October 20, 2023

VIA ELECTRONIC FILING

Ms. Marlene H. Dortch, Secretary

Federal Communications Commission
45 L Street NE
Washington, DC 20554

Re: Notice of Ex Parte Presentation, GN Docket No. 23-135; ICFS File No. SAT-MOD-
20230207-00021

Dear Ms. Dortch:

On October 18, 2023, representatives of Omnispace, LLC 1 met with the Federal Communications
Commission staff 2 to discuss the above-referenced proceedings. The purpose of the Omnispace meeting
with the FCC was to address issues raised by SpaceX during meetings held with FCC staff on September
18, 2023, and reported in an ex parte letter on September 20, 2023. During the October 18 meeting,
Omnispace provided a presentation (attached) to demonstrate that in SpaceX’s recent ex parte
representations, SpaceX has not provided any data to refute Omnispace’s prior conclusions submitted to
the FCC, and its Starlink system will cause significantly more harmful interference to Omnispace than
originally analyzed. In fact, Omnispace and other MSS operators will incur orders of magnitude greater
interference than what SpaceX’s Mars-VLS ITU filing represents and in claims made to the FCC.
Therefore, the FCC should not permit SpaceX to use the 1990-1995 MHz band as a downlink in
contravention to the global uplink allocation.

Using the information in SpaceX’s September 20 ex parte, the interference from a single SpaceX satellite
will cause harmful interference to any S-band MSS satellite more than 17,000 km from SpaceX operations
over the United States. The interference from the 188 co-frequency SpaceX satellites in view will

1
Attending for Omnispace in person were Ram Viswanathan (Chief Executive Officer) and Mindel De La Torre (Chief
Regulatory and International Strategy Officer), and virtually were Amit Saluja (Chief Business Officer and General Counsel),
Jeff Snyder (Chief Technical Officer), Ron Olexa (Vice President for Terminal and RF Engineering), John Zukoski (Vice
President for Satellite Engineering), Lalji Ghedia (Vice President, Technical and Regulatory Affairs), Frank Patry (Chief
Information Officer) and Molly Gavin (Vice President of International Regulatory and Spectrum Policy).
2
Attending for the FCC’s Space Bureau in person were Jennifer Gilsenan, Whitney Lohmeyer, Jeanine Poltronieri, Stephanie
Neville, and Guillermo Belt, and virtually were Merissa Velez and Gregory Boren; attending for the FCC’s Wireless
Telecommunications Bureau in person were Jon Markman and Alice Koethe, and virtually were Roger Noel, John
Lockwood, Robert Pavlak, Kevin Holmes, Jessica Quinley, Kari Hicks, Melissa Conway, Kamran Etemad, and Halie Peacher
of the Wireless Telecommunications Bureau.

Omnispace, LLC
8255 Greensboro Drive, Suite 101, McLean, VA 22102
+1 (202) 930-7922 omnispace.com info@omnispace com
exacerbate the single satellite case by 22.7 dB (188 times more than a single satellite). This cumulative
level of interference would eliminate the possibility of providing any service as the desired signal has as
little as 4 dB C/N and would have to compete with an interferer 25 dB (316 times) stronger than the desired
signal.

According to the operating characteristics outlined in the SpaceX MARS-VLS ITU filing, a single SpaceX
satellite will raise the noise floor above acceptable levels over an entire hemisphere, as well as to harmful
interference levels at 5,400 km from the U.S. operations. Because Omnispace’s satellites are in constant
motion, as are SpaceX’s, the interference Omnispace will see will be constant and pervasive for any of
our satellites operating at distances 5,400 km from any U.S. territory where SpaceX is operating a single
satellite in its proposed SCS system. While a dynamic analysis is useful when an interference condition is
random and of limited impact, the interference condition in this case is so massive and pervasive that a
dynamic analysis brings nothing new to the table. Given the significant interference generated by a single
SpaceX satellite, it is more useful to describe an exclusion zone to show the area constantly affected by
harmful interference, as is shown in the attached presentation.

