This letter corrects the record in response to misleading and incorrect filingsrecently submitted by Viasat, Inc. and Hughes Network Systems, LLC (collectively,"GSO operators" or "GSOs"). In both filings, the GSO operators, neither of whom hasever operated any satellites in Low Earth Orbit ("LEO"), repeat false assumptions andmisrepresent record filings in a strained effort to reach false conclusions about howSpaceX's non-geostationary orbit ("NGSO") satellite system works. In contrast, SpaceXis operating more than 700 LEO satellites that are already providing high-qualitybroadband service to users, and has conducted millions of performance tests on its network.In short, while the GSOs postulate theoretical claims about how they might operatean NGSO network and their inability to provide low-latency service, SpaceX has conductedmillions of tests on its actual operating equipment that demonstrate definitively it candeliver to consumers a true low-latency broadband.SpaceX Has Run Extensive Real-World Tests That Show Conclusively That ItsSystem Delivers Low-Latency Service.The GSOs' arguments about SpaceX's latency hinge entirely on the assertion thatbecause SpaceX used a few images of screen tests for illustrative purposes in a previouspresentation to the Commission, SpaceX lacks other data to support the parameters of itsnetwork performance. But the GSOs are reading too much into a single image used in anoverview presentation. Indeed, if true, Viasat's contortions about latency would seem tocall into question the credibility of its own stated reason for asking to modify itsauthorization for its NGSO system—to operate, for the first time, its own low-latencyservice from an altitude twice as high as SpaceX.In fact, SpaceX has now conducted millions of tests on actual consumer-gradeequipment in congested cells, showing consistent observed median latency ofapproximately 30 ms. These end-to-end latency measurements—based on actual data, nottheory—include all sources of network latency. Contrary to the GSOs' claims, these beta-test results of latency and throughput are not "best-case" performance measurements.Rather, they reflect testing performed using peak busy-hour conditions, heavily loadedcells, and representative locations. If anything, SpaceX's beta testing uses conditionsdesigned to support on-going optimization and testing of the network that make networkperformance measurements worse, not better. For example, all the user terminals wereconfigured to transmit debug data continuously, even if the beta customer didn't have anyregular internet traffic, forcing every terminal to continuously utilize the beam.Moreover, these results are based on beta-test software frame grouping settings thatdo not yet reflect performance using the software designed to optimize performance forcommercial use. Until recently, the network had been grouping user terminals in groupsof 8 per radio-frame, instead of the 20 terminals per radio-frame the system supports. Thisoperating choice is to support on-going optimization and testing of the network but has theconsequence of introducing 2.5 times longer delay between radio-frames for a given userin a fully loaded cell, corresponding to the smaller group sizes. Importantly, this softwarefeature has just been enabled and is specifically designed to optimize speeds in highlypopulated cells, increasing throughput by approximately 2.5 times.In addition to the datapoints representing SpaceX's aggregate performance, SpaceXanalyzed the last week of measurements for a community of 30 high-usage customers. Asshown in Figure 1, these measurements, totaling 1,048,576 datapoints, indicated a95th percentile latency of 42 ms and percentile latency of 30 ms between end users andthe point of presence connecting to the Internet. These measurements confirm the SpaceXnetwork is capable of allocating resources efficiently such that latency remains consistentwhether the measurement point is the overall network or individual groups of customers.*Figure 1. One Week of Latency Measurements (15 second data, 30 users)*The Commission should not be distracted by self-interested, ill-informedspeculation from GSOs that have never operated an actual low-latency system. Instead, itshould rely on actual data that SpaceX has provided the Commission.Viasat's Conclusions About SpaceX Operations Are Based on DocumentedMisrepresentations and Skewed Analysis.Viasat steadfastly refuses to allow facts to get in the way of the story it wishes weretrue. To support its claims about SpaceX's operations, Viasat relies extensively on researchby Professor Jonathan McDowell. SpaceX urges the Commission to review the letterProfessor McDowell himself filed in the record in which he called Viasat's filing a"misreading of my results" and stated that Viasat's analysis is an "inexplicableinterpretation."SpaceX is fully transparent about reporting when satellites lose maneuveringcapability. All satellite failures are marked on space-track.org, to which every operatorand the public at large have access. SpaceX has been continuously and diligently workingto upgrade its satellites as technology improves. As a result of these upgrades—and asSpaceX has previously reported, but Viasat continues to ignore—the last 233 satellitesSpaceX has launched have had no failures at the time of this filing. Nonetheless, SpaceXcontinues to work to improve the performance and reliability of its vehicles.Despite the heated rhetoric from competitors, SpaceX's modification will in factsignificantly improve its safety profile and ensure consumers have access to a truly low-latency service. The Commission would be particularly justified in discounting claimsfrom Viasat, given its ongoing misrepresentations and its apparent flaunting of Commission rules by its seeming unauthorized use of certain spectrum bands.The Commission should quickly approve SpaceX's modification.
