Starlink : New FCC and ITU Filings

[raptorx2]

I missed this filing from October with the proposed Gen 2 satellite dimensions for Starship and F9 versions.
https://licensing.fcc.gov/myibfs/download.do?attachment_key=17429628

Did anybody actually download this and attach it to a post? I can't get it to load.

There has also been speculation that SpaceX could implement a VHF GNSS service through these beacons

[Barley]

There has also been speculation that SpaceX could implement a VHF GNSS service through these beacons

Where is the market, when the US gives GPS, WAAS etc away for free?

[docmordrid]

There has also been speculation that SpaceX could implement a VHF GNSS service through these beacons

Where is the market, when the US gives GPS, WAAS etc away for free?

Not so much a market but  a redundancy, in case some bad actor decided to compromise GPS etc. IIRC this was mentioned in SpaceX's trademark for Starshield

https://forum.nasaspaceflight.com/index.php?topic=57671.0

[su27k]

There is also the interesting point that SpaceX may be able to meet some of these conditions more easily than their competitors, who may eventually regret asking for such restrictions when they have to meet them too.

That would require FCC applies the same conditions on their competitors, so far we're not seeing it. For example the object-year thing should be established via rule making instead of being applied to Starlink specifically.
...

FCC could be sued if they don't apply the conditions in a fair manner. So I'm fully confident this will happen.

"Could" is the operative word here, yes they could be sued but is anybody actually willing to sue them? I'm not sure SpaceX wants to do that, too many things relying on FCC right now.

More likely SpaceX will just register their systems in foreign countries like Germany from now on, they're already doing this for the T-Mobile direct-to-cell system.

[gongora]

Pretty much all of the Starlink ITU filings are outside the US.  All of the gen2 ITU filings are through Germany, not just the cell antennas.

[Robotbeat]

There is also the interesting point that SpaceX may be able to meet some of these conditions more easily than their competitors, who may eventually regret asking for such restrictions when they have to meet them too.

That would require FCC applies the same conditions on their competitors, so far we're not seeing it. For example the object-year thing should be established via rule making instead of being applied to Starlink specifically.
...

FCC could be sued if they don't apply the conditions in a fair manner. So I'm fully confident this will happen.

"Could" is the operative word here, yes they could be sued but is anybody actually willing to sue them? I'm not sure SpaceX wants to do that, too many things relying on FCC right now.
...

Absolutely they can and would sue the FCC, and they'd be right to. FCC stonewalling them in retribution for suing would increase the probability that SpaceX gets some relief by the judicial system and would be illegal.

[Robotbeat]

I missed this filing from October with the proposed Gen 2 satellite dimensions for Starship and F9 versions.
https://licensing.fcc.gov/myibfs/download.do?attachment_key=17429628

Did anybody actually download this and attach it to a post? I can't get it to load.

You may have to click it twice.  It's a feature of the FCC web site.

Or you can find here.  https://www.dropbox.com/s/dhjubtpzkl03z39/SpaceX.pdf?dl=0

Thanks. I've attached it to this post, in case anyone wants it. (And a screen capture of the relevant page with masses.)

[virtuallynathan]

https://twitter.com/VirtuallyNathan/status/1608172202641481729


https://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SESLICINTR202204333&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Number

https://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SESLICINTR202204334&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Number

https://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SESLICINTR202204335&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Number

https://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SESLICINTR202204336&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Number

https://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SESLICINTR202204337&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Number

It appears there's also a 6th site at Port Matilda, PA: https://www.statecollege.com/antenna-project-to-support-starlink-internet-access-in-centre-county/ -- They Applied for a normal 8 antenna site here as well.

[RedLineTrain]

I wonder why they would file for E-band gateways when approval for E-band frequencies seems far off, if ever.

[russianhalo117]

https://twitter.com/VirtuallyNathan/status/1608172202641481729


https://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SESLICINTR202204333&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Numberhttps://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SESLICINTR202204334&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Numberhttps://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SESLICINTR202204335&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Numberhttps://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SESLICINTR202204336&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Numberhttps://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SESLICINTR202204337&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Number

It appears there's also a 6th site at Port Matilda, PA: https://www.statecollege.com/antenna-project-to-support-starlink-internet-access-in-centre-county/ -- They Applied for a normal 8 antenna site here as well.

