SPACEX NON-GEOSTATIONARY SATELLITE SYSTEM

ATTACHMENT A
TECHNICAL INFORMATION TO SUPPLEMENT SCHEDULE S

A.1 SCOPE AND PURPOSE

In 2018, the Commission authorized Space Exploration Holdings, LLC, a wholly owned

subsidiary of Space Exploration Technologies Corp. (collectively, “SpaceX”), to construct,

deploy, and operate a constellation of 4,425 non-geostationary orbit (“NGSO”) satellites using

Ku- and Ka-band spectrum. 1 Since then, the Commission has authorized SpaceX to relocate

1,584 satellites to an altitude of 550 km, where they would be able to achieve better performance

and orbital debris mitigation characteristics without increasing interference to any other licensed

user of the relevant spectrum, and to respace those satellites to place coverage and capacity more

evenly and rapidly across more of the United States. 2 With this application, SpaceX proposes to

build on the success of its earlier modifications in accelerating broadband deployment and

increasing space safety by operating the remaining satellites in its Ku/Ka-band constellation at

lower altitudes.

Specifically, SpaceX proposes to relocate the satellites that are currently authorized to operate

at altitudes from 1,110 km to 1,325 km down to altitudes ranging from of 540 km to 570 km, and to

make related changes to the operations of the satellites in these new lower shells of the

constellation. This modification to the SpaceX Authorization will slightly reduce the total

number of spacecraft in the constellation (from 4,409 to 4,408), meet all required protection

criteria for other systems operating in the same frequencies, and cause no material overall

1
See Space Exploration Holdings, LLC, 33 FCC Rcd. 148 (2018) (“Initial Authorization”).
2
See Space Exploration Holdings, LLC, 34 FCC Rcd. 2526 (IB 2019) (“First Modification”); Space Exploration
Holdings, LLC, 34 FCC Rcd. 12307 (IB 2019) (“Second Modification”).

1
increase in radiofrequency interference. The modification will meet or exceed all space safety

requirements and will reduce the potential for orbital debris through operation of the remainder

of the constellation at lower altitudes. In addition, SpaceX requests that the Commission revise

its license to include authority to perform telemetry, tracking, and control (“TT&C”) functions

during orbit-raising and de-orbit maneuvers, consistent with what is authorized by rule for

geostationary orbit (“GSO”) satellite systems, 3 as well as testing during the orbit-raising process.

SpaceX requests no other technical changes to its authorization at this time, and certifies that all

other technical information provided in its previous Ku/Ka-band applications, as modified,

remains unchanged. 4

This attachment contains the updated technical information with respect to the newly-

proposed operations required under Part 25 of the Commission’s rules that cannot be fully

captured by the Schedule S software. The accompanying Schedule S reflects the system as it will

operate once modified and fully deployed. 5

A.2 OVERALL DESCRIPTION

This information is generally available in Attachment A (“Technical Information to

Supplement Schedule S”) to the Previous Applications. SpaceX now proposes a modification

based on the success of the deployment of its first 362 satellites and in an effort to even further

3
See 47 C.F.R. §§ 25.282, 25.283.
4
See id. § 25.117(c). See also Application for Approval for Orbital Deployment and Operating Authority for the
SpaceX NGSO Satellite System, IBFS File No. SAT-LOA-20161115-00118 (Nov. 15, 2016); Application for
Approval for Orbital Deployment and Operating Authority for the SpaceX NGSO Satellite System Supplement,
IBFS File No. SAT-LOA-20170726-00110 (July 26, 2017); Application for Modification of Authorization for
the SpaceX NGSO Satellite System, IBFS File No. SAT-MOD-20181108-00083 (Nov. 8, 2018); Application for
Modification of Authorization for the SpaceX NGSO Satellite System, IBFS File No. SAT-MOD-20190830-
00087 (Aug. 30, 2019). These applications are referred to collectively herein as the “Previous Applications.”
5
The Schedule S and the separate database of technical parameters include channel plans for each beam. Although
we have submitted channel plans indicating that each beam will be divided uniformly into 50 MHz channels,
SpaceX anticipates that these channels will often be bonded into various combinations to create larger effective
channel sizes – or potentially subdivided into smaller ones – depending on operational needs.

2
Operating these shells at lower altitude will significantly decrease each satellite’s footprint

on the Earth. To maintain suitable coverage, SpaceX will use a minimum elevation angle as low

as 25 degrees for user beams. For gateway beams, SpaceX will generally observe the same 25

degree minimum elevation, although certain shells may use lower elevations in certain

circumstances as discussed more fully in Section A.3.2 below.

