September 29, 2023

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

Re: GN Docket No. 23-135 and ICFS File No. SAT-MOD-20230207-00021

Dear Ms. Dortch:

Omnispace continues to falsely claim that SpaceX’s supplemental coverage operations will
cause harmful interference to Omnispace, even though their foreign system remains speculative
and will not serve American consumers. Following SpaceX’s demonstration that it will not
interfere with Omnispace’s future operations, 1 Omnispace makes another series of hasty revisions
to its own “study,” including using inaccurate assumptions about SpaceX’s off-axis performance
and relying on a noise floor contrary to the laws of physics. 2 The Commission should see
Omnispace’s campaign for what it is, and move on to approve SpaceX’s application to connect
millions of American consumers with supplemental coverage from space.

SpaceX reasonably relied on the -132.5 dBW/MHz internal noise floor that Omnispace
itself provided in the record. Omnispace’s second revised analysis incorrectly claims that SpaceX
misrepresented Omnispace’s receiver (i.e., internal) noise floor, even though SpaceX used the
‑132.5 dBW/MHz level Omnispace itself provided—twice—in the record: 3

From Omnispace Table 1

Required I/N: -12.2 dB
Required Ix Power at Rx: -174.7 dBm/Hz
Noise Calculation: -174.7 dBm/Hz + 12.2 dB = -162.5 dBm/Hz = -132.5 dBW/MHz

From Omnispace Table 2

Required I/N: 0 dB
Required Ix Power at Rx: -162.5 dBm/Hz
Noise Calculation: -162.5 dBm/Hz + 0 dB = -162.5 dBm/Hz = -132.5 dBW/MHz

1
See Letter from David Goldman to Marlene H. Dortch, GN Docket No. 23-135 and ICFS File No. SAT-MOD-
20230207-00021, Attachment B (July 26, 2023) (“SpaceX July 26 Ex Parte”).
2
See Letter from Mindel De La Torre to Marlene H. Dortch, GN Docket No. 23-135 and ICFS File No. SAT-
MOD-20230207-00021, Attachment (Aug. 18, 2023) (“Omnispace Aug. 18 Ex Parte”).
3
See Omnispace, LLC Reply Comments to Responses, GN Docket No. 23-135 and ICFS File No. SAT-MOD-
20230207-00021, at 13, 15 (June 5, 2023).

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Marlene H. Dortch
September 29, 2023
Page 2 of 3

SpaceX reasonably relied on Omnispace’s repeated representations to demonstrate that the

aggregate interference of SpaceX’s PCS G Block downlink into Omnispace’s satellite uplink falls
significantly below Omnispace’s internal noise floor, as shown in Figure 1.

Figure 1. Potential interference from SpaceX’s direct-to-cellular system shown in blue

as a cumulative distribution function (“CDF”) compared to Omnispace’s
-132.5 dBW/MHz receiver (i.e., internal) noise floor shown in red.

Omnispace’s revised internal noise floor defies the laws of physics. After SpaceX
demonstrated that SpaceX’s direct-to-cellular downlink will not cause Omnispace harmful
interference because it will fall well below Omnispace’s -132.5 dBW/MHz receiver noise floor,
Omnispace attempts to move the goalposts by claiming that its noise floor is actually 11.5 dB
lower (at ‑144 dBW/MHz). Unfortunately for Omnispace, its revision defies the laws of physics.
A radio-frequency receiver cannot operate at the ideal “kTB” thermal noise floor that Omnispace
claims; instead, it physically must operate at a level set by the ideal thermal noise floor combined
with a factor called the receiver noise figure. But Omnispace incorrectly omits its own receiver’s
noise figure. This omission creates a noise floor value that is physically impossible for a receiver
to realize, undermining Omnispace’s analysis.

Omnispace continues to misrepresent SpaceX’s off-axis antenna performance.

Although SpaceX provided Omnispace its off-axis antenna performance, 4 Omnispace insists on
using incorrect values. Omnispace claims it used “the best case expectation of Rec. ITU-R S.1528
and raised the sidelobe attenuation,” 5 but in fact Omnispace has made no change to the value of
off-axis gain in its flawed technical analysis and continues to misrepresent SpaceX’s off-axis gain
as 0 dBi. 6

Omnispace once again misstates the number of visible SpaceX satellites in its analysis.
In its first set of corrections to Omnispace’s study, SpaceX explained that Omnispace should have
assumed 188 SpaceX satellites in view in its analysis (rather than 100 satellites). SpaceX showed

4
Of course, SpaceX could operate at even higher off-axis gain values without causing harmful interference to the
foreign system Omnispace claims it will deploy one day.
5
See Omnispace Aug. 18 Ex Parte, Attachment at 3.
6
See id., Attachment at 4.

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Marlene H. Dortch
September 29, 2023
Page 3 of 3

that even under a full deployment, Omnispace would not experience harmful interference. 7
Strangely, Omnispace claimed in its revised analysis that SpaceX only assumed a single SpaceX
satellite in view, which is simply not true. Even now, Omnispace continues to cling to its error. 8
The fact remains that SpaceX demonstrated that it will not cause harmful interference even using
its fully deployed system with 188 satellites in view.

Omnispace raises baseless claims about terrestrial interference. Omnispace falsely

claims that SpaceX will cause harmful terrestrial interference across borders. 9 But Omnispace
has no terrestrial operations anywhere in the world, and its lack of experience shows in its
confusing response. For example, Omnispace provides no evidence for its claim that the existing
limit in Part 24 is not strict enough to accommodate satellite-to-ground transmissions. Further,
Omnispace fails to note that once an operator meets the field strength limit at a border, it will meet
the limit at any more distant geographic point, regardless of whether the signal is from a satellite
or terrestrial source. Omnispace’s latest untimely efforts to throw up new obstacles to SpaceX’s
deployment are as flawed as the ones it raised initially.

***

SpaceX will not cause harmful interference to Omnispace’s speculative foreign system,
and Omnispace’s shapeshifting analysis provides no basis for the Commission to delay the
deployment of beneficial services to millions of American consumers. SpaceX urges the
Commission to dismiss Omnispace’s efforts and expeditiously grant SpaceX’s application for
supplemental coverage from space.

Sincerely,
/s/ David Goldman
David Goldman
Vice President, Satellite Policy

SPACE EXPLORATION TECHNOLOGIES CORP.

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

7
See SpaceX July 26 Ex Parte, Attachment B at 4.
8
See Omnispace Aug. 18 Ex Parte, Attachment at 6.
9
See id. at 6, 10.

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