ATTACHMENT A

TECHNICAL INFORMATION TO SUPPLEMENT SCHEDULE S

This attachment contains the information required for SpaceX’s proposed operations of

space stations on its Starship launch vehicles—including its standard Ship, tanker, propellant

depot, and Human Landing System (“HLS”) variants—that cannot be fully captured by the

associated Schedule S.

A.1 ORBITAL PARAMETERS

In this application, SpaceX requests authority to launch and operate space stations on its

Starship vehicle variants. Authorization will support a series of missions including but not limited

to those in preparation for and in support of NASA’s Artemis program, including Artemis III and

IV, in which SpaceX will safely deliver astronauts to and from the lunar surface. Starship is a two-

stage reusable super-heavy launch vehicle. The second stage of Starship will have several variants,

including the standard Ship, a tanker used for in-orbit refueling, a propellant depot, and an HLS

optimized for lunar landing missions. These variants will have certain mission-specific

optimizations including, for example, landing thrusters located mid-body on the HLS variant to

limit any disturbance to the lunar surface from the engines’ exhaust plumes. Consistent with its

other spacecraft, SpaceX will employ an iterative design for Starship. As such, SpaceX seeks

authority to operate the space stations requested in this application on current or future versions of

Starship.

Individual missions will include one or more broad categories, each of which will occur in

a range of orbital altitudes and inclinations. The duration and number of simultaneous space

station operations during each mission and mission phase will vary. Depending on the mission,

operations could last several hours or, for longer-term missions to the Moon and beyond, months

or even years.

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 Low Earth Orbit. SpaceX will conduct a range of Starship operations in low-Earth orbit

(“LEO”). Each fully reusable Starship spacecraft is capable of carrying up to 150 metric tons to

Earth orbit, and this authorization will enable SpaceX to reliably launch and deploy satellites to

support broadband, mobile connectivity, earth observation, science, and other use cases that will

benefit humanity. Missions beyond LEO will also require a tanker version of Starship for

propellant aggregation. During these missions, SpaceX will launch one or more propellant tanker

versions of Starship. Some of these tanker variants will remain in LEO as “depots,” and will be

filled with propellant by subsequent tanker launches. LEO operations will occur in a circular orbit

at 281 km altitude (+/- 100 km) and an inclination ranging from equatorial (0 degrees) to polar.

Medium-Earth Orbit/High-Earth Orbit/Final Tanking Orbit. Missions beyond LEO will

also require space station operations in medium-Earth orbit (“MEO”) to high-Earth orbit (“HEO”).

For example, crewed lunar missions will include a secondary propellant transfer in MEO/HEO,

the Final Tanking Orbit (“FTO”). Operations in MEO/HEO will occur in an elliptical orbit of 281

km x 34,534 km and an altitude tolerance of +116,000/-24,000 km apogee and +/- 100 km perigee,

with inclination between 28 and 33 degrees (+/- 2 degrees).

Translunar Injection and Coasting. Missions beyond MEO/HEO may include Trans-

lunar Injection (“TLI”) and a coasting phase toward the lunar region. The TLI will always be in

the perigee of orbit in LEO as shown in Error! Reference source not found..

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 Figure 1. Conceptual representation of propellant aggregation, propellant transfer, TLI and trans-lunar coast orbits

Lunar orbit. Lunar missions of Starship will include space station operations in lunar orbit

including in Near Rectilinear Halo Orbit (“NRHO”) and Low Lunar Orbit (“LLO”). NRHO orbit

around the moon has perilune of ~3,000 km and apolune of ~70,000 km. NRHO orbital plane is

perpendicular to the Earth-Moon vector. LLO has a circular orbital altitude of ~120 km above the

lunar surface.

Lunar descent, ascent, and surface. Lunar missions, such as the Uncrewed Demo,

Artemis III, and Artemis IV missions, may also include space station operations while descending

from LLO and landing on the lunar surface, operations on the lunar surface, and operations during

ascent from the lunar surface to LLO.

Figure 2 shows a conceptual representation of a mission incorporating all five categories

of orbits, although any given mission may incorporate one or more of these orbits:

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 Figure 2. Artemis III Concept of Operations1

A.2 SPACE STATION OVERVIEW

Starship spacecraft will carry various space stations using a range of frequency bands for

communications and telemetry, tracking, and command (“TT&C”). These radios fall into several

categories. Below SpaceX describes the space stations for which SpaceX seeks authority in this

application, the orbits in which they will operate, and the general uses of those space stations.

A.2.a UHF Band

Starship HLS lander will carry four UHF radios that will be used for communication with

astronauts during extravehicular activities (“EVAs”) on the surface of the moon. Each radio is

connected to a single low-gain UHF antenna with hemispherical coverage equally spaced around

the perimeter of the lander, operating in both transmit and receive mode in half duplex TDMA.

