December 14, 2022

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

Re: IBFS File No. SAT-MOD-20211207-00186

Dear Ms. Dortch:

Amazon unfortunately continues to disregard established safe operational practices, relying

instead only on lower-cost alternatives and vague promises to paper over its shortcomings.
Troublingly, in its most recent letter, 1 Amazon fails to substantively address any of SpaceX’s
previously stated concerns with Amazon’s high-risk elliptical deorbit plans. Indeed, while the
letter promises that Amazon will limit conjunction risk while deorbiting and will cooperate with
other operators, it provides no technical detail to substantiate whether and how it will keep its
promise. The Commission must seek more information and further commitments from Amazon
before it can process its modification.

I. Amazon Must Substantiate Whether and How It Can Safely Conduct its High-Risk
Elliptical Deorbit Strategy

In its letter, Amazon misleadingly claims that an elliptical deorbit is faster than a circular
deorbit and incorrectly concludes that a faster deorbit would necessarily result in a safer deorbit. 2
As an initial matter, operators such as Amazon that rely on drag to conduct an elliptical deorbit
will not necessarily deorbit faster than operators such as SpaceX that conduct a controlled, circular
deorbit, calling into question the fundamental premise of Amazon’s argument. Further, collision
risk during deorbit is not simply a function of how long it takes to deorbit, but also depends upon
the prediction quality while deorbiting. Blindly careening through another constellation quickly
and creating less predictable conjunction events is highly unlikely to be safer than descending
through that constellation in a slow, controlled, and predictable manner. By analogy, a car
speeding through stop signs may make it out of a city faster, but it would spike the risk to everyone
around it. Tellingly, to defend its position, Amazon must rely on a paper that is 15 years old. 3
Yet, this paper is outdated at best, considering best practices have evolved substantially over the
past decade-and-a-half, with the development of low-Earth orbit operations and the impact of anti-
satellite demonstrations, which together have created a heightened need for controlled, predictable
deorbit strategies.

1
See Letter from Carrie Gage to Marlene Dortch, SAT-MOD-20211207-00186 (Nov. 23, 2022) (“Amazon
Letter”).
2
See id. at 2.
3
See id. at 2 n.9.

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Marlene H. Dortch
December 13, 2022
Page 2 of 3

Amazon also claims—without basis or experience—that its risky deorbit strategy is less of
a burden to other operators. 4 But Amazon has not yet transferred any satellites through an
operational constellation. Tellingly, Amazon provides no support for its assertion from direct
experience, analysis, or other peer-reviewed papers. In contrast, SpaceX has extensive experience
coordinating with other operators whose satellites transfer through its main constellation—in a
circular manner—and these operators have not added a significant burden to SpaceX’s operations.

To be clear, SpaceX has never claimed that a responsible operator could not safely
implement an elliptical deorbit strategy. Instead, SpaceX has pointed out that such a strategy must
be supported, at the very least, with rigorous technical analysis, proof of sufficient prediction
accuracy for collision avoidance, an assumption of maneuver responsibility, sufficient fuel to
retain full control over satellites until the entire deorbit altitude (i.e., apogee and perigee) falls
completely below other active satellites and human spaceflight systems, and a commitment not to
begin an elliptical deorbit until the apogee of the satellite has descended below the operational
altitudes of other constellations. Together, these steps would help substantiate that elliptically
deorbiting satellites such as Amazon’s will not impose an unreasonable space sustainability burden
on constellations through which they pass.

Unfortunately, Amazon refuses to commit to even these basic measures and its letter
simply doubles down on prior claims, raising new concerns that it in fact has no plan to mitigate
the risks of its strategy. The Commission must seek further information and commitments from
Amazon to resolve these significant outstanding issues before processing its modification.

II. Amazon Must Provide Additional Information to Demonstrate that It Can Effectively
Coordinate and Accurately Predict the Future Positions of Its Own Satellites

Rather than provide technical information about how it intends to mitigate the risks of the
constellation it hopes one day to deploy, Amazon once again relies on its proposed panacea for all
its ills—its supposed superior ability to coordinate. Yet, as SpaceX has pointed out in the past,
Amazon has never demonstrated such coordination skills (or desire), instead repeatedly demanding
that the Commission restrict its competitors’ operations to make way for Amazon’s own
constellation. For example, in response to Amazon’s claims that its system is too fragile to handle
the remote possibility of overlapping with a small number of SpaceX satellites, SpaceX is the one
that offered to condition its own license on operating at lower altitudes. 5 And even in this case,
Amazon has only belatedly accepted SpaceX’s offers to physically coordinate, opting instead to
first race to the Commission.

More broadly, for Amazon to meaningfully respond to collision risks, it must be able to
accurately predict the future positions of its own satellites. While Amazon asserts it will share

4
Id. at 3.
5
See Letter from David Goldman to Marlene H. Dortch, IBFS File No. SAT-MOD-20200417-00037, at 8 (Apr.
15, 2021).

1155 F St NW, Suite 475, Washington, DC 20004 | phone 202.649.2700 | fax 202.649.2701 | spacex.com
Marlene H. Dortch
December 13, 2022
Page 3 of 3

location information with other operators, 6 that sharing does not decrease risk if the data is not
accurate enough for collision avoidance. SpaceX therefore urges Amazon to provide the
Commission the following information, at minimum:

• how it plans to achieve good prediction accuracy and covariance realism, with
sufficient data to substantiate its claims;
• what time horizon it plans to use for collision avoidance;
• estimates indicating the prediction accuracy it can achieve on that time horizon,
given the variability seen in space weather that precipitates drag misestimation;
• how long it would take for Amazon’s satellites to transit through other operators,
both when orbit-raising and when deorbiting (using a circular deorbit strategy or
its planned high-risk elliptical deorbit strategy); and
• whether it has a backup plan in case it is not able to achieve its promised level of
prediction accuracy.

With sufficient investment in satellites and tracking technology, Amazon may be able to
operate its satellites safely, but its latest letter fails to substantiate Amazon’s vague assertions and
promises, and instead raises fresh questions about Amazon’s commitment to space sustainability.
The Commission cannot approve Amazon’s modification until it is satisfied that Amazon has taken
the steps outlined above to ensure sustainable orbits and assume appropriate responsibility for its
operations.

Sincerely,

/s/ David Goldman

David Goldman
Senior Director, Satellite Policy

SPACE EXPLORATION TECHNOLOGIES CORP.

1155 F Street, NW
Suite 475
Washington, DC 20004
Tel: 202-649-2691
Email: David.Goldman@spacex.com

6
See Amazon Letter at 3.

1155 F St NW, Suite 475, Washington, DC 20004 | phone 202.649.2700 | fax 202.649.2701 | spacex.com