SpaceX Believes Amazon’s Proposed License Rules Changes Better For Pre-“Space Shuttle” Era

Aug 18, 2020
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The roll-out of fifth-generation cellular networks (5G) has also intensified the race between companies to provide users all over the globe, and particularly those in otherwise hard to access areas, with internet connectivity through non-geostationary fixed satellites. On this front, SpaceX, Amazon and others intend to launch thousands of satellites to create mega-constellations that serve as a new source of the internet.

To launch these constellations, service providers require authorization from the Federal Communications Commission (FCC), and once they have applied, there is a limit codified through the body's rules to prevent the companies from making extensive changes to the details already submitted. This codification is now the topic of intensive back-and-forth between Kuiper Systems LLC, who is responsible for Amazon's Kuiper constellation and SpaceX - with the latter having outright rejected Kuiper's demands for rule modifications in an FCC filing made today.

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Today's filing from SpaceX is in response to the one made by Kuiper at the start of July. Back then, the Amazon subsidiary had requested the FCC to make four new rule additions to Section 25.117 of its codes. This section deals with the types of modifications that service operators are required to make to their applications for NGSO FSS systems. Both Starlink and Kuiper constellations are such systems, and both have been authorized by the FCC to use certain Ka-band frequencies.

The rule additions suggested by Amazon require that if an applicant that has already been granted a license to operate satellites makes modifications to its license after the grant, then the suggested modifications should be made part of a new processing round if they cover:

  • changes in apogee or perigee by 10 km in altitude, to include the accuracy with which the apogee and perigee will be maintained before and after the modification;
  • changes in orbital inclination of more than 2 degrees, to include the accuracy with which the inclination will be maintained before and after the modification;
  • changes that materially increase the number or duration of in-line interference events with NGSO FSS space station licensees, market access participants, and applicants;
  • changes that materially increase the received interference power density to other co-frequency NGSO FSS space station licensees, market access participants, and applicants.
Amazon boss Mr. Jeff Bezos at the re:MARS 2019 fireside chat. Image: Getty Images

Kuiper believes that the current rules that allow satellite operators to make "far reaching" changes make it difficult for applicants that apply in later licensing rounds to determine what current industry standards are. Subsequently, the company proposes its modifications to stop such changes from happening and preserve what it believes is a fair environment.

SpaceX rejects these arguments and states that the current rules accurately reflect protecting what the FCC has termed as the 'public interest'. Under the current rules, any proposed modifications that either do not disqualify a system from operating, do not harm the public interest and do not ask for more frequency allocation are allowed. The public interest allocation also protects other service providers from frequency and signal interference.

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SpaceX believes that the changes will force existing service providers to saddle consumers with outdated systems and slow down innovation. It also highlights Amazon's proposal as being "more suitable to a time before the Space Shuttle", when operators left their satellites in orbit for years and did not intend to upgrade them post-launch. Interestingly, Kuiper also argues that the current rules hinder innovation, and it's up to the FCC to decide the precise definition of the term now.

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Kuiper's proposed rules would also go against the changes that the FCC previously categorized as falling in the public interest, and they assume that the current judgments exercised by the body fall beyond the scope of public interest, states SpaceX in today's filing. The company also suggests the Commission make two additions to existing rules. These would ensure all modifications save those that cause significant interference pass through and applications to increase in satellites in a constellation are classified as a major modification.

SpaceX launched the tenth batch of operational Starlink satellites today on the Falcon 9 B1049 booster that has now reflow and landed for a record six times. The company has stated that the Falcon 9s are capable of ten launches with little refurbishment and can be launched up to 100 times before retirement. Image: SpaceX

Additionally, and in what is perhaps the most important point raised by SpaceX in today's filing, the company argues that Kuiper's proposed rule changes will end up harming the Kuiper satellite constellation over the long term. Under the FCC's rules, Kuiper is required to launch at least half of its 3,236 approved satellites by the end of 2026. The company is most likely to use Blue Origin's launch vehicles for the purposes, with the launch service provider yet to demonstrate the operational capability of its vehicles.

SpaceX argues that if the FCC were to accept Kuiper's new rules, then the company will be forced to operate its authorized satellite constellation under today's technical specifications by the end of 2035. The new rules would prohibit the upgradation of the Kuiper constellation, and would in effect render it technically backward when compared to the new satellites that take to space in the years between now and license expiration;

In addition to today's filing, SpaceX has also regularly requested the FCC to maintain its access to the 12GHz band for Starlink use. A coalition of MVDDS (Multi Video Data and Distribution) service providers petitioned the Commission in 2016 to grant it additional rights over the spectrum and SpaceX argues that such a decision will put its extensive Starlink investment at risk.

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