bizjournals.com/seattle/news/2023/03/20/project-kuiper-plans-first-satellite-launches.html

That article has a photo of the shipping containers for the two satellites.
Amusingly, they are labeled "Velociraptor Containment"

[RedLineTrain]

The deadline is a non-issue.  Amazon should wish to get its megaconstellation up as soon as possible no matter the deadline. And it should have no problem contracting with SpaceX to do so.  SpaceX will have plenty of spare launch capacity.

But even if Amazon doesn't make the deadline because of technical issues or a shortsighted insistence not to contract with SpaceX, it still won't be an issue because the FCC will extend it.  The FCC has every reason to extend the deadline and no reason not to do so.

[Robotbeat]

Unless one web or star link wants to use it

[ulm_atms]

The deadline is a non-issue.  Amazon should wish to get its megaconstellation up as soon as possible no matter the deadline. And it should have no problem contracting with SpaceX to do so.  SpaceX will have plenty of spare launch capacity.

But even if Amazon doesn't make the deadline because of technical issues or a shortsighted insistence not to contract with SpaceX, it still won't be an issue because the FCC will extend it.  The FCC has every reason to extend the deadline and no reason not to do so.

Actually, they may.  If the FCC just ignores it's deadlines, I see the other companies that were held to FCC deadlines suing.  The FCC as a regulatory body is suppose to treat everyone equal....technically.  We all know they don't but I guarantee the other companies will want to know why they are being treated differently.  What is the point of a deadline if it means absolutely nothing?  Two companies met the deadlines set(AFAIK)....why is Kuiper different?

[tssp_art]

The deadline is a non-issue.  Amazon should wish to get its megaconstellation up as soon as possible no matter the deadline. And it should have no problem contracting with SpaceX to do so.  SpaceX will have plenty of spare launch capacity.

But even if Amazon doesn't make the deadline because of technical issues or a shortsighted insistence not to contract with SpaceX, it still won't be an issue because the FCC will extend it.  The FCC has every reason to extend the deadline and no reason not to do so.

I'm not sure this is true. These rules are not dissimilar from the Federal Acquisition Rules in that they define the mutual obligations of the Government and the contractor community. From what I've heard, if the 100% deployment deadline is not met then approval for the constellation size becomes automatically limited to the number of satellites deployed at that time. If the 50% deployment deadline is not met then the number is twice the number of satellites deployed at that time. I'm not sure if my understanding is correct (there must be better informed FCC experts on the forum) and I don't know if this has ever been enforced or contested.

[RedLineTrain]

Unless one web or star link wants to use it

I have not heard any grumbling from the customer side about not being able to find a ride at a reasonable price.  Quite the opposite, actually.  Payloads are moving to SpaceX with pretty short lead times and it is just assumed that SpaceX has the capacity.  This leads me to believe that it does.

[RedLineTrain]

I'm not sure this is true.

Oh, it's true.  Competition is in the public interest.  The FCC will bend over backward to promote it in this instance and nobody will gainsay it.  Probably even SpaceX wouldn't argue against it.

[gongora]

Deployment deadlines get extended all the time, both by FCC and ITU.  If Amazon is actively launching satellites, has launch contracts for the rest, and has production lined up for the rest, then they will almost certainly get an extension.  FAR has no relevance to this.

[Zed_Noir]

<snip>
If Amazon/Kuiper is serious about this, they will launch the prototypes on a Atlas in the near future. This would allow them to complete the initial evaluation prior to the first Vulcan. They would then launch the remaining 8 Atlas flights at the best rate ULA can support, and they would be able to shift to Vulcan as soon as it is actually operational. This cost of this approach is high: they basically throw away one of their nine Atlas launches. They could then choose to fly a full-up Vulcan mission on the second Vulcan Centaur flight.
<snip>

There is no need for Amazon to use up an Atlas V to fly the Kuiper prototype satcoms. Just put them on a Transporter launch.

At this point the Kuiper Project have to start deploying their LEO constellation ASAP before permanently losing market share. The Vulcan Centaur, the Ariane 6 & the New Glenn are all way behind schedule. They need to acquire additional launch capacity that is available.

Since the Russians and the Chinese launchers are banned by fiat. The only other option in the form of the ISRO LVM-3 have limited availability due to domestic payloads and low production rate. The nascent JAXA H3 have development issues and hasn't flown a successful flight yet, maybe Q4 2023 like the Ariane 6  .

Amazon like everyone else will need to call up the folks at Hawthorne.

[tssp_art]

I'm not sure this is true.

Oh, it's true.  Competition is in the public interest.  The FCC will bend over backward to promote it in this instance and nobody will gainsay it.  Probably even SpaceX wouldn't argue against it.