The maximum range of operation for the UHF system is a radius of 2 km from the lander. The

UHF antenna pattern (gain vs elevation angle) is shown in Figure 3 for two azimuthal cuts of 0

1
‘Human Landing System,’ Kent Chojnacki, NASA Marshall Space Flight Center, IEEE Aerospace Conference,
Big Sky, Montana 2022.

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and 90 degrees.

Figure 3. UHF antenna pattern

A.2.b S Band

Starship and its variants will use S-band frequencies for communications directly between

the spacecraft and Earth and between multiple spacecraft during proximity operations.

Starship’s second-stage Ship, including its tanker and depot variants, has four low-gain

hemispherical S-band transmit and four low-gain hemispherical S-band receive antennas located

around the perimeter of the spacecraft and used for Space-to-Earth, Earth-to-Space, and Space-to-

Space communication in LEO (for tanker and depot) and MEO/HEO (for depot).

Starship’s HLS lander variant has two low-gain hemispherical S-band transmit antennas

and two low-gain hemispherical S-band receive antennas located around the perimeter of the

lander on opposite sides, 180 degrees apart. These antennas will be used in LEO and MEO/HEO

for Space-to-Earth, Earth-to-Space, and Space-to-Space communication with the Starship depot

variant.

Additionally, HLS lander has sixteen low-gain S-band antennas (transmit and receive)

grouped in four antenna pods spaced equally around the perimeter of the lander (one pod in each

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quadrant). These low-gain antennas will be used during the lunar phase including trans-lunar

coasting, NRHO, LLO, lunar descent, landing, and ascent, as well as on the lunar surface for TT&C

between lander and ground stations and as proximity TT&C between HLS lander and Orion or

Gateway.

HLS Lander also has four high-gain dual band dish antennas that operate in S-band and

Ka-band. These four high-gain dual-band dish antennas are equally spaced around the perimeter

of the lander (one in each quadrant). The high-gain S-band antenna will be used as a backup for

Direct with Earth (“DWE”) TT&C, backup for proximity TT&C, primary for high-data rate

downlink to ground stations, and primary for long-range low-data rate communication with

Gateway.

i. LEO/MEO/HEO Low-Gain S-Band Space Stations

Starship will operate several S-band space stations with low-gain hemispherical antennas.

These space stations will operate in LEO and MEO/HEO for Space-to-Earth and Earth-to-Space

telemetry/data and commanding as well as Space-to-Space telemetry and commanding between

two Starship vehicles and NASA’s Tracking and Data Relay Satellite System (“TDRSS”).

Communication with TDRSS satellites will only be utilized by the lander and depot in the final

tanking orbit when either vehicle is above an altitude of approximately 300 km.

Each Starship will utilize two channels for downlink (Space-to Earth), one channel for

uplink (Earth-to-Space), one channel for ship-to-ship (Space-to-Space) return link transmit (RSRT

beam), one channel for Space-to-Space forward link transmit (RSFW beam), one channel for

Space-to-Space return link receive (RSTN beam), one channel for Space-to-Space forward link

receive (RSFD beam), one channel for TDRSS Space-to-Space return link transmit (except tanker)

and one channel for TDRSS Space-to-Space forward link receive (except tanker).

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 Tanker and HLS lander share the same frequency channels for uplink, downlink and

proximity link with depot. When all three types of Starship vehicles are in orbit, lander will not

be using its proximity link and tanker will utilize the frequencies for its proximity link with depot

rendezvous. In this scenario, lander will only utilize one of its S-band downlink telemetry channels

and the tanker will also only use one S-band downlink channel, keeping the total amount of

allocated aggregate bandwidth in S-band constant. The LEO/MEO/HEO S-band radios will be

inactive in the lunar region and their S-band channels will be reused for lunar S-band

communication system.

Table 1 shows the number of transmit and receive channels for each Starship vehicle plus

the total number of unique channels requested for all vehicles.

Table 1. Number of transmit and receive S-band channels in LEO and MEO/HEO
Starship Number of transmit channels Number of receive channels
Starship 2 2
Tanker 3 3
Depot 4 3
HLS Lander 4 3
Total (Max) 7 3

S-band antenna patterns used in LEO/MEO/HEO operations for transmit and receive are

shown in Figure 4 and 5, respectively, for two azimuthal angles, 0 and 90 degrees.

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 Figure 4. Antenna pattern for (tanker, depot, lander) low-gain S-band transmit antenna used in LEO and MEO/HEO

Figure 5. Antenna pattern for (tanker, depot, lander) low-gain S-band receive antenna used in LEO and MEO/HEO

ii. Lunar Low-Gain S-band Space Stations

Starship HLS lander will carry four S-band radios (different from LEO/MEO/HEO S-band

radios) that will be used for DWE TT&C during trans-lunar coasting as well as in lunar regions.