SpaceX also requests that the Commission grant authority in its modified license for

communications during transition phases before and after reaching authorized positions. This

would include authority to perform TT&C functions during orbit-raising and de-orbit maneuvers,

as is authorized by rule for GSO satellite systems. 6 This would also include authority for testing

the Ku- and Ka-band communications payloads during the orbit-raising process, which would be

conducted on a non-protected, non-harmful interference basis. Given that there are over 4,000

satellites in the constellation with a design life of five years, it is likely that SpaceX will be engaged

in launch and de-orbit activities on an ongoing basis. Granting the requested authority as part of

the space station license would obviate the need for SpaceX to file – and the Commission to

process – a never-ending stream of applications for special temporary authority to cover operations

as satellites are raised into and de-orbited out of the constellation. 7

A.3 PREDICTED SPACE STATION ANTENNA GAIN CONTOURS

The antenna gain contours for the transmit and receive beams for a representative space

station operating at 540 km, 560 km, and 570 km are embedded in the associated Schedule S, as

required by Section 25.114(c)(4)(vi)(B). Below we describe the methodology for their

presentation.

6
See 47 C.F.R. §§ 25.282, 25.283.
7
Over the last eight months, SpaceX has been granted eleven space station STAs to cover orbit-raising and de-
orbit activities for its constellation. It has received no reports of interference from any other licensed operator.

4
As in the Previous Applications, all downlink spot beams on each SpaceX satellite are

independently steerable over the full field of view of the Earth. Yet earth stations communicate

only with satellites above a minimum elevation angle. Figure A.3-1 below illustrates the steerable

service range of satellite beams using generalized parameters.

Figure A.3-1: Steerable Service Range of Satellite Beams

Tables A.3-1 and A.3-2 provide the specific values for the parameters in Figure A.3-1 for each of

the new orbital altitudes proposed herein based on the minimum earth station elevation angle (θ)

involved.

altitude "a" [km] 540 560 570

Max steering angle α [deg] 56.7 56.4 56.3

Coverage radius "r" [km] 926.8 954.6 968.4

Table A.3-1: Values for 25° Minimum Elevation Angle θ

altitude "a" [km] 540 560 570

Max steering angle α [deg] 66.7 66.3 66.1

Coverage radius "r" [km] 2037.3 2079.7 2100.5

Table A.3-2: Values for 5° Minimum Elevation Angle θ

5
A.3.1 Ku-Band Beams

The minimum elevation angle at which user terminals communicate with SpaceX satellites

may be as low as 25 degrees. As discussed in the Previous Applications, beams from antennas

using phased arrays widen incrementally as they are steered away from boresight. 8 As a result,

the shape of a phased array beam at boresight is circular but becomes increasingly elliptical when

steered away from boresight. The antenna beam contours provided in Schedule S illustrate this

dynamic by plotting antenna gain contours (for both uplink and downlink beams) for operations at

540 km at nadir and at 25, 45, and 57 degrees away from nadir (which are essentially the same for

560 km and 570 km). As illustrated in Figure A.3.1-1 below with respect to operations at 540 km

altitude, as the transmitting beam is steered, the power is adjusted to maintain a constant maximum

power flux-density (“PFD”) at the surface of the Earth, compensating for variations in antenna

gain and path loss associated with the steering angle.

Figure A.3.1-1. EIRP Density Variation by Beam Steering Angle (540 km)

Table A.3.1-1 shows the maximum equivalent isotropically radiated power (“EIRP”) density at

each proposed new operating altitude.

8
For this purpose, we use “boresight” to refer to the direction normal to the phased array plane.

6
Figure A.3.2-1: EIRP Density Variation by Beam Steering Angle

Each satellite transmits two beams at the same frequency (with right hand and left hand circular

polarization (“RHCP” and “LHCP”)), with up to eight satellites beaming transmissions to a

gateway location, for a maximum of sixteen co-frequency beams. SpaceX will adjust power in

order to achieve the PFD levels indicated above. The maximum EIRP density for all proposed

altitudes is 12.7 dBW/MHz. For receiving beams, G/T will remain constant at 11.5 dB/K.

A.3.3 Ku-Band and Ka-Band TT&C Beams

This information is available in Attachment A to the Previous Applications and in

Schedule S attached hereto.

A.4 GEOGRAPHIC COVERAGE

The Commission has found that the SpaceX constellation, when fully deployed, will

satisfy all applicable geographic coverage requirements. 10 The proposed modification will not

alter that conclusion.

10
See SpaceX Authorization, ¶ 33.

8
Figure A.7.1-1. Compliance with Downlink
PFD Limits in the 10.7-11.7 GHz Band (540 km)

The ITU Radio Regulations include PFD limits across the 11.7-12.7 GHz band that are effectively

2 dB higher than the PFD limits in the 10.7-11.7 GHz band plotted above. 13 Accordingly, given

that the modified system will comply with the lower limits applicable in the 10.7-11.7 GHz band,

it will also comply with the limits applicable in the 11.7-12.7 GHz band. 14

Section 25.208(o) of the Commission’s rules specifies low elevation PFD limits that apply

in the 12.2-12.7 GHz band to protect the Multichannel Video and Data Distribution Service

(“MVDDS”). Figure A.7.1-2 below shows that satellites in the proposed 540 km shell will comply

with these limits as well.

