The FCC "must send a clear message" the National Environmental Policy Act doesn't apply to activities in space, SpaceX representatives told FCC staffers including International Bureau Chief Tom Sullivan, per a bureau ex parte filing Monday. It said it has shown the agency doesn't have jurisdiction over satellite reflectivity since its rules have no provision applicable to that issue and Congress hasn't passed anything giving it that jurisdiction. It urged FCC approval of its pending second-generation satellite constellation.

While SpaceX's Starlink satellites are maneuvering more due to debris generated from Russia's 2021 anti-satellite weaponry test than any other objects in space, the low orbits it plans to use for its second-generation constellation will mean any increase in debris flux will be temporary, the company told the FCC International Bureau last week. It said in the nine months since the testing, about 62% of the resulting debris has deorbited. It said even the highest-altitude second-gen operations will passively deorbit within three to four years.

The global space economy added up to $469 billion in 2021, the Space Foundation said Wednesday. Based on past growth rates, it should hit $639 billion by 2026 and expectations of a trillion-dollar global space economy by 2040 are "reasonable," the foundation's Lesley Conn said in a webinar regarding the release of its space economy report. She said commercial space sector revenues were up 9% from the foundation's revised 2020 figure. A chief driver of space economy growth has been commercial space products and services, with that sector up 283% since 2005, she said. She said budget allocations by non-U.S. governments are up 246% since 2005. Conn said Africa and Latin America are seeing significant space investment. She said the space economy took roughly a 5% dip in the first six months of this year in reaction to international and general market conditions. She said launch attempts and successful launches are at a record high. There were more identified satellites, 1,022, launched in the first half of 2022 than in the first 52 years of the space age, she said.

Dish Network, currently authorized to use the 2 GHz band, is barely doing so, SpaceX told the FCC International Bureau in an application Monday asking for OK to use the band to add mobile satellite service capabilities to its first-generation constellation. The band "provides a unique opportunity to put underutilized MSS spectrum to highly productive use," it said, adding "there is scant evidence that DISH is actually providing MSS service to anyone, anywhere." It said Dish's planned 2 GHz terrestrial network would still leave big parts of the country unserved by 2 GHz operations. SpaceX said it would add 2 GHz MSS transceiver payloads to its already-licensed fixed satellite service system. Dish didn't comment Tuesday. Satellite and spectrum consultant Tim Farrar emailed us that the filing is "just the next stage in SpaceX’s take-no-prisoners fight over 12GHz." He said the MSS payload would seem to have significant impact on the first-generation satellites as it would bring more antennas as well as more processors and converters. SpaceX Satellite Policy Senior Director David Goldman in a call with reporters Tuesday (see 2207260050) said the 2 GHz plans and 12 GHz proceeding are unrelated. Lightshed analyst Walt Piecyk emailed us that Dish is sure to fight the SpaceX 2 GHz plans. "Anytime a new use is proposed in a spectrum band you can be assured that the incumbent will contest it," he said.

Repeating its argument that spectrum in the 1600 MHz and 2400 MHz bands that Kepler wants to use for its proposed 212-satellite constellation's U.S. operations is "fully utilized" now, (see 2202020053) Globalstar told the FCC International Bureau Monday that Kepler "significantly underestimates" the extent to which its plans would harm to the incumbent mobile satellite service (MSS). Globalstar said it's "happy to compete" with systems employing available spectrum, but co-channel market access requests like Kepler "would inevitably result in substantial interference and lost capacity" for existing MSS operators. Kepler emailed it's "focusing on ensuring we address any questions the Commission could have. Globalstar seems intent on being anticompetitive and publishing fiction, despite what they have said on record in the past about their system."

OneWeb withdrew two comments filed earlier this year on SpaceX's proposed second-generation satellite system, and SpaceX withdrew a partial petition to deny OneWeb's pending modification of its first-generation system and its second-gen application, the companies told the FCC International Bureau Thursday. They said they withdrew the filings as a result of successfully coordinating their systems. The coordination should "make further conditions on these authorizations unnecessary," they said. They urged FCC OK of the various pending applications.

Critics of O3b's pending market access grant, which would add 70 satellites to its 20-satellite medium earth orbit system, were unbowed by the company's arguments that most of their appraisals were off base (see 2207080003), per FCC International Bureau filings Tuesday. Amazon repeated its case that the FCC clarify how its rules apply to phased systems, including the interference protection those systems receive, and ensure that at minimum any expanded non-geostationary orbit system with earlier processing round status doesn't significantly increase the potential for interference. Viasat said rather than just demonstrate it meets the agency's orbital safety guidelines, O3b should need to show that grant of its application would serve the public interest such as by addressing additional sources of risk like aggregate collision risk. With O3b now asking the FCC to hold in abeyance the part of its application seeking inter-satellite links in the 19.4-19.6 GHz band, Iridium said its opposition to that part of the application need not be considered. It said O3b questioning whether the proposed links could interfere with Iridium's co-channel feeder links didn't take into account the potential for aggregate interference. OneWeb, backing O3b, said the argument by Amazon's Kuiper that since O3b wants to add satellites, the constellation should move from the 2016 processing round to the 2020 one "is contrary to Commission precedent and common sense." Systems authorized in a processing round "logically require a means by which to modify their system without forfeiting their protections; and the Commission’s rules and precedent afford them exactly that," it said.

The C-band clearing claims processing process remains problematically slow, SES officials told the FCC per a docket 18-122 ex parte post Wednesday. It said it was reimbursed for some of its submitted relocation costs, but it also is incurring financing charges from pending claims. SES told agency representatives it hopes the Relocation Payment Clearinghouse (RPC) will "improve its claims processing timeline in the near term." The FCC didn't comment. SES said its SES-20 and SES-21 C-band replacement satellites should launch in September, and SES-18 and SES-19 should be available for launch in November at the earliest. Noting AT&T's petition for reconsideration of the RPC procedures, SES said the agency should keep its current 20-day period for parties to object to RPC reimbursement decisions. "The current 20-day objection rule is clear, equitable, and advances the Commission’s goal of achieving an expeditious transition of the 3.7 GHz band," SES said. It urged the agency to make clear the burden of proof in a multiparty dispute should be on each party trying to challenge the RPC invoice. AT&T's recon petition said FCC rules don't mandate 20-day objection windows for notices of objection and such a deadline made via the public notice laying out the RPC dispute procedures isn't enough of an opportunity to comment on its merits. AT&T said the agency should clarify the 20-day period doesn't start until an objecting party knows or should know the basis for its objection. It said the burden of proof in a multi-party challenge should be with the party claiming reimbursement.

De Havilland Aircraft of Canada is adding SpaceX Starllink internet connectivity for its Dash 8-400 aircraft, the aerospace company said Tuesday. It said the agreement marks the first between Starlink and any original equipment manufacturer.

SpaceX's proposed second-generation Starlink constellation would cause interference far in excess of applicable equivalent power-flux density limits governing the system itself and also those for all non-geostationary orbit systems operating in a given band, Viasat told the FCC International Bureau Monday. It said its conclusions are based on a more-thorough analysis of SpaceX-provided EPFD data, simulating the combined effect of all second-gen satellites. An earlier Viasat analysis had raised other EPFD red flags (see 2204260002). SpaceX didn't comment. The throughput with SpaceX's first-generation Starlink constellation grows linearly the more satellites are in orbit, and its proposed second-gen satellites "are at least 5 times better (conservative estimate) than V1," CEO Elon Musk tweeted Monday. He said current Starlink bandwidth varies depending on time of day and user terminal density. "That’s why the long wait in some areas" for service, he said.