They are hoping long term to eventually have a minimum of one site per state. ULCS (Underwriters Laboratories Consulting Services) and SpaceX are currently examining some potential sites in the Little Rock Greater Metropolitan Area, Arkansas with the main antenna site in Central Arkansas being the Shinall Mountain Antenna Farm (34°47′55″N 92°29′49″W).

[virtuallynathan]

They are hoping long term to eventually have a minimum of one site per state. ULCS (Underwriters Laboratories Consulting Services) and SpaceX are currently examining some potential sites in the Little Rock Greater Metropolitan Area, Arkansas with the main antenna site in Central Arkansas being the Shinall Mountain Antenna Farm (34°47′55″N 92°29′49″W).

Do you have a source for that?

[russianhalo117]

They are hoping long term to eventually have a minimum of one site per state. ULCS (Underwriters Laboratories Consulting Services) and SpaceX are currently examining some potential sites in the Little Rock Greater Metropolitan Area, Arkansas with the main antenna site in Central Arkansas being the Shinall Mountain Antenna Farm (34°47′55″N 92°29′49″W).

Do you have a source for that?

Visual and in person. ULCS has a contract from SpaceX at least on this potential location.

[su27k]

New Gen1 Semi-Annual Report: https://licensing.fcc.gov/myibfs/download.do?attachment_key=19127252

Nothing noteworthy in the report.

[OceanCat]

SpaceX anticipates launching satellites with E-band capability beginning in early February
2023. Accordingly, SpaceX requests that the Commission expeditiously grant the STA for E-band
communications between Gen2 satellites and gateway earth stations for 60 days to support those
operations beginning in early February while the Commission continues to consider the E-band
portion of SpaceX’s underlying Gen2 system application.

SpaceX will operate its E-band links with the technical parameters set
forth in the underlying Gen2 application, both for testing upon initial orbital insertion and once the
satellites reach their assigned orbital locations.

SpaceX will use the E-band spectrum to communicate with gateway earth stations located
throughout the U.S. and around the world.

Application

[pyromatter]

In regards to Gen2 LeoLabs is not happy with the FCC.

"The Commission imposed a condition in that authorization in response to a concept described in ex parte filings by LeoLabs. We commend and appreciate the Commission taking this proactive step toward addressing the issue of orbital debris by adopting one of LeoLabs’ suggested methodologies. But the condition adopts an inappropriate and unvalidated 100 “object years” value that LeoLabs included in its presentation solely for illustrative purposes and computational ease."

"Unfortunately, this value is unrealistically low for SpaceX—and may be impossible for any other NGSO system operator. This arbitrarily low value would needlessly hinder the benefits satellite systems in low-Earth orbit can provide to American consumers without offsetting improvements for space sustainability. Thus, we request that the Commission revise the condition to include a more appropriate threshold value for the realized burden metric that achieves the goal of promoting space safety without unduly preempting deployment of advanced satellite systems that provide valuable services in the United States and worldwide."

"Although LeoLabs discussed a 100 object-years threshold, LeoLabs was also clear that the 100 object-years metric was not meant as a proposal but simply was chosen for ease of exposition and calculation in describing the methodology. In fact, LeoLabs stated that the Commission should “not consider the thresholds used in this presentation as definitive thresholds – this would need some thorough vetting.”"

"While LeoLabs has not yet arrived at a definitive limit for this metric, a 100 object-year threshold is far too stringent for any NGSO systems and should be replaced by a higher threshold that strikes a better balance between benefit for the American people and space sustainability."

"While a more refined metric is considered during the rulemaking, further examination of this threshold shows that a limit as high as 1,000 object-years is not unreasonable in the near term, as it would encourage safe operations without effectively precluding deployment of NGSO systems operating at altitudes above 600 km. However, we strongly urge further discussion among stakeholders through the pending orbital debris rulemaking to derive a meaningful threshold that provides both a fair and enforceable threshold for the entire industry."