13
See ITU Radio Regs., Table 21-4.
14
In the Ku-band, SpaceX will operate TT&C downlinks in the 12.15-12.25 GHz band. The maximum EIRP for
the TT&C links is always below the minimum EIRP radiated in any direction by the user links in this band. As
a result, the PFD created when TT&C links in this band are active falls significantly below the PFD created due
to operational links in all cases. Because, as demonstrated above, the Ku-band operational links comply with the
applicable PFD limits, the TT&C downlinks necessarily will do so as well. Moreover, SpaceX plans to deploy
only two TT&C earth stations in the U.S. – one on the East Coast and one on the West Coast. Areas outside the
immediate vicinity of those facilities would be unaffected by their operations. Accordingly, SpaceX’s TT&C
operations in this band should prompt no concern.

11
Figure A.7.1-2. Compliance with Downlink
PFD Limits in the 12.2-12.7 GHz Band (540 km)

Operations at this lowest shell provide a worst-case PFD scenario, yet still remain compliant.

Accordingly, all Ku-band downlink transmissions from SpaceX satellites operating in the modified

constellation will comply with all applicable Commission and ITU PFD limits.

A.7.2 PFD Limits in the Ka-Band

The ITU has adopted a single set of PFD limits for NGSO systems across the entire 17.7-

19.3 GHz band, which the Commission has incorporated by reference into its rules as well. 15

Unlike the limits applicable to the Ku-band, here the limits are expressed as a function of the

number of satellites in the entire NGSO system, without any consideration to whether the satellites

are in view of the terrestrial system or whether the satellites are turned on or off. These limits can

be stated as follows:

• -115-X dB(W/m2) in any 1 MHz band for angles of arrival between 0 and 5 degrees above
the horizontal plane;

• -115-X+((10+X)/20)(δ-5) dB(W/m2) in any 1 MHz band for angles of arrival δ (in degrees)
between 5 and 25 degrees above the horizontal plane; and

• -105 dB(W/m2) in any 1 MHz band for angles of arrival between 25 and 90 degrees above
the horizontal plane.

15
See ITU Radio Regs., Table 21-4; 47 C.F.R. § 25.108(a)(2).

12
Where X is defined as a function of the number of satellites in the NGSO FSS constellation,
n, as follows:
• X = 0 dB for n ≤ 50

• X = (5/119) (n - 50) dB for 50 < n ≤ 288

• X = (1/69) (n + 402) dB for n > 288

For the modified SpaceX system, the value of “n” is 4,408, and therefore X is equal to 69.71 dB

according to the above formulae. This results in the PFD masks for gateway and TT&C operations

shown in Figures A.7.2-1 and A.7.2-2 below, respectively.

Figure A.7.2-1. SpaceX Gateway Compliance with

Downlink PFD Limits in the 17.7-19.3 GHz Band

Figure A.7.2-2. SpaceX TT&C Compliance with

Downlink PFD Limits in the 17.7-19.3 GHz Band

13
As shown in these figures, the modified SpaceX system complies with the PFD limits specified by

the Commission and the ITU at most elevation angles by a significant margin, but at low elevation

angles – below about twenty degrees – the flawed calculation technique appears to yield a result

that exceeds the limit.

In Attachment A to its Previous Applications, SpaceX argued that the ITU methodology

for establishing the PFD limits was not developed with capability to scale up for application to

dynamically controlled NGSO constellations with more than 840 satellites. In granting the Initial

Authorization, the Commission agreed with several points raised by SpaceX, “in particular that

the ITU limits were derived for constellations up to 840 satellites and under worst case

assumptions.” 16 Rather than grant a waiver of these PFD limits, the Commission imposed a

condition under which SpaceX must, before starting operation, file a modification application with

a technical showing demonstrating that its operation will protect a fixed-service station with the

characteristics described in Recommendation ITU-R SF.1483. 17 SpaceX has made such showings

in connection with previous modifications. As discussed below, SpaceX makes a renewed

showing with respect to the modification proposed herein.

A.8 INTERFERENCE ANALYSES

The Commission has recognized that a proposed modification to an NGSO authorization

should be granted where it “does not present any significant interference problems and is otherwise

consistent with Commission policies.” 18 In this case, the lowering of existing SpaceX satellites

16
See Initial Authorization, ¶ 35.
17
See id.
18
Teledesic LLC, 14 FCC Rcd. 2261, ¶ 5 (IB 1999). See also The Boeing Co., 18 FCC Rcd. 12317, ¶ 7 (IB 2003).
(“In recognition of the length of time it takes to construct a satellite system, the rapid pace of technological change,
and the goal of promoting more efficient use of the radio spectrum, the [Commission] has granted such requests

14
will not have any significant impact on other users of the Ku- and Ka-band spectrum. To

demonstrate this fact, SpaceX has included with this Technical Attachment three analyses of the

interaction between its system as modified and other licensed systems in the band.

