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FEDERAL COMMUNICATIONS COMMISSION Washington, D.C Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ____________________________________ ) Application of ) ) SPACE EXPLORATION HOLDINGS, LLC ) Call Signs: S2983 and S3018 ) For Modification of Authorization for the ) File No. SAT-MOD-20200417-00037 SpaceX NGSO Satellite System ) ____________________________________) CONSOLIDATED OPPOSITION TO PETITIONS AND RESPONSE TO COMMENTS OF SPACE EXPLORATION HOLDINGS, LLC William M. Wiltshire David Goldman Paul Caritj Director, Satellite Policy HARRIS, WILTSHIRE & GRANNIS LLP SPACE EXPLORATION TECHNOLOGIES CORP. 1919 M Street, N.W. 1155 F Street, N.W. Suite 800 Suite 475 Washington, DC 20036 Washington, DC 20004 202-730-1300 tel 202-649-2700 tel 202-730-1301 fax 202-649-2701 fax Counsel to SpaceX July 27, 2020 SUMMARY Given the urgency of bringing broadband to every American no matter where they live, SpaceX is proud to be on the cusp of delivering truly high-speed, low-latency service to customers in the United States and around the world, especially those in underserved and unserved areas including in Polar regions. In just over two years since having received its license, SpaceX has launched many hundreds of satellites for its broadband constellation – many hundreds more satellites than any other non-geostationary orbit (“NGSO”) satellite operator authorized in its processing round – and begun to deploy a large-scale ground-based infrastructure. SpaceX operates the satellites currently on-orbit at an altitude of 550 km where the effects of atmospheric drag ensure that orbital debris and any failed satellites de-orbit rapidly. As the Commission has recognized, operating at this low altitude enhances the safety of all systems operating in space. Also, operations at this orbit ensure that SpaceX can offer service that far surpasses the Commission’s definition of a low-latency system. Building on the success of its ongoing deployment and to enhance the already considerable safety attributes of its constellation, SpaceX proposes to relocate those additional satellites currently authorized by the Commission to operate at altitudes above 1,100 km down at the 540- 570 km range. Critically, this modification will reduce service latency throughout its constellation without having to request additional spectrum or the deployment of additional satellites. The Commission grants such requests when they do not present significant interference problems and are otherwise consistent with Commission policies. Accordingly, in support of its proposed modification, SpaceX submitted analyses to show that operating at lower altitude will have little to no interference impact on other licensed systems. It has also demonstrated that its modified i system will meet all applicable orbital debris mitigation requirements, including those recently adopted by the Commission that have not yet gone into effect. Predictably, several parties – mostly competitors whose deployment lags behind that of SpaceX – have filed comments and petitions trying to prevent the proposed modification. As demonstrated herein, commenters raise no genuine issues of space safety or interference concerns, but rather rely on competitive gamesmanship that ultimately hurts the consumer. These comments and petitions fail to raise issues that should prevent the Commission from granting this application and thereby speeding delivery of robust service for consumers. As the first private company to transport astronauts to the International Space Station (“ISS”) and whose very existence depends upon the ability to safely operate in space, ensuring a safe operating environment in space is paramount for SpaceX. The Commission has recognized, and no party in this proceeding denies, that operating satellites at lower altitudes has inherent safety benefits that accrue from the increased atmospheric drag that effectively removes debris (including non-maneuverable satellites) fairly quickly, significantly reducing the risk of collision. SpaceX’s proposed modification is designed to capitalize on these safety-enhancing characteristics. Yet despite these well-understood benefits, some parties – whose own systems present much more concerning risk profiles – have resorted to hyperbole in a transparent effort to slow SpaceX’s progress. Worse, several non-U.S. operators who themselves consistently refuse to provide detailed debris mitigation plans for their own systems attempt to game the Commission’s rules to put U.S.