These radios will also be used for the proximity communication, two-way ranging and Doppler

tracking with Orion and Gateway in the lunar region. Each radio is connected to four antennas

resulting in a total of sixteen hemispherical S-band antennas. A maximum of three of these

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antennas will be transmitting at any given time (two for DWE TT&C and one for Orion/Gateway

proximity communication and ranging).

The HLS lander lunar S-band communication system will be used for coherent radiometric

ranging. The downlink frequencies are related to the uplink frequencies by a factor of 240/221. S-

band antenna patterns used in lunar operations for transmit and receive are shown in Figures 6 and

7, respectively, for two azimuthal angles, 0 and 90 degrees.

Figure 6. Antenna pattern for HLS lander low-gain S-band transmit antenna

Figure 7. Antenna pattern for HLS lander low-gain S-band receive antenna

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iii. Lunar High-Gain S-band Space Stations

Starship HLS lander will carry four S-band radios connected to four dual-band gimbaled

parabolic reflector antennas. These radios will provide backup for:

i) DWE TT&C during trans-lunar coasting and the lunar region;

ii) Proximity communication and ranging;
iii) Long range bidirectional TT&C with Gateway in lunar vicinity; and
iv) Data and video downlink to Earth during dynamic phases of flight.

Table 2 shows the maximum number of lunar S-band transmit and receive channels used for

overall missions including primary and backup S-band systems for DWE and lunar region

proximity with Orion/Gateway and long-range communication with Gateway.

Table 2. Maximum number of transmit and receiver for lunar S-band systems
Starship Number of transmit channels Number of receive channels
Lander 5* 3
* Maximum 3 channels for DWE downlink

Directional S-band high-gain antenna patterns used in lunar operations for transmit and

receive are shown in Figures 8 and 9, respectively, for two azimuthal angles, 0 and 90 degrees.

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Figure 8. Antenna pattern for HLS lander high-gain S-band transmit antenna

Figure 9. Antenna pattern for HLS lander high gain S-band receive antenna

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 A.2.c Ku-band Space Stations

Starship variants will communicate via the SpaceX Starlink constellation while in LEO to

support bidirectional high-speed telemetry and commanding as well as high-definition engineering

videos of the interior and exterior of Starship. Starship tanker and depot will carry four phased

array Ku-band radios and Starship HLS lander will carry two of these radios. These radios are

exclusively used during launch, ascent, LEO, reentry, and landing (only for tanker) for

bidirectional high-data rate communication with the Starlink satellite constellation. During launch,

ascent and reentry (only for tanker), all available Ku radios will be actively communicating with

Starlink when beam coverage allows. LEO Ku radios will be inactive above 300 km and during

the lunar phase of mission.

Antenna patterns for the Starship Ku-band antenna is enveloped by ITU-R AP8 (pattern

name: APERR_001V01).

A.2.d Lunar High-Gain Ka-band Space Stations

Starship HLS lander will carry four Ka-band radios connected to four dual-band gimbaled

parabolic reflector antennas. These four high-gain dual-band dish antennas are equally spaced

around the perimeter of lander (one in each quadrant).

The Ka-band dish will be used for DWE communication throughout transit, lunar region

(NRHO and LLO), lunar descent, landing, ascent, and lunar surface. The Ka high-gain antenna

will also be used for the long-range communication with Gateway in lunar region (NRHO, LLO,

descent, landing, ascent, and lunar surface). HLS lander will use one uplink and one downlink

channel during all phases except the lunar surface, which will switch to one uplink and two

downlink channels. Table 3 shows the maximum number of lunar Ka-band transmit and receive

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channels used for combination of DWE communication and long-range high data rate with

Gateway, including two transmit channels for DWE downlink, two transmit channels for lunar

long range return link to Gateway, one receive channel for DWE uplink, and two receive channels

for lunar long-range communication with Gateway forward link.

Table 3. Maximum number of transmit and receiver for lunar Ka-band systems
Starship Number of transmit channels Number of receive channels
Lander 4* 3
* Maximum 2 channels for DWE downlink

SpaceX will use the Ka-band for DWE communications (in 22.55 – 23.15 GHz and 25.5 –

27 GHz) and between Starship/HLS and Lunar Gateway (in 23.15 – 23.55 GHz and 27 – 27.5

GHz).

Figures 10 and 11 show Ka-band directional antenna patterns in two principle azimuthal

cut plane of 0 and 90 degrees are shown in for transmit and receive frequency bands, respectively.

A single dish can operate simultaneously in transmit and receive mode.

Figure 10. Ka-band directional transmit antenna pattern

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 Figure 11. Ka-band directional receive antenna pattern

A.2.e Lunar Landing Radar

Starship HLS lander will carry two radars operating in 35.5-36 GHz band. The pulse

Doppler radar will be used during lunar landing from 4 km altitude above lunar surface until

touchdown for altimetry and velocimetry. Each radar will be connected to three antennas

providing a total of 6 antenna beams pointed toward the aft of lander.