A.8.1 Interference Protection for GSO Satellite Networks

Pursuant to Section 25.146 of the Commission’s rules, SpaceX hereby certifies that its

NGSO constellation, as modified, will comply with the applicable equivalent power flux-density

(“EPFD”) limits set forth in Article 22 of the ITU Radio Regulations, which have been

incorporated by reference into the Commission’s rules. 19 As corroboration, SpaceX provides in

Annex 1 to this Technical Attachment an updated analysis demonstrating that its modified

constellation will continue to comply with applicable EPFD limits. 20 The Commission’s rules and

the Initial Authorization contemplate that, prior to initiation of service, the ITU

Radiocommunication Bureau will issue a “favorable” or “qualified favorable” finding regarding

the constellation’s compliance with those EPFD limits. 21 When the Commission granted the First

Modification, it waived the requirement that SpaceX receive such a finding from the ITU prior to

commencing operations, but retained the requirement that SpaceX receive such a finding at some

in cases where the proposed modification presents no significant interference problem and is otherwise consistent
with Commission policies.” (internal citation omitted)).
19
See 47 C.F.R. § 25.146(a)(2).
20
SpaceX will also operate its system in some portions of Ka-band spectrum where no EPFD limits exist (the 28.6-
29.1 GHz uplink and 18.8-19.3 GHz downlink frequency bands, where NGSO satellite use is designated as
primary). According to ITU procedures applicable to these frequency ranges, coordination between NGSO and
GSO networks is on a first-come, first-served basis. See ITU Radio Regs. No. 9.11A. SpaceX is actively engaged
in coordination negotiations with GSO operators and is confident that compatibility with all GSO satellite
networks in these bands can be achieved. In addition, Resolution 76 of the ITU Radio Regulations includes limits
on aggregate EPFDdown produced by all co-frequency satellites of all NGSO FSS systems operating in certain Ku-
and Ka-bands. SpaceX is prepared to work with other NGSO FSS operators to ensure compliance with the
applicable limits.
21
47 C.F.R. § 25.146(a)(3). This is also a condition of SpaceX’s authorization. See SpaceX Authorization, ¶ 40n.

15
point and adjust its operations as necessary to satisfy ITU requirements, essentially allowing

SpaceX to proceed only at its own risk. 22 SpaceX will continue to proceed on that basis.

A.8.2 Interference with Respect to Other NGSO Satellite Systems

SpaceX has engineered its system with technical flexibility that will facilitate the

necessary coordination with other NGSO satellite systems and is committed to achieving

mutually satisfactory agreements. Because the proposed modification will slightly decrease the

total number of satellites (from 4,409 to 4,408) and relocate many of them to operate at lower

altitude, fewer of them will be visible above the minimum elevation angle at any particular time

throughout the United States. The Commission has previously recognized this factor as

demonstration that a modification will not increase interference to other NGSO systems. 23 In

addition, by operating at lower altitude, these satellites will be able to transmit and receive at

lower EIRP levels – another factor that will reduce the potential for interference.

To confirm and quantify these observations, SpaceX performed an analysis that considers

the dynamic, time-varying interference expressed as a cumulative distribution function (“CDF”)

of the interference-to-noise ratio (“I/N”), for varying percentages of time. The I/N CDF is derived

from a time-domain simulation of the two NGSO systems over a long enough time to produce

meaningful statistics. The analysis considers the effect of the proposed modification on one

NGSO system hypothetically operating in the Ku-band (OneWeb) and two operating in the Ka-

band (Telesat and O3b). That analysis, set forth in Annex 2 to this Technical Attachment,

demonstrates that the modification would have no material effect on the interference environment

of other NGSO systems.

22
See First Modification, ¶¶ 28, 37. See also Second Modification, ¶ 10 (finding that further waiver is unnecessary
in light of requirement for ultimate ITU determination).
23
See Teledesic, ¶ 13.

16
A.8.3 Interference With Respect to Terrestrial Networks

As demonstrated above, the SpaceX constellation as modified will comply with all relevant

PFD limitations in the Ku-band. In addition, Annex 3 to this Technical Attachment presents an

updated analysis to demonstrate that SpaceX’s operations will continue to satisfy the condition

imposed to protect terrestrial fixed services operating in a portion of the Ka-band. Accordingly,

SpaceX requests that the Commission find that it has satisfied the condition of the Initial

Authorization by demonstrating that its operations will protect a fixed-service station with the

characteristics described in Recommendation ITU-R SF.1483.

A.8.4 Interference With Respect to the Radio Astronomy Service

This information is available in Attachment A to the Previous Applications.

A.8.5 Coordination With GSO FSS Earth Stations in the 10.7-12.75 GHz Band

This information is available in Attachment A to the Previous Applications.

A.9 COORDINATION WITH U.S. GOVERNMENT OPERATIONS

This information is available in Attachment A to the Previous Applications.

A.10 ITU FILINGS FOR SPACEX

SpaceX is preparing the modified system information for ITU publication and will submit

this information when complete. SpaceX will unconditionally accept all consequent ITU cost-

recovery responsibility for the filings.

A.11 ORBITAL DEBRIS MITIGATION

An overview of orbital debris mitigation information is available in Attachment A to the

Previous Applications. Maintaining a clean orbital environment is a fundamental consideration

for SpaceX, which is planning to launch its Falcon 9 vehicles into orbital altitudes dozens of times

this year alone for its commercial and government customers, as well as undertaking Dragon cargo

17
missions to the International Space Station (“ISS”) for NASA and Dragon Crew missions that will

carry astronauts to the ISS. SpaceX is implementing an aggressive and effective space-debris

mitigation plan, leveraging its nearly two decades of technical and operational experience in cost-

effectively deploying large, complex space systems to support other operators.

