BEFORE THE

FEDERAL COMMUNICATIONS COMMISSION

WASHINGTON, D.C. 20554

)
Application of )
)
SPACE EXPLORATION HOLDINGS, LLC ) Call Sign: S3069/S2992
)
For Amendment of Application for the ) ICFS File No. SAT-AMD-_____________
SpaceX Gen2 NGSO Satellite System )
)

AMENDMENT OF APPLICATION
FOR THE SPACEX GEN2 NGSO SATELLITE SYSTEM

Jameson Dempsey
Director, Satellite Policy

SPACE EXPLORATION
TECHNOLOGIES CORP.

1 Rocket Road
Hawthorne, CA 90250
310-682-9836 tel

October 11, 2024

 SUMMARY

In the two years since first launching satellites into its second-generation (“Gen2”) system,

SpaceX has continually sought to refine and enhance its satellite technology to improve the coverage,

capacity, and sustainability of the system and deliver truly high-speed, low-latency broadband to

millions of people around the world. Drawing upon this experience and innovation, this amendment

requests to upgrade the orbital configuration, frequencies, and operational parameters of the pending

portion of SpaceX’s application for its Gen2 non-geostationary satellite orbit (“NGSO”) system (the

“Gen2 Upgrade Amendment”). The amendment application also seeks several conforming changes

to better align the pending part of the Gen2 application with the Commission’s flexible use policies,

the Space Innovation Agenda, and recent updates in Commission policy and international rules

following the International Telecommunications Union (“ITU”) 2023 World Radiocommunication

Conference (“WRC-23”).

In parallel to this amendment, SpaceX has filed a modification application to similarly

upgrade the orbital configuration and operational characteristics of the authorized portion of its Gen2

system (the “Gen2 Upgrade Modification”). Together, this amendment and its companion

modification will enable the Gen2 system to deliver gigabit-speeds, truly low-latency broadband and

ubiquitous mobile connectivity to all Americans and the billions of people around the world who still

lack access to adequate broadband.

While each of these applications—collectively the “Gen2 Upgrade Applications”—will

independently serve the public interest, and may be granted separately where applicable, SpaceX has

prepared consolidated technical showings to demonstrate that, taken as a whole, SpaceX’s entire

proposed Gen2 upgrade will benefit the public interest and will not cause significant interference

problems to other spectrum users. The Gen2 Upgrade Amendment requests the following changes

to SpaceX’s pending Gen2 application:

i
 Orbital reconfiguration to dynamically respond to evolving consumer demand. SpaceX first

requests several amendments to the orbital parameters of its Gen2 system between 340 km and 365

km altitude to keep pace with rapidly evolving global demand for high-quality broadband. First,

SpaceX amends the inclination of its orbital shell at a nominal altitude of 345 km from 46 degrees to

48 degrees. SpaceX also amends its pending Gen2 application to seek authority to operate satellites

in its Gen2 system in two additional orbital shells—at 355 km altitude in a 43-degree inclination and

at 365 km altitude in a 28- or 32-degree inclination.1 The total number of operational satellites will

remain 29,988 satellites across the amended Gen2 system. The proposed orbital reconfiguration is

as follows:

Gen2 Application 2024 Gen2 Amendment

Altitude (km) Inclination (deg) Altitude (km) Inclination (deg)
340 53 → 340 53
345 46 → 345 48
350 38 → 350 38
355 43
360 96.9 → 360 96.9
365 28 or 322

With the exception of its polar shell at 360 km, which will remain unchanged, SpaceX also amends

its application to more flexibly distribute satellites in its shells between 340 km and 365 km than

requested in its pending application, specifically, in up to 72 planes per shell and up to 144 satellites

per plane. While this reconfiguration will result in two additional shells and a higher maximum

number of orbital planes and satellites per plane for all but one shell between 340 km and 365 km,

the total number of operational satellites in the Gen2 system will remain 29,988 satellites. Consistent

1
SpaceX requests authority to operate satellites in its 365 km shell at 32 degrees inclination to accommodate upcoming
Starship launches of satellites for SpaceX’s Gen2 system from its Starbase launch facilities in Boca Chica, TX. If
the Federal Aviation Administration (“FAA”) does not allow for Starship launches at 32 degrees from Starbase,
SpaceX requests authority to launch into the 28-degree inclination at 365 km altitude.
2
Id.
ii
with the ITU Radio Regulations, SpaceX requests to operate these shells within an altitude tolerance

of +/- 100 km and an inclination tolerance of +/- 2 degrees.