Radar continuously transmits RF pulses with a duty cycle of 0.08% -- 1.25% and pulse

repetition frequency of 15.625 kHz during this time and measures the reflected signal to determine

vehicle altitude and velocity. Radars will be turned off once the spacecraft touches down on the

lunar surface. Active transmit duration will be less than 5 minutes.

Radar will also be powered up a few times in the mission for system health checkouts

(including in LEO, trans-lunar coasting, and LLO). Landing radar antenna pattern operating in

Ka-band is shown in Figure 12. Each radar is connected to three antennas on each side of HLS

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lander (total six antennas). The beams are pointing approximately toward the aft of HLS lander

and used for altimetry and velocimetry during lunar landing.

Figure 12. Landing radar antenna pattern

A.2.f 5.8 GHz Lunar Surface Wireless Communication

In addition to UHF, SpaceX plans to use lunar surface wireless communications during

EVAs in the 5.8 GHz band (5.735 – 5.875 GHz) using the IEEE 802.11ac protocol. NASA’s

Artemis program requires this surface communication, and frequency use will be coordinated with

NASA.

Communications in the 5.8 GHz band will occur between the HLS lander space station

and communication devices that will be carried either by astronauts during EVA or by rovers and

other fixed or mobile assets in the vicinity of HLS lander and up to a radius of 2 km from the HLS

lander. SpaceX will use these links to transmit high-resolution videos and images for scientific

investigation of lunar regions.

Each radio will be connected to a single low-gain 5.8 GHz antenna with hemispherical

coverage equally spaced around the perimeter of the lander, operating in both transmit and receive

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mode in half duplex TDD. Figure 13 shows the antenna pattern for 5.8 GHz lunar surface in two

principle azimuthal planes.

Figure 13. 5.8 GHz antenna pattern for LGAWTX and LGARX beams

A.3 EARTH STATION OVERVIEW

A.3.a Earth Orbit S-band Earth Stations

S-band space stations in Earth orbit will communicate with a distributed network of earth

stations in the United States and around the world. SpaceX identifies these earth stations below

in Table 4 (Any additional earth station sites or changes to this list will be identified):

Table 4. List of S-band Earth Stations used during LEO/MEO/HEO phases

Class Provider Location Latitude (deg) Longitude (deg) Size (m)
Small S-band SpaceX USA 27.832054 -97.049767 0.9
Small S-band SpaceX USA 29.5597063 -95.1152401 0.9
Small S-band SpaceX USA 30.0195 -89.9189 0.9
Small S-band SpaceX USA 24.552753 -81.789639 0.9
Small S-band SpaceX South Africa -25.88686899 27.70763045 0.9
Commercial S-band Partner South Africa -25.886985 27.706665 10
Medium S-band SpaceX USA 26.06948151 -97.19440456 1.8
Small S-band SpaceX USA 18.19105552 -65.83785801 0.9
Small S-band SpaceX USA 25.965806 -97.244369 0.9
Small S-band SpaceX USA 25.986268 -97.187904 0.9

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Medium S-band SpaceX Bermuda 32.3143 -64.7488 3.7
Medium S-band SpaceX USA 28.6235 -80.6864 3.7
Medium S-band SpaceX Mexico 22.263333 -97.796421 1.8
Commercial S-band Partner Mauritius -20.5014 57.4506 7.3
Medium S-band SpaceX USA 13.2823 144.7554 3.7
Medium S-band SpaceX USA 34.565574 -120.500392 3.7
Medium S-band SpaceX USA 33.920506 -118.326001 1.4
Medium S-band SpaceX Maldives -0.614334 73.09665 5
Medium S-band SpaceX USA 20.817143 -156.4542956 1.4
Medium S-band SpaceX Australia -10.553735 105.6512 1.8
Commercial S-band Partner Singapore 1.3962 103.8343 9
Medium S-band SpaceX Oman 23.566443 58.162079 1.8
Medium S-band SpaceX Kenya 1.349995 36.749642 1.8
Medium S-band SpaceX Sri Lanka 7.9365 79.745417 1.8
Medium S-band SpaceX Brazil -3.735322 -38.461674 1.8

A.3.b Lunar S-band Earth Stations

S-band TT&C earth stations used during the lunar phase of mission for HLS lander will

be a combination of Deep Space Network and commercial 13-meter stations as shown in the

Table 5 (Any additional earth station sites or changes to this list will be identified).

