Starlink Blows DISH Away & Accepts Competitors’ Demands   

SpaceX Starlink February 2021 launch
The Falcon 9 Block 5 launching sixty Starlink satellites to orbit from the Cape Canaveral Space Force Station earlier this year. Image: SpaceX

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Space Exploration Technologies Corp.'s (SpaceX) director of satellite policy, Mr. David Goldman, has agreed to accept DISH Corporation's conditions for operating his company's Starlink satellite-based internet constellation. His concessions come following a letter sent by DISH to the Federal Communications Commission (FCC) in which it asked the agency to modify SpaceX's license authorization to enforce operating parameters.

In his latest submission to the FCC, Mr. Goldman has accepted DISH's demand and provided a consolidated response to Starlink's competitors' concerns for the service's pending third-modification application.

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Starlink License Modification Demand By DISH Accepted - Satellites Under Modification Will Not Operate Above 580 Kilometers As Demanded By Amazon

The saga of DISH's demand that SpaceX's Starlink license be modified began when the company submitted a third-part analysis to the FCC. This analysis used data that SpaceX had submitted to DISH to demonstrate that if a specific Starlink satellite parameter were violated, the company's user terminals would face significant interference from the internet service.

The parameter referred to as Nco is about the frequency beams that the satellites use to communicate with the user terminals. SpaceX had shared data with the FCC before DISH's analysis showing that it intended to use only one beam per frequency per satellite for similar areas, but DISH, following the analysis, disputed SpaceX's intention of doing so.

As a result, the company demanded that SpaceX's Starlink license be modified to limit the company from using more than one beam explicitly. In response, Mr. Goldman has agreed to the modification, with the updated license's relevant portion to now read as follows:

Operations in the 12.2-12.7 GHz (space-to-Earth) frequency band are authorized up to the power flux-density limits in 47 CFR § 25.208(o) and Article 21 of the ITU Radio Regulations, and up to the equivalent power flux-density requirements of Article 22 of the ITU Radio Regulations, as well as Resolution 76 (Rev. WRC-15) of the ITU Radio Regulations, subject to the condition that SpaceX not use more than one satellite beam from any of its satellites in the same frequency in the same or overlapping areas at a time.

By agreeing to the concession, the SpaceX executive has also asked the FCC to reject any further demands made by DISH. Additionally, he has also dismissed DISH's demand that Starlink is subject to future FCC findings for determining equivalent power flux density (EPFD) limits by arguing that Starlink will be required to adhere to them by default.

Additionally, Goldman has also rendered DISH's third-party analysis moot by stating that the Commission does not require EPFD data to be validated by external parties before a system is deployed. He has also rejected the requirement that SpaceX stops Starlink operations if any of pending FCC proceedings.


Aiming his guns at Amazon next, the SpaceX executive accepts the company's demand that Starlink satellite subject to the third modification restrict their operating altitude to 580 kilometers even if Amazon does not launch any satellites for its Kuiper constellation. Furthermore, he also accepted Amazon's requirement that Starlink protects Kuiper from interference despite the latter being filed in a later FCC round. SpaceX's condition for this is that it be granted a similar level of protection from Kuiper for Starlink satellites operating at lower altitudes.

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The SpaceX executive's criticism of Viasat is the strongest in his latest FCC filing. While he conceded to another demand, this time to provide success rates for Starlink satellites by agreeing to provide a bi-annual report detailing satellite efficiency rates, and he states that Viasat's demand that SpaceX shares confidential Starlink data publically goes against Viasat's previous statements made to the commission.

Goldman believes that Viasat is seeking access to this information so that it can design its own satellite system and that the demands are "blatantly anti-competitive and concerning."

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