SpaceX Pushes Back Against Argument Linking Regulatory Fees to Constellation Size

Viasat's argument that assessing a satellite constellation's regulatory complexity should consider factors beyond altitude (see 2405170032) ignores that there is "a direct, physics-based relationship" between altitude and regulatory complexity issues, such as spectrum efficiency and complexity of orbital debris, SpaceX representatives told FCC Space Bureau staffers, according to a filing Friday in docket 24-85. A large system at a lower orbit can present much less complexity than a smaller, higher one, it said. It said the FCC repeatedly rejected constellation size as a good proxy for system complexity and the work burden on staff. "Using a proceeding to determine regulatory fees to reverse this long-standing policy, while rejecting an altitude-based proxy that directly aligns with system complexity, would be arbitrary and capricious," it said.