Additionally, with regard to terrestrial interference, based on SpaceX’s September 20 ex parte power flux
density numbers, Omnispace calculates that SpaceX exceeds the FCC market border and international
border limits of 47 dBuV/M by over 20 dB.

Given the additional information provided by SpaceX and Omnispace’s further calculations, Omnispace
believes SpaceX’s interference-free operation is unachievable in the real world and that the actual
interference levels from hundreds of visible satellites will cause sufficient interference to make the
Omnispace and other S-band MSS operator’s internationally authorized and coordinated use of the 1990-
1995 MHz spectrum impossible over large portions of the globe.

Please direct any questions regarding this matter to the undersigned.

Respectfully Submitted,

/s/ Mindel De La Torre

Mindel De La Torre
Chief Regulatory and International Strategy Officer
Omnispace, LLC

Attachment

Omnispace, LLC
8255 Greensboro Drive, Suite 101, McLean, VA 22102
+1 (202) 930-7922 omnispace com info@omnispace.com
Omnispace Response to SpaceX Ex Parte of
20 September 2023

In the Matter of Filings of SpaceX and T-Mobile

Requesting to Establish Supplemental Coverage from
Space

Space Exploration Holdings, LLC Application Accepted for

Filing (IBFS File No. SAT-MOD-20230207-00021)

October 18, 2023, Meeting at the FCC

 Introduction and summary
 Using SpaceX’s recent ex parte representations, the Starlink system will cause significantly more harmful interference to
Omnispace than originally analyzed. Omnispace and other MSS operators will incur orders of magnitude greater
interference than what SpaceX’s Mars-VLS ITU filing represents and in claims made to the FCC
 Using the information in SpaceX’s September 20 ex parte, the interference from a single SpaceX satellite will
cause harmful interference to any S-band MSS satellite more than 17,000 km from SpaceX operations over the
U.S.
 The interference from the 188 co-frequency SpaceX satellites in view will exacerbate the single satellite case by
22.7 dB (188 times more than a single satellite)
 This cumulative level of interference would eliminate the possibility of providing any service as the desired signal
has as little as 4 dB C/N and would have to compete with an interferer 25 dB (316 times) stronger than the desired
signal.
 Additionally, based on SpaceX’s September 20 ex parte power flux density numbers, Omnispace calculates that
SpaceX exceeds the FCC market border and international border limits of 47 dBuV/M by over 20 dB
 Given the recent information, Omnispace believes SpaceX’s interference-free operation is unachievable in the real world
and that the actual interference levels from hundreds of visible satellites will cause sufficient interference to make the
Omnispace and other S-band MSS operator’s use of the 1990-1995 MHz spectrum impossible over large portions of the
globe
 SpaceX has not provided any data to refute Omnispace’s prior conclusions submitted to the FCC, therefore the FCC
should not permit SpaceX to use the 1990-1995 MHz band as a downlink in contravention to the global uplink allocation

