Starlink : New FCC and ITU Filings

[RedLineTrain]

SpaceX may have made an error in informing the FCC that it would soon be requesting that the already-authorized 7,500-satellite V-band constellation be folded into the Gen2 constellation.  FCC just took that and said that they weren't going to authorize any more satellites and frequency bands.

Also, I believe that SpaceX got an Nco = 1 on Gen2, meaning that the overall Gen1+Gen2 will now have a combined Nco=2.  I imagine that SpaceX wanted better than that.

[vaporcobra]

SpaceX may have made an error in informing the FCC that it would soon be requesting that the already-authorized 7,500-satellite V-band constellation be folded into the Gen2 constellation.  FCC just took that and said that they weren't going to authorize any more satellites and frequency bands.

Also, I believe that SpaceX got an Nco = 1 on Gen2, meaning that the overall Gen1+Gen2 will now have a combined Nco=2.  I imagine that SpaceX wanted better than that.

It's really bizarre, the FCC actually proudly notes that this new "grant" will reduce the total number of licensed Starlink satellites if SpaceX follows through with plans to combine its V-band and Gen2 constellations (7518 to 7500). Simultaneously, it adds several far more annoying restrictions and uncertainties not present on the V-band constellation grant, making it a worse license for SpaceX if it goes that route.

The irony is that in every possible way, it now motivates SpaceX to launch the V-band constellation in addition to Gen2. I don't think SpaceX has enough time to do so even if it wanted to, but it just makes it clear that the FCC understands it sort of has SpaceX over a barrel after taking 2.5 years to functionally deny its Gen2 application.

[gongora]

The previous V-band only sats weren't going to get built and deployed.  Ever.

[gongora]

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

[gongora]

The NCO=1 being separate for the two systems is a win for SpaceX, and they weren't going to do any better.  It's for a couple specific frequency bands.

[vaporcobra]

The previous V-band only sats weren't going to get built and deployed.  Ever.

We can say that that's fairly apparent with years of hindsight and the recent knowledge that Starlink Gen1 probably isn't sustainable, but it's a stretch to claim that SpaceX was never serious about building the V-band constellation.

[FutureSpaceTourist]

twitter.com/planet4589/status/1598461377672318985

Starlink Gen2 summary: FCC approves launch of layers 5, 6, and 7 in my SG2 table at https://planet4589.org/space/con/conlist.html, to a total of 2500 out of the requested 3360 sats in each of those layers.  Approval of the remaining 22500 Gen2 sats is deferred

https://twitter.com/planet4589/status/1598462878109032451

This corresponds to the magenta line in this simulation   https://planet4589.org/astro/starsim/figs03/Fig6aG2.jpg but reduced by 0.75 to about 230 sats above horizon at midsummer twilight at 52N (e.g. UK) compared to the blue line corresponding to the full 30000 sats

[gongora]

Some excerpts from the 74 page document:

up to 7,500 satellites operating at altitudes of 525, 530, and 535 km and inclinations of 53, 43, and 33 degrees, respectively, using frequencies in the Ku- and Ka-band

We decline to require SpaceX to combine its Gen1 Starlink and Gen2 Starlink systems for purposes of meeting aggregate EPFD limits

We therefore condition this authorization, consistent with SpaceX’s commitment on the record of this proceeding, such that SpaceX must operate its Gen2 Starlink constellation with an NCo of 1, in the 12.2-12.7 GHz (spaceto-Earth) frequency band

We nonetheless condition this authorization to require SpaceX to utilize a 25 degree minimum elevation angle for its user terminals, except for operations above 62 degrees latitude, where SpaceX may observe a minimum elevation angle of 5 degrees.

We note that effective September 19, 2022, the filing of applications for new earth station licenses, and modifications to earth stations already authorized, to operate in the 12.7 GHz band are subject to a freeze, pending the outcome of the Commission’s ongoing rulemaking proceeding regarding use of the 12.7-13.25 GHz band.

We also note that in the 14.0-14.2 GHz band, NASA operates Tracking and Data Relay Satellite System facilities at three locations: Guam (latitude 13°36′55″ N, longitude 144°51′22″ E); White Sands, New Mexico (latitude 32°20′59″ N, longitude 106°36′31″ W and latitude 32°32′40″ N, longitude 106°36′48″ W); and Blossom Point, Maryland. For transmissions in the 14-14.2 GHz band from certain NGSO FSS earth stations located within 125 kilometers of these three sites, earth station operations must take account of these NASA facilities.

