February 20, 2024

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

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

Dear Ms. Dortch:

SpaceX designed its second-generation satellite system to be the most capable and
sustainable constellation in space, providing high-speed, low-latency broadband to consumers
wherever they are and using orbital resources responsibly. SpaceX is proud to report that its
second-generation satellites have performed even better than expected, including during the launch
and early orbit phase of their operations where atmospheric drag on the satellites is at a maximum.
Based on the early successes of its second-generation satellites, SpaceX requests authority to
leverage the shells included in its application in the 340 km-360 km range 1 as an option within its
first tranche of 7,500 satellites.

Expanding the range of options in SpaceX’s Gen2 license to include the lower shells for
which SpaceX applied would improve space sustainability and enhance quality of service for
consumers, enterprises, and first responders. As the Commission recognized in the Gen2 Order,
satellite “failures at lower altitudes present lower risk than at higher altitudes, where remaining
orbital lifetimes are longer.” 2 In fact, SpaceX demonstrated in this proceeding that the collision
probability of second-generation satellites in lower shells will be as much as an order of magnitude
lower than its satellites operated at higher orbits, which themselves operate well below the
established threshold. 3 Further, just as the Commission found when authorizing SpaceX to
conduct LEOP operations, operations at lower altitudes allow SpaceX to “deorbit any non-
functional satellites in a matter of . . . weeks,” 4 not only in the post-deployment period, but also
during the entire orbital lifetime of these satellites.

Moreover, operating at these lower altitudes will enable SpaceX to provide higher-quality,
lower-latency satellite service for consumers, keeping pace with growing demand for real-time

1
SpaceX’s amended application for its second-generation system requested to operate at altitudes of 340 km (53-
degree inclination), 345 km (46-degree inclination), 350 km (38-degree inclination), and 360 km (96.9-degree
inclination). See Amendment, ICFS File No. SAT-AMD-20210818-00105, Technical Attachment at 3 (Aug. 18,
2021).
2
Space Exploration Holdings, LLC, 37 FCC Rcd. 14882, ¶ 85 (2022) (“Gen2 Order”).
3
See Letter from David Goldman to Marlene H. Dortch, ICFS File Nos. SAT-LOA-20200526-00055, SAT-AMD-
20210818-00105, at Exhibit B (Oct. 4, 2022).
4
Gen2 Order ¶ 91.

1155 F St NW, Suite 475, Washington, DC 20004 | phone 202.649.2700 | fax 202.649.2701 | spacex.com
Marlene H. Dortch
February 20, 2024
Page 2 of 2

applications to support remote work, distance education, telehealth, and emergency response.
Lower-latency service is particularly important for consumers in rural and remote areas that lack
terrestrial broadband options and for terrestrial broadband networks that rely on satellite backhaul.

SpaceX urges expeditious approval to include its 300 km shells as a part of its first tranche
of 7,500 satellites to advance space sustainability and maximize the benefits of its constellation
for consumers everywhere.

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

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