December 30, 2022

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

Re: SpaceX Annual Report re Optical Astronomy

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

Dear Ms. Dortch:

Pursuant to paragraph 135gg of the authorization for its second-generation (“Gen2”) non-
geostationary orbit (“NGSO”) satellite system issued on December 1, 2022, 1 Space Exploration
Holdings, LLC (“SpaceX”) provides the following initial annual report on its efforts to mitigate
the potential impact of its Gen2 satellites on optical ground-based astronomy. Although SpaceX
has only just begun to deploy its first Gen2 satellites, it has already invested significant time and
resources, in cooperation with the astronomy community, to identify the main sources of satellite
reflectivity and to develop strategies and technologies that can reduce the potential for NGSO
satellites to affect optical astronomy. SpaceX appreciates this opportunity to update the
Commission and the public about its efforts.

SpaceX values astronomical observation for pursuits ranging from scientific exploration to
the simple pleasure of enjoying a beautiful starry night, which is why it has made significant
investments to ensure its satellites are effectively invisible to the naked eye at their standard
operational altitude. SpaceX has specifically designed the Gen2 satellites and their on-orbit
operations to minimize the extent to which they reflect sunlight toward observers on Earth. For
example, SpaceX has:

 Designed its Gen2 satellites to accommodate a 25-percent power generation reduction

so that they can off-point solar arrays as the satellite crosses Earth’s terminator to
minimize sunlight reflected toward Earth;

 Developed a next-generation dielectric mirror film for the bottom of Gen2 satellites
that is an order of magnitude better at reducing observed brightness than the first-
generation film used on earlier satellites;

 Developed an opaque pigmented backsheet for the solar arrays that prevents light
transmission without overheating the solar cells;

1
See Space Exploration Holdings, LLC, FCC 22-91, ¶ 135gg (rel. Dec. 1, 2022).

1155 F St NW, Suite 475, Washington, DC 20004 | phone 202.649.2700 | fax 202.649.2701 | spacex.com
Marlene H. Dortch
December 30, 2022
Page 2 of 3

 Developed two different types of space-stable black paint to use (one of which is
believed to be the least reflective space-stable black paint ever developed) for surfaces
not covered by the dielectric mirror film;

 Developed analysis to predict brightness based on satellite design, with techniques

corroborated by targeted observations which SpaceX has undertaken with third parties;

 Invested resources into material development focused solely on brightness mitigations,

which has yielded improved, specular thermal stickers that can reduce satellite
brightness by orders of magnitude (with the initial generation of this material on
satellites currently in-orbit); and

 Offered the dielectric mirror film and black paint at cost to other companies, even our
competitors.

In addition to all of these innovations, to mitigate brightness during orbit raising, SpaceX
satellites may also use an “open book” attitude for some Gen2 form factors, such that satellites
will roll about the velocity vector to present the minimal surface area possible toward the sun.
While SpaceX uses these strategies today, it continues to refine them and to seek out new ones that
can help reduce the effect of Gen2 satellites on astronomical observations. Over time, SpaceX
may change its approach or hardware to further address satellite reflectivity based on its real-world
experience flying the Gen2 satellites and continued collaboration with the astronomy community.

Furthermore, SpaceX continues to seek such solutions with the assistance of the astronomy
community, including the National Science Foundation. SpaceX has greatly benefited from the
discussions and expects that they will bear fruit in the very near future. SpaceX will also publish
very accurate state predictions for its Gen2 satellites, which can be used by operators of highly
sensitive ground telescopes to best schedule observations at times least likely to be affected by
Gen2 satellites.

But SpaceX reiterates that it cannot address these issues alone and without non-U.S. firms
participating; no operator, and indeed no country, can do so. SpaceX therefore pleads once again
for other operators—including those that have chosen to license their satellites outside the U.S.
and claim not to be bound by U.S. rules yet want to offer services here—to join in the effort to
mitigate the impact of their satellites on optical astronomy. Only with all operators working
together and cooperating with the astronomy community can we hope to preserve opportunities
for optical astronomy even as satellites make productive use of valuable spectrum and orbital
resources.
Marlene H. Dortch
December 30, 2022
Page 3 of 3

If you have any questions, please do not hesitate to direct them to me.

Sincerely,

/s/ David Goldman

David Goldman
Senior Director of Satellite Policy

SPACE EXPLORATION TECHNOLOGIES CORP.

1155 F Street, NW
Suite 475
Washington, DC 20004
Email: David.Goldman@spacex.com

cc: Karl Kensinger