Author Topic: Starlink : New FCC and ITU Filings  (Read 195151 times)

Offline su27k

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Re: Starlink : New FCC and ITU Filings
« Reply #480 on: 08/20/2022 02:18 pm »
New Gen2 filing: https://licensing.fcc.gov/myibfs/download.do?attachment_key=16832647

Interesting tidbits:
1. Gen2 collision probability calculation used a satellite size that is larger than the actual Gen2 satellite just to be safe: mass 2,000kg, area 294 square meters
2. Some Gen2 satellite will carry a beacon for emergency communication during orbit raise, and this beacon is a hosted payload with frequency authorized by Germany, its use will be outside US.

But the biggest bombshell is SpaceX will use both F9 and Starship to launch Gen2, and it sounds like the Gen2 launched on F9 will be smaller:

Quote
As another example, SpaceX is proud to inform the Commission that it has decided to further accelerate its already record-breaking deployment schedule for its Gen2 system by using both its new Starship vehicle as well as its tested and dependable Falcon 9. While SpaceX will use technically identical satellites on both rockets, the physical structures will be tailored to meet the physical dimensions of the rockets on which they will be launched. In no event will any satellite exceed the overly conservative DAS analysis SpaceX provided to the Commission. To be clear, while SpaceX plans to accelerate deployment by using both of the rockets in its fleet, it remains committed to deploying all of its satellites—whether from Starship or from Falcon 9—into orbits described in Configuration 1 as described in its Amendment from August 2021 and confirmed in its letter to the Commission in January of this year. Specifically, SpaceX plans to launch satellites for its Gen2 constellation beginning with its three 500-kilometer shells, followed by satellites in its lower-altitude shells. The result will be that more Americans will receive high-quality broadband faster.


Offline AmigaClone

Re: Starlink : New FCC and ITU Filings
« Reply #481 on: 08/21/2022 01:25 am »
But the biggest bombshell is SpaceX will use both F9 and Starship to launch Gen2, and it sounds like the Gen2 launched on F9 will be smaller:

I agree with you that the Gen2 launched by F9 being less massive, besides being shaped differently.

SpaceX would need to launch roughly 280 (±20) Starships within 6 years of the constellation being approved to get to the halfway point. A similar number would need to be launched in three additional years to complete the Gen2 constellation. Having F9s replace some of those launches should help, even if it would take 2-5 F9 launches to send up the same number of Gen2 satellites as a Starship.

For now, SpaceX is insisting Gen1 and Gen2 Ka and Ku Starlink constellations be treated as separate entities. I can see that changing once Gen2 is fully deployed.

Offline su27k

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Re: Starlink : New FCC and ITU Filings
« Reply #482 on: 09/08/2022 05:25 am »
Wow

https://twitter.com/Megaconstellati/status/1567614524060061698

Quote
BREAKING - 12d after @SpaceX's @FCC modification request for Starlink Gen1 to provide direct-to-handset service using @tmobile@dish's AWS-4 band (https://licensing.fcc.gov/myibfs/download.do?attachment_key=16760354) SpaceX files another license request challenging @globalstar's exclusive spectrum:

https://licensing.fcc.gov/myibfs/download.do?attachment_key=16935258
[1/4]



Apart from the 2020-2025MHz band SpaceX seeks to use the 1610-1617.775 MHz & 2483.5-2500 MHz bands which @globalstar uses for the #iPhone14 sat service, considers "key assets" (https://globalstar.com/Globalstar/media/Globalstar/Downloads/Spectrum/GlobalstarOverviewPresentation.pdf) & promotes to be co-utilized on the ground for small cells (Band 53).
[2/4]



SpaceX says "Globalstar, has enjoyed exclusive access to portions of the 1.6/2.4 GHz bands, even though the Commission did not provide Globalstar with perpetual exclusive use of the bands", believes "cutting-edge innovations" will ensure they don't cause intereference.
[3/4]



The application was filed 6-SEP-22, the day before the $AAPL + $GSAT deal was announced with the #iPhone14 premiere. This is the 2nd party after @KeplerComms challenging @globalstar's spectrum (http://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SATPDR2021122400204&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Number - check "other filings" for Globalstar's opposition).