2 © Omnispace LLC 2023

Omnispace’s interference concerns have not yet been addressed
 Omnispace has raised interference concerns at various comment and reply
comment stages of the FCC’s NPRM on the Single Network Future:
Supplemental Coverage from Space and SpaceX/T-Mobile’s Application for
Modification of Authorization for the SpaceX Gen2 NGSO Satellite System to
Add a Direct-to-Cellular System
 Omnispace operates consistently with the ITU global allocations for MSS in the S-band
with its uplink in the 1990-1995 MHz band that SpaceX/T-Mobile have applied to use for
SCS in the downlink MSS mode, which will cause harmful interference to Omnispace
 Omnispace’s interference concerns have been supported by extensive technical analyses
 SpaceX’s most recent ex parte of September 20 provides no additional
information to the FCC to demonstrate that the “proposed operations will not
cause harmful interference to in-band, out-of-band, and cross-border users”
 In fact, the latest information from SpaceX causes even greater concern as to the actual
level of interference that will be generated
© Omnispace LLC 2023
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 Even using SpaceX’s unrealistic antenna performance, Omnispace has
shown that harmful interference will occur
 Throughout the history of this proceeding, SpaceX has used unrealistic antenna performance and
Omnispace has shown that those performance levels will still cause harmful interference
 Omnispace’s first analysis used performance parameters expected of the direct radiating arrays
(DRAs) required to provide a service such as that proposed by SpaceX:
 Each satellite must produce many spotbeams at many angles to create a coverage field of view
 30 dB side lobe attenuation was used in Omnispace’s original analysis
 SpaceX challenged this, stating they achieve -20 dBi gain in the sidelobes, which Omnispace and its
satellite manufacturing partners believe is unobtainable
 To give benefit of the doubt to SpaceX claims, Omnispace’s reply comments raised the sidelobe
attenuation to 38 dB resulting in 0 dBi sidelobe gain but it still showed harmful interference
 SpaceX’s ITU filing and their September 20 ex parte submission show that SpaceX’s earlier
representations are both highly exaggerated and inconsistent with their ITU filing data, as well as
their July 26 ex parte submission
 Using SpaceX’s ITU filing or September 20 ex parte antenna performance as the basis for
analysis shows significantly more interference than Omnispace originally calculated
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© Omnispace LLC 2023
 ITU-R Rec. M.1184 and SpaceX’s ITU filing show antenna sidelobe
attenuation to be far less than SpaceX’s claimed 58 dB

ITU-R Rec. M.1184

Table 4A shows sidelobe
attenuation of -20 dB
• Not a reference to -20
dBi, as SpaceX claims
• Actually a 20 dB
reduction referenced to
main lobe peak gain

Instead of operating
at -20 dBi gain in
sidelobes, the 38 dBi
gain antenna will have
a sidelobe gain of 18
dBi, far in excess of
SpaceX’s claims and
Omnispace’s earlier
conservative
assumptions
5 © Omnispace LLC 2023
 Space-to-space Interference from SpaceX satellites to
Omnispace Satellite(s)

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© Omnispace LLC 2023
SpaceX Mars-VLS filing antenna gain patterns
 SpaceX filing has Tx beams TBLS1 thru TBLS6 comprising two antenna types with
gain of 27.6 dBi and 34.8 dBi as shown below

TBLS1, TBLS2, TBLS3 TBLS4, TBLS5, TBLS6

Max Antenna Gain 1st sidelobe level 1st sidelobe suppression SpaceX 1st sidelobe suppression claim
(dBi) (dBi) dB dB
27.6 12.5 15.1 47.6
34.8 20.0 14.8 54.8

Using antenna with the above filed performance will generate

extreme levels of harmful interference into Omnispace’s MSS system
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© Omnispace LLC 2023
 SpaceX September 20 ex parte shows worse antenna
performance than SpaceX’s Mars-VLS ITU filing
SpaceX provided the following Tx beam Max power flux density table

The 29.0 dBi, 32.0 dBi and 38 dBi gain antennas are expected to have similar performance
as for the ITU filed 27.6 dBi and 34.8 dBi gain antennas
Best performing antenna (29 dBi): 1st sidelobe attenuation level: 8.9 dB referenced to peak
Worst performing antenna (38 dBi): 1st sidelobe attenuation level: 0 dB referenced to peak
ITU filed 35 dBi gain antenna: 1st sidelobe attenuation level: 14.8 dB referenced to peak
But ex parte table above (35 dBi): 1st sidelobe attenuation level: 2.9 dB referenced to peak
The antenna performance indicated by the Power Flux Density table above indicates an even poorer performance
(11.9 dB, 15 times worse) contrary to what has been claimed in SpaceX filings
Using SpaceX’s own information provided to the FCC leads to a serious interference
scenario: Omnispace and other MSS operators will incur orders of magnitude greater
interference than what the SpaceX ITU filing represents and in claims made to the FCC
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© Omnispace LLC 2023
Interference calculations based on ITU-R Rec. M.1184
Using the information referenced in ITU-R Rec. M.1184, the interference from a single
SpaceX satellite will cause harmful interference to a satellite (using the
same spectrum) more than 11,000 km from SpaceX operations over the U.S.
Parameter Value Units Notes

