Starlink’s Hard Fought FCC Victory Sees DISH, Amazon Falter Before Body

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Space Exploration Technologies Corp.'s (SpaceX) request to change its Starlink satellite altitudes has been approved by the Federal Communications Commission (FCC). The International Bureau (IB) adopted the modification last week, but it publicly revealed the decision today. This adoption comes after SpaceX was granted partial authority to launch satellites in polar orbit in January, as the company asked the FCC to partially grant a portion of its request due to the difficulty of placing spacecraft above remote regions.

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The IB's public order thoroughly evaluates concerns raised by all companies and other parties opposing the third modification. Starlink's strongest opposition came from Amazon's subsidiary Kuiper and DISH Corporation, both arguing that the modification will increase interference with their services.

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Kuiper's arguments stated that since SpaceX was proposing significant system redesigns, the Starlink license should e relegated to FCC's 2020 processing round instead of the earlier one in which it had been granted. Commenting on this, the IB in its public order states that FCC rules do not discriminate between the nature of the modification, and therefore there is no basis to relegate Starlink to the recent processing round.

In a similar vein, the Bureau replied to Kuiper's arguments that since SpaceX will lower its ground station elevation angles, more satellites will be visible. This will increase interference as Kuiper satellites will also be in the ground stations' operating 'cone' (the area in the sky visible to each station).

In response, SpaceX had argued that while the potential for interference resulting from this change will increase, the overall interference from the modification will drop since it will also lower Starlink satellite altitudes. The Bureau concurs with this line of argument, as it states in the public order that:

Specifically, after analyzing the technical arguments in the record, we conclude that the lower altitude of the satellites will in fact result in fewer satellites in view, and therefore will result in fewer in-line interference events with respect to other NGSO operators, even if the number of active satellites in view of a particular earth station is increased. . . .However, when the satellite altitude is lowered, the satellites will need to be closer to the earth station in order to be within view, and therefore lowering the altitude of the satellites helps to offset the fact that additional satellites may be visible due to the lower elevation angles, in turn offsetting the potential increase in in- line interference events.

Amazon's presentation from November 2020 highlighting the impact on its constellation from reduced earth station elevation angles. Image: Amazon Project Kuiper presentation dated November 12, 2020, and filed on November 17, 2020, in FCC International Bureau File Number: SATMOD2020041700037

The order also highlights how SpaceX's concession to accept interference from Kuiper resulted in its modification request being granted. In several FCC filings, SpaceX agreed that due to the modification, more of its system would be susceptible from interference by Kuiper, and it assented to accept this interference.

This did not go unnoticed by the Bureau, who comments:

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We conclude that there is the potential for increased interference to SpaceX’s system as a result of the modification, but since SpaceX has agreed to accept the additional interference, and will accept this grant subject to such potential additional interference, as conditioned, we also conclude that the potential for additional interference into the SpaceX system does not weigh against grant of the modification in this instance

While Amazon's arguments against the third modification were noteworthy, they were not similarly striking in nature to those raised by DISH Corporation. The television services provider had centered its claims on doubting SpaceX's commitment to using only one satellite to service one geographical area in one frequency, in a parameter referred to as Nco.

DISH produced multiple analyses showing that if SpaceX were to violate this commitment, it would create significant interference for DISH's systems.

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DISH then produced another analysis using what it termed as real-world parameters to demonstrate that even if Starlink adhered to a Nco of 1, it would still end up interfering with DISH terminals. The company concluded its arguments by requiring the FCC to mandate SpaceX to share data with DISH to allow the latter to determine its operating environment accurately. These arguments came alongside a demand that SpaceX modifies its Starlink license to explicitly agree to a Nco of 1 and limit itself to future FCC rulings.

At this point, SpaceX's director of satellite policy, Mr. David Goldman, in a masterstroke, agreed to modify Starlink's license to explicitly state that SpaceX would stick to a value of one for Nco. This concession proved crucial in Mr. Goldman's company securing approval for the third modification, as the IB notes:

A certification of compliance with EPFD limits is what is required by our rules, and we are satisfied with SpaceX’s certification that it will not violate ITU EPFD limits relevant to the 12.2-12.7 GHz band. We find that SpaceX has addressed DISH’s inquiry regarding whether an Nco value of one is reflective of the way that SpaceX operates its system, and condition this grant accordingly. As noted, DISH asks us to condition SpaceX’s grant to require 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.” SpaceX has stated on the record that an Nco value of one, as an input value for how many co-frequency simultaneously transmitting satellites will service a given point on Earth, actually reflects the way it operates its system. SpaceX has also agreed to the condition proposed by DISH 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. We condition this grant accordingly.

The Bureau has also rejected DISH's demands for more data and that Starlink be explicitly required to accept future revisions in the criteria chosen by the FCC to determine interference.

Spacecraft debris orbiting the Earth rendered by Reddit user whoadave.

Another concern raised by commentators regarding the modification request was the potential for space debris. At this front, the IB will require SpaceX to submit a semi-annual report highlighting the number of potential collision events identified, satellites removed from operation due to a collision risk, satellites that entered the Earth's atmosphere and satellites that are not responding to ground monitoring. SpaceX is also now required by the Commission to report if the number of unresponsive satellites is equal to or greater than three in a year. This report is separate from the semi-annual requirement stated above.

Finally, commenting on whether Starlink blocking astronomers' line of sigh requires an Environmental Assessment, the Bureau notes:

We take note of SpaceX’s representation that it has diminished the average brightness of its satellites from a 4.99 apparent magnitude to a 6.48 apparent magnitude and made commitments to the astronomy community regarding further reduction in the visibility of its satellites. We also take note of SpaceX’s representation that its efforts to reduce satellite reflectivity not only would benefit communities of astronomers, but also will, reduce brightness of the Starlink satellites to a naked eye observer.359 We recognize that while SpaceX is still testing some of these solutions, SpaceX must continue its efforts to fulfill its commitments to the astronomy community.

. . .Accordingly, we will continue to monitor this situation and SpaceX’s efforts to achieve its commitments in this record.

In a small win for Amazon, all Starlink satellites in the lower orbits will be required to operate below 580 kilometers, as SpaceX agreed to do so in the aftermath of its partial authorization to launch in polar orbits earlier this year.

The author has no position in any of the stocks mentioned. WCCF TECH INC has a disclosure and ethics policy.
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