Deployment deadlines get extended all the time, both by FCC and ITU.  If Amazon is actively launching satellites, has launch contracts for the rest, and has production lined up for the rest, then they will almost certainly get an extension.  FAR has no relevance to this.

I would tend to agree that what you both say is sensible and logical - but not necessarily correct. Government agencies operate in accordance with rules that govern their interaction with interested parties. And yes, the FAR is for conducting acquisitions which has no relevance because this is not an acquisition. The Federal Acquisition Rules are Title 48 in the CFR (Code of Federal Regulations) while the rules that govern the FCC specific activities are Title 47 in the CFR. Violation of these rules by the Government is just as serious (and undesirable) as violation by an individual or a corporation. So I've gone and dug these up and here is what they seems to say. And BTW, there is an anachronism that can be confusing here - what we call Satellites, the FCC calls Space Stations. Sigh.

This first relevant rule one is the one that establishes the milestones of 50% and 100% deployment in six and nine years respectively:

§ 25.164 Milestones.
(a) The recipient of an initial license for a GSO space station, other than a SDARS space station, granted on or after August 27, 2003, must launch the space station, position it in its assigned orbital location, and operate it in accordance with the station authorization no later than five years after the grant of the license, unless a different schedule is established by this chapter or the Commission.[not relevant - for GSO satellites only]

(b)

(1) The recipient of an initial authorization for an NGSO satellite system, other than an SDARS system, must launch 50 percent of the maximum number of space stations authorized for service, place them in their assigned orbits, and operate them in accordance with the station authorization no later than 6 years after the grant of the authorization, unless a different schedule is established by Title 47, Chapter I. This paragraph does not apply to replacement NGSO space stations as defined in § 25.165(e).

(2) A licensee that satisfies the requirement in paragraph (b)(1) of this section must launch the remaining space stations necessary to complete its authorized service constellation, place them in their assigned orbits, and operate each of them in accordance with the authorization no later than nine years after the grant of the authorization.


The second relevant rule is the one that establishes the automatic penalty for not meeting the milestone(s). For clarification, the FCC gives authorization for each individual "station" (satellite). So it says that failure to meet a milestone will cause automatic termination of authorization for satellites not yet launched.


§ 25.161 Automatic termination of station authorization.
A station authorization shall be automatically terminated in whole or in part without further notice to the licensee upon:

(a)

(1) The failure to meet an applicable milestone specified in § 25.164(a) or (b), if no authorized space station is functional in orbit;

(2) The failure to meet an applicable milestone specified in § 25.164(b)(1) or (2), if at least one authorized space station is functional in an authorized orbit, which failure will result in the termination of authority for the space stations not in orbit as of the milestone date, but allow for technically identical replacements; or

(3) The failure to meet any other milestone or construction requirement imposed as a condition of authorization. In the case of a space station authorization when at least one authorized space station is functional in orbit, however, such termination will be with respect to only the authorization for any space stations not in orbit as of the milestone date.


So my earlier interpretation is not quite correct. The rules are actually stricter than I thought. Note language in the opening -"A station authorization shall be automatically terminated". It says "shall be" not "may be" meaning there is no discretion by the administrator. So failure to meet the 50% milestone on July 30, 2026 will result in automatic termination of authorization for anymore satellites other than replacements for the ones already launched.

[DJPledger]

Only if Amazon bites the bullet and launches a significant portion of Kuiper on Starship.

[Nomadd]

 SpaceX is taking care of it's customers at the expense of Starlink launches. Oneweb was a special case of not wanting to take advantage of a bad situation, but I'm not sure if they'll be too happy about sacrificing Starlink launch opportunities to loft Kupiers.

[Rebel44]

SpaceX is taking care of it's customers at the expense of Starlink launches. Oneweb was a special case of not wanting to take advantage of a bad situation, but I'm not sure if they'll be too happy about sacrificing Starlink launch opportunities to loft Kupiers.

I think SpaceX would be willing to provide Kuiper with some launches, but not so many that it would be detrimental to the ongoing deployment of Starlink - and Kuiper would definitely not get any discounts - plus I would expect at least an unspoken arrangement for Kuiper to drop some regulatory objections to Starlink (just like OneWeb IIRC did around the time they got their contract for F9 launches).

[gongora]

So my earlier interpretation is not quite correct. The rules are actually stricter than I thought. Note language in the opening -"A station authorization shall be automatically terminated". It says "shall be" not "may be" meaning there is no discretion by the administrator. So failure to meet the 50% milestone on July 30, 2026 will result in automatic termination of authorization for anymore satellites other than replacements for the ones already launched.