SpaceX explains that two Ka-band gateway beams are transmitted at the same frequency, right hand circular polarization and left hand circular polarization, and 32 satellites may communicate with the same gateway at the same time, for a maximum of 64 co-frequency beams

we also condition SpaceX’s Gen2 Starlink operations in the 19.7-20.2 GHz band (space-to-Earth) to require that SpaceX not use more than one satellite beam on the same frequency to the same or overlapping areas at a time. ... As discussed herein, we find that SpaceX’s Gen2 Starlink system is a separate system from its Gen1 Starlink system, and both systems must maintain an NCo of 1 on an individual basis.
Should GSO operators experience actual interference from SpaceX, the Commission will take appropriate action, which could include, but is not limited to, requiring SpaceX to operate with an NCo of 1 across both its Gen1 Starlink and Gen2 Starlink constellations in the 19.7-20.2 GHz band.

Pending further review and coordination with Federal users, we defer acting on SpaceX’s request to use the E-Band as well as any action regarding SpaceX’s described use of the emergency beacons.

SpaceX states there are circumstances where it is preferrable for the other operator to conduct collision avoidance maneuvers, such as a case of a satellite transiting slowly through SpaceX’s shells using electric propulsion, and in such cases SpaceX will ask the operator to conduct the maneuver.

75. NASA raises a distinct and broader concern with respect to Gen2 Starlink, noting that while individual SpaceX satellites may be deemed to have a collision risk of zero because of their propulsive capabilities with a constellation of this size, error-free systems and a collision risk of zero should not be assumed.293 In response to this concern, we will apply reporting conditions as adopted for Gen1 Starlink in the SpaceX Third Modification Order to Gen2 Starlink, including reporting the number of collision avoidance maneuvers. In order to address NASA’s observation that systems cannot be assumed to be error free, we also are broadening this condition to include reporting with respect to any collision avoidance system outages or  navailability, either on a system wide basis or for individual satellites, due to any cause other than disabling of the system for a single satellite in order to facilitate operator-to-operator coordination. An “outage” would include any individual satellite anomaly that results in a satellite not achieving targeted risk mitigation via maneuver.

We will follow the approach of the SpaceX Third Modification Order,311 and require SpaceX to restrict its Gen2 Starlink operations to below 580 km

87. Starship and Falcon 9 deployment mechanism. We asked SpaceX to clarify whether Starship’s satellite deployment mechanism will use spacers or stiffening rods, which would generate additional debris.316 While SpaceX initially stated the deployment mechanism for Starship had not yet been finalized as of January 2022,317 SpaceX has since informed the Commission that it will not use spacers or stiffening rods for the deployment mechanism for Gen2 Starlink satellites deployed on SpaceX’s Starship launch vehicle.318 However, SpaceX does state that it will use spacers and tension rods for the initial satellites deployed on its Falcon 9 launch vehicle.319 SpaceX describes its deployment mechanism and procedures for satellites launched on its Falcon 9 launch vehicles as follows: “In deploying multiple satellites with each launch, SpaceX uses four separate rod assemblies, each consisting of two rods, to hold the stacked satellites in place within the fairing. To deploy the stack of satellites from the launch vehicle, the rods release the satellites to separate them prior to further orbit raising activities. Thereafter, the rods — which are made of lightweight aluminum and are only 1.5 inches in diameter and about six meters long — naturally re-enter the Earth's atmosphere.”320 SpaceX has used its internal software which it describes as leveraging the capabilities of NASA’s DAS but with higher fidelity analysis, to calculate that these rods have an expected orbital lifetime of at most 36 days (assuming the highest deployment SpaceX plans).321 SpaceX also states these rods will fully demise in the atmosphere and pose no casualty risk.322 Although it is unclear at this point how many launches will utilize these deployment mechanisms, given the short orbital lifetime and full demise of this operational debris, and in light of longer-term plans for deployment using a different method, we take no further action at this time concerning spacers and tension rods. As plans for deployment of the Gen2 Starlink system are refined, including through modifications and further actions to address additional frequency bands, we retain discretion to address this matter further if necessary

aa. In the event of satellite failures resulting in more than 100 post-failure object years, SpaceX may not deploy any additional satellites until the Commission has approved a license modification that includes an updated orbital debris mitigation plan addressing reduction in the failure rate or mitigation of the risk of satellite failures.

dd. SpaceX may not deploy any satellites authorized in this grant directly to their operational altitude.

