SpaceX Terms DISH’s Arguments “Irrelevant” In Determining Starlink Operations

Ramish Zafar
A Starlink user terminal in the snow. Image: Steve Golson/YouTube

This is not investment advice. The author has no position in any of the stocks mentioned. has a disclosure and ethics policy.

Space Exploration Technologies Corp.'s (SpaceX) fight to get its third modification for the Starlink constellation of internet satellites took an intense turn as the company's director of satellite policy Mr. David Goldman lambasted competitors for their opposition. Mr. Goldman's comments come in response to DISH Corporate and Viasat, who have argued before the Commission that Starlink will not operate as SpaceX promises in the modification application and that the modification violates environmental protection rules, respectively.

DISH Using "Desperate Tactics" To Clear 12GHz Spectrum Alleges SpaceX As It Rejects Competitor's Claims

In a detailed analysis of Starlink's equivalent power flux density (EPFD) data submitted in February, DISH relied on an analysis conducted by a third-party consulting firm to claim that if SpaceX used more than one frequency beam in one frequency channel to serve users, then it would place DISH's consumer terminals at a significant interference risk.

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SpaceX's executive rejected this claim, which goes against the company's submissions to the International Telecommunications Union (ITU). The ITU is responsible for determining interference of satellites and their constellations and Mr. Goldman argued in February that the fact that DISH was willing to assume that rivals would violate their operational assumptions submitted to the FCC raised questions about its own intentions. He concluded his arguments by stating that after it has failed to persuade the FCC to change the rules for the 12 GHz spectrum, DISH is resorting to "desperate tactics".

Following Mr. Goldman's reply, DISH argued that the SpaceX executive had tacitly proven DISH's arguments by explicitly failing to deny that SpaceX would use only one frequency beam per satellite, the company was proving DISH's assumptions.

DISH's Jeffrey Blum stated that if SpaceX was sincere about limiting itself to its commitment of using a single beam, it would have directly said so. Since it didn't, the company was trying to "operate free of its own assumption" and that the only reason it had submitted data for one beam per satellite to the ITU was that the body would not challenge the submission argued Mr. Blum.

SpaceX's Falcon 9 Block 5 booster number 1051 takes to the skies for the eighth time to deliver a batch of 60 Starlink satellites in January. Image: SpaceX/Twitter

Mr. Goldman replied to these claims a few days later when he outlined to the FCC that SpaceX has submitted its own EPFD analysis post-modification to demonstrate that the changes proposed in the third modification will not violate interference limits.

He also proceeded to reply to DISH's claim that since SpaceX did not directly respond to assumptions of using more than one beam per satellite, it intended to not hold its end of the bargain. At this front, Mr. Goldman stated that SpaceX did not imply such a conclusion and that it will "not operate as DISH and its paid consultant hypothesize. Instead, it will comply with the terms of its license."  He concluded his argument by stating that "DISH's submission is irrelevant and should be ignored."

A few days after his response to DISH, the SpaceX director turned his aim towards Viasat. Viasat opposed the third modification by stating that it violates the FCC's National Environmental Policy Act (NEPA) due to the reduced altitudes of the satellites subject to the modification.

He refuted the claims point by point by stating that the modification will end up:

  •  reducing the number of satellites SpaceX deploys;
  • maintaining the number launches required to deploy the constellation;
  • not affecting SpaceX’s impressive and improving satellite success rate;2
  • greatly reducing the collision risk of satellites on orbit, orbit raising, and de-
  • reducing the chances of orbital debris3 (indeed SpaceX remains the only satellite
    operator to have proposed that the Commission adopt a rule preventing any
    persistent debris);4
  • having no material effect on chemicals released in the atmosphere (while the
    modification will not change the total number of satellites that de-orbit, the few satellites that de-orbit passively will reach the atmosphere sooner at the lower altitudes that SpaceX proposes, but any impact of this tiny number of passively de-orbiting satellites reaching the atmosphere sooner would be de minimis in the context of total effluents released into the atmosphere each day. According to the EPA, the United States alone emitted 70 million tons of pollution into the atmosphere in 2019);
  • having no effect on the risk to life on the ground; unlike Viasat, SpaceX has already demonstrated that its satellites have no calculated casualty risk (SpaceX is the only operator to have proposed that the Commission adopt a rule requiring zero calculated risk to life on the ground5);
  • having no effect on aircraft, especially considering SpaceX’s satellites, unlike Viasat’s, were already designed to fully demise in the atmosphere even before this upgrade; and
  •  improving visibility for optical astronomers and the general public.

Mr. Goldman concluded his arguments by stating that Viasat has set double standards when it comes to space debris mitigation and environmental protection, by previously arguing before the Commission that non-U.S. providers should not be subject to the same requirements as American subscribers. Even if the FCC were to accept that the Starlink modification requires a NEPA review, Viasat would argue that its own system would fall beyond the scope of a similar review since it is based outside of the United States believes the SpaceX executive.

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