Starlink Stuns NASA As Rivals Seek FCC Protection From ~30,000 Satellites

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Space Exploration Technologies Corporation's (SpaceX) Starlink satellite internet constellation is facing criticism from multiple fronts on its plans to launch approximately 30,000 second-generation satellites. Starlink has launched closed to 2,000 spacecraft to date as it speeds up its launch cadence to rapidly develop its constellation before larger rivals get their satellites off the ground. At this front, the company has petitioned the Federal Communications Commission (FCC) to let it use its newer rocket, dubbed Starship, to launch the spacecraft.

This application, which was filed last year is facing criticism from both competitors and government agencies, with the complaints ranging from the number of satellites that Starlink aims to put in orbit, to revised parameters that some believe will harm other satellite networks, to worries about orbital collisions between different constellations.

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The fight for the second-generation satellites gained widespread media coverage earlier this month as the National Aeronautics and Space Administration (NASA) expressed its desire to 'work' with SpaceX in a letter submitted to the FCC via the National Telecommunications and Information Administration (NTIA).

In its letter, NASA expressed its concerns regarding the sheer number of satellites that SpaceX plans to put in orbit as part of Starlink's second-generation upgrade. NASA's strongest criticism targetted Starlink's claim in its application that the satellites would present "zero" risk of collision with large objects since they can maneuver themselves.

The space agency outlined that while this risk can be zero for large, singular spacecraft, the fact that the Starlink constellation will feature "tens" of thousands of satellites, it is unwise to assume that all equipment, software and maneuvers (both manual and auto) are "100%" error-free. NASA went on to add that while Starlink can scale up its existing collision avoidance mechanisms, this does not apply to the actions that SpaceX and other companies with large constellations at the same altitudes will have to take place to ensure that their constellations and spacecraft do not collide with each other.

Due to these worries, NASA requested that SpaceX conduct a risk assessment of inter-constellation conjunction events, and provide it with the results to ensure that NASA assets and operations remain unaffected.

An excerpt from NASA's letter submitted to the FCC outlining how the interaction between multiple satellite constellations in Earth orbit remains unstudied. Image: SAT-AMD-20210818-00105

The scale of the second generation Starlink constellation was a theme also present in concerns raised by OneWeb, who believes that if the FCC does grant Starlink's application to launch the 29,988 satellites, then the SpaceX subsidiary should be made subject to several conditions that ensure smaller constellations, like OneWeb's, are not harmed. OneWeb argues that the current rules for spectrum sharing between non-geostationary satellite operators (NGSO) are insufficient, which can result in larger constellations using the ambiguity to their advantage.

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It goes on to add that simply due to the higher number of satellites in orbit, a band splitting event which is triggered once two competing satellites from different companies will occur 100% of the time for OneWeb's satellites due to the fact that they will be always in the vicinity of a Starlink spacecraft. This would provide Starlink with access to more spectrum in the absence of a coordination agreement, outlines OneWeb.

Subsequently, the company argues that the FCC should condition the approval of second-generation Starlink spacecraft on SpaceX being required to avoid interference with other operators, and ensure that all companies have adequate access to resources.

The 429 feet launch and arrest tower for Starship are visible during a SpaceX event earlier this month. Starship will be solely responsible for launching the second-generation satellites into orbit according to SpaceX's modified plans submitted to the FCC. Image: SpaceX/YouTube

OneWeb's concerns are still muted when compared to Starlink's age-old FCC rivals DISH Network and Michael Dell's RS Access, LLC. Presenting a united front, both want the Commission to explicitly reject the second-generation satellite application, with RS Access using a slightly milder tone which requests the FCC to 'defer in part'.

DISH reiterates its concerns surrounding a satellite beam per frequency per satellite (Nco) used to serve an area. The company had brought this up in an earlier FCC proceeding that saw Starlink accept that it will limit Nco to 1, following which Starlink's license was modified. DISH's latest concerns against Starlink once again bring up this issue, as it argues that the large number of satellites will translate into an effective Nco of 6 due to passive transmissions, even if Starlink is limited to a Nco of 1.

It also raises the possibility of more than one beam making it to a Starlink terminal since the dish will be able to receive signals from both the first and second-generation satellites. DISH stretches Starlink's 'typical' scenario of one beam per terminal to accuse the company of ambiguity for an "atypical" scenario.

RS Access takes aim at Starlink's proposed minimum elevation angle of 5 degrees to state that this is an illogical parameter that is "principally designed to impede the Commission’s 12 GHz evaluation." The two are butting heads at another FCC proceeding which aims to establish new rules for the 12GHz frequency band that is used by both Starlink user terminals and multi-video data distribution service (MVDDS) providers such as RS Access.

An image from the 5G-based MVDDS provider Cibola Wireless's website showing the download speeds for its service. Image: Cibola Wireless

Starlink's response to an FCC request, submitted in January shared key parameters of the second-generation system. This saw the company gamble its future on SpaceX's Starship rocket, which is currently under development at the company's facilities in Boca Chica, Texas and is awaiting an environmental assessment by the Federal Aviation Agency (FAA).

In this letter, the company shared optimism about launching the new satellites as soon as next month, but this is out of the question now since the FAA aims to complete its assessment by March-end. It also shared other details such as the orbital lifetime of the new satellites, their launch mechanism on Starship, a higher station orbit and a minimum elevation of 5 degrees if a gateway is located at higher latitudes.

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