gg. SpaceX must coordinate with NSF to achieve a mutually acceptable agreement to mitigate the impact of its satellites on optical ground-based astronomy. SpaceX must submit an annual report to the Commission, by January 1st each year covering the proceeding year containing the following information: (1) whether it has reached a coordination agreement with NSF addressing optical astronomy; and (2) any steps SpaceX has taken to reduce the impact of its satellites on optical astronomy, including but not limited to darkening, deflecting light away from the Earth, attitude maneuvering, and provision of
orbital information to astronomers for scheduling observations around satellites’ locations.

hh. SpaceX must follow its commitment to work with the scientific community to explore methods to collect observational data on formation of alumina from satellite reentry, to implement reasonable methods that are discovered to the extent practicable, and to report findings from these measurements taken to the Commission, as part of its annual report specified in condition gg.

b. SpaceX must launch 50% of the maximum number of proposed space stations, place them in the assigned orbits, and operate them in accordance with the station authorization no later than December 1, 2028, and SpaceX 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 December 1, 2031. 47 CFR §
25.164(b)



supplemental info:

Moreover, SpaceX does not intend to include tension rods or spacers for its Starship-based Gen2 satellite deployments, but may initially use tension rods and spacers for Gen2 satellite deployments on Falcon 9.

SpaceX has budgeted sufficient propellant to accommodate approximately 5,000 propulsive maneuvers over the life of a satellite, including a budget of approximately 350 collision avoidance maneuvers per satellite over that time period.

SpaceX anticipates launching satellites into the Gen2 constellation at a rate of at least once per week during 2023, with a more rapid cadence over time. While the number of satellites per launch will vary depending on the launch vehicle used and whether any other payloads are involved, SpaceX expects that launches will have approximately twenty to sixty satellites on each Falcon 9 launch and approximately fifty to one hundred satellites initially on each Starship launch,

[su27k]

SpaceX may have made an error in informing the FCC that it would soon be requesting that the already-authorized 7,500-satellite V-band constellation be folded into the Gen2 constellation.  FCC just took that and said that they weren't going to authorize any more satellites and frequency bands.

I'm not sure SpaceX had a choice, I get the impression that there're backroom discussions between FCC and SpaceX, and this is the compromise they reached which allows Gen2 to launch immediately. I think there's probably a good reason the filing wrt folding V-band into Gen2 is called "Gen2 Letter Final.pdf", seems they know this is what's needed to get a partial authorization.

Still a small win for SpaceX since Gen2 satellite size is a lot bigger than Gen1/V-band satellite, and they get to use ~500km orbit instead of the super low ~300km orbit of the V-band.

[scr00chy]

Looks like SpaceX saw this coming. From the October 2022 document:

Now, two-and-a-half years after filing the Gen2 application and over a year since filing its amended application, the Bureau is requesting yet more information beyond the scope of the Commission’s rules. SpaceX values transparency with the Commission, but is concerned that this additional information, which no other operator is required to provide, will be used as a basis for conditioning a grant of its application.

[deadman1204]

gg. SpaceX must coordinate with NSF to achieve a mutually acceptable agreement to mitigate the impact of its satellites on optical ground-based astronomy. SpaceX must submit an annual report to the Commission, by January 1st each year covering the proceeding year containing the following information: (1) whether it has reached a coordination agreement with NSF addressing optical astronomy; and (2) any steps SpaceX has taken to reduce the impact of its satellites on optical astronomy, including but not limited to darkening, deflecting light away from the Earth, attitude maneuvering, and provision of
orbital information to astronomers for scheduling observations around satellites’ locations.

This is awesome. The NSF (national science foundation) - which runs big ground based observatories has a say in how much light mitigation spaceX must do. Rule making means this isn't just up to the largesse of a for profit company.
This bodes well for precedent for all future constellations of other companies.

[Robotbeat]

gg. SpaceX must coordinate with NSF to achieve a mutually acceptable agreement to mitigate the impact of its satellites on optical ground-based astronomy. SpaceX must submit an annual report to the Commission, by January 1st each year covering the proceeding year containing the following information: (1) whether it has reached a coordination agreement with NSF addressing optical astronomy; and (2) any steps SpaceX has taken to reduce the impact of its satellites on optical astronomy, including but not limited to darkening, deflecting light away from the Earth, attitude maneuvering, and provision of
orbital information to astronomers for scheduling observations around satellites’ locations.