P.S.: "SpaceX has not yet submitted system information for ITU publication. SpaceX will submit
this information at the appropriate time to the Commission for filing through the U.S. [...]
source: https://licensing.fcc.gov/myibfs/download.do?attachment_key=16935259
[5/4]


FCC filing: SpaceX application to provide mobile satellite service in the 1610-1617.775 MHz uplink Earth-to-space, the 2020-2025 MHz uplink Earth-to-space, and the 2483.5-2500 MHz downlink space-to-Earth band.

They propose to add this to Gen1 as hosted payload.


« Last Edit: 09/08/2022 05:26 am by su27k »

Offline RedLineTrain

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Re: Starlink : New FCC and ITU Filings
« Reply #483 on: 09/08/2022 02:30 pm »
SpaceX application to provide mobile satellite service in the 1610-1617.775 MHz uplink Earth-to-space, the 2020-2025 MHz uplink Earth-to-space, and the 2483.5-2500 MHz downlink space-to-Earth band.

They propose to add this to Gen1 as hosted payload.

It is unclear to me whether SpaceX is proposing to use omnidirectional terminals (like Swarm) or phased array terminals (like Starlink).

Offline gongora

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Re: Starlink : New FCC and ITU Filings
« Reply #484 on: 09/08/2022 03:04 pm »
The lastest modification adds the 1.6GHz and 2.4GHz to the already requested 2.0GHz filing that was done recently.

Offline RedLineTrain

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Re: Starlink : New FCC and ITU Filings
« Reply #485 on: 09/08/2022 03:31 pm »
The lastest modification adds the 1.6GHz and 2.4GHz to the already requested 2.0GHz filing that was done recently.

And after rereading the 2.0GHz filing, it also is not crystal clear to me whether the terminals will be directional or omnidirectional for those frequencies.

On first read through a few weeks ago, I thought they were doing directional on the 2.0GHz filing.  But now I'm not sure.

Offline RedLineTrain

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Re: Starlink : New FCC and ITU Filings
« Reply #486 on: 09/08/2022 03:48 pm »
Following up on the recent Court of Appeal decision on the Gen1 constellation, the Natural Resources Defense Council and International Dark Sky Association filed an opposition to the Gen2 constellation.

The thrust of the filing is that a categorical exclusion from NEPA (the environmental assessment law) is unlawful.

Offline su27k

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Re: Starlink : New FCC and ITU Filings
« Reply #487 on: 09/09/2022 02:23 am »
Following up on the recent Court of Appeal decision on the Gen1 constellation, the Natural Resources Defense Council and International Dark Sky Association filed an opposition to the Gen2 constellation.

The thrust of the filing is that a categorical exclusion from NEPA (the environmental assessment law) is unlawful.

This seems to be just a repackaging of Viasat's argument, except with more hyperbole added, I think FCC can easily dismiss this using the same argument they used in approving Gen1 relocation, the question is does FCC want to stick their neck out for SpaceX or not.
« Last Edit: 09/09/2022 02:33 am by su27k »

Online FutureSpaceTourist

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Re: Starlink : New FCC and ITU Filings
« Reply #488 on: 09/09/2022 09:36 pm »
https://twitter.com/thesheetztweetz/status/1568352153026154504

Quote
Update: SpaceX filed a request to the FCC, asking to appeal the FCC's RDOF decision and saying the denial issued last month "is flawed as a matter of both law and policy."

https://www.fcc.gov/ecfs/filing/status/detail/confirmation/20220909251827409
« Last Edit: 09/09/2022 09:37 pm by FutureSpaceTourist »