Additional frequencies to enhance service quality and network capacity, promoting

symmetrical broadband speeds for consumers. With its Gen2 upgrade, SpaceX has designed a

system that will finally bring fiber-like gigabit speeds and ubiquitous mobile connectivity to all

Americans and the billions of people around the world who still lack access to broadband. To achieve

this step-change in service quality, SpaceX amends its application to request authority to

communicate in additional uplink and downlink frequencies to complement the existing frequencies

authorized for the Gen2 system. These additional frequencies will significantly improve the upload

and download speeds of SpaceX’s earth stations, thereby allowing SpaceX to stay ahead of increasing

demand from consumers, enterprises, and government users. These additional frequencies hold

particular promise for those in rural, remote, Tribal, and polar areas who require reliable and high-

quality connectivity to participate in the modern, Internet-enabled economy. Additional uplink

frequencies will promote more symmetrical broadband speeds for end users and handle increasing

uplink traffic needed for bandwidth-intensive, real-time applications. These frequencies will also

support 5G and emerging 6G networks that interweave terrestrial and satellite capabilities, including

through supplemental coverage from space, traditional mobile-satellite service, and satellite backhaul

of remote cellular networks.

For spectrum bands governed by the ITU’s overly conservative EPFD downlink limits—

outdated limits that the Commission has found to harm consumers, competition, and satellite

innovation—SpaceX submits a waiver request and demonstration that its proposed Gen2 satellite

system can continue to protect GSO Fixed-Satellite Service (“FSS”) and Broadcasting-Satellite

Service (“BSS”) networks from unacceptable interference for downlink operations in the United

States.
iii
 Lower minimum elevation angles to improve network performance. To maintain high-

speed, low-latency broadband service for consumers as many millions more users join the network,

SpaceX amends its pending Gen2 Application to lower its minimum elevation angle from 25 degrees

to 10 degrees for satellites operating below 400 km altitude and to 20 degrees for satellites operating

between 400 and 500 km altitude.3 Reducing the minimum elevation angle in this way will improve

network latency and performance by allowing satellites to connect to more earth stations directly and

to maintain connections with these earth stations for a longer period of time while flying overhead.

***

This Amendment will vastly improve the coverage, quality, and reliability of SpaceX’s Gen2

system for American consumers and people around the world, and will do so without causing harmful

interference to other licensed operators or increasing any orbital debris mitigation risk. Accordingly,

the Commission should find that grant of this amendment would serve the public interest.

3
SpaceX will continue to operate down to five degrees minimum elevation angle at latitudes in polar regions, i.e.,
above 62 degrees. See Gen2 Authorization ¶ 42.
iv
 TABLE OF CONTENTS

SUMMARY .................................................................................................................................... i

TABLE OF CONTENTS .............................................................................................................. 5

I. DESCRIPTION OF AMENDMENT ................................................................................. 2

II. GRANT OF THIS AMENDMENT WOULD SERVE THE PUBLIC INTEREST ...... 8

III. ITU COST RECOVERY .................................................................................................. 13

CONCLUSION ........................................................................................................................... 13
 BEFORE THE
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, D.C. 20554

)
Application of )
)
SPACE EXPLORATION HOLDINGS, LLC ) Call Signs: S3069/S2992
)
For Amendment of Application for the ) ICFS File No. SAT-AMD-_____________
SpaceX Gen2 NGSO Satellite System )
)