SES-LIC-20190816-01063This application has been amended by IBFS File Number SES-AMD-20200220-00178 to operate this Ka-band gateway with eight technically identical 1.5-meter antennas in Loring, Maine. SpaceX originally applied for authority to transmit in the 28.35-29.1 GHz and 29.5-30.0 GHz bands and receive in the 17.8-18.6 GHz and 18.8-19.3 GHz bands. However, it deferred in requesting authority to operate this earth station in the 27.5-28.35 GHz band designated for use by the Upper Microwave Flexible Use Service (UMFUS) on a primary basis, with a secondary designation for FSS.SpaceX has completed its analysis of the Loring Gateway site so that it can demonstrate compliance with the requirements of Section25.136(a)(4) of the Commission's rules such that this earth station may operate without providing additional interference protection to terrestrial UMFUS systems operating in the band. Technical Appendix A demonstrates that the Loring Gateway will satisfy the criteria set forth in Section25.136(a)(4).SpaceX also submits with this amendment updated antenna performance information for its gateway operations. SpaceX will comply with a mask similar to the one in Section 25.209(a)(3) applicable to earth station antennas operating in the 24.75-25.25 GHz and 28.35-30.0 GHz bands with geostationary satellites but will improve that pattern to -3 dBi (rather than 0 dBi) beyond 25 degrees off-axis.
SpaceX leadership spoke with FCC officials on Tuesday to give an update on its Starlink satellite internet constellation progress, with "the successful launch and operation of nearly 300 additional satellites without a failure since before its last report."
SpaceX included an updated Starlink presentation, highlighting:—over 700 satellites deployed—beta service begun across multiple states—consistent observed median latency of approx. 30 ms—recent software upgrade improved speeds by 2.5x
New Ka-band gateways...Dumas, TXRobbins, CAWise, NCMandale, NCGateway Map
https://web.acma.gov.au/rrl/register_search.main_pageWagin, WA, AU -33.308268°,117.343372° Boorowa, NSW, AU -34.462093°,148.705734° Broken Hill, NSW, AU -31.998258°,141.441058° Pimba, SA, AU -31.250747°,136.801335°
https://rrf.rsm.govt.nz/smart-web/smart/page/-smart/domain/licence/SelectLicencePage.wdkThe New Zealand gateway locations:Cromwell Starlink SES 169.2057700 E 45.0602440 SWellsford Starlink SES 174.5137550 E 36.2846540 S
Do you thing you could start adding international gateways as well? I think we might see international service sooner rather than later.
Quote from: niwax on 10/19/2020 08:32 pmDo you thing you could start adding international gateways as well? I think we might see international service sooner rather than later.I think that would be great, but I do not maintain that map. Don't recall who the owner is.
SpaceX filed for a Ku-band gateway at McGregor, which is a little odd at this point. I guess they'll use the Ku gateways for testing the payloads after launch?https://fcc.report/IBFS/SES-LIC-INTR2020-03198
Quote from: gongora on 10/26/2020 01:57 pmSpaceX filed for a Ku-band gateway at McGregor, which is a little odd at this point. I guess they'll use the Ku gateways for testing the payloads after launch?https://fcc.report/IBFS/SES-LIC-INTR2020-03198It is not Garteway, it is user terminal with 1 m dish, for high speed like 300...500 Mbits
The Commission has previously granted experimental authority to test these same user terminals at various locations within the United States.3 In order to expand its assessment of the end-to-end capabilities of its satellite system, SpaceX seeks authority to test up to five user terminals electrically identical to those covered by its blanket license when mounted on a Gulfstream jet for a period of up to two years. Specifically, SpaceX seeks experimental authority for operation of one user terminal aboard each of up to five private jets while they are (1) on the ground at an airport, and (2) in flight over the United States (including its territories and territorial waters). Such authority would enable SpaceX to obtain critical data regarding the operational performance of its user terminals and the SpaceX NGSO system more broadly.
Quote from: vsatman on 10/30/2020 08:54 pmQuote from: gongora on 10/26/2020 01:57 pmSpaceX filed for a Ku-band gateway at McGregor, which is a little odd at this point. I guess they'll use the Ku gateways for testing the payloads after launch?https://fcc.report/IBFS/SES-LIC-INTR2020-03198It is not Garteway, it is user terminal with 1 m dish, for high speed like 300...500 Mbits That isn't the user terminal.
As I understand Space X file for FCC all what work in Ka band are Gatewaysall what work in Ku band are user terminal