Table 5. List of lunar S-band Earth Stations

Class Provider Location Latitude Longitude (deg) Size (m)
(deg)
DSN 34 m NASA Goldstone, CA, USA 35.15853 -116.875 34
DSN 34 m NASA Goldstone, CA, USA 35.15434 -116.873 34
DSN 34 m NASA Madrid, Spain 40.23577 -4.2541 34
DSN 34 m NASA Madrid, Spain 40.42596 -4.25206 34
DSN 34 m NASA Canberra, Australia -35.217 148.982 34
DSN 34 m NASA Canberra, Australia -35.214 148.979 34
13 m S-band SSC/SANSA Hartebeesthoek, SA -25.887 27.7074 12
13 m S-band SSC Dongara, Australia -29.0458 115.3487 13
13 m S-band SSC South Point, Hawaii 19.0139 -155.663 13
13 m S-band SSC Santiago, Chile -33.1514 -70.6681 12
13 m S-band SSC Inuvik, Canada 68.31784 -133.538 13

A.3.c Ka-band Earth Stations

Ka-band earth stations used during the lunar phase of mission for HLS lander will be a

combination of DSN, SpaceX 1.8 m, and commercial stations as shown in Table 6 (Any

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additional earth station sites or changes to this list will be identified).

Table 6. List of Ka-band Earth Stations used during lunar phases

Class Provider Location Latitude (deg) Longitude (deg) Size (m)
DSN 34 m NASA Goldstone, CA, USA 35.1585346 -116.875 34
DSN 34 m NASA Goldstone, CA, USA 35.1543409 -116.873 34
DSN 34 m NASA Madrid, Spain 40.2357726 -4.2541 34
DSN 34 m NASA Madrid, Spain 40.42596 -4.25206 34
DSN 34 m NASA Canberra, Australia -35.21698 148.982 34
DSN 34 m NASA Canberra, Australia -35.214 148.979 34
SX 1.8m Ka SpaceX Hawthorne, USA 33.9206 -118.328 1.85
SX 1.8m Ka SpaceX Tasmania, Aus. -42.4307 147.2882 1.85
SX 1.8m Ka SpaceX Oman, Oman 20.61022 56.3789 1.85
SX 1.8m Ka SpaceX Santiago, Chile -33.151389 -70.6681 1.85
Commercial SpaceX/Partner Weilheim, Germany 47.881208 11.07833 13
Commercial SpaceX/Partner Latvia 57.559328 21.84735 16
Commercial SpaceX/Partner Madrid, Spain 40.2357726 -4.2541 20
Commercial SpaceX/Partner New Mexico, USA 32.5408 -106.612 20
Commercial SpaceX/Partner West Australia -29.010029 115.3417 20
Commercial SpaceX/Partner Punta Arenas, Chile -52.9381 289.1428 11
Commercial SpaceX/Partner Troll, Antarctica -72.0022 2.0575 7.3

A.4 POWER FLUX DENSITY COMPLIANCE

A.4.a S-band Power Flux Density

S-band does not have any specific power flux density (“PFD”) requirement in Section

25.208. However, SpaceX is providing the technical information that shows the Starship radios

including stations on depot, tanker, and HLS lander will conform to the NTIA’s PFD limits2 in S-

band for space stations during Earth orbit and lunar phases of missions. A few examples of PFD

levels and compliance performance for low-altitude phase of flights, LEO, and near-Earth lunar

phases of missions are shown in Figures 14-16. PFD values for all transmit S-band beams are

included in the Schedule S.

2
Manual of Regulations and Procedures for Federal Radio Frequency Management, NTIA 2022, Section 8.2.36.

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Figure 14. S-band PFD at low-altitude (beam RSTXA)

Figure 15. S-band PFD in LEO (beam RSTXL)

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 Figure 16. Low-gain S-band PFD for near Earth TT&C (beam LGASNETX)

A.4.b Ku-band Power Flux Density

Frequency band 14-14.5 GHz used by Starship radios does not have any specific PFD

requirement in Section 25.208 for space station operations. However, Starship radios will comply

with the Section 25.228(i) PFD limits for ESIMs when operating at altitudes of 37 km and higher

including LEO (at altitude of 281 km) for the transmit beams. The PFD levels vs elevation angle

for altitudes of 37 km, 100 km, and 281 km are shown in Figure 17.

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Figure17. Ku-band transmit PFD for KUTX beam for several altitudes

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 A.4.c Ka-band Power Flux Density

i. Frequency range 25.5-27.5 GHz

Ka-band radios in 25.5-27.5 GHz on HLS lander meet the PFD specified in Section

25.208(p) during all phases of mission and for all modes and bandwidths. Examples of PFD

density vs angle of arrival above horizontal plane on Earth’s surface is shown for a few transmit

beams in Figures 18-22. PFD values for all transmit Ka-band beams are included in the Schedule

S.