Offline raptorx2

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Re: Starlink : New FCC and ITU Filings
« Reply #489 on: 09/10/2022 09:50 pm »
Wow

https://twitter.com/Megaconstellati/status/1567614524060061698

Quote
BREAKING - 12d after @SpaceX's @FCC modification request for Starlink Gen1 to provide direct-to-handset service using @tmobile@dish's AWS-4 band (https://licensing.fcc.gov/myibfs/download.do?attachment_key=16760354) SpaceX files another license request challenging @globalstar's exclusive spectrum:

https://licensing.fcc.gov/myibfs/download.do?attachment_key=16935258
[1/4]



Apart from the 2020-2025MHz band SpaceX seeks to use the 1610-1617.775 MHz & 2483.5-2500 MHz bands which @globalstar uses for the #iPhone14 sat service, considers "key assets" (https://globalstar.com/Globalstar/media/Globalstar/Downloads/Spectrum/GlobalstarOverviewPresentation.pdf) & promotes to be co-utilized on the ground for small cells (Band 53).
[2/4]



SpaceX says "Globalstar, has enjoyed exclusive access to portions of the 1.6/2.4 GHz bands, even though the Commission did not provide Globalstar with perpetual exclusive use of the bands", believes "cutting-edge innovations" will ensure they don't cause intereference.
[3/4]



The application was filed 6-SEP-22, the day before the $AAPL + $GSAT deal was announced with the #iPhone14 premiere. This is the 2nd party after @KeplerComms challenging @globalstar's spectrum (http://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SATPDR2021122400204&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Number - check "other filings" for Globalstar's opposition).



P.S.: "SpaceX has not yet submitted system information for ITU publication. SpaceX will submit
this information at the appropriate time to the Commission for filing through the U.S. [...]
source: https://licensing.fcc.gov/myibfs/download.do?attachment_key=16935259
[5/4]


FCC filing: SpaceX application to provide mobile satellite service in the 1610-1617.775 MHz uplink Earth-to-space, the 2020-2025 MHz uplink Earth-to-space, and the 2483.5-2500 MHz downlink space-to-Earth band.

They propose to add this to Gen1 as hosted payload.

This is pretty shocking.  The Big LEO Band is occupied by Globalstar  (1610- 1617.775 earth-to-space) and 2483.5-2500Mhz space-to-earth, and Iridium 1617.25-1626Mhz. As described, Original Big LEO Band licenses were awarded to 4 companies.  Globalstar, Iridium, TRW, and MCHI. Only 2 ultimately went commercial.  SpaceX makes an application to share the Globalstar L Band.  This puts Globalstar in a very precarious position. Apple has several "convenants" in the agreement between themselves and Globalstar for Satellite SOS Messaging.  Among them is 

*Provide and maintain all resources, including personnel, software, satellite, gateways, satellite spectrum and regulatory rights necessary to provide the Services (the “Required Resources”);

•Allocate 85% of its current and future network capacity to support the Services (see further discussion of capacity below);"

If SpaceX was provided a license to share Globalstars spectrum. Then Globalstar "could be viewed" to be in default of these requirements.  Now Globalstar is REQUIRED by the Terms Agreement to raise capital to pay for 18 new satellites and ground network, as well as launch costs by Dec. 31,2022.  Maybe $650MM which AAPl will reimburse (straight line over useful lives starting in 2025)  So first question.  Will SpaceX's BIG LEO application throw caution to the GSAT Capital Raise ambitions?  Globalstar already filed BK once. The second "unresolved issue" is the lack of a Launch Contract.  How do you know how much Capital you need to raise without a Launch Contract in hand?  Globalstar paid SpaceX about $40MM (my guess) according to the GSAT SEC statements to launch their single spare satellite earlier this year.  I am sure GSAT paid a premium to move to the front of the rideshare line, as their satellite appeared to be added at the last minute. Their FCC license requires an on-orbit spare. So now SpaceX has "belly-flopped" into the GSAT/AAPL party via their Big LEO application.   Why a launch for Globalstar's satellites has not been announced?  Well, perhaps SpaceX isn't interested in launching its 18 satellites in 2025.  Which would lead them to currently unproven and more expensive launch options.  Like Vulcan, New Glen, Ariane 6.  So perhaps SpaceX can "leverage" their position as a nearly "sole source" Launch Provider to GSAT in exchange for not standing in the way of SpaceX's BIG LEO application.  DOUBTFUL.  As noted earlier, a Big LEO license for SpaceX would almost surely doom the GSAT / AAPL deal.   In the meantime, the bureaucracy of the FCC would require issuing a NOI/NPRM which can take years to navigate.  In the meantime, the Capital Markets may take a 'wait and see" to the Globalstar Capital Raise, which would also put Globalstar in default of the AAPL agreements.

