August 19, 2022

BY ELECTRONIC FILING
Marlene H. Dortch
Secretary
Federal Communications Commission
45 L Street, N.E.
Washington, DC 20554

Re: IBFS File Nos. SAT-LOA-20200526-00055 and SAT-AMD-20210818-00105

Dear Ms. Dortch:

SpaceX is committed to the sustainable, responsible, and efficient use of space and
spectrum resources to drive rapid deployment of high-speed, low-latency broadband service to
consumers across the country, wherever they are. SpaceX has invested in technologies,
techniques, and collaborations to ensure that its second-generation (“Gen2”) system is both the
most advanced and the most responsible non-geostationary orbit (“NGSO”) satellite constellation
in operation. SpaceX not only complies with all applicable Commission and ITU rules, but
exceeds industry best practices and regularly provides public updates on its progress and
innovations. In the spirit of transparency and in response to specific requests from Commission
staff, SpaceX submits the following information to facilitate expeditious authorization and
deployment of the Gen2 constellation to benefit American consumers and businesses as quickly
as possible.

I. SPACEX MEETS OR EXCEEDS ALL APPLICABLE SPACE SUSTAINABILITY RULES

As SpaceX noted in its application and Consolidated Response, the Gen2 system complies
with all applicable orbital debris mitigation rules, including not-yet-effective rules that the
Commission adopted in the Orbital Debris Update Order. 1

A. The Gen2 System Complies with the Commission’s Collision Probability Thresholds

In its applications and supplemental submissions, SpaceX has provided significant

technical information about its Gen2 system and spacecraft. This information already complies
with and often exceeds the requirements for NGSO satellite applicants under Part 25, which the
Commission has determined is sufficient to support licensing the deployment and operation of
NGSO satellites. 2 As a part of these submissions, SpaceX has provided the results of an analysis
1
See Consolidated Opposition to Petitions and Response to Comments of Space Exploration Holdings, LLC, IBFS
File Nos. SAT-LOA-20200526-00055 and SAT-AMD-20210818-00105, at 4-21 (Feb. 24, 2022) (“SpaceX
Consolidated Response”) (discussing Mitigation of Orbital Debris in the New Space Age, 35 FCC Rcd. 4156, ¶¶
15-19 (2020) (“Orbital Debris Update Order”)).
2
See 47 C.F.R. § 25.110(b)(2) (launch and operation of a space station requires the filing of an application
containing the information specified in Section 25.114); id. § 25.114 (describing the information required in a
space station application).
Marlene H. Dortch
August 19, 2022
Page 2 of 10

using NASA’s Debris Assessment Software (“DAS”), demonstrating that the Gen2 system—even
with conservative assumptions about the size and mass of its satellites—will comply with the
Commission’s per-satellite collision risk thresholds. 3

In the Orbital Debris Update Order, the Commission found (consistent with NASA’s
expert judgment) that systems with maneuverable satellites warranted an assumption of zero
collision risk 4—an assumption the Commission has also found applicable to SpaceX’s first-
generation NGSO system. 5 Yet to give the Commission a more complete picture of the very low
collision risks over a satellite’s orbital lifetime, SpaceX recently voluntarily updated its DAS
analyses using a recently released version of NASA’s DAS tool (version 3.2.1). In that analysis,
SpaceX used conservative mass and area inputs to demonstrate that the Gen2 system will easily
meet or beat NASA standards and Commission rules. 6 Since that time, NASA has updated DAS
yet again, now in version 3.2.2. In the interest of providing the Commission with the most up-to-
date results, SpaceX once again voluntarily provides an updated analysis, incorporating even more
conservatism to demonstrate the inherent low collision risk of its Gen2 system.