Satellite EIRP 88 dBm Maximum specified in SpaceX Tech Narrative and Schedule S

Bandwidth 5 MHz
Antenna Gain 38 dBi Maximum from SpaceX Tech Narrative and Schedule S
Transmit Power -17.0 dBm/Hz

SpaceX Off-axis Gain in direction of

18 dBi From ITU-R Rec. M.1184, Table 4A
Omnispace satellite

EIRP toward Omnispace Satellite 1.0 dBm/Hz

Required I/N -6 dB Noise rise of 1 dB as per ITU-R Rec. S.2131
Required Interference Power at Receiver -168.5 dBm/Hz

Omnispace Off-axis Gain in direction of

10 dBi Assume sidelobes are attenuated 20 dB as per ITU-R Rec. M.1184
SpaceX satellite

Power at Omnispace Receiver (no

11.0 dBm/Hz
separation)
Required Isolation 179.5 dB

Required Separation Distance 11,336 km

9 © Omnispace LLC 2023

Interference calculations based on SpaceX’s ITU filing
Using the information in SpaceX’s September 20 ex parte, the interference from a
single SpaceX satellite will cause harmful interference to any S-band MSS satellite
more than 17,000 km from SpaceX operations over the U.S.
Parameter Value Units Notes

Satellite EIRP 88 dBm Maximum specified in SpaceX Tech Narrative and Schedule S

Bandwidth 5 MHz
Antenna Gain 38 dBi Maximum from SpaceX Tech Narrative and Schedule S
Transmit Power per Hz -17.0 dBm/Hz

SpaceX Off-axis Gain in direction of

22 dBi From SpaceX ITU Filing
Omnispace satellite

EIRP toward Omnispace Satellite 5.0 dBm/Hz

Required I/N -6 dB Noise rise 1 dB as per ITU-R Rec. S.2131
Required Interference Power at Receiver -168.5 dBm/Hz

Omnispace Off-axis Gain in direction of

10 dBi Assume sidelobes are attenuated 20 dB as per ITU-R Rec. M.1184
SpaceX satellite
Power at Omnispace Receiver (no
15.0 dBm/Hz
separation)
Required Isolation 183.5 dB
Required Separation Distance 17,967 km

10 © Omnispace LLC 2023

 What does this mean for Region 2 operations and beyond?
 1990-1995 MHz is allocated and licensed
throughout Central and South America as
MSS uplink spectrum
 In previous filings and ex partes, Omnispace
used the impact on our Colombia service
(over 1600 km away) as an example
 Extrapolating the current interference analysis
to show the impact to Omnispace’s Colombia
service shows the following:
➣An Omnispace satellite at 630 km has a view to
the edge of the Earth greater than 2700 km and
encompasses much of the U.S. from a satellite
serving Colombia
➣The graphic presents the surface of the earth
visible to the satellite (i.e., earth curvature radio
horizon)
Singe Omnispace satellite providing coverage to Colombia overlay
11 © Omnispace LLC 2023
of field of view with 7,500 satellite SpaceX constellation
SpaceX’s operation will cause harmful interference to an
Omnispace satellite serving Colombia and beyond
 Basing an interference analysis upon ITU-R Rec. M.1184 showed that a co-frequency MSS
operation would need to be 11,300 km away in order maintain a 1 dB noise floor rise
 That equates to a Free Space Path Loss of 179 dB
 Omnispace’s satellite serving Colombia is impacted by satellites over the U.S. up to 2700 km away
 Path loss at 2700 km is 167 dB, 12 dB closer
 This means that the Omnispace Satellite serving Colombia will see a noise floor rise of 6 dB over
thermal noise from a single SpaceX satellite
 SpaceX has previously noted that the Omnispace example satellite serving Colombia would
be subject to cumulative interference from 188 SpaceX satellites
 The cumulative energy from those satellites would increase the single satellite interference
by an additional 22.7 dB creating a total interference 28.7 dB above the thermal noise floor
 This level of interference would eliminate the possibility of providing any service as the
desired signal has as little as 4 dB C/N and would have to compete with an interferer 25
dB, or 316 times stronger