As demonstrated from the operations of its constellation to date, operating at a lower

altitude offers several attractive features both during nominal operation and in unplanned

scenarios. In particular, moving satellites to the proposed lower shells would yield tangible

benefits, including:

 Rapid, passive disposal in the unlikely event of a failed spacecraft

 Self-cleaning debris environment in general
 Reduced fuel requirements and thruster wear
 Benign ionizing radiation environment
 Fewer NGSO operators affected by the SpaceX constellation

These benefits directly address the Commission’s concerns with respect to system reliability, and

in particular reliability of the method for de-orbiting spacecraft. 24

As discussed in Previous Applications, SpaceX intends to perform an active disposal of all

of its satellites at the end of their life, in which the satellites first drop to a perigee of approximately

300 km while maintaining an apogee at approximately 540 km to 570 km. For the new lower

shells of satellites, this “active” phase of the deorbit sequence will take a few weeks for each

vehicle, after which several weeks to months of “passive” disposal follow, with the exact time

depending on solar activity. Even this phase is not fully passive – to minimize the risk of debris

even further, SpaceX satellites will continue to perform conjunction avoidance until the high

24
See Initial Authorization, ¶ 15. These benefits are discussed in greater detail in pages 38-44 of the Technical
Attachment for IBFS File No. SAT-MOD-20181108-00083.

18
atmospheric torques from low altitudes cause the vehicle to be uncontrollable. 25 At all times

during this descent, including the period during which they will traverse the orbital altitude of the

ISS and other NASA assets, the spacecraft will retain sufficient fuel to perform maneuvers. After

all propellant is consumed, the spacecraft will be reoriented to maximize the vehicle’s total cross-

sectional area. Finally, the spacecraft will begin to passivate and power down.

While SpaceX expects its satellites to perform nominally and deorbit actively as described

above, in the unlikely event a vehicle is unable to finish its planned disposal maneuver, the denser

atmospheric conditions at the 540-570 km altitude provide fully passive redundancy to SpaceX’s

active disposal procedures. The natural orbital decay of a satellite at 1,110-1,325 km requires

hundreds of years to enter the Earth’s atmosphere, but the lower satellites will take less than five

years to do so, even considering worst-case assumptions. Due to the very lightweight design of

the new spacecraft, SpaceX achieves a very high area-to-mass ratio on its vehicles. Combined

with the natural atmospheric drag environment at lower altitude, this high ratio ensures rapid decay

even in the absence of the nominally planned disposal sequence. Thus, even assuming an extreme

worst-case scenario – i.e., the spacecraft fails while in the operational orbit, has no attitude control,

and solar activity is at a minimum – the longest decay time is still only approximately 4.5-5.5

years. The time to satellite demise from various altitudes is illustrated in Figure A.11-1 below. 26

25
The 300 km target does not account for a fuel margin stack-up reserved for other uses. In the vast majority of
cases, any remaining margin would allow satellites to expedite demise. SpaceX will reserve at least 70 m/s of
delta-V – a measure of the impulse required for a given maneuver or, here, the capability to perform those
maneuvers if necessary – to deliver the described de-orbit functionality.
26
This figure shows demise time as a function of altitude, using ballistic coefficients corresponding to the SpaceX
spacecraft. Solid curves show conditions around solar minimum, characteristic of the current atmosphere, and
dashed curves show conditions around solar maximum, characteristic of the atmosphere in the early/mid 2020s.
The black curves assume that propulsion has failed, but the vehicle can still orient itself into a high-drag attitude.
The blue curves assume that the Attitude Determination & Control System (“ADCS”) has also failed, and the
vehicle is unable to hold a specific attitude. As discussed above, at 540-570 km all cases demise in less than 5.5
years.

19
Figure A.11-1. Demise Time at Various Altitudes

In reality, this confluence of worst-case assumptions is unlikely to be realized for a number

of reasons, not the least of which is that overall solar activity is ramping up into the next decade,

meaning a more realistic worst-case decay time of one to three years. But even assuming the

unlikely five-year decay period, SpaceX satellites will reach demise well within the prevailing 25-

year deorbit standard. In fact, SpaceX will exceed new stricter parameters NASA recently

determined for safe operation of large constellations 27 by achieving a 100% success rate of post-

mission disposal within about five years even assuming worst-case conditions, directly addressing

one concern previously identified by the Commission. 28 Nonetheless, SpaceX’s nominal disposal

plan that it anticipates for nearly every spacecraft will result in a lifetime of less than six months

27
See J.-C. Liou, et al., NASA ODPO’s Large Constellation Study, ORBITAL DEBRIS QUARTERLY NEWS, at 4-7
(Sept. 2018) (suggesting that post-mission disposal within five years at a 99% success rate would mitigate the
debris concern related to large NGSO constellations), https://orbitaldebris.jsc nasa.gov/quarterly-
news/pdfs/odqnv22i3.pdf.
28
See Initial Authorization, ¶ 15 and n.55.