DAS 3.2.2 Gen2 Analysis

Decay Large Object
Altitude
Inclination Time Passive Decay
(km)
(years) Collision Probability
535 33 1.66 6.56E-04
530 43 1.57 5.78E-04
525 53 1.47 5.59E-04
360 96.9 0.07 1.17E-03 7
350 38 0.05 6.98E-05
345 46 0.05 7.03E-05
340 53 0.04 6.94E-05
604 148 3.86 1.82E-03
614 115.7 3.24 2.50E-03

3
See, e.g., Letter from Jameson Dempsey to Marlene H. Dortch, IBFS File Nos. SAT-LOA-20200526-00055 and
SAT-AMD-20210818-00105 (July 28, 2022) (“SpaceX July Letter”) (attaching updated DAS 3.2.1 analysis).
4
See Orbital Debris Update Order ¶ 35 & n.102.
5
See Space Exploration Holdings, LLC, 36 FCC Rcd. 7995, ¶ 58 (2021) (“SpaceX 2021 Authorization”).
6
See SpaceX July Letter at 1 n.2.
7
As SpaceX noted in its July letter, the higher collision probability at this low altitude and high inclination results
from the Russian ASAT demonstration, which has caused a large increase in debris flux in DAS at lower altitudes,
with a disproportionate impact on polar orbits. See id. at 1. Fortunately, even in the short time since that
demonstration, more than half of the resulting debris has already deorbited, due to the higher atmospheric drag at
these self-cleaning low altitudes. Further, SpaceX does not anticipate deploying at this altitude and inclination
until it has completed its 500-kilometer shells, likely long after the remnants of the Russian ASAT demonstration
have deorbited. As such, the true large object collision probability for SpaceX’s operations in this orbital shell
will be significantly lower than today’s version of DAS reflects.
Marlene H. Dortch
August 19, 2022
Page 3 of 10

This analysis assumes physical parameters significantly larger than satellites currently planned
within the Gen2 system and demonstrates that such satellites will comply with both applicable and
not-yet-effective collision probability thresholds.

Despite SpaceX’s extensive good faith efforts, Viasat—an operator that has argued it
should not be subject to the Commission’s orbital debris rules because it chose to license its
systems outside the U.S.—has once again cited an inapposite provision related to replacement
satellites to demand the Commission force SpaceX, a U.S. licensee, to provide information about
its space stations not required by U.S. rules. 8 As SpaceX has previously noted, that rule does not
require submission of any information—a conclusion the Commission confirmed in rejecting
Viasat’s previous demand for the exact same information on the exact same grounds with respect
to SpaceX’s last satellite application. 9 Viasat has provided no change in law that would justify the
full reversal of Commission precedent that it now seeks. Indeed, the Commission wisely deleted
the requirement to provide such information nearly a decade ago, finding it to be “redundant or
unnecessary” 10—a reform Viasat praised as “a significant step in the right direction to reduce the
amount of information applicants are required to provide.” 11 The Commission was correct—not
only is this information unnecessary, it would quickly become outdated. As technology develops
or supply chain issues arise, satellite operators may be required to change certain components on
their satellites that do not change in any way the technical parameters of the satellites, but could
affect the mass, dimensions, or other unrelated details of the satellites. Anticipating that such
alterations will be necessary, the Commission correctly concluded that each satellite “need not . .
. have the identical physical structure or microelectronics.” 12 Any other conclusion would not just
inhibit innovation, but risk grinding satellite production to a standstill.

In fact, to accommodate these types of potential changes and innovations, SpaceX took an
overly conservative approach in performing its DAS analysis, assuming physical structures beyond
SpaceX’s current satellite design. As SpaceX’s CEO explained in recent public statements,
SpaceX plans to launch satellites on Starship that are approximately 1250 kg and seven meters
long. 13 But to further demonstrate the inherently low risk of SpaceX’s Gen2 satellites, the DAS
analysis provided here assumed a larger satellite with a total mass of 2000 kg and an area of 294
square meters (i.e., an area-to-mass ratio of 0.147). In addition to assuming this larger size, SpaceX
added more conservatism by assuming the satellite was tumbling and by averaging the large object
passive decay collision probability over 11 years starting in 2022 to capture the entire solar cycle,