Offline su27k

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Re: Starlink : New FCC and ITU Filings
« Reply #490 on: 09/18/2022 02:59 am »
« Last Edit: 09/18/2022 03:10 am by su27k »

Offline OceanCat

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Re: Starlink : New FCC and ITU Filings
« Reply #491 on: 09/19/2022 04:03 am »
If SpaceX was provided a license to share Globalstars spectrum. Then Globalstar "could be viewed" to be in default of these requirements.

It doesn't work like that. SpaceX would get a lower priority license. It is supposed to not interfere with prior licensees substantially. Globalstar has just made the first filing:

Quote
Given Globalstar’s priority position at
1610-1617.775 MHz/2483.5-2500 MHz, existing critical services depending on the spectrum, and
very established regulatory precedent to protect such incumbent services, any other operator
seeking to use this spectrum would need to successfully complete coordination with both
Globalstar’s U.S.-filed HIBLEO-4 system and French-filed HIBLEO-X system (including current
and future satellites for these systems). Based on the scant data provided to date, SpaceX has not
demonstrated that a successful coordination between Globalstar and SpaceX is possible or that
harmful interference would not be expected from SpaceX’s operations to Globalstar’s MSS
network. In particular, SpaceX has not provided any actual interference analysis to substantiate its
claims about “modern communication technologies, sophisticated phased-arrays, and advanced
beam scheduling protocols inherent in its 1.6/2.4 GHz MSS system” that will prevent harmful
interference with Globalstar’s systems. Vague statements provide no basis for Commission action,5
especially when harmful interference could upend the safety-of-life services that Globalstar
provides to consumers and inflict irreparable harm on Globalstar’s MSS business.

It does look like SpaceX made its filing in a rush. The FCC will not reject it as Globalstar asks though. It will just wait for more information.

Offline su27k

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Re: Starlink : New FCC and ITU Filings
« Reply #492 on: 10/10/2022 04:56 am »
SpaceX says 5G plan could disrupt Starlink more than previously thought

Quote from: SpaceNews
Plans to use a part of Ku-band for 5G networks in the United States could disrupt Starlink broadband services even more than SpaceX previously estimated, the company said Oct. 4 as it released interference analysis from a third party.

SpaceX said the analysis validates its in-house study in June, when it warned Starlink would be unusable for most Americans if a 5G high-power mobile service is allowed to operate with 12 GHz band frequencies across the United States.

The analysis from engineering consulting firm Savid also shows “SpaceX may have underestimated the likelihood of interference and potential harm to Starlink services,” SpaceX senior director of satellite policy David Goldman wrote to the Federal Communications Commission.

Offline AmigaClone

Re: Starlink : New FCC and ITU Filings
« Reply #493 on: 10/20/2022 01:38 pm »
In August, SpaceX sent a letter request to the FCC requesting that the Commission find that SpaceX has satisfied the milestone of launching over half of it's (first) authorized constellation (call signs S2983/3018) and is therefore relieved of its obligation to maintain a performance bond related to this non-geostationary orbit (NGSO) system.

