Starlink Ties Rivals In Delicious Knots Amidst Estimated 156 Million Pounds Worth Of Launches

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Space Exploration Technologies Corporation's (SpaceX) Starlink satellite internet constellation continues its back and forth with rivals in a Federal Communications Commission (FCC) proceeding. Starlink has currently requested the FCC to allow it to launch second-generation (Gen2) satellites with SpaceX's Starship next-generation rocket in order to rapidly build out a constellation consisting of tens of thousands of satellites. Its rivals in the satellite internet industry have responded to these plans with a host of concerns, ranging from accusations of improper regulatory procedures to insufficient data.

In two filings made to the FCC earlier this month, SpaceX's director of satellite policy Mr. David Goldman has responded to most of these concerns and used competitors' arguments against them. The executive's response comes after earlier filings raised a myriad of issues, including one from geostationary satellite operator Viasat, which had estimated that over its lifetime, Starlink will place a staggering 156 million pounds of aluminum in orbit.

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The bulk of Mr. Goldman's arguments is aimed at Viasat. In its filings opposing the Gen2 modification request, Viasat had claimed that the Starlink satellites would exceed 0.001 probability levels of collision, that SpaceX should provide detailed information about its satellites for Viasat to determine operational fluidity and explain how it would prevent interference with geostationary systems and claimed that the low Earth orbits (LEOs) chosen by Starlink for the spacecraft would create debris that would last for decades.

Responding to these concerns, SpaceX's Goldman has outlined to the Commission that Viasat's claim of the probability violation is patently false. SpaceX's satellite policy chief believes that not only is the probability of collision of the Gen2 satellites while they are maneuvering zero but that SpaceX has also provided data for when a satellite failure might create a chance of collision. When compared with the probability limit of 0.001, the chances of a Gen2 colliding are 0.00125 at 604 kilometers and 0.00199 at 614 kilometers.

NASA's data for the expected orbital decay of a satellite destroyed by Russia as part of an anti-satellite missile test.

Adding to this, the SpaceX executive claims that Viasat's attempts at extracting more data from Starlink are nothing but "[a] quest to better inform [itself on] how to build its own competing NGSO system". He bolsters his argument by pointing out an earlier FCC proceeding in which the company had praised the FCC's decision to not require companies to share the kind of data that Viasat is asking for.

Attacking the rival's argument of long decay times for Starlink spacecraft, Mr. Goldman uses a NASA analysis of satellite data (shared above) to outline that even when a satellite operating at roughly 500 kilometers in altitude is destroyed by a missile, most of its debris will have decayed and reentered the Earth's atmosphere in just six years.

He then turns his guns towards OneWeb and Amazon. OneWeb had stated to the Commission that unless it solicits public comments for all other applications in the same process round as the Gen2 application, the application cannot be granted. Mr. Goldman points out that if this were the case then OneWeb's own application for a satellite system that was approved in 2016 was in violation of FCC rules. Taking another jibe at Viasat, the executive states that Viasat's requirement that Starlink shares detailed data for interference protection had previously been rejected by the Commission and that the company had raised no such requirement when the body was in the process of approving Amazon's Kuiper satellite constellation.

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Accusing Amazon of seeking "a government-sanctioned monopoly against other U.S.- licensed satellite broadband systems over vast swaths of space it claims for itself", the SpaceX director states that Amazon's requirements of a keep out zone for Starlink satellites reek of a double standard when compared with its submissions for a Kuiper modification for debris mitigation.

According to Mr. Goldman:

SpaceX has proposed to operate only 468 Gen2 satellites above 580 km (at 604 km and 614 km) on a regular basis, but those two orbital shells have inclinations of 148° and 115.7°—far more than two degrees away from the inclinations Amazon is authorized to use (33°, 42°, and 51.9°). Using the methodology Amazon applied to its own system, SpaceX’s satellites present no cause for concern.

A Space Starlink launch from May 2021. Image: SpaceX

Viasat had however not limited itself to only seeking more data and raising questions about interference. Instead, it had also pointed out in a filing that estimates suggest that the Gen2 satellites will require Starlink to place a staggering 156 million pounds of aluminum in orbit over the constellation's lifetime.

Viasat had written that:

However, using a basic calculation that SpaceX itself has used151 reveals that 29,988 deorbiting Gen2 satellites alone would deposit about 13,000,000 pounds of alumina into the upper atmosphere. Factoring in replacements for those Gen2 satellites over a 15-year license term and that Gen2 satellites may be four times more massive, the proposed Starlink expansion could well result in SpaceX releasing over 156,000,000 more pounds of alumina into the upper atmosphere.

While it appears as if the above estimation relies on some questionable assumptions. SpaceX's Goldman has been silent on this claim so far. Using the estimate, Viasat believes that the Commission should conduct an environmental review of the constellation; a demand that it has been making since 2020.