8
See 47 C.F.R. § 25.113(i).
9
SpaceX 2021 Authorization ¶ 28.
10
See Comprehensive Review of Licensing and Operating Rules for Satellite Services, 28 FCC Rcd. 12403, ¶ 89
(2013).
11
Letter from Elizabeth R. Park to Marlene H. Dortch, GN Docket No. 14-25 and IB Docket No. 12-267, at 1 (Aug.
8, 2014).
12
See Amendment of the Commission’s Rules to Establish Rules and Policies Pertaining to a Mobile Satellite
Service in the 1610-1626.5/2483.5-2500 MHz Frequency Bands, 9 FCC Rcd. 5936, ¶ 182 n.250 (1994) (noting
that “technically identical” satellites “need not . . . have the identical physical structure or microelectronics.”);
see also 47 C.F.R. § 25.114(a)(2) (describing a “technically identical” space station “type” on the basis of required
information submitted pursuant to Sections 25.114(c) and (d) of the Commission’s rules).
13
See SpaceX July Letter at 1 & n.2.
Marlene H. Dortch
August 19, 2022
Page 4 of 10

as opposed to the approach taken by some of selecting only the most favorable year to run their
DAS analysis or omitting hundreds-to-thousands of years of decay time. Importantly, even if
SpaceX calculated its large-object collision risk using the worst-case year over the last 11 years,
the per-satellite collision risk for a Gen2 satellite would still fall well within Commission
thresholds.

As another example, SpaceX is proud to inform the Commission that it has decided to
further accelerate its already record-breaking deployment schedule for its Gen2 system by using
both its new Starship vehicle as well as its tested and dependable Falcon 9. While SpaceX will
use technically identical satellites on both rockets, the physical structures will be tailored to meet
the physical dimensions of the rockets on which they will be launched. In no event will any
satellite exceed the overly conservative DAS analysis SpaceX provided to the Commission. To
be clear, while SpaceX plans to accelerate deployment by using both of the rockets in its fleet, it
remains committed to deploying all of its satellites—whether from Starship or from Falcon 9—
into orbits described in Configuration 1 as described in its Amendment from August 2021 and
confirmed in its letter to the Commission in January of this year. Specifically, SpaceX plans to
launch satellites for its Gen2 constellation beginning with its three 500-kilometer shells, followed
by satellites in its lower-altitude shells. The result will be that more Americans will receive high-
quality broadband faster.

B. SpaceX Strives to Lead the Industry in Responsible Operations in Space

SpaceX has designed the satellites and collision avoidance concept of operations for its
Gen2 constellation to provide sufficient flexibility to promote space sustainability throughout the
lifecycle of the system. As an initial matter, SpaceX plans to deploy its satellites into its Gen2
constellation at low altitude to confirm that each one is operating nominally before moving the
satellite to its operational altitude. 14 During transit and once at its operational altitude, SpaceX
generally will take maneuver responsibility for potential conjunctions with other operators,
including when addressing potential conjunctions in overlapping and adjacent orbits. Importantly,
however, in some circumstances other operators are in a better position than SpaceX to take
maneuver responsibility, such as when an operator slowly transits through SpaceX’s shells using
electric propulsion. In those cases, SpaceX has urged those operators to assume responsibility for
maneuvering. In all events, SpaceX will continue to actively coordinate with operators with
satellites near or transiting through its operational shells.

Moreover, while SpaceX designed the satellites for the Gen2 constellation to operate at the
altitudes specified in the application, it has requested an orbital tolerance of +70/-50 kilometers,
which helps provide necessary flexibility to protect against large increases or decreases in
atmospheric drag due excursions in solar cycle predictions. This orbital tolerance will allow the
satellites in the Gen2 constellation to retain their operational life in periods of high drag and
maintain low passive decay times in the highly unlikely event that a satellite becomes non-
maneuverable. In both cases, SpaceX will deconflict with its Gen1 constellation. SpaceX will

14
See SpaceX January Letter at 5. In any event, SpaceX will not deploy its Gen 2 satellites at the operational
altitudes above 500 km without first ensuring sufficient post-deployment reliability.
Marlene H. Dortch
August 19, 2022
Page 5 of 10

also continue to take maneuver responsibility based on its highly sensitive maneuver triggers to
avoid collisions both with satellites from other operators and with manned spacecraft.