AMENDMENT OF APPLICATION FOR

THE SPACEX GEN2 NGSO SATELLITE SYSTEM

Space Exploration Holdings, LLC (“SpaceX”) submits this amendment to its pending

application for its next-generation non-geostationary orbit (“NGSO”) satellite system (the “Gen2

system”).4 This amendment reflects SpaceX’s iterative approach to satellite innovation and the

significant on-orbit experience it has gained in the four years since SpaceX first submitted its Gen2

application and the two years since it first began launching satellites into its partially authorized Gen2

constellation. This experience has emphasized the need for operational flexibility to ensure that U.S.-

licensed satellite operators not only keep pace with growing and evolving consumer demand for high-

speed, low-latency broadband, but also remain globally competitive amidst the rise of state-owned

and state-backed satellite systems that have been deploying at a rapid clip. A completed Form 312,

accompanying Schedule S, Technical Attachment, and Waiver Requests are associated with this

application, consistent with the information required by the Commission’s rules in support of the

requested authorization.

4
See Application for Approval of Orbital Deployment and Operating Authority for the SpaceX Gen2 NGSO Satellite
System, ICFS File No. SAT-LOA-20200526-00055 (filed May 26, 2020); Amendment, ICFS File No. SAT-AMD-
20210818-00105 (filed Aug. 18, 2021) (collectively, “Original Application”).
1
I. DESCRIPTION OF AMENDMENT

The Commission has granted in part and deferred in part SpaceX’s application for its Gen2

satellite system, authorizing SpaceX to deploy and operate a first tranche of 7,500 satellites

operating using Ku-, Ka-, V-, and E-band spectrum distributed among three orbital shells at

nominal altitudes of 525, 530, and 535 km.5 The Commission has also authorized SpaceX to

deploy and conduct initial checkout testing for 7,500 payloads capable of operating between

1429-2690 MHz.6 The Commission deferred action with respect to the remainder of the Gen2

application, which includes the remaining 22,488 satellites in the Original Application in orbital

shells with nominal altitudes between 340 km and 360 km (the “300 km shells”) and between

604 km and 614 km (the “600 km shells”).7 This amendment seeks to dramatically improve the

coverage, service quality, and reliability of the Gen2 system by updating the orbital characteristics,

requested frequencies, and operational parameters of the deferred part of SpaceX’s pending Gen2

application. In parallel, SpaceX will submit a modification to its current Gen2 authorization to

reflect the requested changes to the entire 29,988 Gen2 satellite system.8

5
See Space Exploration Holdings, LLC, Order and Authorization, 37 FCC Rcd. 14882 (2022) (“Gen2
Authorization”); Space Exploration Holdings, LLC; Request for Orbital Deployment and Operating Authority for
the SpaceX Gen2 NGSO Satellite System, DA 24-222, ICFS File Nos. SAT-LOA-20200526-00055 SAT-AMD-
20210818-00105 SAT-AMD-20221216-00175, Call Sign: S3069 (SB rel. Mar. 8, 2024)(“E-band Authorization”)
(granting authority for E-band payloads); Stamp Grant, ICFS File No. SAT-MOD-20230322-00062 (SB reissued
Nov. 9, 2023) (granting authority for V-band payloads).
6
See Stamp Grant, ICFS File No. SAT-MOD-20230207-00021 (rel. Dec 1, 2023).
7
See Gen2 Authorization ¶ 1. SpaceX is also submitting, in parallel, a modification to the authorized portion of its
Gen2 application. For avoidance of doubt, SpaceX intends for this amendment to apply to all space stations in
SpaceX’s Gen2 system. Moreover, while neither the Commission’s rules nor the Gen2 Authorization require
SpaceX to file a modification or amendment to request Commission action on the deferred remainder of SpaceX’s
Gen2 Application, for completeness, SpaceX requests that as a part of any grant of the Gen2 Upgrade Applications
that it authorize SpaceX to deploy its entire requested Gen2 system, as modified or amended.
8
As explained in more detail in the Technical Attachment, in parallel with this amendment, SpaceX will request
to modify its authorized orbital shells at 525, 530, and 535 km to promote space sustainability, to provide
additional flexibility to dynamically respond to evolving consumer demand, and to anticipate upcoming launches
of the Starship launch vehicle. As with this proposed amendment, that modification would not cause the total
Gen2 system to exceed the maximum number of 29,988 satellites. Where applicable, the interference showings
in the Technical Attachment account for both this proposed amendment and the parallel modification to
demonstrate that, in total, these updates to the Gen2 system will not cause significant interference problems and

