Hughes EPFD Analysis Flawed: SpaceX

Hughes' claim SpaceX's planned constellation raises a big threat of harmful interference to Ka-band geostationary orbit (GSO) systems (see 2201190007) is flawed and doesn't support Hughes' predetermined claim, SpaceX told the FCC International Bureau last week. It again urged the agency to deny Hughes' request that a SpaceX petition and Kuiper application be consolidated (see 2111230008). It said the ITU confirmed that SpaceX's plans would comply with application equivalent power flux density (EPFD) limits, but Hughes' analyses modified SpaceX's data and also dumped the ITU methodology for its own. Hughes, recapping a meeting with an aide to Chairwoman Jessica Rosenworcel, said one analysis used ITU-approved software and SpaceX input data files that were modified to reflect operations of the entire SpaceX system. It said the analyses' findings undercut SpaceX and Kuiper arguments that an ITU finding of EPFD compliance without regard to the effects of multiple ITU filings is enough to protect primary GSO operations.