Federal Communications Commission
Washington, D.C. 20554
June 7, 2024
VIA ELECTRONIC MAILING
Mr. William M. Wiltshire
Harris, Wiltshire & Grannis LLP
1919 M Street, NW
Suite 800
Washington, D.C. 20036
[email protected] Re: ICFS File Nos. SAT-LOA-20200526-00055, SAT-AMD-20210818-
00105, SAT-AMD-20221216-00175, SAT-MOD-20240423-00089,
SAT-MOD-20230207-00021, and SAT-AMD-20240322-00061; GN
Docket No. 23-135; Call Sign: S3069
Dear Mr. Wiltshire:
On February 20, 2024, Space Exploration Holdings (SpaceX) filed a letter in the docket for its
second generation (Gen2) application, as amended, 1 requesting to “leverage the shells included in its
application in the 340 km-360 km range as an option within its authorized first tranche of 7,500
satellites.” 2 SpaceX has also amended its pending application for “direct to cell” operations with its Gen2
satellites, 3 and filed a modification 4 seeking to operate using authorized V-band frequencies in the 340
km-360 km altitude range. In light of SpaceX’s renewal of its request for authorization to operate in the
340 km-360 km shells, as well as the amendment and modification filed related to its Gen2 satellite
operations, we request SpaceX provide further information detailed below to assist in review of the
above-captioned applications. 5
1
See Space Exploration Holdings, LLC, Application for Orbital Deployment and Operating Authority for the
SpaceX Gen2 NGSO Satellite System, ICFS File No. SAT-LOA-20200526-00055 (filed May 26, 2020) (SpaceX
Gen2 Application); Space Exploration Holdings, LLC, Amendment to Pending Application for the SpaceX Gen2
NGSO Satellite System, ICFS File No. SAT-AMD-20210818-00105 (dated Aug. 18, 2021) (SpaceX Gen2
Amendment).
2
See Letter from David Goldman, Vice President of Satellite Policy, Space Exploration Holdings LLC, to Marlene
H. Dortch, Secretary, FCC, ICFS File Nos. SAT-LOA-20200526-00055 and SAT-AMD-20210818-00105 (dated
Feb. 20, 2024).
3
See Space Exploration Holdings, LLC, Application for Modification of the Authorization for the SpaceX Gen2
NGSO Satellite System to Add a Direct to Cellular System, Grant Stamp, ICFS File No. SAT-MOD-20230207-
00021 (granted-in-part, deferred-in-part Dec. 1, 2023); Space Exploration Holdings, LLC, Amendment to
Application for Modification of the Authorization for the SpaceX Gen2 NGSO Satellite System to Add a Direct-to-
Cellular System, ICFS File No. SAT-AMD-20240322-00061 (filed Mar. 22, 2024) (SpaceX Direct-to-Cell
Modification amendment).
4
See Space Exploration Holdings, LLC, Request for Modification of the Authorization for the SpaceX V-band
NGSO Satellite System, ICFS File No. SAT-MOD-20240423-00089 (filed Apr. 23, 2024) (SpaceX V-band
Modification Application).
5
47 CFR § 25.111(a).
1. The Commission’s partial grant of authority for SpaceX’s operations of the Gen2 system included
a condition that SpaceX not deploy any satellites designed for operations at altitudes below the
International Space Station (ISS). 6 Please provide the exact amount of time Gen2 satellites
currently spend in the orbits below the ISS (at approximately 400 km) during on-orbit testing and
launch and early-orbit phase (LEOP) operations, before being raised to their authorized
operational orbits at altitudes of 525-535 km. If there is a range of times, please provide the
minimum and maximum number of days that a Gen2 satellite could spend at a lower-than-
operational altitude during any launch and early-orbit phase operations. Please also provide the
minimum and maximum number of days during which SpaceX Gen2 satellites are located in
orbits between 300 and 400 kilometers during the de-orbit phase.
2. Please provide the maximum number of satellites that are located at altitudes below the ISS
(assuming an ISS altitude of 400 km for purposes of this response) at any one time during LEOP
operations.
3. The National Aeronautics and Space Administration (NASA) has raised concerns about the
functioning of SpaceX’s autonomous collision avoidance system operating at low altitudes during
periods of increased solar activity. 7 Has SpaceX coordinated with NASA to address these
concerns? If coordination is complete, please provide details regarding the outcome, including a
description of any modifications to SpaceX’s proposed operations and/or use of its autonomous
collision avoidance system at these lower altitudes resulting from such coordination. If
coordination with NASA is ongoing, please provide an update on the status of these discussions.
4. SpaceX’s original request was for roughly two thirds (19,440 satellites) of its proposed
constellation to operate at altitudes between 340 km and 360 km. 8 Taking into account SpaceX’s
request for authority to deploy a subset of the initial tranche of the 7,500 satellites authorized in
the Gen2 partial grant to the 340 km-360 km shells, as well as SpaceX’s original request, how
many total satellites would SpaceX now seek to ultimately operate between 340 km and 360 km?
5. Of the Gen2 satellites that SpaceX proposes to operate between 340-360 km, how many does
SpaceX anticipate would have capability to operate in the frequencies requested in SpaceX’s
“direct to cell” application? How many of these Gen2 satellites does SpaceX anticipate would
have V-band capabilities? For purposes of this response, please refer only to the previously
authorized first tranche of 7,500 Gen2 satellites and not all proposed 29,988 Gen2 satellites.