SpaceX also actively collaborates with NASA pursuant to a Space Act Agreement to
promote space sustainability and the efficient use of orbital resources, consistent with our shared
mission and values. SpaceX and NASA conduct frequent, recurring meetings to share information,
present analysis results, and continually improve operations for mutual benefit. Among other
issues, SpaceX and NASA regularly engage on the scaling of the SpaceX autonomous collision
avoidance system; coordination between the International Space Station (“ISS”) and satellites in
the Gen2 constellation operating at altitudes below the ISS; and how to improve interoperability
between multiple autonomous satellite systems. This strong working relationship continues to
provide NASA with insights to ensure its on-orbit assets remain safe when sharing space with
responsibly managed large constellations. Throughout SpaceX’s collaboration with NASA on the
Gen2 system, neither SpaceX nor NASA has identified any risks that cannot be mitigated through
their continued, bilateral partnership. Indeed, NASA has expressed in its submissions in this
proceeding its appreciation for those ongoing collaborative efforts “which should continue to
facilitate safe operations in space and result in mutual success.” 15

Finally, SpaceX’s proven autonomous collision avoidance system is highly reliable and
consistent with the Commission’s rule to assume zero-collision risk for maneuverable satellites.
SpaceX has invested in developing a system with redundant safeguards that maintains safe
operations for all of its satellites. First, the system exports high-fidelity propagations based on
satellite Global Navigation Satellite System ephemeris, which are extremely accurate and reliable.
Second, SpaceX gets its data for conjunction screening from two independent providers and
frequently updates this information to SpaceX satellites. Collecting data from separate sources
allows for independent state confirmation and situational awareness, even in the event that a single
provider experiences an interruption for any reason. Third, SpaceX’s software has extensive fail-
safes and back-up protocols to ensure uninterrupted operation. Indeed, SpaceX’s Gen1 system,
which also relies on SpaceX’s autonomous collision avoidance system, has been able to seamlessly
accommodate a large increase in debris flux that resulted from the Russian COSMOS 1408 ASAT
demonstration.

II. SPACEX COMPLIES WITH ALL APPLICABLE INTERFERENCE REQUIREMENTS

The Gen2 constellation will rely on both radiofrequency spectrum and optical links to drive
even better quality next-generation satellite broadband to more consumers and businesses
throughout the country while complying with all applicable interference requirements. SpaceX’s
optical links will connect satellites using continuous optical waves with a wavelength of 1550 nm16

15
See Letter from Samantha Fonder to Marlene Dortch, IBFS File No. SAT-AMD-20210818-00105, at 1 (Mar. 8,
2022), attached to Letter from Kathy Smith to Marlene Dortch, IBFS File No. SAT-AMD-20210818-00105 (Mar.
10, 2022).
16
The Commission has recognized that such wavelengths fall outside its jurisdiction. See, e.g., Teledesic LLC, 14
FCC Rcd. 2261, ¶ 14 (Int’l Bur. 1999) (“Because optical ISLs do not involve wire or radio frequency
transmissions, the Commission does not have jurisdiction over the use of optical ISLs.”).
Marlene H. Dortch
August 19, 2022
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operating at ~3W output power. In addition, some of the satellites in the Gen2 constellation will
host a small radiofrequency beacon for use only in emergency communications during orbit raise.17

The Gen2 system will use 25-degree minimum elevation angles outside of polar regions,
which will minimize the risk of interference to co-primary users. Above 62-degrees latitude,
SpaceX will observe a five-degree minimum elevation angle for gateways, as well as for user
terminals communicating with satellites located in the two highest altitude orbital shells.

The Gen2 system will also comply with Article 22 of the ITU’s Radio Regulations,
including equivalent power flux-density (“EPFD”) limits, which were designed decades ago as an
overly conservative means to protect geostationary orbit (“GSO”) satellites from interference. The
Commission adopted these limits to “harmonize [its] rules with international regulations and
provide greater certainty for NGSO FSS operators.” 18 Section 25.146 of the Commission’s rules
establishes a two-step process for compliance with the ITU’s EPFD limits: (1) an NGSO satellite
operator certifies it will comply with these limits; and (2) the operator subsequently confirms its
compliance by obtaining a “favorable” or “qualified favorable” finding from the ITU
Radiocommunication Bureau. 19 By relying on the ITU for this compliance determination, the
Commission sought to ensure “that the validation test used domestically is the same as that used
by the ITU-BR and other Administrations,” which has the added benefit of “provid[ing]
consistency in the output of the validation test and enabl[ing] these results to be reproduced by all
affected Administrations.” 20 The Commission has made clear, however, that its compliance
process does not include any separate compliance review by the Commission or its staff. 21