Once the FCC approves a the deployment of a constellation, the owner has to commit to putting up and operating half the satellites within six years of the approval date with the second half in the following three years. For the original 4409 Starlink constellation, SpaceX reached the initial goal more than 18 months early.

The request was approved in September.
https://licensing.fcc.gov/ibfsweb/ib.page.FetchPN?report_key=16967401

Offline su27k

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Re: Starlink : New FCC and ITU Filings
« Reply #494 on: 10/22/2022 04:19 am »
In the latest response to Viasat, SpaceX quoted 3 studies to show satellite reentry has negligible effect on the environment:

Quote
Similarly, two independent studies that the European Space Agency (“ESA”) commissioned in 2019—the ATISPADE and ARA studies—show that satellite reentry has a “negligible” effect on the environment.18

The ATISPADE study looked at the effect of reentering satellites on the ozone layer. It found that, in the worst case analyzed, the additional yearly ozone reduction was “negligible when compared to the impact of anthropogenic activities,” only between 0.0006% and 0.0008% of global annual ozone loss.19 While the worst case used in the study assumed an average of 450 tons worth of satellites reentering every year and a peak of 650 tons per year,20 the fundamental conclusion—that the impact to the ozone is “negligible” compared to other sources—remains valid even when extrapolating to one order of magnitude more mass per year, as Viasat aggressively assumes would occur.21

But Viasat presents no justification for its allegations that these extremely aggressive scenarios will come to pass. Indeed, one leading study raises questions about Viasat’s fundamental premise, finding that the chemical reactions that take place during meteorite reentry do not create alumina at all, even though meteorites contain aluminum.22 In fact, no alumina has ever been detected using rocket-borne spectrometry specifically looking for all aluminum species precipitated by reentering meteorites.

The ESA-commissioned ARA study undercuts Viasat’s overblown claims—parroted by NRDC/IDA and others—about the climate effects of the Gen2 satellites. The study found the climate effects of satellite reentry to be minute compared to other man-made sources. For instance, in the worst-case scenario, the annual impact of satellite reentry was 290,000 times less than the annual impact of the aviation sector and 650,000 times less than the annual impact of the road transportation sector.23 Again, even when extrapolated to an order of magnitude greater than the worst case evaluated in the ARA study, the effect would remain negligible relative to other man-made sources. Similarly, assuming the extremely aggressive reentry figures that Viasat touts, the annual impact of reentering Gen2 satellites on Earth’s albedo—the fraction of solar radiation that is reflected away from Earth—will be negligible compared to natural sources (i.e., just 0.005% of the amount of mineral dust created annually through naturally occurring dust storms from the Sahara Desert alone).24

FCC filing: https://licensing.fcc.gov/myibfs/download.do?attachment_key=17743215

Reference #22 is the paper Meteor-Ablated Aluminum in the Mesosphere-Lower Thermosphere
« Last Edit: 10/22/2022 04:20 am by su27k »

Offline OceanCat

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Re: Starlink : New FCC and ITU Filings
« Reply #495 on: 10/28/2022 11:29 am »
Quote
    SpaceX remains committed to leading the way on space sustainability, and
recognizes that further dialogue with the scientific community on this issue would be valuable.
For instance, the U.S. Government Accountability Office hypothesized that additional
“observational data” on the release of alumina from satellite reentry could help the scientific
community better quantify emissions and develop “more accurate atmospheric modeling studies.”
To that end, SpaceX commits to work with the scientific community to explore methods to collect
observational data on the formation of alumina from satellite reentry. SpaceX will implement
reasonable methods that are discovered to the extent practicable and will report findings from these
measurements to the Commission.

