SpaceX Second-Gen Constellation Plans Face EPFD Criticisms

SpaceX's proposed second-generation non-geostationary orbit (NGSO) system still raises big interference concerns, numerous satellite operators told the FCC International Bureau in comments filed Tuesday, rejecting SpaceX objections to their petitions or criticisms (see 2202250002). SpaceX data files produced in February on the power levels generated into DBS TV dishes in the 12 GHz band show the second-gen system would exceed applicable equivalent power flux density (EPFD) limits even using ITU-approved methodology, Dish Network said. It said SpaceX is trying to obfuscate that by splitting its system into 18 mini-systems. It said not only should the 12 GHz of the application be denied, the FCC also should reopen its approval of SpaceX's first-gen system to see if it "has taken similar liberties." SES/O3b said there should be independent verification of the second-gen EPFD limits, and the data and analysis SpaceX provided don't establish it would operate within relevant limits. Nor has SpaceX shown the 30,000 second-gen satellites operating together would be within EPFD levels, or said anything about the combined EPFD levels of the first- and second-gen systems, it said. OneWeb said any second-gen system approval should be conditioned on SpaceX acting to avoid in-line interference with co-frequency NGSO systems, meeting a higher disposal reliability standard, continuing periodic reporting on the health of its constellation, and clarifying how it will distribute aggregate EPFD among multiple NGSO systems. It said the FCC shouldn't approve the system until the notice and comment stage of the 2020 Ku/Ka-band processing round is done. Lacking either facts or legal backing, "SpaceX simply pounds the table, hoping to bludgeon yet another regulator into submission," Viasat said. It criticized SpaceX for "refus[ing] to provide basic information about the physical and other characteristics of its satellites." Even with 2,000 satellites in orbit, SpaceX's Starlink falls short of providing service "consistent with the ambitious public interest claims it has repeatedly made before the Commission," Viasat said. Kepler said, contrary to SpaceX claims it was seeking a benefit for its own constellation, its comments highlight a concern about end of life of NGSO satellites broadly. RS Access said SpaceX hasn't justified its proposed 5-degree minimum elevation angle, which appears to be about stymying terrestrial wireless use of the 12 GHz band. SpaceX didn't comment Wednesday.