As required by Step 1 of Section 25.146, SpaceX certified that its Gen2 system will comply
with applicable EPFD limits. 22 In support of its application, in response to ITU staff guidance,
and consistent with well-established industry practice, SpaceX submitted multiple filings to the
ITU for its Gen2 constellation to address a well-recognized flaw in the ITU methodology for
determining compliance with downlink PFD limits in portions of the Ka-band. SpaceX voluntarily
provided to all requesting parties the underlying data files that can be used with the ITU-approved
software to validate SpaceX’s compliance. SpaceX also provided the outputs obtained by a
straightforward application of the ITU software to the SpaceX data files, confirming that the Gen2
system will comply with all applicable limits. 23 In the context of the Gen1 system, the Commission
found SpaceX’s similar actions (1) resolved questions about EPFD compliance and (2) supported

17
These beacons are an independent hosted payload licensed through the German administration. They are
specifically geofenced to ensure they will not operate in the U.S. SpaceX has rerun the DAS analysis to account
for these beacons, and they do not change the already conservative analysis provided to the Commission. These
beacons all are self-powered and do not rely on the electrical components of the rest of the satellite.
18
Update to Parts 2 and 25 Concerning Non-Geostationary, Fixed-Satellite Service Systems and Related Matters,
32 FCC Rcd. 7809, ¶ 35 (2017) (“NGSO Update Order”).
19
47 C.F.R. §§ 25.146(a)(2), (c).
20
Amendment of Parts 2 and 25 of the Commission’s Rules to Permit Operation of NGSO FSS Systems Co-
Frequency with GSO and Terrestrial Systems in the Ku-Band Frequency Range, 16 FCC Rcd. 4096, ¶ 89 (2000).
21
NGSO Update Order ¶ 41.
22
See Amendment, IBFS File No. SAT-AMD-20210818-00105, Technical Attachment at 14 (Aug. 18, 2021).
23
See SpaceX Consolidated Response, Exhibit 1.
Marlene H. Dortch
August 19, 2022
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a waiver of Step 2 of the Commission’s process to allow deployment at SpaceX’s own risk in
advance of the ITU’s compliance finding. 24

Despite SpaceX following the Commission’s approved compliance process for its Gen2
system, certain competitors have called for the Commission to reject its own rules and the accepted
ITU process by imposing special burdens on SpaceX. 25 They argue that the Commission should
ignore the data filed with the ITU and instead combine multiple ITU filings into a single data set
for evaluation. To reiterate, ITU staff specifically advised SpaceX in the past to submit its data
through multiple files, and as SES/O3b has observed, the ITU has no process for considering
multiple EPFD filings on a combined basis: “[c]urrent ITU regulations require an evaluation of
EPFD compliance for each ITU filing related to an NGSO system, but not for the NGSO system
as a whole if the system relies on multiple ITU filings.” 26 While the Commission has made clear
that its policy is to rely on the ITU for EPFD compliance determinations per Section 25.146, these
competitors have urged the Commission to conduct its own analysis on a combined basis that is
inconsistent with the ITU’s EPFD compliance methodology.

The Commission has already ruled on this very issue in the context of authorizing SpaceX’s
modified Gen1 system and must similarly reject these competitors’ efforts here. There, the
Commission confirmed that its policy is to defer to the ITU’s EPFD findings—and even to do so
prospectively, granting SpaceX a waiver to allow immediate deployment while the ITU conducts
its EPFD analysis.

