Commenters Oppose SpaceX's Plans for D2D Mega Constellation

The 15,000 additional satellites, atop the 12,000 already authorized and the thousands more SpaceX is seeking approval for, would give the company that much more ability and incentive to elbow out other operators from orbits and spectrum, Viasat said in its petition to deny. It also warned of "insurmountable interference risks," arguing that SpaceX makes no effort to show that its proposed operations in MSS spectrum in the 1429-2690 MHz range can coexist with incumbents in that swath.

In its petition, Globalstar said the FCC Space Bureau should make clear that its reasoning for denying SpaceX access to the 1.6/2.4 GHz bands two years ago (see 2403270002) still stands.

SpaceX's latest plans to operate in 1617.775-1626.5 MHz raise the same issues as its previous application for nearly 30,000 other Starlinks in the same spectrum, said Iridium, which also petitioned in March to deny that request. In both cases, SpaceX erroneously claims that Iridium is underutilizing the swath of spectrum, Iridium said. SpaceX efforts to use the spectrum also ignore the fact that the FCC has made clear that the frequencies aren't available for more MSS applications, Iridium added.

Ligado said that before the FCC signs off on SpaceX's use of the same L-band spectrum that Ligado uses in North America, the agency must first account for the international coordination framework governing North American use of the band, which doesn't allow entry of new operators.

The Mobile Satellite Services Association noted that its members, which include Viasat and Ligado, and other MSS operators are already using the 1429-2690 MHz band. The MSS portions of that band "are generally unavailable for new applicants," and SpaceX didn't even try to show that it could operate there without interfering with existing and planned MSS operations.

SpaceX's requested waiver of equivalent power flux density limits conflicts with the FCC's EPFD framework and its pending proceeding evaluating whether to change that framework, Eutelsat/OneWeb said. The company added that SpaceX doesn't address how that waiver might affect geostationary orbit systems like its own, and the waiver request should be denied or deferred.

Astronomy

The in-band power flux density levels of supplemental coverage from space (SCS) "are extraordinarily high," which can easily impair radio observation, the National Radio Astronomy Observatory said. It called SCS "an extraordinarily potent ... source of interference" and said radio telescopes might not be able to operate in the presence of ubiquitous SCS. SpaceX should have to show how it will meet its commitment not to interfere in the adjacent radio astronomy band at 42.5-43.5 GHz, the observatory added.

The American Astronomical Society argued that frequency bands allocated to radio astronomy service both domestically and internationally must be protected. With Starlink satellites associated with unintended electromagnetic radiation, such a large constellation in very low earth orbit risks creating "a pervasive [unintended radiation] background in Earth orbit." While the relatively low orbits might reduce the satellites' impact on optical astronomy, the group said those lower altitudes are "not a comprehensive solution to optical astronomy interference."

Tomorrow.io's earth exploration satellite service operations in the 90.13-92.65 GHz and 114.5-0122.75 GHz frequency ranges need a low-noise radio frequency environment, the company noted. It said new spectrum uses adjacent to passive sensing bands need to be evaluated to ensure that such earth observation operations can continue. Allowing large-scale uplink operations at the band edges of passive sensing ranges before the FCC completes its satellite spectrum proceeding on the W band "would risk foreclosing or constraining" what the agency does. The W band is part of a spectrum NPRM adopted unanimously in May (see 2505220056).

With SpaceX looking to put its 15,000 satellites at an orbital altitude of 326-335 kilometers, the "very dense" very low earth orbit environment that it's creating could impose launch-availability constraints, Blue Origin said. The company urged the FCC to look at requiring deployment incrementally, with each phase authorized based on evidence that the satellites aren't constraining launch missions. The agency might also want to consider formal expectations for coordination with launch operators, Blue Origin added.

Liberty Latin America said any approval of SpaceX's plans should make clear that it can't interfere with Liberty's terrestrial use of its AWS-3, H-block and AWS-4 spectrum within Puerto Rico and the U.S. Virgin Islands. An owner of multiple licenses in the B1 block of the AWS-3 band also urged the FCC not to waive or modify any AWS-3 technical or operating rules.

SpaceX's and CEO Elon Musk's ties to the Chinese government and Chinese Communist Party raise questions about his qualifications to hold FCC licenses, activist organization Frequency Forward said in its petition to deny. The group has similarly said SpaceX's China connections should halt its plans to buy EchoStar spectrum licenses (see 2510300035).