Figure 18. Ka-band KTX1 beam PFD

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Figure 19. Ka-band KTX4 beam PFD

Figure 20. Ka-band KTX5 beam PFD

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 Figure 21. Ka-band KTX6 beam PFD

Figure 22. Ka-band KPRTN4 beam PFD

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 ii. Frequency range 35.5-36 GHz

HLS lander will use 35.5-36 GHz for landing radar. This frequency band does not have

any specific PFD requirement in Section 25.208. However, as shown in the Schedule S for this

application, the landing radar will conform to ITU footnote 5.549A for Space Research in this

band and meets the -73.3 dBW/m2 on Earth’s surface above 0.8o from the beam center for beams

RDRCTX and RDRTX when operating low power hardware in-flight checkouts or full power

lunar landing, respectively. For example, the maximum PFD for HLS radar in orbit checkout at

0.8o is -79 dBW/m2 which has 5.7 dB margin to the ITU footnote 5.549A limit. The maximum

PFD of HLS radar during lunar landing reduces to -142.2 dBW/m2, which has 68.9 dB margin to

the ITU footnote 5.549A limit.

A.4.d 5.8 GHz Lunar Surface Wireless Power Flux Density

The PFD on Earth’s surface for this link is maximum -237.2 dBW/m2/4 kHz. Assuming a

maximum interfered-with Wi-Fi antenna gain of 10 dBi on Earth’s surface, the maximum power

spectral density at receiver antenna output will be approximately -300 dBW/Hz which is 98 dB

below thermal noise floor at ambient temperature (-204 dBW/Hz). This considerable margin

shows that HLS lander wireless links will protect all terrestrial users in ISM bands, even with

significant variation in the receiver antenna gain or system noise temperature compared to the

calculations above.

A.5 COORDINATION WITH U.S. GOVERNMENT NETWORKS

Starship will use several frequency bands shared with federal users, including in the UHF

band, S-band, and Ka-band. In anticipation of filing this application, SpaceX has collaborated

closely with NASA to ensure that this application strikes an appropriate balance between securing

necessary spectrum to achieve mission success and protecting important federal assets from

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harmful interference. To that end, SpaceX will coordinate its operations with federal users in

shared bands and will operate consistent with the coordination arrangements that it reaches with

federal agencies. Because this coordination will occur on an ongoing basis and may require

SpaceX to use different channels within a given frequency range for individual missions depending

on federal agency needs, SpaceX has requested authority for the entire relevant frequency band

(e.g., 2200 – 2290 MHz), rather than specific channels within that range. Authority to operate in

any channel within the requested frequency ranges will provide necessary flexibility for SpaceX

and federal agencies—as well as other non-federal users that seek to use those bands—to deconflict

individual launches and missions under this Part 25 license. In any event, SpaceX will only operate

in these shared bands as coordinated with federal agencies.

A.6 ITU FILINGS FOR SPACEX

SpaceX has not yet submitted system information for ITU publication. SpaceX will submit

this information at the appropriate time and will unconditionally accept all consequent ITU cost-

recovery responsibility for the filing.

A.7 ORBITAL DEBRIS MITIGATION

Below, SpaceX details its compliance with the Commission’s orbital debris rules:

Rule Subsection Rule Text Starship Part 25

25.114(d)(14) A description of the design and operational See Section A1 above.

strategies that will be used to mitigate orbital
debris, including the following information:

25.114(d)(14)(i) A statement that the space station operator has Covered in NASA HLS
assessed and limited the amount of debris released ODAR submissions and
in a planned manner during normal operations. therefore reviewed and
Where applicable, this statement must include an assessed in coordination with
orbital debris mitigation disclosure for any separate NASA.
deployment devices, distinct from the space station

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 launch vehicle, that may become a source of orbital
debris.

25.114(d)(14)(ii) A statement indicating whether the space station Covered in NASA HLS
operator has assessed and limited the probability ODAR submissions and
that the space station(s) will become a source of therefore reviewed and
debris by collision with small debris or meteoroids assessed in coordination with
that would cause loss of control and prevent NASA.
disposal. The statement must indicate whether this
probability for an individual space station is 0.01 (1
in 100) or less, as calculated using the NASA
Debris Assessment Software or a higher fidelity
assessment tool.

25.114(d)(14)(iii) A statement that the space station operator has Covered in NASA HLS
assessed and limited the probability, during and ODAR submissions and
after completion of mission operations, of therefore reviewed and
accidental explosions or of release of liquids that assessed in coordination with
will persist in droplet form. This statement must NASA.
include a demonstration that debris generation will
not result from the conversion of energy sources on
board the spacecraft into energy that fragments the
spacecraft. Energy sources include chemical,
pressure, and kinetic energy. This demonstration
should address whether stored energy will be
removed at the spacecraft's end of life, by depleting
residual fuel and leaving all fuel line valves open,
venting any pressurized system, leaving all
batteries in a permanent discharge state, and
removing any remaining source of stored energy,
or through other equivalent procedures
specifically disclosed in the application.