It's automatic unless a waiver is applied for and granted.  It is perfectly legal for a waiver to be applied for and granted.

[tssp_art]

So my earlier interpretation is not quite correct. The rules are actually stricter than I thought. Note language in the opening -"A station authorization shall be automatically terminated". It says "shall be" not "may be" meaning there is no discretion by the administrator. So failure to meet the 50% milestone on July 30, 2026 will result in automatic termination of authorization for anymore satellites other than replacements for the ones already launched.

It's automatic unless a waiver is applied for and granted.  It is perfectly legal for a waiver to be applied for and granted.

That may be, but I've searched all of 47 CFR chapter 25 for waiver procedures and I've found many rules that identify the procedure for waivers to specific rules. None of the ones I've found deal with the rule in section 25.161. Almost all of them require that an applicant identify which rule they are asking be waived as part of their application - i.e. not after the applicant has accepted the terms of the license and is now going to violate the rule by missing the milestone.

Perhaps you know of where this waiver procedure is identified and described or has been used before?

[meekGee]

In its approval for the Amazon Kuiper constellation, the FCC confirmed deadlines of July 30, 2026 to launch 50% of the constellation and July 20, 2029 to launch the remaining 50%. The 50% deadline is for 1,618 satellites.

In April of 2022 Amazon contracted for 18 launches on the Ariane 6, 12 launches (with option for 15 more) on New Glenn, and 38 launches on Vulcan. None of these vehicles have flown yet.

At the time of placing those orders the Ariane 6 was supposed to fly later that year. There have been several official slips of that date, the last positing a launch in late 2023 but industry sources have ruled out a launch this year and are now expecting it in Q1 2024.

Also at that time, New Glenn was expected to fly later that year but now best estimates place the first flight in late 2024 or early 2025 (although they are contracted with NASA for an August launch of ESCAPADE. I don't see that as being credible with what we've seen to date.)

And of course ULA has most recently delayed Vulcan's inaugural launch for NET Q4 2023.

Part of the payload for that inaugural launch are the first two prototype satellites for the Kuiper network. If Amazon stays with the current plan, the two prototype satellites could be orbited late this year (IMO more likely early next year). If the prototypes function as expected (a big "if") and if no modifications are needed to the production satellite design (another big "if"), and if they have production satellites ready to be launched (yet another big "if"), it's possible that they could start launching production satellites as early as Q1 2024.

Prior to placing that record breaking order for launches, Amazon had contracted for the remaining 9 Atlas Vs from ULA. In its most powerful configuration the Atlas V can lift about 15.5 metric tons to LEO. The production Kuiper satellites are rumored to be ~500Kg (are there more accurate numbers available?) which translates to ~31 satellites per launch. Atlas V launch cadence has not exceeded 7 per year but let's say that ULA is motivated to help (to preserve the order for 38 Vulcan launches) and can get all 9 Atlas Vs launched in 2024, each carrying 31 Kuiper satellites. That's 279 Satellites in orbit by the end of 2024. Ariane 6 has quite a backlog of orders but might get one Kuiper launch in 2024 (possibly 40 satellites). Similarly ULA may get a Kuiper Vulcan launch off next year (maybe 55 satellites). I don't believe that New Glenn will have a Kuiper launch until 2025.

So, very optimistically, Kuiper may have as much as 279+40+55=374 satellites in orbit by the end of 2024. That leaves 19 months until the 50% deadline with 1244 satellites left to launch.

Historically new rockets don't achieve more than a couple of launches per year for their first couple of years. So will there be enough capacity in Ariane 6, Vulcan and New Glenn for the more than 20 launches (combined) needed to get to the 50% mark? Ariane 6 is hoping to eventually get up to 11 launches per year. New Glenn and Vulcan are both completely dependent on Blue Origin's production of BE-4 engines which still haven't ever flown. And there are no more Atlas Vs to be had.

This doesn't look promising, but maybe I'm missing something.

That analysis is exactly why Vulcan flight 1 and 2 are so critical to Kuiper.  It's not the demo satellites, it's validating BE-4 in flight.

Any delay there will affect both Vulcan and NG, which are the only two launchers that have a theoretical chance to scale.

If BE-4 has any flight issues, Kuiper will have no choice but to pivot to a SpaceX product.

[Robotbeat]

Except for the 2026 date, I'd disagree. Terran-R, Neutron, and Antares/Firefly can all scale. All have better chance of F9-like low cost reusability than Vulcan. But they have first launch dates of 2026, 2024, and 2025, respectively. There's a decent chance one of them could actually beat New Glenn to first launch, given Blue Origin's history and pace.