2
 Orbital reconfiguration of 300 km shells. SpaceX requests several changes to the orbital

characteristics of its operations between 340 km and 365 km altitude. For the shell at a nominal

altitude of 345 km, SpaceX amends the requested inclination from 46 degrees to 48 degrees to

allow more consumers across the United States and around the world at similar latitudes to connect

more directly to high-elevation beams, improving latency and user experience. SpaceX next

amends its Gen2 application to add two new orbital shells: one at 355 km altitude and a 43-degree

inclination, and a second at 365 km in a 28- or 32-degree inclination.9 The orbital reconfiguration

for the 300 km orbital shells will be as follows:

Gen2 Application 2024 Gen2 Amendment

Altitude (km) Inclination (deg) Altitude (km) Inclination (deg)
340 53 → 340 53
345 46 → 345 48
350 38 → 350 38
355 43
360 96.9 → 360 96.9
365 28 or 32

For these two new shells at 355 km and 365 km, and all but one of its pending orbital shells

between 340 km and 365 km,10 SpaceX also seeks additional flexibility to keep pace with evolving

consumer demand by updating the maximum potential number of orbital planes and satellites in

each plane. Specifically, SpaceX seeks authority to distribute up to 144 satellites in each of up to

72 orbital planes in its proposed shells between 340 km and 365 km, with the exception of its

proposed sun-synchronous orbit (“SSO”) shell at 360 km, which will remain unchanged. While

any one of these revised orbital shells could conceivably contain up to 10,368 satellites, in no event

will not cause unacceptable interference to other users across the requested frequency bands.
9
If the Federal Aviation Administration (“FAA”) does not allow for Starship launches at 32 degrees from Starbase,
TX, SpaceX requests for authority to launch into the 28-degree inclination at 365 km altitude.
10
The only exception is SpaceX’s polar shell at 360 km altitude and 96.9 degrees inclination, which will remain
unchanged.

3
would the total number of operational satellites across the entire updated Gen2 system exceed the

maximum number of 29,988 satellites.11

Consistent with recent updates to the ITU Radio Regulations following the 2023 World

Radiocommunication Conference (“WRC-23”), SpaceX requests to operate its Gen2 orbital shells

within an altitude tolerance of +/- 100 km and within an inclination tolerance of +/- 2 degrees.12

Aligning the altitude and inclination tolerance of orbital shells within the Gen2 system with those

that the ITU has approved for all satellite systems would provide additional flexibility during

operations, promoting space sustainability as a greater number of non-geostationary orbit satellite

systems deploy in and around similar orbits.

As demonstrated in the companion Technical Attachment, this orbital reconfiguration will

maintain the space sustainability features of SpaceX’s Gen2 satellites included in the Original

Application, leveraging low, self-cleaning altitudes and industry-leading collision avoidance

technologies to remain within applicable thresholds and post-mission disposal timeframes.

Moreover, SpaceX’s operations in these shells will remain consistent with its coordination

arrangements with NASA pursuant to the parties’ Space Act Agreement and the coordination

conditions of its Gen2 Authorization. While the specific operational strategies and altitude ranges

of the Gen2 system may vary over time to facilitate coordination with crewed space stations,

SpaceX will ensure that its operations in these lower-altitude shells do not affect any operations of

crewed space stations within its orbital tolerances.

Additional frequencies. SpaceX also amends its pending Gen2 Application to add certain

L-, S-, Ku-, Ka-, V-, and W-Band frequencies for communications between satellites and earth

11
SpaceX has provided interference analyses for example configurations of the updated 29,988 satellites in its
Technical Attachment.
12
See ITU Radio Regs., Res. 8 (WRC-23).

4
stations. Below, SpaceX provides a list of all requested frequencies for its Gen2 system, including

already authorized frequencies and new frequencies that are the subject of this amendment

(highlighted in blue and bolded).13 With two exceptions, SpaceX requests authority to launch and

operate satellites using all of the frequencies below on up to 29,988 satellite across all of its Gen2

orbital shells, including those in its parallel Gen2 Upgrade Modification. Specifically, SpaceX

requests to operate only up to 7,500 L-band and S-band payloads between 1429-2690 MHz and

only up to 450 VHF-band payloads.

