EchoStar: No Reason SpaceX SCS Operations Should Get a PFD Waiver

With SpaceX acknowledging its proposed G-block supplemental coverage from space (SCS) operations can't comply with the required aggregate out-of-band emissions limit, there is no reason for waiving the aggregate emissions limit, EchoStar said Thursday in docket 23-135. Even if the agency isn't ready to dismiss SpaceX's noncompliant application, the waiver at the very least necessitates a new public notice and pleading cycle because the amended waiver request is a major amendment, the filing argued. In its amended waiver request, filed earlier this month, SpaceX said the emissions limit set in the FCC's SCS order "is not practically achievable on an aggregate basis." SpaceX said the waiver, allowing for a different power flux density than the rules specify, would still protect adjacent band networks from harmful interference. The waiver also "would avoid placing artificial caps on the number of satellites that an operator may use to provide supplemental coverage," it said.