25.114(d)(14)(iv) A statement that the space station operator has Covered in NASA HLS
assessed and limited the probability of the space ODAR submissions and
station(s) becoming a source of debris by collisions therefore reviewed and
with large debris or other operational space assessed in coordination with
stations. NASA.

25.114(d)(14)(iv)( Where the application is for an NGSO space See below.

A) station or system, the following information must
also be included:

25.114(d)(14)(iv)( A demonstration that the space station operator has Large debris collision
A)(1) assessed and limited the probability of collision avoidance for Starship satellite
between any space station of the system and other deployment missions will be
large objects (10 cm or larger in diameter) during covered by launch COLA
the total orbital lifetime of the space station, screening conducted in
including any de-orbit phases, to less than 0.001 (1 accordance with FAA launch
in 1,000). The probability shall be calculated using licensing.
the NASA Debris Assessment Software or a higher
fidelity assessment tool. The collision risk may be Longer duration Starship
assumed zero for a space station during any period missions will be covered in-

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 in which the space station will be maneuvered depth in NASA HLS ODAR
effectively to avoid colliding with large objects. submissions and therefore
reviewed and assessed in
coordination with NASA.

25.114(d)(14)(iv)( The statement must identify characteristics of the Starship will use orbits below
A)(2) space station(s)' orbits that may present a collision ISS for orbital insertion,
risk, including any planned and/or operational parking and orbital refilling.
space stations in those orbits, and indicate what
steps, if any, have been taken to coordinate with
the other spacecraft or system, or what other
measures the operator plans to use to avoid
collision.

25.114(d)(14)(iv)( If at any time during the space station(s)' mission All Starship trajectories that
A)(3) or de-orbit phase the space station(s) will transit transit through the orbits of
through the orbits used by any inhabitable inhabitable spacecraft will be
spacecraft, including the International Space screened for conjunctions in
Station, the statement must describe the design and coordination with NASA and
operational strategies, if any, that will be used to covered in-depth in NASA
minimize the risk of collision and avoid posing any HLS ODAR submissions and
operational constraints to the inhabitable therefore reviewed and
spacecraft. assessed in coordination with
NASA.

25.114(d)(14)(iv)( The statement must disclose the accuracy, if any, The accuracy of Starship
A)(4) with which orbital parameters will be maintained, orbital parameters and the
including apogee, perigee, inclination, and the right efficacy of its propulsion
ascension of the ascending node(s). In the event system are covered in NASA
that a system is not able to maintain orbital HLS ODAR submissions and
tolerances, e.g., its propulsion system will not be therefore reviewed and
used for orbital maintenance, that fact must be assessed in coordination with
included in the debris mitigation disclosure. Such NASA.
systems must also indicate the anticipated
evolution over time of the orbit of the proposed
satellite or satellites. All systems must describe the
extent of satellite maneuverability, whether or not
the space station design includes a propulsion
system.

25.114(d)(14)(iv)( The space station operator must certify that upon Starship launch collision
A)(5) receipt of a space situational awareness conjunction avoidance screening is
warning, the operator will review and take all covered by Launch COLA
possible steps to assess the collision risk, and will screening per FAA launch
mitigate the collision risk if necessary. As licensing requirements.
appropriate, steps to assess and mitigate the
collision risk should include, but are not limited to: All longer duration operations
Contacting the operator of any active spacecraft are covered in NASA HLS
involved in such a warning; sharing ephemeris data ODAR submissions and
and other appropriate operational information with therefore reviewed and
any such operator; and modifying space station assessed in coordination with
attitude and/or operations. NASA.

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25.114(d)(14)(iv)( Where a space station requests the assignment of a N/A
B) geostationary orbit location, it must assess whether
there are any known satellites located at, or Starship will not operate in
reasonably expected to be located at, the requested geostationary orbit.
orbital location, or assigned in the vicinity of that
location, such that the station keeping volumes of
the respective satellites might overlap or touch. If
so, the statement must include a statement as to the
identities of those satellites and the measures that
will be taken to prevent collisions;

25.114(d)(14)(v) A statement addressing the trackability of the space Due to Starship's size, it is
station(s). Space station(s) operating in LEO will presumed trackable.
be presumed trackable if each individual space
station is 10 cm or larger in its smallest dimension,
excluding deployable components. Where the
application is for an NGSO space station or system,
the statement shall also disclose the following:

25.114(d)(14)(v)( How the operator plans to identify the space Starship will submit
A) station(s) following deployment and whether space propagated ephemerides with
station tracking will be active or passive; covariance to NASA and/or
the U.S. screening authority
(either 18SDS or Office of
Space Commerce).
Full details covered in NASA
HLS ODAR submissions and
therefore reviewed and
assessed in coordination with
NASA.

