By Electronic Filing: GN Docket No. 23-135 ICFS File No. SAT-MOD-20230207-00021

November 30, 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; ICFS File No. SAT-MOD-20230207-00021
Dear Ms. Dortch:
SpaceX and T-Mobile are excited to bring their innovative direct-to-cellular partnership to
American consumers, with launches and initial testing scheduled to begin next month. To assist
the Commission’s review of the companies’ applications, SpaceX provided a showing
demonstrating how its supplemental coverage system will bring ubiquitous connectivity without
causing harmful interference to any current or future in-band, out-of-band, or cross-border users. 1
In response to a clarifying question from the Bureau, Exhibits A and B to this letter further
supplement SpaceX’s earlier analysis, demonstrating that SpaceX’s direct-to-cell system will not
cause harmful interference even at the lower-altitude shells in SpaceX’s ITU filings. With a
complete record before it, the Commission should expeditiously grant SpaceX and T-Mobile’s
applications to allow them to rapidly deploy supplemental coverage to consumers everywhere.
Sincerely,
/s/ Jameson Dempsey
Jameson Dempsey
Director, Satellite Policy
SPACE EXPLORATION TECHNOLOGIES CORP.

1 Rocket Road
Hawthorne, CA 90250
Email: Jameson.Dempsey@spacex.com
Phone: +1 (310) 682-9836
Attachments
1
See Letter from Kathyrn J. Medley to William M. Wiltshire, ICFS File No. SAT-MOD-20230207-00021 and GN
Docket No. 23-135 (Nov. 7, 2023); Letter from Jameson Dempsey to Marlene H. Dortch, ICFS File No. SAT-
MOD-20230207-00021 and GN Docket No. 23-135 (Nov. 14, 2023) (“SpaceX Non-Interference Analysis”).
1155 F St NW, Suite 475, Washington, DC 20004 | phone 202.649.2700 | fax 202.649.2701 | spacex.com
Exhibit A
Response to Question 1 – Non-Interference Showing
1. Please provide an interference analysis, including link budgets, for operations in the 1990-
1995 MHz (space-to-Earth) and 1910-1915 MHz (Earth-to-space) bands, calculating the
difference in interference in clear sky and rain fade or cloud cover conditions. This analysis
should take into account the worst case scenario of all satellites transmitting at the same
time, including different power levels required for rain fade and cloud cover as well as clear
sky conditions over a particular area of coverage, and analyze the resultant level of
interference produced and the possibility of loss of service by other authorized satellite and
terrestrial operators in that area. For satellite-to-satellite analysis, provide monte-carlo
simulation results that produce time-based statistics for the level of interference expected to
be seen by other satellite operators operating in the reverse-band mode of operations. These
need not be co-frequency or co-coverage.
SpaceX has carefully designed its direct-to-cell system to provide the best possible
consumer experience while meeting applicable technical limits and non-interference requirements.
The SpaceX system is designed to maintain a constant power flux-density (“PFD”) on the ground,
independent of satellite elevation. As the satellite steers the transmitting beam, it adjusts the
transmit power to maintain a constant PFD at the surface of the Earth, compensating for variations
in antenna gain and path loss associated with the steering angle. Further, SpaceX’s topology
software incorporates applicable geographic borders to ensure that the aggregate emissions do not
cause harmful interference to any in-band or out-of-band user. In this further supplement, SpaceX
demonstrates that it will not cause harmful interference even in the lower-altitude shells in its
direct-to-cell ITU filings and at the full constellation size for those altitudes.
(1) SpaceX Direct-to-Cell Link Budget
The link budgets below show the EIRP density for 340 km and 360 km altitudes and four
representative elevation values: 90, 60, 37, and 25.9 degrees. All link budgets are representative
for clear sky conditions. The satellites transmit at the same power levels under rain fade
conditions, so the PFD on the ground and C/(N+I) (where “I” accounts for self-interference) will
be slightly lower under rain fade. SpaceX presents four link budget variants below for a PFD on
the ground ranging from -89.5 dBW/m2/MHz up to -80 dBW/m2/MHz.
The following characteristics apply to all downlink link budgets (340 km altitude):
DL Frequency [MHz] 1990