This is awesome. The NSF (national science foundation) - which runs big ground based observatories has a say in how much light mitigation spaceX must do. Rule making means this isn't just up to the largesse of a for profit company.
This bodes well for precedent for all future constellations of other companies.

SpaceX has done more to mitigate optical effects than any other company, but they’ve gotten more hate about it than anyone else. Without an international agreement, this may just hamper US constellations while doing nothing to reduce overall light pollution. No good deed ever goes unpunished.

(It’s also a potential conflict of interest… space based astronomy will be revolutionized by the launch vehicle required for Starlink V2… ground based astronomy may have an interest in not being made largely obsolete? Or at least unduly dismissive of the BENEFITS to astronomy that Starlink’s launch vehicle brings to space astronomy… a launch vehicle which wouldn’t be adequately funded—or cost lowered—without the launch demand provided by megaconstellations.)

[Robotbeat]

SpaceX may have made an error in informing the FCC that it would soon be requesting that the already-authorized 7,500-satellite V-band constellation be folded into the Gen2 constellation.  FCC just took that and said that they weren't going to authorize any more satellites and frequency bands.

I'm not sure SpaceX had a choice, I get the impression that there're backroom discussions between FCC and SpaceX, and this is the compromise they reached which allows Gen2 to launch immediately. I think there's probably a good reason the filing wrt folding V-band into Gen2 is called "Gen2 Letter Final.pdf", seems they know this is what's needed to get a partial authorization.

Still a small win for SpaceX since Gen2 satellite size is a lot bigger than Gen1/V-band satellite, and they get to use ~500km orbit instead of the super low ~300km orbit of the V-band.

The super low orbit is actually good for a bunch of reasons (below ISS’s orbit, debris reenters extremely quick, optical effects are limited exclusively to dusk/dawn conditions—totally in shadow during the fully dark hours of the night, lower latency). I hope they return to that at some point.

[RedLineTrain]

At first blush, this satellite failure requirement seems unnecessarily draconian by several orders of magnitude and would already be breached by Gen1, OneWeb, and Iridium.  Generally, the FCC appears to be saying that satellites without operating thrusters are unacceptable in LEO and that it rejects the concept of self-cleaning orbits.

In anticipation of a quick breach of this condition, SpaceX might as well include a new mitigation plan in its upcoming v-band modification for Gen2 and start developing a deorbit package on a specialized satellite.

Some excerpts from the 74 page document:

...

aa. In the event of satellite failures resulting in more than 100 post-failure object years, SpaceX may not deploy any additional satellites until the Commission has approved a license modification that includes an updated orbital debris mitigation plan addressing reduction in the failure rate or mitigation of the risk of satellite failures.

[Barley]

At first blush, this satellite failure requirement seems unnecessarily draconian by several orders of magnitude and would already be breached by Gen1, OneWeb, and Iridium.  Generally, the FCC appears to be saying that satellites without operating thrusters are unacceptable in LEO and that it rejects the concept of self-cleaning orbits.

Some excerpts from the 74 page document:

...

aa. In the event of satellite failures resulting in more than 100 post-failure object years, SpaceX may not deploy any additional satellites until the Commission has approved a license modification that includes an updated orbital debris mitigation plan addressing reduction in the failure rate or mitigation of the risk of satellite failures.

Is it something that SpaceX expects to be able to easily meet in the normal course of events with no additional effort?


Tighter that it needs to be is not necessarily draconian.  Sometimes it's just lazy, and this could either SpaceX, the regulator, or both.  (And in this context lazy may be a virtue)

[matthewkantar]

I am an amateur astronomer and student of astronomy. Astronomy can deal with this.

These actions by the regulators are about monkey wrenching SpaceX while paying lip service to astronomers and fans of the night sky. US over regulation in this area will cede the industry to other nations.

[oldAtlas_Eguy]

The side effect of these regs is that cheaper $/kg launchers that deliever more payload per launch are incentivized. Something the US at the moment is positioned to exceed in with Starship, FH, NG, Vulcan at the door. With a need for more mass allowance per sat at lower costs per kg it means that these large LVs will be kept very busy.

It may be in the short term some pain but in the long run will cause the US to practically corner the market on NGEOs and BEO launch. In country to launch provider usually incurs some level of savings for the sat developer/operator. Even with these restrictive regs whose existence may put more and more pressure on International treaties to do the same by most launching countries.