12 © Omnispace LLC 2023

Significance of the issue
 Omnispace has used a single situation analysis to show the impact of SpaceX’s
intended operation
 As shown, according to the operating characteristics of a single SpaceX satellite the noise
floor will be raised above acceptable levels over an entire hemisphere and to harmful
interference levels at 5,400 km from the U.S. operation
 Omnispace plans over 600 satellites and will operate over maritime areas as well as land
mass areas
 Because Omnispace’s satellites are in constant motion, as are SpaceX’s, the interference Omnispace
will see will be constant and pervasive for any of our satellites operating at distances 5,400 km from any
U.S. territory where SpaceX is operating a single satellite in its system
 That effectively paints a 5,400 km exclusion zone around the continental U.S., as well as an
identical exclusion zone around Alaska, Hawaii, and any U.S. territories where SpaceX plans to
operate a single satellite in its system using 1990-1995 MHz as downlink for its SCS operations
 More SpaceX satellites yield greater levels of harmful interference within the exclusion zone and
therefore will extend this exclusion zone
 The extent of the harmful interference within the exclusion zone can be seen in the next slide

13 © Omnispace LLC 2023

Extent of a 5,400 km exclusion zone from SpaceX U.S. territory use

© Omnispace LLC 2023

14
Additional terrestrial interference considerations
 Beyond Omnispace’s satellite to satellite interference concerns, SpaceX’s
claims regarding cross-market or cross-border interference are specious
given SpaceX’s supplied power flux density (pfd) table
 SpaceX’s supplied table is incomplete, as it does not state the distance at which the
measurement was taken
 Assuming this is representative of the pfd on the Earth -80 dBW/M^2 equates to a
signal strength in dBm between -70 and -75 dBm depending upon the altitude of the
satellite (between 340 km and 550 km based on SpaceX filings)
 SpaceX’s pfd table shows no beam roll-off, so this level of signal will be pervasive, even
at market and country borders
 Based on SpaceX’s numbers, Omnispace calculates that SpaceX exceeds the FCC’s
market border and international border limits of 47 dBuV/M by over 20 dB

© Omnispace LLC 2023

15
Conclusions
 Using SpaceX’s current representations and ITU filing parameters, the Starlink system will cause
significantly more harmful interference to Omnispace than originally analyzed, therefore the solution to
the problem is for SpaceX to use 1990-1995 MHz consistent with global MSS uplink allocations
 The interference from the 188 SpaceX satellites in view will significantly exceed the thermal noise floor
 Satellite systems are designed to operate at very low carrier-to-noise (C/N) levels
 If interference is added, then the impacted system can no longer provide the service that is
achievable in an interference free environment
 The new base for system performance will be based on C/(I+N)
 ITU-R Rec. S.2131 recognizes a 1 dB noise floor rise as acceptable, so the interference
power must be 6 dB below thermal noise
 This cumulative level of interference from 188 SpaceX satellites operating over the U.S. would
eliminate the possibility of providing any service to areas thousands of km away as the desired signal
has as little as 4 dB C/N and would have to compete with an interferer 25 dB (316 times) stronger than
the desired signal
The actual interference levels from hundreds of visible satellites will create a level
of interference that will make Omnispace and other S-band MSS operators
use of the 1990-1995 MHz spectrum impossible over large portions of the globe
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© Omnispace LLC 2023
 Thank you

© Omnispace LLC 2023

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