Sat Altitude [km] 340.0
UE Rx Gain [dBi] -8.0
UE Noise Figure [dB] 7.0
Satellite Tx EVM at Max Power [dBc] -35.0
Desense due to self-interference [dB] 2.0
Cell edge definition (relative to cell center) [dB] -5.0
A-1
The remaining characteristics differ depending on the PFD:
PFD = -80 dBW/m2/MHz

Elevation [deg] 90 60 37 25.9
distance to SAT [km] 340.0 389.3 541.8 708.9
Spreading loss [dB] 121.6 122.8 125.7 128.0
Path loss [dB] 149.0 150.2 153.1 155.4
EIRP density @ beam peak [dBW/Hz] -18.4 -17.2 -14.3 -12.0
PFD [dBW/m2/MHz] -80.0 -80.0 -80.0 -80.0
C/(N+I) @ cell center [dB] 19.4 19.4 19.4 19.4
C/(N+I) @ cell edge [dB] 14.5 14.5 14.5 14.5

Path loss [dB] 149.0 150.2 153.1 155.4
PFD [dBW/m2/MHz] -82.0 -82.0 -82.0 -82.0
C/(N+I) @ cell edge [dB] 12.5 12.5 12.5 12.5
PFD = -84.5 dBW/m2/MHz

Path loss [dB] 149.0 150.2 153.1 155.4
PFD [dBW/m2/MHz] -84.5 -84.5 -84.5 -84.5
C/(N+I) @ cell edge [dB] 10.0 10.0 10.0 10.0

Path loss [dB] 149.0 150.2 153.1 155.4
PFD [dBW/m2/MHz] -89.5 -89.5 -89.5 -89.5
C/(N+I) @ cell edge [dB] 5.0 5.0 5.0 5.0
A-2
The following characteristics apply to all downlink link budgets (360 km altitude):
DL Frequency [MHz] 1990

Sat Altitude [km] 360.0
UE Rx Gain [dBi] -8.0
UE Noise Figure [dB] 7.0
Satellite Tx EVM at Max Power [dBc] -35.0
Desense due to self-interference [dB] 2.0
Cell edge definition (relative to cell center) [dB] -5.0
The remaining characteristics differ depending on the PFD:

Path loss [dB] 149.5 150.7 153.6 155.9
PFD [dBW/m2/MHz] -80.0 -80.0 -80.0 -80.0
C/(N+I) @ cell edge [dB] 14.5 14.5 14.5 14.5

Path loss [dB] 149.5 150.7 153.6 155.9
PFD [dBW/m2/MHz] -82.0 -82.0 -82.0 -82.0
C/(N+I) @ cell edge [dB] 12.5 12.5 12.5 12.5