"Rather than maintain the possibility that SpaceX consumers could be uniquely penalized depending upon the timing of future action in the pending orbital debris proceeding, the Commission should proactively revise the condition to establish a more appropriate limit, such as 1,000 object-years, as an initial modification subject to the outcome of the broader orbital
debris proceeding. This would ensure that American consumers would not be unduly prevented from realizing the benefits of the latest satellite systems while the Commission refines the approach to be applicable and beneficial for all space operators."

Attached filing.

[RedLineTrain]

"Unfortunately, this value is unrealistically low for SpaceX—and may be impossible for any other NGSO system operator. This arbitrarily low value would needlessly hinder the benefits satellite systems in low-Earth orbit can provide to American consumers without offsetting improvements for space sustainability. Thus, we request that the Commission revise the condition to include a more appropriate threshold value for the realized burden metric that achieves the goal of promoting space safety without unduly preempting deployment of advanced satellite systems that provide valuable services in the United States and worldwide."

"Although LeoLabs discussed a 100 object-years threshold, LeoLabs was also clear that the 100 object-years metric was not meant as a proposal but simply was chosen for ease of exposition and calculation in describing the methodology. In fact, LeoLabs stated that the Commission should “not consider the thresholds used in this presentation as definitive thresholds – this would need some thorough vetting.”"

Be careful what you ask for...

[novo2044]

"Unfortunately, this value is unrealistically low for SpaceX—and may be impossible for any other NGSO system operator. This arbitrarily low value would needlessly hinder the benefits satellite systems in low-Earth orbit can provide to American consumers without offsetting improvements for space sustainability. Thus, we request that the Commission revise the condition to include a more appropriate threshold value for the realized burden metric that achieves the goal of promoting space safety without unduly preempting deployment of advanced satellite systems that provide valuable services in the United States and worldwide."

"Although LeoLabs discussed a 100 object-years threshold, LeoLabs was also clear that the 100 object-years metric was not meant as a proposal but simply was chosen for ease of exposition and calculation in describing the methodology. In fact, LeoLabs stated that the Commission should “not consider the thresholds used in this presentation as definitive thresholds – this would need some thorough vetting.”"

Be careful what you ask for...

Given their recent failure rates, orbits and reentry rates I feel like 100 o-yrs isn't unrealistic for SpaceX.  If they can meet the standard, would they have genuine cause for complaint if it was altered?  It's not trivial to engineer for that level of reliability, to change the rules after they've designed, build, and launched a billion+ worth of satellites would be irritating, I assume.  The rules that govern fairness and competitiveness in federal law can be a morass sometimes.

[su27k]

Given their recent failure rates, orbits and reentry rates I feel like 100 o-yrs isn't unrealistic for SpaceX.  If they can meet the standard, would they have genuine cause for complaint if it was altered?  It's not trivial to engineer for that level of reliability, to change the rules after they've designed, build, and launched a billion+ worth of satellites would be irritating, I assume.  The rules that govern fairness and competitiveness in federal law can be a morass sometimes.

The problem is currently this rule only applies to Starlink, there's no indication that FCC is going to apply this rule to anybody else, so if you expect this rule to be some kind of moat, it doesn't work.

And it is in SpaceX's own best interest to avoid too many failures at operational orbit, they have to dodge their own failed satellites after all. And if a failed Starlink is involved in a collision, it would be a PR nightmare. So I wouldn't say investment in more reliability is wasted if FCC relaxes the requirement.

[matthewkantar]

I’m no lawyer, but I am pretty sure a regulation applied unevenly is not going to survive court challenges. Even more so if applied to only one company.

[kevin-rf]

While not ideal,  the drag at 550km does cause dead satellites to drop below the constellation in a reasonable amount of time. Looking at some of Jonathan McDowell's graphs,  6-9 months to drop that first 50km. While still a hazard,  it's manageable.

Compare this to other constellations at much higher altitudes.  For some, that time could be measured in decades. Or, longer. Space X really did pick the best location for a large constellation.

For instance,  look at the decay of failed starlink 2060.
https://planet4589.org/space/con/star/spl20/s2060.jpg