Transmission Frequency Ranges

Direction
Satellite to Earth 137-138 MHz
Station 1429-2690 MHz14
10.7-12.75 GHz
17.3-17.8 GHz
17.8-18.6 GHz
18.6-18.8 GHz
18.8-19.3 GHz
19.3-19.7 GHz
19.7-20.2 GHz
20.2-21.2 GHz
37.5-42.0 GHz15
42.0-42.5 GHz16
71.0-76.0 GHz
Earth Station to 148-150.05 MHz
Satellite 1429-2690 MHz17

13
This list excludes frequencies authorized for Telemetry, Tracking and Command as authorized in the Gen2
Authorization, which SpaceX will continue to use in its upgraded Gen2 system.
14
While SpaceX includes the full range of frequencies from 1429-2690 MHz that it has requested for supplemental
coverage from space, actual directionality will depend, for example, on frequency allocations, mobile operator
partnerships, and local authorizations. Consistent with its USASAT-NGSO-MVLS ITU filing, SpaceX also
requests to operate in allocated MSS frequencies in this range outside of the United States pursuant to their
international MSS allocations.
15
While the Commission has authorized SpaceX to deploy and operate V-Band capabilities on SpaceX’s
currently-authorized up to 7,500 Gen2 satellites, SpaceX hereby requests authorization to operate V-Band
payloads on every satellite of its entire 29,988 satellite Gen2 constellation.
16
SpaceX only requests authorization to use the 42.0-42.5 GHz band outside of the United States.
17
While SpaceX includes the full range of frequencies from 1429-2690 MHz that it has requested for supplemental
coverage from space, actual directionality will depend on frequency allocations, mobile operator partnerships,

5
 12.7-12.75 GHz
12.75-13.25 GHz
13.75-14.00 GHz
14.00-14.50 GHz
14.50-14.75 GHz
14.75-14.80 GHz
15.43-15.63 GHz
24.75-25.25 GHz
27.5-29.1 GHz
29.1-29.5 GHz
29.5-30.0 GHz
30.0-31.0 GHz
47.2-50.2 GHz18
50.4-51.4 GHz19
51.4-52.4 GHz
81.0-86.0 GHz
92.0-94.0 GHz
94.1-95 GHz
95.0-100.0 GHz
102.0-109.5 GHz
111.8-114.25 GHz
Table 1. Summary of Gen2 Frequencies

A more precise description of the frequency and channelization plan for the upgraded Gen2

system is included in Schedule S and the Technical Attachment accompanying this application.

Some of these new frequencies do not currently have an FSS or Mobile-Satellite Service (“MSS”)

allocation in either the U.S. Table of Frequency Allocations or in the International Table of

Frequency Allocations. For any new frequency band that does not conform with the U.S. Table

of Frequency Allocations but does conform with the International Table of Frequency Allocations

on a regional or global basis (in whole or part), SpaceX requests to operate in that band outside

and local authorizations. Consistent with its USASAT-NGSO-MVLS ITU filing, SpaceX also requests authority
to operate in allocated MSS frequencies in this range outside of the United States pursuant to their international
MSS allocations.
18
While the Commission has authorized SpaceX to deploy and operate V-Band capabilities on SpaceX’s
currently-authorized up to 7,500 Gen2 satellites, SpaceX hereby requests authorization to operate V-Band
payloads on every satellite of its entire 29,988 satellite Gen2 constellation.
19
Id.

6
the United States consistent with those international satellite allocations, and seeks a waiver of the

U.S. Table of Frequency Allocations to permit operations in that frequency band on a non-

interference, non-protection basis within the United States. To the extent that any new frequency

band does not conform with both the U.S. Table of Frequency Allocations and the International

Table of Frequency Allocations (in whole or part), SpaceX requests authority to operate on a non-

conforming basis consistent with Article 4.4 of the Radio Regulations, and seeks a waiver to do

so. SpaceX attaches a waiver request setting forth the strong reasons in support of these waivers.