Path loss [dB] 149.5 150.7 153.6 155.9
PFD [dBW/m2/MHz] -84.5 -84.5 -84.5 -84.5
C/(N+I) @ cell edge [dB] 10.0 10.0 10.0 10.0
A-3
Path loss [dB] 149.5 150.7 153.6 155.9
PFD [dBW/m2/MHz] -89.5 -89.5 -89.5 -89.5
C/(N+I) @ cell edge [dB] 5.0 5.0 5.0 5.0
(2) Satellite-to-Satellite In-Band Interference Analysis
SpaceX previously demonstrated that its direct-to-cell operations in its 525, 530, and 535
km shells will not cause harmful interference to any in-band satellite services. Below, it provides
supplemental analysis demonstrating that it also can operate consistent with ITU Radio Regulation
4.4 in the lower altitude shells included in its U.S. and German ITU filings (or any altitude in
between these lower- and higher-altitude shells). As with its previous analysis, this supplemental
analysis uses a Monte Carlo simulation—a probabilistic analysis that propagates the SpaceX
constellation over time and calculates the resulting aggregate interference from randomly-placed
beams from all eligible SpaceX satellites into a single Omnispace satellite at each time step.
As with its initial response, SpaceX assumes the latest values that Omnispace has claimed
for its prospective foreign constellation, a system that exists only on paper based on spectrum
rights that Omnispace has left fallow for a decade. Omnispace now claims that its required
interference power at its satellite receiver is -168.5 dBm/Hz and SpaceX’s analysis considers the
worst possible interference case—i.e., a satellite as close as possible to the continental United
States with a 0 dBi off-axis antenna gain in the direction of SpaceX satellites. SpaceX also uses
EIRP values as measured in the lab to calculate SpaceX’s EIRP towards the Omnispace satellite
under the operating conditions mentioned in each case (PFD on the ground). Because SpaceX’s
satellites do not adjust their transmit power to compensate for rain fade, rain fade does not impact
the results of this simulation.
SpaceX will maintain a maximum PFD level that ensures that it will not cause harmful
interference to other satellite operators, including the system Omnispace claims it will deploy. As
SpaceX deploys its constellation, it can dynamically adjust its PFD level to avoid causing harmful
interference to any other system. Of course, these limits are only relevant to the extent that
SpaceX’s direct-to-cell operations would cause harmful interference to another operational
satellite. The Commission should not harm American consumers by artificially constraining
SpaceX’s PFD levels in a way that arbitrarily limits its service, particularly to satisfy far-fetched
demands by a hypothetical foreign satellite system that claims wildly unrealistic operating
parameters to harm its competitors and may never commercially deploy.
The following four cases provide illustrative examples of how SpaceX can adjust PFD
while remaining below Omnispace’s latest interference threshold even in the worst-case scenario:
A-4
Case # Sat. Altitude PFD Active Typical EIRP Time below
count (km) (dBW/m2/MHz) sats. toward interference
in Omnispace threshold
view Satellite
(dBW/MHz)
1 1320 340 -80 36 12 100%
2 2640 340 -82 71 10 100%
3 5280 340 -84.5 141 7.5 100%
4 19440 340/345/ -89.5 507 2.5 100%
350/360
Each case below relies on a worst-case snapshot in time with the SpaceX satellites in the
constellation at their proposed lower altitudes accounting for the number of active satellites
(providing service to CONUS) in view of the Omnispace satellite. Each case also provides a plot
showing the interfering power density at the Omnispace satellite. The red dotted line in the plot
adopts the interference threshold that Omnispace used in its recent analysis. 1 Due to different PFD
levels at different satellite counts, each case presents slightly different interference levels towards
Omnispace’s satellites. But in all cases, SpaceX can maintain an interference level below
Omnispace’s claimed harmful interference threshold at all times, even under the latest figures in
Omnispace’s shape-shifting analysis.
1
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 at 9-10 (Oct. 20, 2023). Omnispace has since filed a fundamentally flawed
response to SpaceX’s November 14 non-interference showing. See Letter from Mindel De La Torre to Marlene
H. Dortch, GN Docket No. 23-135 and ICFS File No. SAT-MOD-20230207-00021 (Nov. 17, 2023). Because
this latest Omnispace analysis relies on physically impossible parameters and inapposite standards, SpaceX does
not incorporate those parameters here.
A-5
(3) Out-of-Band Interference Analysis
SpaceX’s direct-to-cell operations in the PCS G Block will not cause harmful, out-of-band
interference to any other terrestrial or satellite users. In an earlier analysis, SpaceX demonstrated
that its out-of-band emissions would fall below the thermal noise floor at the ground under either
the Part 24 or Part 25 emissions masks, eliminating any risk of harmful interference to terrestrial
out-of-band users. 2 Since SpaceX will use the same maximum PFD for its lower altitude shells,
this earlier non-interference analysis applies equally at lower altitudes. More recently, SpaceX
has shown that it will not cause harmful out-of-band interference to DISH/TerreStar’s foreign, out-
of-band satellite operations even under the Commission’s Part 25 mask. 3 Below, SpaceX
demonstrates that operations in the 340, 345, 350, and 360 km shells in its direct-to-cell ITU
filings—even at full deployment in those filings—will not cause harmful interference to out-of-
band satellite users.
2
See Consolidated Opposition to Petitions and Response to Comments of Space Exploration Holdings, LLC, GN
Docket No. 23-135 and ICFS File No. SAT-MOD-20230207-00021, at 19-20 (May 30, 2023).
3
See Reply of Space Exploration Holdings, LLC, ICFS File No. SAT-MOD-20230207-00021 (June 2, 2023);
Letter from David Goldman to Marlene H. Dortch, GN Docket No. 23-135 and ICFS File No. SAT-MOD-
20230207-00021, Attachment B at 7 (July 26, 2023).
A-6
Satellite-to-Satellite Out-of-Band Emissions Analysis (19,440-satellite constellation)
Parameter Value Description
OOB antenna input power density [dBW/Hz] -79.0 in 2000-2020MHz band, -43dBW/4kHz per
Section 25.202(f)
SpaceX antenna gain towards TerreStar -10.0 Very conservative gain
satellite [dBi]
OOB EIRP density towards TerreStar -89.0 Based on one SpaceX satellite
[dBW/Hz]
SpaceX max altitude [km] 360.0 The highest orbit is the worst case
TerreStar altitude [km] 35,786.0 Geostationary orbit
Min possible distance [km] 35,426.0 The minimum theoretically possible distance
from SpaceX to TerreStar
Min possible free space path loss [dB] 189.4 Conservatively assumes this path loss for
interference coming from all SpaceX satellites
G/T [dBi/K] 21.5 Per TerreStar Schedule S Tech Report (SAT-

