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    The document discusses SpaceX operating satellites at altitudes lower than authorized and summarizes altitude and orbit data from two SpaceX test satellite launches in tables. It notes SpaceX operates satellites hundreds of kilometers lower than authorized, from 354 to 359 kilometers compared to the authorized range of 370 to 460 kilometers where the International Space Station operates.

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    Wa0081. 7

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    waluyo dosen
    13 views1 page
    The document discusses SpaceX operating satellites at altitudes lower than authorized and summarizes altitude and orbit data from two SpaceX test satellite launches in tables. It notes SpaceX operates satellites hundreds of kilometers lower than authorized, from 354 to 359 kilometers compared to the authorized range of 370 to 460 kilometers where the International Space Station operates.

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    DOC-20240524-WA0081.-7

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    The document discusses SpaceX operating satellites at altitudes lower than authorized and summarizes altitude and orbit data from two SpaceX test satellite launches in tables. It notes SpaceX operates satellites hundreds of kilometers lower than authorized, from 354 to 359 kilometers compared to the authorized range of 370 to 460 kilometers where the International Space Station operates.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    13 views1 page

    Wa0081. 7

    Uploaded by

    waluyo dosen
    The document discusses SpaceX operating satellites at altitudes lower than authorized and summarizes altitude and orbit data from two SpaceX test satellite launches in tables. It notes SpaceX operates satellites hundreds of kilometers lower than authorized, from 354 to 359 kilometers compared to the authorized range of 370 to 460 kilometers where the International Space Station operates.

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    May 17, 2024

    Page 7

    altitude, many kilometers below SpaceX’s authorized orbital altitude and contrary to the operating
    authority the Commission awarded to SpaceX. 16 Although SpaceX sought to obtain FCC authority
    to operate in the range of 360 kilometers, 17 the Commission has not authorized operations 18 at that
    altitude and, indeed, on March 8, 2024 reiterated that “SpaceX may not deploy any satellites
    designed for operational altitudes below the International Space Station,” which operates between
    altitudes of 370 and 460 kilometers. 19 Based on May 1, 2024 data drawn from the U.S. Space
    Force, however, SpaceX operates its satellites many kilometers lower than their authorized
    locations in the range of 354 to 359 kilometers, well below the International Space Station. 20 Table
    1 summarizes the altitude and orbit of the SpaceX test satellite launch in April 2024 as of May 1,
    2023, and Table 2 summarizes the altitude and orbit of the SpaceX test satellite launch in January
    2024 as of May 1, 2024.

    Table 1

    Table 2

    Inserting and maintaining so many different satellites for use in tests at altitudes hundreds of
    kilometers away from the altitudes the Commission has actually authorized for experimental

    16
    Cf., e.g., Jonathan McDowell (@planet4589), X (Mar. 4, 2024, 2:03 AM), https://twitter.com/planet4589/status/
    1764547101969494427?lang=en (posting a plot of SpaceX test satellite altitudes and noting that “[t]he six test
    satellites for … direct-to-cell system were launched as part of Group 7-9 in Jan…. [and] are being operated at 360
    km”).
    17
    See Letter from David Goldman, Vice President of Satellite Policy, SpaceX to Marlene H. Dortch, Secretary, FCC,
    ICFS File Nos. SAT-LOA-20200526-00055 & SAT-AMD-20210818-00105 (Feb. 20, 2024).
    18
    SpaceX Gen2 Partial Grant ¶ 19 (deferring consideration of SpaceX’s proposed satellites at altitudes lower than 525
    km).
    19
    Space Exploration Holdings, LLC Request for Orbital Deployment and Operating Authority for the SpaceX Gen2
    NGSO Satellite System, Order and Authorization, SAT-LOA-20200526-00055, SAT-AMD-20210818-00105 SAT-
    AMD-20221216-00175, __ FCC Rcd. __ (Mar. 8, 2024) (emphasis added). SpaceX’s subsequent request to operate
    its direct-to-cellular payloads in the 340 km-360 km altitude shells is likewise still pending. Application of Space
    Exploration Holdings, LLC for Modification of Authorization for the SpaceX Gen2 NGSO Satellite System to Add a
    Direct-to-Cellular System, ICFS File No. SAT-AMD-20240322-00061 (filed Mar. 22, 2024).
    20
    See Satellite Database, HEAVENS ABOVE, https://heavens-above.com/Satellites.aspx?lat=0&lng=0&loc=Un
    specified&alt=0&tz=UCT (search “*DTC*” for all years of launch and with a satellite number range of 1 to 99999).

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