20
after SpaceX initiates disposal, an advantage of operating at the lower altitude proposed in the

modification. Moreover, due to SpaceX’s decision to minimize risk by using a low injection

altitude of no more than approximately 350 km, in the unlikely event any satellites after the initial

launch experience immediate failure upon deployment, they would decay to the point of demise

very quickly – as little as two weeks to at most eight months depending on the solar cycle.

Collision Risk

SpaceX has made clear that it intends to conduct active maneuvers to avoid collisions with

both debris and other spacecraft throughout the life of its satellites, even through the de-orbit phase

until the spacecraft enters the atmosphere. As the Commission has recognized, because SpaceX

has invested in advanced propulsion capabilities for its satellites, collision risk is considered to be

zero (or near zero). 29

Due to SpaceX’s decision to minimize risk by using a low injection altitude, in the unlikely

event any satellites after the initial launch experience immediate failure upon deployment, they

would decay to the point of demise very quickly – as little as two weeks to at most eight months

depending on the solar cycle. Consistent with the prevailing NASA safety standard, which the

Commission has regularly relied upon for orbital debris mitigation assessments, 30 the probability

of accidental collision between a spacecraft passing through low-Earth orbit and space objects

larger than 10 cm in diameter is calculated to be less than 0.001. Specifically, using NASA’s

Debris Assessment Software (“DAS”), the probability of collision between a space object larger

29
See, e.g., First Modification, ¶ 22.
30
See Requirement 4.5-1, NASA Technical Standard, Process for Limiting Orbital Debris, NASA-STD-8719.14A
(with Change 1), at 32 (May 25, 2012), https://standards.nasa.gov/standard/nasa/nasa-std-871914. See also
Mitigation of Orbital Debris in the New Space Age, 33 FCC Rcd. 11352, ¶ 6 (2018) (“Both applicants and the
Commission, however, have relied in a number of cases on standards and related assessment tools, such as the
technical standards and related software tools developed by NASA for its space activities, to, respectively, prepare
such orbital debris plans and assess their adequacy.”).

21
Joint Space Operations Center (“JSpOC”)), and will provide it or other relevant regulatory

agencies with forecasts of vehicle positions, during both ballistic and propulsive phases of flight.

SpaceX will also provide such forecasts through secure interfaces to other operators, if

communication is necessary beyond CSpOC.

Beyond these active steps that SpaceX had always planned, the move to a lower altitude

will bring the additional benefit of increasing the space between large NGSO constellations that

do not use smallsats, such as OneWeb, Boeing, and Telesat. The Commission has authorized two

such NGSO systems (OneWeb and Telesat) and is considering a third (Boeing) that will operate

at altitudes between 1,000 km and 1,248 km. 32 These systems will operate at altitudes that could

extend through SpaceX’s currently authorized orbits at 1,110-1,325 km. SpaceX recognizes that

the Commission has authorized Spire Global (“Spire”) to deploy cubesats at a variety of altitudes

from 400 km to 650 km, 33 and has authorized Kepler Communications (“Kepler”) to deploy

microsatellites in near-polar orbits at a range of altitudes from 500 km to 600 km. 34 SpaceX will

engage Spire, Kepler, and any other system seeking to operate at the same nominal orbital ranges

sought by SpaceX in this modification to carefully coordinate physical operations to ensure that

their respective constellations can coexist safely.

Further, operating at lower altitude means that SpaceX satellites will transit through fewer

systems during orbit raising or end-of-life disposal. In its Previous Applications, SpaceX planned

to transition all of its satellites from approximately 400 km to altitudes of 1,110 km and above.

32
See WorldVu Satellites Limited, 32 FCC Rcd. 5366 (2017); Telesat Canada, 32 FCC Rcd. 9663 (2017); The
Boeing Company, Application for Authority to Launch and Operate an NGSO System in the FSS, IBFS File No.
SAT-LOA-20170301-00028 (Mar. 17, 2017).
33
See, e.g., Letter from George John to Marlene H. Dortch, IBFS File No. SAT-LOA-20151123-00078 (June 28,
2018) (Annual Report for IBFS Call Sign S2946).
34
See Kepler Communications Inc., 33 FCC Rcd. 11453 (2018).

23
By using a lower operational altitude for its spacecraft, SpaceX will eliminate any risk from

physical interaction with these SpaceX satellites for other systems operating in the 570 km to 1,325

km range – some of the most congested altitudes in low-Earth orbit.

Post-Mission Disposal

As discussed above, SpaceX anticipates that its satellites in the proposed lower shells will

reenter the Earth’s atmosphere within approximately six months after completion of their mission

– much sooner than the international standard of 25 years. The spacecraft’s small mass and

predominantly aluminum construction maximize the likelihood of atmospheric demise on re-

entry. As SpaceX previously stated, all Starlink satellites launched after the first deployment will

be fully demisable upon atmospheric re-entry, and no components will survive to reach the

Earth’s surface. Accordingly, the modification will have no effect on the risk of human casualty

– which will remain zero for all launches from here on.

24
ENGINEERING CERTIFICATION

I hereby certify that I am the technically qualified person responsible for preparation of the

engineering information contained in this application, that I am familiar with Part 25 of the

Commission’s rules, that I have either prepared or reviewed the engineering information submitted

in this application, and that it is complete and accurate to the best of my knowledge and belief.