6. In its V-band Modification Application, SpaceX provides the proposed configuration for its 340-
360 km and 525-535 km shells to demonstrate deployment options for its V-band satellites, 9 but
this configuration is for all proposed satellites in the Gen2 constellation, including those deferred
in the SpaceX Gen2 Dec. 2022 Partial Grant, not only for the 7,500 authorized satellites with V-
band capabilities. SpaceX also provided three representative configurations of the 7,500 satellites
6
See Space Exploration Holdings, LLC, Request for Orbital Deployment and Operating Authority for the SpaceX
Gen2 NGSO Satellite System, order and Authorization, 37 FCC Rcd 14882, 14952, para. 135bb (2022) (SpaceX
Gen2 Dec. 2022 Partial Grant).
7
Id. at 14922, paras. 76-77.
8
Id. at 14888-89, para. 7.
9
See SpaceX V-band Modification Application, Technical Attachment at 4.
2
for the purpose of demonstrating that the V-band modification will not cause additional
interference to other NGSO systems, 10 but it is unclear if these three representative configurations
encompass all configurations SpaceX is considering for these 7,500 satellites. 11 Please provide
the specific proposed configuration of the first tranche of 7,500 Gen2 satellites, including the
altitudes, number of orbital planes, and maximum number of satellites proposed in each altitude
and orbital plane. If SpaceX has not yet decided on a configuration, please provide all options
under consideration. If SpaceX is seeking flexibility in how it chooses to configure its satellites,
please provide a detailed description of factors that will affect SpaceX’s decision.
7. Please provide an updated large object collision risk assessment for Gen2 satellites in all 340-360
km shells, taking into account all authorized and pending modifications and amendment. 12 In
addition, please provide an updated risk assessment for collisions with small debris or
meteoroids. 13 Please also provide updated information regarding SpaceX’s plans to reserve
sufficient propellant for collision avoidance and deorbit maneuvers for operations at the 340-360
km altitudes.
8. Please provide updated information regarding how SpaceX plans to ensure that its operations do
not affect operations of inhabitable space stations, including the ISS and the Chinese space
station, given SpaceX’s authorized orbital tolerances of -50/+70 km. 14
9. Please also provide an update regarding coordination with NASA to protect safe launch windows
for NASA’s scientific missions as well as resupply missions to the ISS. 15 If coordination is
complete, please provide details regarding the outcome, including any modifications to SpaceX’s
proposed operations at the 340-360 km orbital altitudes. If coordination is ongoing, please
provide an update on the status of these discussions.
10. In the SpaceX Gen2 Dec. 2022 Partial Grant the Commission deferred consideration of
additional impacts on optical astronomy from satellites located at the 340-360 km orbital shells,
in particular concerns raised on the record that satellites located at these lower altitudes will be
brighter than those at higher altitudes, even though they reflect sunlight for shorter amounts of
time. 16 Please provide updated information regarding SpaceX’s coordination with the National
Science Foundation (NSF) regarding any measures that have been taken or that will be taken to
mitigate impacts to optical astronomy. Specifically, does SpaceX’s coordination with NSF
10
Id. Technical Attachment, Annex A.
11
For example, none of the three representative configurations place satellites in the 350 km, 360 km, or 535 km
shells. Id.
12
See 47 CFR § 25.114(d)(14)(iii).
13
See 47 CFR § 25.114(d)(i).
14
See e.g. Letter from Kathy Smith, Chief Counsel, National Telecommunications and Information Administration,
to Marlene H. Dortch, Secretary, FCC, ICFS File No. SAT-AMD-20210818-00105, NASA Letter at 1-2 (dated Feb.
8, 2022) (NTIA Letter); Letter from Darren McKnight, LeoLabs, to Karl A. Kensinger, Chief, Satellite Division,
International Bureau, FCC, ICFS File Nos. SAT-LOA-20200526-00055 and SAT-AMD-20210818-00105, IB
Docket No. 18-313 at 4 (dated March 29, 2022) (LeoLabs March 29, 2022 Letter).
15
See NTIA Letter, NASA Letter at 4.
16
See Gen2 Dec. 2022 Partial Grant at 14932-33, para. 101.
3
address mitigation of impacts from these lower altitude shells? If not, please provide an update
on SpaceX’s progress coordinating mitigation efforts for these lower altitude satellites. Please
also provide details on any additional mitigation efforts SpaceX has implemented or plans to
implement to reduce the reflectivity of its satellites that will be operating at these lower altitudes,
including the predicted apparent magnitude for the satellites SpaceX proposes to operate between
340 and 360 km and how this predicted apparent magnitude compares to the actual apparent
magnitude of the Gen2 satellites at 525-535 km.
11. In the amendment to the modification application seeking to conduct ”direct to cell” operations,
SpaceX requests to operate its Gen2 satellites for mobile satellite service (MSS) in the 1400-2700
MHz bands. 17 Please clarify whether SpaceX would intend to operate with its Gen2 satellites
between 1400 MHz and 2700 MHz, as specified in its Form 312 – Schedule S, or whether
SpaceX would intend to operate between 1429 MHz and 2690 MHz as previously stated in its
modification application.18 Please additionally provide an updated Form 312 - Schedule S that
includes the anticipated transmitting and receiving channels in which SpaceX seeks to operate
within this range, or alternatively, specify when SpaceX would expect to have such information
available. 19
12. Please provide an interference analysis for operations in the PCS G-Block that addresses possible
satellite-to-satellite interference given the side lobe angles at the proposed lower altitudes of 340-
360 km. Please include modeled antenna patterns with this analysis.
Please submit the requested information by July 8, 2024.
Sincerely,
Merissa L. Velez
Merissa L. Velez
Chief, Satellite Programs and Policy Division
Space Bureau
17
See SpaceX Direct-to-Cell Modification Amendment, Schedule S at 3.
18
See ICFS File No. SAT-MOD-20230207-00021, Technical Narrative at 13-14 (mentioning ITU filings
contemplating use of frequencies from 1429 MHz to 2690 MHz).
19
Id. at 20, 35.