Given the condition in SpaceX’s license, as modified, requiring that SpaceX receive
the “favorable” or “qualified favorable” finding from the ITU, and in the case of an
unfavorable finding, adjust its operations to satisfy the ITU requirements, we agree
that SpaceX has “every incentive” to ensure that its EPFD analysis has been
performed properly – and we also conclude that the ITU is in the best position to
determine whether SpaceX appropriately relied on multiple ITU filings in its
analysis. Therefore, we do not see the need to further address the parties’ claims
with respect to aggregation of “single entry” values from separate ITU filings, or
to condition the grant as Hughes requests. 27

The Commission issued this ruling almost a year after SpaceX filed its Gen2 application, and more
than a year and a half after the Commission had submitted the associated network filings to the
ITU. 28 Presumably the Commission was aware of its ruling’s applicability to the pending Gen2
system and the files the Commission itself submitted to the ITU.

24
See Space Exploration Holdings, LLC, 34 FCC Rcd. 2526, ¶ 28 (IB 2019).
25
See, e.g., SpaceX Consolidated Response at 22-30.
26
Comments of SES Americom and O3b Limited, IBFS File Nos. SAT-MOD-20210806-00095 and SAT-MOD-
20200417-00037, at 4 (Sep. 20, 2021).
27
SpaceX 2021 Authorization ¶ 34 (emphasis added; footnote omitted).
28
The ITU filings for the Gen2 system were submitted on October 7, 2019.
Marlene H. Dortch
August 19, 2022
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As the Commission recognized when considering this issue for SpaceX’s Gen1 system,
SpaceX has a strong incentive to ensure that its EPFD analysis for the Gen2 system conforms to
ITU requirements, because under a waiver by the Commission, SpaceX must deploy at its own
risk and change its operations should the ITU not render a favorable finding. Here, SpaceX’s
competitors have provided no basis for the Commission to deviate from this unanimous
Commission decision made just last year, either by requiring an aggregation of multiple ITU filings
or by denying a waiver of the ITU finding prior to authorizing SpaceX to commence system
deployment.

Beyond conflicting with Commission precedent, these competitors’ suggestions on EPFD

limits would not serve the public interest. For example, ITU Working Party 4A is currently
considering a number of refinements to the ITU’s EPFD methodology, and that multinational
forum, not SpaceX’s Gen2 application proceeding, is the appropriate venue to propose a new
international consensus that can then be applied consistently across all NGSO systems. Were the
Commission to depart unilaterally from the ITU’s current approach to determining EPFD
compliance, the United States would become an outlier and the resulting uncertainty would put
U.S. operators at a disadvantage that would provide yet more incentive for NGSO satellite
operators to seek authorization from foreign administrations instead. Moreover, because the ITU
has no established procedure for evaluating multiple EPFD data sets as these competitors suggest,
this new approach would invite interested parties to present their own bespoke, self-serving
analyses and thereby force the Commission to devote the personnel and time necessary to choose
among the submissions—precisely an outcome it sought to avoid by relying on the ITU. 29

It is well understood that the EPFD rules are overly protective of GSOs and in fact
unnecessarily harm consumers who depend on NGSOs for their broadband service. 30 For example,
EPFD rules require NGSOs to operate at lower power even when no GSO receiver is in the vicinity,
meaning NGSO customers receive diminished service with no offsetting benefit. Similarly, EPFD
worst-case calculations assume that steerable beams, which are actually designed to limit
interference with others, will instead be used to maximize interference between systems. The
EPFD calculation also assumes an unrealistic and overly conservative GSO earth station antenna
pattern mask. Once again, this unrealistic calculation leads to diminished service to NGSO
customers with no resulting benefit. Given how skewed the EPFD rules are in favor of GSOs to
the detriment of those who rely on NGSOs, if the Commission were to deviate from the established
ITU approach to EPFD, it should roll back these harms to American consumers rather than add to
them.