/s/ Mihai Albulet

Mihai Albulet, PhD
Principal RF Engineer
SPACE EXPLORATION TECHNOLOGIES CORP.

April 17, 2020

Date
ANNEX 1

POTENTIAL INTERFERENCE WITH RESPECT TO OTHER NGSO SATELLITE SYSTEMS

SpaceX has engineered its Starlink system with the technical flexibility that will facilitate

the necessary coordination with other NGSO satellite systems and is committed to achieving

mutually satisfactory agreements. To demonstrate this point, SpaceX performed an analysis of

the effect of the proposed modification on downlink and uplink interference using the

characteristics of three NGSO systems authorized through the Commission’s most recent Ku/Ka-

band processing round – OneWeb for Ku-band and Telesat and O3b for Ka-band.

The analysis considers the dynamic, time-varying interference expressed as a cumulative

distribution function (“CDF”) of the interference-to-noise ratio (“I/N”), for varying percentages

of time. The I/N CDF is derived from a time-domain simulation of the two NGSO systems over

a long enough time to produce meaningful statistics, using random antenna pointing. The

corresponding interference levels before and after the modification are calculated and plotted. To

present a worst-case assessment of the interference environment, the analysis also assumes that

the two systems do not implement any interference mitigation strategies. As demonstrated below,

the new interference levels resulting with the modification are mostly less than (and at worst

equal to) the interference levels that would have been experienced with the current constellation

in the noise-dominated environment (i.e., I/N ≤ 0 dB). In the interference-dominated

environment (i.e., I/N > 0 dB), the victim system already typically experiences at least 3 dB

receiver de-sensitivity (if not 15 dB or more) and the two systems are not likely able to share the

spectrum in a meaningful way outside of band segmentation both with and without the proposed

modification. Though some of the following plots show a theoretical increase in interference

after the proposed modification at fairly high I/N levels, in practice the two systems would need

to implement band segmentation even before reaching such a highly interference-dominated

A1-1
environment. Hence, this proposed modification will not increase the potential interference into

these NGSO systems operating in areas where true spectrum-sharing options may be available

with the currently authorized system. It also will not increase the likelihood of exceeding the

Commission’s -12.2 dB (6% ΔT/T) threshold above which parties will be required to either split

the spectrum or coordinate. 1

In conducting the analysis, SpaceX used the following assumptions.

For downlink interference from SpaceX satellites to a victim earth station:

1. The SpaceX earth station is collocated with the victim earth station. Locations at

35°N and 75°N latitude are considered in this simulation. 2

2. The victim earth station can communicate with any satellite in its own system

following the rules applicable for that system (e.g., the GSO avoidance angle or

minimum elevation angle). All possible valid cases are considered in evaluating the

I/N CDF.

3. The SpaceX system places one co-frequency beam per Ku-band spot and four or eight

co-frequency beams per Ka-band spot (for the before and after cases, respectively),

and any satellite in view meeting the GSO avoidance angle and the minimum

elevation angle is eligible. SpaceX satellites are chosen randomly for consideration

in evaluating the I/N CDF, and operate at the power flux-density levels described in

the original application and this proposed application.

4. The results are set forward in Figures A1-1 through A1-6 below. Note that this

1
47 C.F.R. § 25.261(c).
2
Note that SpaceX ran its simulation with multiple latitudes and achieved similar results for both the downlink
and uplink analysis. Accordingly, it chose to provide results for two latitudes that are representative of its
primary service area.
A1-2
simulation is conservative (i.e., it overestimates I/N), as it does not consider the effects

of atmospheric attenuation.

For uplink interference from SpaceX earth stations to victim satellites:

1. The SpaceX earth station is collocated with an earth station from the other system.

Locations at 35°N and 75°N latitude are considered in this simulation.

2. The other system’s earth station can communicate with any satellite in its own system

following the rules applicable for that system (e.g., the GSO avoidance angle or

minimum elevation angle). All possible valid cases are considered in evaluating the

I/N CDF.

3. In the SpaceX system, one co-frequency tracked satellite in Ku-band and four or eight

co-frequency tracked satellites in Ka-band (for the before and after cases,

respectively) can receive simultaneously from an earth station. Any satellite in view

meeting the GSO avoidance angle and the minimum elevation angle is eligible.

SpaceX satellites are randomly chosen for consideration in evaluating the I/N CDF.

4. The results are set forth in Figures A1-7 through A1-12 below. Note that this

simulation is conservative (i.e., it overestimates I/N), as it does not consider the effects

of atmospheric attenuation.