SpaceX plans to leverage its existing ground infrastructure for the upgraded Gen2 system,

but will submit earth station applications to the Commission as needed to request access to these

new frequencies in the United States pursuant to Sections 25.115 and 25.130 of the Commission’s

rules.

The various space and ground facilities comprising the updated Gen2 System are described

below and in more detail in Schedule S, Technical Attachment (Attachment A), and waiver

requests accompanying this application. Where applicable, SpaceX provides interference analyses

demonstrating that its proposed updated Gen2 satellite system will not cause harmful interference

to protected services while operating in the frequencies above. For spectrum bands governed by

the overly conservative EPFD limits of the ITU, SpaceX submits a waiver request and

demonstration that its proposed Gen2 satellite system can continue to protect GSO FSS and BSS

networks from unacceptable interference for downlink operations in the United States.

SpaceX requests to use its new Ku-, Ka-, V-, and W-band frequencies for either gateway

earth station or non-gateway earth station links. Doing so would better enable SpaceX to deploy

equipment for consumer, enterprise, and government use cases to meet individual capacity needs.

In any event, authorized earth station operations will comply with relevant technical limits and

7
licensing requirements—including individual or blanket licensing as applicable. For clarity,

SpaceX refers to different stations by their antenna type—parabolic or phased array—where

phased array antennas will be used for communications in Ku- and Ka-bands, and parabolic

antennas will be used for communications in the Ka-, V-, and W-bands.

Lower minimum elevation angle for communications with earth stations. SpaceX

amends its pending Gen2 application to update the minimum elevation angles for communications

with earth stations for satellites operating in shells at nominal altitudes below 500

km. Specifically, SpaceX seeks to lower its minimum elevation angle from 25 degrees to 10

degrees for satellites operating below 400 km altitude and to 20 degrees for satellites operating

between 400 and 500 km altitude.20

II. GRANT OF THIS AMENDMENT WOULD SERVE THE PUBLIC INTEREST

Granting this amendment would promote the public interest by improving the coverage,

quality, reliability, and sustainability of SpaceX’s Gen2 system for American consumers without

causing significant interference problems for other NGSO systems or unacceptable interference

for GSO systems.

The orbital reconfiguration will promote space sustainability and enable dynamic

deployment to meet demand. SpaceX has continually sought opportunities to lead the way in

space sustainability, including by operating its satellites at lower altitudes even when doing so

comes at great cost to SpaceX. After testing satellites in its Gen2 system at lower altitudes over

the course of the last two years, SpaceX has determined that these satellites are even more robust

and resilient than expected. As such, SpaceX seeks to swiftly take advantage of operations at these

20
SpaceX will continue to operate down to five degrees minimum elevation angle at latitudes in polar regions, i.e.,
above 62 degrees. See Gen2 Authorization ¶ 42.

8
lower, self-cleaning altitudes to improve the sustainability of the Gen2 system. As the Technical

Attachment demonstrates, SpaceX’s operations in these lower altitude shells will fall well below

applicable collision probability thresholds and will significantly reduce passive decay time and

post-mission disposal for satellites in the Gen2 system.

The updated orbital configuration for the 300 km shells will also enable SpaceX to more

responsively adapt its network deployment to efficiently respond to evolving consumer demand

on a global scale. As next-generation satellite systems provide an increasing array of beneficial

services to people on the ground—from consumer broadband and cellular backhaul to Internet of

things and supplemental coverage—network demand has rapidly grown and evolved. This

demand from consumers, enterprises, industries, and government users—including first

responders in emergency situations—far outpaces one-to-two-year space station application

processing timeframes, creating significant risks of coverage and capacity constraints that could

otherwise be swiftly addressed through targeted deployments. Just as terrestrial operators are not

required to commit to specific base station locations at the time of licensing, SpaceX’s proposed

Gen2 orbital configuration would enable it to launch satellites and deploy capacity where it is

needed most in anticipation of, and in response to, evolving consumer demand. In so doing,

SpaceX can more efficiently deploy a global service free from capacity constraints and with a high

quality of service for consumers anywhere in the world.