25.114(d)(14)(v)( Whether, prior to deployment, the space station(s) Starship will be registered
B) will be registered with the 18th Space Control with 18SDS or successor
Squadron or successor entity; and entity.

25.114(d)(14)(v)( The extent to which the space station operator All Starship information will
C) plans to share information regarding initial be shared with 18SDS or its
deployment, ephemeris, and/or planned maneuvers successor entity and NASA.
with the 18th Space Control Squadron or successor
entity, other entities that engage in space
situational awareness or space traffic management
functions, and/or other operators.

25.114(d)(14)(vi) A statement disclosing planned proximity Starship proximity operations

operations, if any, and addressing debris generation will be covered in detail in
that will or may result from the proposed NASA HLS ODAR
operations, including any planned release of debris, submissions and therefore
the risk of accidental explosions, the risk of reviewed and assessed in
accidental collision, and measures taken to mitigate coordination with NASA.
those risks.

25.114(d)(14)(vii) A statement detailing the disposal plans for the N/A

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 space station, including the quantity of fuel—if
any—that will be reserved for disposal maneuvers. Starship will not be disposed
In addition, the following specific provisions of in Earth orbit.
apply:

25.114(d)(14)(vii)( For geostationary orbit space stations, the N/A

A) statement must disclose the altitude selected for a
disposal orbit and the calculations that are used in Starship will not operate in
deriving the disposal altitude. geostationary orbit.

25.114(d)(14)(vii)( For space stations terminating operations in an N/A

B) orbit in or passing through the LEO region below
2,000 km altitude, the statement must disclose Starship will not be disposed
whether the spacecraft will be disposed of through of via atmospheric reentry or
atmospheric re-entry, specifying if direct retrieval direct retrieval.
of the spacecraft will be used. The statement must Contingency operations are
also disclose the expected time in orbit for the covered in NASA HLS ODAR
space station following the completion of the submissions and therefore
mission. reviewed, assessed in
coordination with NASA.

25.114(d)(14)(vii)( For space stations not covered by either paragraph N/A

C) (d)(14)(vii)(A) or (B) of this section, the statement
must indicate whether disposal will involve use of Starship will not use storage
a storage orbit or long-term atmospheric re-entry orbits or long-term re-entry.
and rationale for the selected disposal plan.

25.114(d)(14)(vii)( For all space stations under paragraph (d)(14)(vii) See below.
D) (B) or (C) of this section, the following additional
specific provisions apply:

25.114(d)(14)(vii)( The statement must include a demonstration that N/A

D)(1) the probability of success of the chosen disposal Contingency operations are
method will be 0.9 or greater for any individual covered in NASA HLS ODAR
space station. For space station systems consisting submissions and therefore
of multiple space stations, the demonstration reviewed, assessed in
should include additional information regarding coordination with NASA.
efforts to achieve a higher probability of success,
with a goal, for large systems, of a probability of
success for any individual space station of 0.99 or
better. For space stations under paragraph
(d)(14)(vii)(B) of this section, successful disposal
is defined as atmospheric re-entry of the spacecraft
within 25 years or less following completion of the
mission. For space stations under paragraph
(d)(14)(vii)(C) of this section, successful disposal
will be assessed on a case-by-case basis.

25.114(d)(14)(vii)( If planned disposal is by atmospheric re-entry, the See below.

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D)(2) statement must also include:

25.114(d)(14)(vii)( A disclosure indicating whether the atmospheric Starship will accomplish

D)(2) (i) re-entry will be an uncontrolled re-entry or a controlled reentry and landing
controlled targeted reentry. for reuse and covered by
Starship launch licenses
through the Federal Aviation
Administration (“FAA”).

25.114(d)(14)(vii)( An assessment as to whether portions of any Starship reentry is licensed by

D)(2) (ii) individual spacecraft will survive atmospheric re- the FAA.
entry and impact the surface of the Earth with a
kinetic energy in excess of 15 joules, and
demonstration that the calculated casualty risk for
an individual spacecraft using the NASA Debris
Assessment Software or a higher fidelity
assessment tool is less than 0.0001 (1 in 10,000).

25.114(d)(14)(vii)( Applicants for space stations to be used only for N/A

E) commercial remote sensing may, in lieu of
submitting detailed post-mission disposal plans to Starship's primary purpose is
the Commission, certify that they have submitted not commercial remote
such plans to the National Oceanic and sensing.
Atmospheric Administration for review.

25.114(d)(14)(viii) For non-U.S.-licensed space stations, the N/A

requirement to describe the design and operational
strategies to minimize orbital debris risk can be Starship is licensed in the U.S.
satisfied by demonstrating that debris mitigation
plans for the space station(s) for which U.S. market
access is requested are subject to direct and
effective regulatory oversight by the national
licensing authority.

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