A1-3
Figure A1-1. Downlink Comparison for Various OneWeb Antennas at 35ºN (Ku-band)

Figure A1-2. Downlink Comparison for Various OneWeb Antennas at 75ºN (Ku-band)

A1-4
Figure A1-2. Downlink Comparison for Various Telesat Antennas at 35ºN (Ka-band)

Figure A1-3. Downlink Comparison for Various Telesat Antennas at 75ºN (Ka-band)

A1-5
Figure A1-5. Downlink Comparison for Various O3B Antennas at 35ºN (Ka-band)

Figure A1-6. Downlink Comparison for Various O3B Antennas at 75ºN (Ka-band)

A1-6
Figure A1-7. Uplink Comparison for Various OneWeb Antennas at 35ºN (Ku-band)

Figure A1-8. Uplink Comparison for Various OneWeb Antennas at 75ºN (Ku-band)

A1-7
Figure A1-9. Uplink Comparison for Typical Telesat Antenna at 35ºN (Ka-band)

Figure A1-10. Uplink Comparison for Typical Telesat Antenna at 75ºN (Ka-band)
A1-8
Figure A1-11. Uplink Comparison for Various O3B Antennas at 35ºN (Ka-band)

Figure A1-12. Uplink Comparison for Various O3B Antennas at 75ºN (Ka-band)

A1-9
ANNEX 2
POTENTIAL INTERFERENCE TO GSO SATELLITE SYSTEMS
A. Demonstration of EPFD Compliance for Ku-Band Operations

The following analysis demonstrates that the Ku-band operations of the SpaceX NGSO

satellite system, as modified, will comply with the applicable equivalent power flux-density

(“EPFD”) limits set forth in Article 22 of the ITU Radio Regulations, which have been

incorporated by reference into the Commission’s rules. 1 For this purpose, SpaceX has used the

latest version of the ITU-approved computer program developed by Transfinite Systems

(“Transfinite”) for determining compliance with the EPFD single-entry validation limits.

The figures below present the results of the Transfinite analysis with respect to the space-

to-Earth direction (EPFDdown), the Earth-to-space direction (EPFDup), for transmissions

between satellites in orbit where spectrum is allocated bi-directionally (EPFDis), and for TT&C

uplink transmissions. The satellite system consists of a deployment of 4,408 satellites operating

at a range of altitudes between 540 and 570 km with a minimum earth station elevation angle of

25 degrees. The labeling of each diagram provides the relevant details for each analysis

generated by the software. On each diagram, the resulting EPFD level is shown by the blue

curve and the EPFD mask that applies is shown by the red line.

As these diagrams demonstrate, SpaceX’s modified NGSO system will continue to comply

with all EPFD limits applicable to its Ku-band operations. SpaceX will make the data files

underlying this analysis available to interested parties upon request.

1
See 47 C.F.R. § 25.146(a)(2).

A2-1
OUTPUTS FOR EPFDDOWN ASSESSMENT OF BSS LIMITS

A2-2
A2-3
A2-4
A2-5
OUTPUTS FOR EPFDDOWN ASSESSMENT OF FSS LIMITS

A2-6
A2-7
OUTPUTS FOR EPFDUP ASSESSMENT

A2-8
TT&C

OUTPUT FOR EPFDIS ASSESSMENT

A2-9
B. Demonstration of EPFD Compliance for Ka-Band Operations

This annex demonstrates that the Ka-band operations of the SpaceX NGSO satellite

system, as modified, will comply with the applicable EPFD limits. For this purpose, SpaceX has

used the latest version of the ITU-approved computer program developed by Transfinite for

determining compliance with the EPFD single-entry validation limits.

The figures below present the results of the Transfinite analysis with respect to the space-

to-Earth direction (EPFDdown), the Earth-to-space direction (EPFDup), for transmissions

between satellites in orbit where spectrum is allocated bi-directionally (EPFDis), and for TT&C

transmissions. The satellite system consists of a deployment of 4,408 satellites operating at an

altitude between 540 and 570 km with a minimum earth station elevation angle of 5 degrees. The

labeling of each diagram provides the relevant details for each analysis generated by the

software. On each diagram, the resulting EPFD level is shown by the blue curve and the

EPFD mask that applies is shown by the red line.

As these diagrams demonstrate, SpaceX’s modified NGSO system will continue to comply

with all EPFD limits applicable to its Ka-band operations. SpaceX will make the data files

underlying this analysis available to interested parties upon request.

A2-10
OUTPUTS FOR EPFDDOWN ASSESSMENT

A2-11
A2-12
A2-13
OUTPUT FOR EPFDUP ASSESSMENT

A2-14
A2-15
OUTPUTS FOR EPFDIS ASSESSMENT

A2-16
The results are shown in Figures A3-1 to A3-8 below. In each case, the results are shown

for the full proposed modified SpaceX constellation at a minimum elevation angle of 5 degrees.

Note that in all cases, the aggregate I/N are lower than Rec. ITU-R F.1495 long-term and short-

term limits.

Figure A3-1. FS Station: Latitude 24°N, Elevation 0°

A3-3
Figure A3-2. FS Station: Latitude 24°N, Elevation 2.2°

Figure A3-3. FS Station: Latitude 45°N, Elevation 0°

A3-4
Figure A3-4. FS Station: Latitude 45°N, Elevation 2.2°

Figure A3-5. FS Station: Latitude 60°N, Elevation 0°

A3-5
Figure A3-6. FS Station: Latitude 60°N, Elevation 2.2°

Figure A3-7. FS Station: Latitude 75°N, Elevation 0°

A3-6
Figure A3-8. FS Station: Latitude 75°N, Elevation 2.2°

A3-7