Viasat Floats SpaceX Second-Gen EPFD Conditions

Viasat, which said SpaceX's proposed second-generation constellation will likely fall outside equivalent power flux density limits (see 2203090006), is suggesting conditions on any FCC approval to address that. In an International Bureau filing Wednesday, Viasat said before any second-gen satellite launches, SpaceX should have to submit an EPFD analysis covering the 34,000 satellites in its first- and second-gen configurations, analyzing their operation as a single system. If the analysis shows SpaceX's Starlink complying with EPFD limits, it should be allowed to deploy the second-gen satellites covered by the analysis using the inputs used in that analysis, Viasat said. If the analysis doesn't show compliance, SpaceX should have to develop a plan for meeting those limits at all test points and for all orbital locations, it said. That could involve fewer Starlink satellites or fewer orbital planes, modifying power flux density or effective isotropic radiated power masks, or increasing avoidance angle, it said. Before any change to EPFD analysis inputs, such as masks or avoidance angle, SpaceX should have to do a new EPFD analysis and get FCC approval of the analysis, Viasat said. SpaceX didn't comment Thursday.