SpaceX Sees Petitions, Proposed Conditions, NASA Red Flags for Second-Gen Constellation

SpaceX faces a new wave of calls for the FCC to reject its proposed second-generation satellite constellation. NASA also raised red flags about the SpaceX plans. A lawyer involved in the proceeding told us it would be surprising if the FCC were able to process the second-gen application in time for SpaceX to commence launches in March, as it targeted (see 2201100004). The FCC and SpaceX didn't comment.

The SES/O3b, Viasat and Dish Network petitions to defer or deny filed with the International Bureau Tuesday follow SpaceX giving them equivalent power flux density data (EPFD) last week that it said mooted their effort to have its application held in abeyance (see 2202070001). SES /O3b in its petition said the data came in a format incompatible with the ITU software, and SpaceX didn't indicate whether it had run that software itself to determine if the second-gen system actually meets EPFD limits.

SES/O3b urged the FCC to stop processing the second-gen application until SpaceX shows the constellation complies with relevant EPFD limits. It also suggested approval be conditioned on similar reporting requirements as those for the first-gen constellation, but with the added requirement that SpaceX must report on the total number of satellites affected by defects that could prevent successful disposal. It said the FCC should set a threshold that would trigger a requirement to halt further launches if disposal failures mount.

SpaceX's proposed expansion of its orbital assets "would foreclose competition, preclude other valuable uses of scarce and shared spectrum and orbital resources, pose an unacceptable risk of interference, and endanger both orbital safety and the human environment," Viasat said. The scale of what SpaceX is doing would make about 86% of the altitudes between 300 and 700 km off limits, letting SpaceX "effectively monopolize vast swaths" of low earth orbit, it said. At a minimum, SpaceX should have to submit "a fulsome analysis" of how it would comply with interference limits protecting geostationary orbit networks, with other parties having full access to the underlying data for their own analyses, it said. It also said SpaceX should be required to amend its orbital debris mitigation plan with full specifications of the physical characteristics of Starlink satellites, and there should be an environmental assessment or environmental impact statement. Viasat said SpaceX should be required to deploy its already-authorized satellites and let other parties evaluate whether it met its commitments and obligations regarding that first-gen.

SpaceX's having amended its plans but not its application, which still reflects the power levels of the constellation configuration it opted to go with, is "a deficiency of commission as well as omission," Dish Network said. It's "laughable" that SpaceX providing the EPFD data just days before petitions to deny were due gives the parties enough time to analyze that data, Dish said. It urged the petition be denied because the huge increase in the number of SpaceX satellites in orbit will mean sidelobe energy from over 1,000 of them affecting the same area. It also seeks denial of the waiver allowing SpaceX to begin service before an ITU finding of compliance.

Saying it had raised similar general concerns about more-frequent conjunction events regarding other proposed mega constellations, NASA said SpaceX should do an analysis showing its auto-maneuver capability is scalable to the size of the proposed constellation. It also recommended SpaceX have a risk analysis done on the efficacy of conjunction assessments involving autonomous satellites from different satellite operators. It said about 8% of Hubble images get satellite interference now, and the second-gen constellation alone could more than double that. It said every image taken by ground-based wide-field telescopes used to survey for asteroids that could hit the Earth could have a Starlink satellite in them, making portions of the images unusable. With potentially 20,000 Starlink satellites in orbit at 328-360 km, below the International Space Station, SpaceX should do an analysis of launch window availability to see if the increase in launch conflicts could affect future commercial crew and re-supply launch opportunities.

Amazon urged any approval to be conditioned on the second-gen sharing some operational information about satellite beam positioning to avoid interference. Warning of hundreds to tens of thousands of second-gen satellites potentially overlapping with its Kuiper constellation's orbit, it said the FCC should ensure physical separation between the two by requiring SpaceX to keep its orbits at or below 580 km. OneWeb said with so many satellites in orbit, a SpaceX satellite will always be geometrically in-line with another non-geostationary orbit fixed satellite service satellite of another system. It said with multiple SpaceX satellites always in view of earth stations at any time, FCC approval should be conditioned on the company selecting the specific satellite that would avoid a potential in-line interference event and that SpaceX bear a large part of the coordination burden to avoid interfering with other systems.

RS Access seeks denial or deferring on the part of the SpaceX application about use of a 5-degree elevation angle for the second-gen satellites using the 12 GHz band. It said that would set a minimum elevation angle for the system with little use for satellite communications, and SpaceX hadn't justified why it needed such a low elevation.

The second-gen constellation raises issues other federal agencies need to tackle first, Balance Group said. It said the DOD, Environmental Protection Agency, and Food and Drug Administration might have thoughts about it. Balance said the pending appeal of the FCC's approval of the SpaceX's first-gen constellation (see 2106020036) also needs to be settled first.