[kevin-rf]

At first blush, this satellite failure requirement seems unnecessarily draconian by several orders of magnitude and would already be breached by Gen1, OneWeb, and Iridium.  Generally, the FCC appears to be saying that satellites without operating thrusters are unacceptable in LEO and that it rejects the concept of self-cleaning orbits.

In anticipation of a quick breach of this condition, SpaceX might as well include a new mitigation plan in its upcoming v-band modification for Gen2 and start developing a deorbit package on a specialized satellite.

I didn't read that as a serious issue. Satellites that arrive on orbit DOA do not last in LEO very long (weeks), while they check out the ones they deem healthy before orbit raising begins. While it has happened at operation altitudes, it is very rare. 

In the case of Starlink 4-7 when they lost 38 satellites shortly after launch, I doubt the cumulative time for those 38 satellites would even add up to a year. Even with a few similar failures it should not be an issue.

But yes, that does put the pressure on SpaceX to make sure the propulsion system for avoidance and deorbit is reliable and redundant. Dare I suggest it will require reliability on par with a manrated system?

Edit:
Looking deeper into the excellent collections of graphs and stats on Jonathan McDowell's Space page.

It looks like the last Starlink to fail and go non-propulsive at operational altitude was one of the survivors from the February Starlink 4-7 launch. Starlink 3165 https://planet4589.org/space/con/star/spl38/s3165.jpg .

Though I wouldn't count out the following three (two of which have already reentered) as non-propulsive
Starlink 3695 https://planet4589.org/space/con/star/spl42/s3695.jpg
Starlink 4161 https://planet4589.org/space/con/star/spl51/s4161.jpg
Starlink 4665 https://planet4589.org/space/con/star/spl51/s4665.jpg

In all, looking at Jonothan's stats, a little over 30 of the v1 satellites went non-propulsive at operational altitude and max four of the newer v1.5 satellites (3165 was abused as a child, and the other three during raising).

(I know off topic, but it was great digging into the actual data)
 

[TheRadicalModerate]

At first blush, this satellite failure requirement seems unnecessarily draconian by several orders of magnitude and would already be breached by Gen1, OneWeb, and Iridium.  Generally, the FCC appears to be saying that satellites without operating thrusters are unacceptable in LEO and that it rejects the concept of self-cleaning orbits.

Some excerpts from the 74 page document:

...

aa. In the event of satellite failures resulting in more than 100 post-failure object years, SpaceX may not deploy any additional satellites until the Commission has approved a license modification that includes an updated orbital debris mitigation plan addressing reduction in the failure rate or mitigation of the risk of satellite failures.

Is it something that SpaceX expects to be able to easily meet in the normal course of events with no additional effort?


Tighter that it needs to be is not necessarily draconian.  Sometimes it's just lazy, and this could either SpaceX, the regulator, or both.  (And in this context lazy may be a virtue)

I read this as something which should be fairly easy to appeal/push back against.  I do think that it's somewhat draconian as written, but the FCC's heart is in the right place:  they're signaling that if you're going to operate a big constellation, you have a higher bar to jump over in terms of reliability.  That's the right thing to do.  Now we'll get some extensive haggling over the correct number.

[oldAtlas_Eguy]

At first blush, this satellite failure requirement seems unnecessarily draconian by several orders of magnitude and would already be breached by Gen1, OneWeb, and Iridium.  Generally, the FCC appears to be saying that satellites without operating thrusters are unacceptable in LEO and that it rejects the concept of self-cleaning orbits.

Some excerpts from the 74 page document:

...

aa. In the event of satellite failures resulting in more than 100 post-failure object years, SpaceX may not deploy any additional satellites until the Commission has approved a license modification that includes an updated orbital debris mitigation plan addressing reduction in the failure rate or mitigation of the risk of satellite failures.

Is it something that SpaceX expects to be able to easily meet in the normal course of events with no additional effort?


Tighter that it needs to be is not necessarily draconian.  Sometimes it's just lazy, and this could either SpaceX, the regulator, or both.  (And in this context lazy may be a virtue)

I read this as something which should be fairly easy to appeal/push back against.  I do think that it's somewhat draconian as written, but the FCC's heart is in the right place:  they're signaling that if you're going to operate a big constellation, you have a higher bar to jump over in terms of reliability.  That's the right thing to do.  Now we'll get some extensive haggling over the correct number.

I wonder what would be the response after 5 years has passed and the number of operational failed failed time on orbit was still lower than the threshold. It would produce a valid trigger value for each constellation based on that constellation's size.

Also how would the orbital operational altitude be calculated in?