MOD-20070529-00075)
Max possible I/N [dB] (one SpaceX satellite) -28.3 The maximum theoretically possible I/N for
one SpaceX satellite
# of SpaceX satellites within the -4 dB 20 Conservative estimate using TerreStar beam
TerreStar beam contour contours (SAT-MOD-20070529-00075 4)
G/T inside the -4dB contour [dBi/K] 21.5 Conservatively assumes beam peak G/T for all
satellites inside the -4dB contour
# of SpaceX sats in view in between the -4dB 25 Conservative estimate using TerreStar beam
and -10dB beam contours contours (SAT-MOD-20070529-00075)
G/T in between the -4dB and -10dB contours 17.5 Conservatively assumes -4dB for all satellites
[dBi/K] in between the -4dB and -10dB contours
# of SpaceX satellites in view outside the - 6,200 One third of all SpaceX satellites may be
30dB beam contour visible from TerreStar
G/T outside the -30dB contour [dBi/K] -8.50 Conservatively assumes -30dB for all satellites
outside the -30dB contour
Aggregate I/N [dB] -13.27 Very conservative estimate for aggregate
interference from all SpaceX satellites
4
SpaceX’s previous analysis referenced SAT-MOD-20230207-00021 in this table, rather than the correct SAT-
MOD-20070529-00075. In all cases, the appropriate TerreStar reference is SAT-MOD-20070529-00075.
A-7
Exhibit B
Response to Question 2 - Coverage Maps
SpaceX will use its innovative direct-to-cell antennas and topology software to comply
with applicable cross-border limits in the PCS G Block, regardless of satellite altitude. As such,
the coverage maps that SpaceX provided in its previous analysis will still apply at lower altitudes. 1
The contours of individual SpaceX direct-to-cell beams will depend on their elevation angle, which
may differ slightly for lower altitude operations. SpaceX provides four representative downlink
beam contours for its 340 km shell at elevation angles of 25, 34.3, 60, and 90 degrees.
1
See SpaceX Non-Interference Analysis, Exhibit B at B-2 – B-3.
B-1

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November 30, 2023

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

Dear Ms. Dortch:

SPACE EXPLORATION TECHNOLOGIES CORP.

(1) SpaceX Direct-to-Cell Link Budget

DL Frequency [MHz] 1990

PFD = -80 dBW/m2/MHz

PFD = -82 dBW/m2/MHz

PFD = -84.5 dBW/m2/MHz

PFD = -89.5 dBW/m2/MHz

DL Frequency [MHz] 1990

The remaining characteristics differ depending on the PFD:

PFD = -80 dBW/m2/MHz

PFD = -82 dBW/m2/MHz

PFD = -84.5 dBW/m2/MHz

(2) Satellite-to-Satellite In-Band Interference Analysis

G/T [dBi/K] 21.5 Per TerreStar Schedule S Tech Report (SAT-

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