-licensed systems at a competitive disadvantage. Yet, for all the commenters’ exaggeration and game playing, the fact remains that this proposed modification would make SpaceX’s system safer in nearly every respect, while helping to close the digital divide in the United States. Even assuming a large avoidance area around each ii satellite SpaceX would deploy under its proposed modification, the total amount of space they would occupy is just 0.000065% of the volume of space between the 540 km and 570 km altitudes. Combining this small volume with the maneuverability of its satellites, their predictable orbital tracks, and very precise location information shared with other operators, SpaceX will be able to both manage the spacing of its own satellites and coordinate their operations with other NGSO systems. Moreover, while SpaceX’s new orbits have the potential to overlap with some other systems, the modification clearly removes overlap with others – even with some of those that surprisingly complain about this move. Some operators, including those that have not even been licensed, have gone so far as to try to use this proceeding to claim monopoly rights for themselves over certain altitudes. Yet the Commission has repeatedly rejected these types of anti-competitive attempts by NGSO operators to claim exclusive use of valuable orbital real estate. And while several competitors tried to latch on to the small number of SpaceX satellites that have lost maneuverability, the Commission already addressed this potential, finding that the rapid deorbit and low collision risk even for a non-maneuverable satellite satisfy applicable safety guidelines. In contrast, failed satellites at higher altitudes like those for which SpaceX is currently authorized and that are used by other operators remain in orbit as a risk for decades, centuries, or longer. Commenters and petitioners also greatly overstate the potential for spectral interference arising from the proposed modification. While improving the safety profile of its system by flying at a lower orbit, SpaceX will also operate at lower power levels, making its uplink and downlink transmissions somewhat more susceptible to interference from other NGSO systems. To address this tension, SpaceX will not object to a condition requiring that it accept any additional iii interference from other NGSO systems authorized in the 2016 processing round resulting from this modification compared to its current authorization. These same power reductions generally work to the benefit of other NGSO operators worried about interference into their own systems. In addition, even accepting interference at the levels of its currently authorized system as discussed above, interference from other NGSO systems into SpaceX uplinks without the modification will overwhelm any effect SpaceX’s modified operations may have on their respective downlinks. In other words, in the absence of coordination, SpaceX and other NGSO operators will already be subject to the spectrum splitting requirements of Section 25.261 due to interference from other operators into SpaceX’s uplinks long before any arguable interference from SpaceX downlinks would trigger that rule. As a result, any impact SpaceX’s modified operations might have on other NGSO systems will not increase the amount of time that the parties will have to split common spectrum in the absence of a coordination agreement. Thus, SpaceX’s modification will not have a “significant” impact on other NGSO systems. Any claims raised by geostationary orbit (“GSO”) satellite operators are fully addressed by the fact that SpaceX will comply with the applicable equivalent power flux-density (“EPFD”) limits that the Commission has adopted to protect GSO systems. Tellingly, no GSO party that weighed in on the proposed modification either accepted SpaceX’s repeated offers to supply the data underlying the EPFD analysis submitted with its application or supplied any analyses of their own to support their comments. Lastly, the Commission should disregard the disjointed and illogical claims raised on behalf of Multichannel Video Distribution and Data Service (“MVDDS”) licensees that somehow SpaceX’s authorized use of its licensed frequencies could harm their speculation in the 12 GHz iv band. Given that these same MVDDS interests have argued for years that any NGSO operations in the band would prevent their attempt to expropriate this spectrum, this latest effort to leverage SpaceX’s modification verges on the nonsensical. Because the MVDSS licensees’ own analysis shows that co-existence with their proposed use is impossible, nothing done in this proceeding could possibly make sharing more difficult. SpaceX has demonstrated that its modified system will comply with all rules imposed to safeguard MVDDS systems as they are currently licensed, following both a fair and a straightforward approach. Nothing about granting SpaceX’s proposed modification will change any of the considerations relevant to the MVDDS licensees’ desired spectrum grab. As SpaceX has demonstrated in its application,
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