Permitting access to additional, complementary frequency bands will enhance network

capacity and service quality and promote symmetrical, fiber-like broadband speeds and

ubiquitous mobile connectivity for consumers. As a part of the Space Innovation Agenda, the

Chairwoman and Space Bureau have recognized the importance of ensuring a reliable pipeline of

spectrum to enable next-generation satellite systems to deliver high-speed, low-latency

9
connectivity to consumer, business, industrial, and government end users and stay ahead of

accelerating demand.21 To that end, the Commission has continually sought opportunities to

protect existing workhorse satellite spectrum bands while making available additional spectrum

for next-generation satellite services, including in the Ku-band, Ka-band, V-band, and E-band. As

the Commission found in its recent 17 GHz Order, among the most promising spectrum bands are

those that lie adjacent or near-adjacent to existing allocations, since, among other things,

contiguous spectrum allows operators to more swiftly upgrade existing equipment to provide even

higher quality service to consumers. Moreover, existing bands can provide an efficient and

established template for operations in adjacent and nearby bands, allowing operators to more

readily coordinate and coexist.

Permitting SpaceX to launch and operate space stations using these additional frequencies

will allow SpaceX to stay ahead of accelerating consumer demand through both robust end-user

earth stations—including fixed earth stations and earth stations in motion—backhaul, and mobile

connectivity, whether backhauling remote 4G/5G networks or providing direct-to-device

connectivity to consumers or Internet of Things devices. SpaceX has designed its upgraded Gen2

system so that it can provide gigabit-speed, low-latency broadband and ubiquitous mobile

connectivity anywhere on Earth, helping to close the digital divide for billions of people who still

lack access to high-quality connectivity. Importantly, SpaceX has focused its amendment

primarily on new bands that can help deliver more symmetrical, fiber-like speeds to end users and

narrow the urban-rural broadband divide, consistent with the Commission’s long-standing

broadband policies and growing demand for bandwidth-intensive, real-time applications. More

21
See, e.g., Amendment of Parts 2 and 25 of the Commission’s Rules to Enable GSO Fixed-Satellite Service (Space-
to-Earth) Operations in the 17.3-17.8 GHz Band, Report and Order and Notice of Proposed Rulemaking, FCC
No. 22-63, IB Docket Nos. 20-330, 22-273, ¶ 1 (rel. Aug. 3, 2022) (allocating spectrum to help “alleviat[e] the
growing need for additional Ka-band GSO FSS downlink spectrum to support communications to earth stations”).

10
symmetrical speeds will not only benefit consumers, but also enterprise and industrial users that

lack access to robust or reliable fiber in rural and remote areas. Outside of the United States, these

bands will permit American satellite operators such as SpaceX to stay ahead in the new space age,

as foreign state-owned and state-backed constellations increasing deploy to compete with U.S.-

licensed satellite systems.

Authorizing SpaceX to operate outside the United States in certain uplink and downlink

MSS frequencies between 1429 MHz and 2690 MHz will also advance ubiquitous connectivity,

American competitiveness, and innovation in the emerging direct-to-device ecosystem abroad

even as the Commission considers how to best modernize its domestic MSS rules to permit new

entry and competition here in the United States. While SpaceX has applied to use traditional

mobile service frequencies in the 1429-2690 MHz range to help mobile operators extend their

networks to off-the-shelf consumer handsets through supplemental coverage from space, the

Commission has recognized the fundamental difference between supplemental coverage and

traditional MSS and the importance of robust MSS service.22 Permitting SpaceX to deliver MSS

outside the United States will thus complement its supplemental coverage operations while making

more efficient and productive use of its innovative direct-to-device hardware, particularly in

international waters and in countries that lack a supplemental coverage framework. SpaceX will

operate in these frequencies consistent with the technical parameters it has included within its

USASAT-NGSO-MVLS ITU filing and relevant ITU Radio Regulations for MSS operations in

those bands.

Ultimately, just as the Commission found when granting SpaceX’s request to pioneer the

22
See, e.g., Single Network Future: Supplemental Coverage from Space , Report and Order and Further Notice of
Proposed Rulemaking, GN Docket No. 23-65, IB Docket No. 22-271 ¶ 237 (rel. March. 15, 2024).

