Dish Network can't cite evidence showing SpaceX's pending lower-orbit license modification (see 2007140001) will violate ITU equivalent power flux density limits, so the company instead argues SpaceX's network would do so if it were operated differently, SpaceX said in a docket 20-443 FCC post Wednesday in response to a Dish-commissioned study (see 2102160012). SpaceX said it will operate as laid out under its license terms, not how Dish hypothesizes. It said Dish not citing any actual EPFD limit violations is its own "tacit admission that none exist." Dish Executive Vice President-External and Legislative Affairs Jeff Blum emailed that SpaceX has yet to refute "the premise, methodology, or conclusion of Dish's expert analysis, which is based on SpaceX's own data. Dish's study shows that SpaceX's proposed system in the 12 GHz band would likely violate the EPFD limits adopted by the ITU and the Commission for the protection of [direct broadcast satellite] customers, including the millions of U.S. households served by DISH. SpaceX has been authorized to use 15,000 megahertz of spectrum outside of the 12 GHz band. If the Commission decides to grant SpaceX’s Third Modification, it should exclude the 12 GHz frequencies."

Guidance on outstanding issues on funding the C-band clearinghouse by incumbent C-band satellite operators "would be extremely helpful," SES told the FCC, recapped a docket 18-122 post Wednesday on calls with acting Chairwoman Jessica Rosenworcel aides and the Wireless Bureau. It didn't specify the issues. SES said the five incumbent operators signed a funding letter to the clearinghouse setting out procedures for the entity's funding and processing of relocation payments to those companies.

Eutelsat won't require compression or other technology upgrades to keep providing the “same or better” transportable fixed earth station service in the U.S. in the 4-4.2 GHz band after the C-band repack, representatives told FCC Wireless and International Bureau and Office of General Counsel staffers, per a docket 20-173 post Wednesday.

SpaceX's Starlink is offering users speeds twice of what's required by the Rural Digital Opportunity Fund and latency at a small fraction of the threshold for a low-latency service, CEO Elon Musk told FCC acting Chairwoman Jessica Rosenworcel, per an RM-11768 post Tuesday. SpaceX said repeated extensive analyses over the past 11 months show that allowing a lower orbit for more than 2,800 proposed satellites (see 2004200003) won't create significant interference issues for other satellite or terrestrial licensees. SpaceX said some opponents, such as Amazon's Kuiper, "have apparently abandoned their own systems" and are focusing on lobbying efforts in opposition to that lower altitude to forestall SpaceX. Amazon emailed that SpaceX "would love to stifle competition and be the only [low earth orbit] system out there. That’s not only unrealistic -- it’s bad for the billions of people on Earth without reliable broadband. The Kuiper team is over 500 people and growing. Amazon is fully committed to Project Kuiper and its mission to deliver fast, affordable broadband to unserved and underserved communities around the world.” SpaceX said multichannel video and data distribution service licensees against the license modification haven't explained how it would affect them, as other non-geostationary orbit systems are already licensed with wider beams and at lower elevation angles in the 12 GHz band.

SpaceX, which has a blanket authorization for up to 1 million end-user earth stations to communicate with its non-geostationary orbit broadband constellation, asked the FCC International Bureau for OK for those earth stations to deploy as vehicle-mounted earth stations, earth stations on vessels and earth stations aboard aircraft. An application Friday said those earth stations in motion would have the same transmit power, gain and effective isotropic radiated power as the authorized user terminals. Pending before the bureau is SpaceX's request for its blanket earth station license to expanded from 1 million to 5 million (see 2008030004).

That SpaceX suggests the FCC can't go back and address the issues raised by allowing 10 SpaceX satellites to operate at a lower orbit because they're already launched underscores the need to tackle those issues through the reconsideration process, Viasat said in an FCC International Bureau filing Friday in response to SpaceX's recon petition opposition (see 2102240005). Viasat said the FCC is obliged to evaluate SpaceX's modified non-geostationary orbit system as a whole, including the lower orbit permitted for 1,584 satellites in 2019. It said the FCC's approval of the 10 satellites ignores the near-term risks of collisions creating clouds of orbital debris. Hughes, recapping a call with staffers including International Bureau Chief Tom Sullivan, said there's "undisputed evidence" of SpaceX noncompliance with equivalent power flux density limits, creating interference risks to incumbent Ka-band geostationary satellite orbit operations. SpaceX didn't comment Monday.

Existing orbital debris mitigation and satellite end-of-life requirements for geostationary operations have worked well for years, so there's no need for additional economic measures on GSO operators, such as the proposed post-mission disposal bond, Astranis representatives told an aide to acting FCC Chairwoman Jessica Rosenworcel, per a docket 18-313 filing Monday. The bond and proposed indemnification requirement would undermine commercial space industry innovation and wouldn't give GSO operators more incentive to successfully dispose of satellites, it said.

The low earth orbit satellite boom will drive active satellites up 20-fold by the end of the decade, with more than 50,000 LEOs in orbit, MTN Consulting said Monday. Constellations are underway or planned, including several from China, and not all will succeed, with constant capital flow and ability to cross-sell services key, it said.

Ignore the "untested and uniquely onerous requirements ... conceived on the fly" by opponents to SpaceX's pending license modification request, company officials told FCC International Bureau Chief Tom Sullivan in a filing Thursday. A lower orbit for 2,800 satellites is inherently a safer altitude due to more orbital drag, it said. Dish Network said SpaceX acknowledged it likely will violate FCC and ITU equivalent power flux density limits for protection of direct broadcast satellite service. It said SpaceX still hasn't been clear on whether it will use overlapping co-frequency satellite beams. SpaceX didn't comment Friday.

In support of appellants Northstar Wireless and SNR Wireless, Dish Network will argue that FCC denial of AWS-3 auction bidding credits to the Dish designated entities deviated from policy and precedent by creating "competitive inequities among participants in FCC spectrum auction processes." That's according to Dish in a notice of intent to participate (in Pacer, docket 18-1209) Thursday in the U.S. Court of Appeals for the D.C. Circuit.