The Commission must similarly reject the unprecedented demands to assess EPFD
compliance on the basis of combining SpaceX’s distinct Gen1 and Gen2 constellations, as if they
were one, while in all other regards the Commission treats these as separate systems. Such an
approach would not only be inconsistent with the methodology that the ITU uses to assess EPFD
compliance (as discussed above), but it would also be inconsistent with the Commission’s own

29
See NGSO Update Order ¶ 41 (“[T]he Commission has found that, due to staffing constraints and technical
complexity, its review of EPFD demonstrations typically takes a few months.”).
30
See, e.g., SpaceX Consolidated Response, Exhibit 2 (discussing bias favoring GSO systems in EPFD limits).
Marlene H. Dortch
August 19, 2022
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licensing concepts and processes in a way that unnecessarily harms American consumers. Unlike
other NGSO operators, SpaceX did not file its Gen2 application as a modification of its Gen1
authorization. Rather, it sought an entirely new license in the 2020 Processing Round for its new
constellation of satellites with different characteristics than its previous constellation. As a result,
SpaceX has not asked for the benefits of having any part of its Gen2 constellation considered as
part of the 2016 Processing Round. Nor has it claimed that any of its Gen2 system should be
afforded the spectrum priority that attaches to the earlier-round systems. As a result, satellites in
each system will be required to operate differently to reflect the different spectrum rules applied
to each processing round.

In addition, the two systems will have different call signs, have separate bond and
milestone requirements, and be subject to separate annual regulatory fees. Indeed, in every aspect
of its regulation of these systems, the Commission will treat them as separate and distinct.
Moreover, applying EPFD to a legal entity rather than a specific operating system could lead to
nonsensical results. For example, if two operators licensed to operate separate NGSO systems
were to merge, each one of their systems could potentially become noncompliant with the newly
suggested EPFD standard applied to the combination of the two systems, not because of any
technical change or change in the interference environment, but simply because the two systems
were now owned by a single legal entity. Neither Commission rules nor ITU rules justify applying
a single EPFD metric on an entity-by-entity basis.

Other SpaceX competitors have gone even further, asking the Commission to apply a single
variable used to calculate EPFD—Nco—to a legal entity, here SpaceX, as opposed to the ITU
filings that cited the variable. 31 In each EPFD data set submitted to the ITU for the Gen2 system,
SpaceX indicated Nco=1 for its Ku-band user beams. As explained above, the ITU requires EPFD
to be applied per filing. Nonetheless, just as SpaceX voluntarily committed to operate its Gen1
system using an Nco=1 for that system, SpaceX clarifies that it plans to operate using Nco=1 across
its Gen2 system such that the entire Gen2 system will only use one co-frequency Ku-band beam
(with Nco=1) to serve a given location at any given time, even though such operation is not
required by Commission or ITU rules.

Lastly, regarding avoidance angles with respect to the GSO arc, the Commission has wisely
refrained from enshrining specific parameters and has instead simply authorized NGSO systems
to operate up to the applicable EPFD limits. 32 For example, while SpaceX previously determined
that it could operate satellites in the Gen2 constellation within EPFD limits at full power while
observing a GSO avoidance angle of approximately 18 degrees, by reducing power as its satellites
approach the GSO arc, SpaceX can continue to operate at angles less than 10 degrees while still
complying with EPFD limits. Such innovative approaches maximize spectrum use without
increasing interference to other operators, and thus should be encouraged.

31
See, e.g., Letter from Jarett S. Taubman to Marlene H. Dortch, IBFS File Nos. SAT-LOA-20200526-00055 and
SAT-AMD-20210818-00105, at 2-3 (July 18, 2022). While parties in the record have referred to this concept as
“Nco,” the official term from the latest Recommendation ITU-R S.1503-3 is “MAX_CO_FREQ.”
32
See, e.g., SpaceX 2021 Authorization ¶ 97b, d, e, and l.
Marlene H. Dortch
August 19, 2022
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III. CONCLUSION

SpaceX has designed its Gen2 system to be the most capable satellite constellation ever
deployed for delivering high-capacity, low-latency broadband services, with spectral efficiency
and space sustainability at the forefront. With a complete record before it, the Commission should
swiftly grant the Gen2 application, enabling rapid deployment of next-generation satellite
broadband to American consumers and businesses, no matter where they are.

Sincerely,
/s/ David Goldman
David Goldman
Director, Satellite Policy

SPACE EXPLORATION TECHNOLOGIES CORP.

1155 F Street, NW
Suite 475
Washington, DC 20004
Tel: 202-649-2641
Email: David.Goldman@spacex.com