11
deployment of E-band frequencies for next-generation satellite systems, allowing SpaceX to once

again lead the way by deploying space stations with the additional frequencies in the Gen2

Upgrade Amendment will allow SpaceX “to utilize the full capacity of its more advanced Gen2

Starlink satellites, which will improve the broadband service that SpaceX is bringing to U.S.

customers, including those in unserved and underserved areas of the country.”23

Upgraded Gen2 hardware will improve spectrum efficiency and sharing. Like its

current Gen2 system, SpaceX has designed its upgraded Gen2 system with spectrum sharing at

the forefront. The upgraded Gen2 system will feature enhanced hardware that can use higher

gain and more advanced beam-forming and digital processing technologies and provide more

targeted and robust coverage for American consumers. As a result, these upgraded satellites can

maximize the use of available bandwidth, enabling more efficient allocation of resources and

facilitating a broader range of services.

Lower minimum elevation angles to improve network performance. SpaceX’s request

to lower the minimum elevation angle of its earth station communications will improve end-user

service and latency by reducing or eliminating the need for communications to transit over

SpaceX’s laser mesh, reducing the end-to-end distance (and thus the potential round-trip latency)

of transmissions over the network. Lowering the minimum elevation angle will also increase

system reliability by allowing earth stations to maintain links with satellites for a longer period

of time as they cross the sky. Lowering the minimum elevation angles for SpaceX’s beams will

also promote more efficient spectrum sharing by increasing the portion of the sky that may be

used for coordination.

The amendment will not cause significant interference problems under the Teledesic

23
See E-band Authorization ¶ 1.

12
standard. The Technical Attachment includes a set of interference analyses demonstrating that

the Gen2 Upgrade Amendment—coupled with its companion Gen2 Upgrade Modification—does

not “present any significant interference problems and is otherwise consistent with Commission

policies”24 and should therefore be granted. These analyses include updated NGSO-NGSO

analyses reflecting the Commission’s recently adopted degraded throughput methodology,25 and

GSO-NGSO interference analyses to demonstrate that SpaceX’s proposed operations will protect

GSO FSS and BSS networks in downlink from unacceptable interference. In frequency bands

where SpaceX proposes non-conforming use, SpaceX has included a waiver request certifying that

it will operate on a non-interference and non-protected basis and coordinate with Federal and non-

Federal users of the band as needed to ensure that existing operations are protected.

III. ITU COST RECOVERY

SpaceX is aware that, as a result of the actions taken at the 1998 Plenipotentiary

Conference, as modified by the ITU Council in 2005, the ITU now charges processing fees for

satellite network filings. As a consequence, Commission applicants are responsible for any and

all fees charged by the ITU. SpaceX confirms that it is aware of this requirement and accepts

responsibility to pay any ITU cost recovery fees associated with this application. Invoices for such

fees may be sent to the contact representative listed in the accompanying FCC Form 312.

CONCLUSION

For the foregoing reasons, and for the reasons set forth in the accompanying materials,

SpaceX requests that the Commission find that authorizing SpaceX to update its Gen2 satellite

24
Space Exploration Holdings, LLC, Request for Modification of the Authorization for the SpaceX NGSO Satellite
System, Order and Authorization and Order on Reconsideration, 36 FCC Rcd. 7995, ¶ 9 (2021) (quoting Teledesic
LLC, Order and Authorization, 14 FCC Rcd. 2261, ¶ 5 (IB 1999)).
25
Revising spectrum Sharing Rules for Non-Geostationary Orbit, Fixed-Satellite Service Systems, Report and
Order and Further Notice of Proposed Rulemaking, 38 FCC Rcd. 3699 ¶¶ 38-42 (2023) (seeking further
comment on implementation issues).

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system would serve the public interest, and issue such grant expeditiously.

By: _/s/ Jameson Dempsey

Jameson Dempsey
Director, Satellite Policy

SPACE EXPLORATION
TECHNOLOGIES CORP.

1 Rocket Road
Hawthorne, CA 90250
310-682-9836 tel

October 11, 2024

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