Quote
    Additionally, SpaceX hereby notifies the Commission of its intent, following issuance of
the Gen2 license, to seek a modification of its V-band authorization to significantly reduce the
total number of satellites ultimately on orbit. SpaceX plans to request Commission authorization
to (1) harmonize the orbital parameters of those V-band space stations with those requested in
SpaceX’s pending second-generation (“Gen2”) application and (2) confirm that these V-band
space stations will be operated as payloads onboard a subset of SpaceX’s proposed Gen2 satellites,
and not as separate spacecraft. This modification will not increase, and may slightly reduce, the
number of V-band space stations and it will not materially affect any other aspects of the V-band
license. SpaceX does not anticipate that this change to its planned V-band operations will alter
any material aspect of its pending application to deploy and operate Gen2 space stations in the Ku-
, Ka-, and E-bands.

Offline russianhalo117

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Re: Starlink : New FCC and ITU Filings
« Reply #496 on: 10/30/2022 12:04 am »
Quote
    SpaceX remains committed to leading the way on space sustainability, and
recognizes that further dialogue with the scientific community on this issue would be valuable.
For instance, the U.S. Government Accountability Office hypothesized that additional
“observational data” on the release of alumina from satellite reentry could help the scientific
community better quantify emissions and develop “more accurate atmospheric modeling studies.”
To that end, SpaceX commits to work with the scientific community to explore methods to collect
observational data on the formation of alumina from satellite reentry. SpaceX will implement
reasonable methods that are discovered to the extent practicable and will report findings from these
measurements to the Commission.

Quote
    Additionally, SpaceX hereby notifies the Commission of its intent, following issuance of
the Gen2 license, to seek a modification of its V-band authorization to significantly reduce the
total number of satellites ultimately on orbit. SpaceX plans to request Commission authorization
to (1) harmonize the orbital parameters of those V-band space stations with those requested in
SpaceX’s pending second-generation (“Gen2”) application and (2) confirm that these V-band
space stations will be operated as payloads onboard a subset of SpaceX’s proposed Gen2 satellites,
and not as separate spacecraft. This modification will not increase, and may slightly reduce, the
number of V-band space stations and it will not materially affect any other aspects of the V-band
license. SpaceX does not anticipate that this change to its planned V-band operations will alter
any material aspect of its pending application to deploy and operate Gen2 space stations in the Ku-
, Ka-, and E-bands.

https://www.pcmag.com/news/spacex-to-cut-down-satellite-count-by-consolidating-v-band-system

Offline su27k

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Re: Starlink : New FCC and ITU Filings
« Reply #497 on: 11/03/2022 03:03 am »
https://twitter.com/SpcPlcyOnline/status/1587894489355808769

Quote
GAO wants FCC to reexamine its 1986 decision excluding most FCC actions from NEPA, particularly regarding mega-constellations. Wants review of whether they normally do not have significant effects on human env & document their findings. FCC agrees. https://gao.gov/products/gao-23-105005

From FCC's reply it doesn't seem that they plan to change anything at the moment, so probably won't affect Gen2, but worth monitoring.

Offline OceanCat

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Re: Starlink : New FCC and ITU Filings
« Reply #498 on: 11/03/2022 07:02 pm »
From FCC's reply it doesn't seem that they plan to change anything at the moment, so probably won't affect Gen2, but worth monitoring.

Yeah, the FCC is not allowed to change the rules mid game. They will have to issue a notice of proposed rulemaking, collect public feedback, and finally issue an order. It will take 1-2 years.

Online FutureSpaceTourist

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Re: Starlink : New FCC and ITU Filings
« Reply #499 on: 12/01/2022 08:33 pm »
https://twitter.com/thesheetztweetz/status/1598429321558986752

Quote
FCC decision on SpaceX's application for its Gen2 Starlink satellites, with some key conditions.

"Our actions will allow SpaceX to being deployment of Gen2 Starlink"

Highlights mine: https://www.fcc.gov/document/fcc-partially-grants-spacex-gen2-broadband-satellite-application
fcc.gov/document/fcc-p…
« Last Edit: 12/01/2022 08:35 pm by FutureSpaceTourist »

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