Critics of SpaceX's D2D System Plans Renew Their Commentary
Challengers and critics of SpaceX's 15,000-satellite supplemental coverage from space service said its response to their concerns is unconvincing. In FCC comments posted Friday (docket 25-340), many argued that SpaceX has yet to make the case for why equivalent power flux density (EPFD) limits should be waived. SpaceX has said opponents' concerns and petitions to deny are unsubstantiated and factually incorrect (see 2601160041).
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Viasat noted that SpaceX hasn't refuted the argument that its D2D plans pose "insurmountable interference risks" for other operators and would preclude them from getting equitable access to spectrum. Nor does the company show why 15,000 more non-geostationary satellites should get greenlit when the FCC Space Bureau denied it near-term authority for nearly the same number in another licensing proceeding, Viasat said. The agency earlier this month approved SpaceX's launch of 7,500 more of its second-generation satellites but deferred action on an additional 14,988 (see 2601120011).
Globalstar said its FCC license makes clear it has exclusive use rights in the 1.6/2.4 GHz "big low earth orbit" band around the world. While SpaceX claims it doesn't need to provide detailed interference showings for operations using the big LEO band outside the U.S., FCC rules require it to do so, Globalstar added.
SpaceX also still hasn't addressed the argument that international coordination frameworks covering North American use of the L band, which includes the big LEO bands, preclude it from operating a new constellation in that band outside the U.S., said Ligado. If the FCC signs off on SpaceX's use of the band outside North America, it should operate there on a non-interference, unprotected basis until it coordinates with other L-band operators, Ligado argued. AST SpaceMobile, which plans to use Ligado's L-band spectrum for direct-to-device capacity and throughput in North America, also pointed to the international coordination frameworks' prohibition of new operators in the North American L band. In addition, Iridium said SpaceX hasn't addressed the FCC's previous determination that the big LEO bands aren't available for other mobile satellite service (MSS) systems.
Eutelsat said SpaceX has yet to back up its claims that its MSS system won't cause harmful interference to geostationary operations in the band, so there aren't grounds to support a waiver of EPFD limits. Even though SpaceX claims that test data and analyses address GSO interference concerns, DirecTV said, it doesn't address the fact that tests involving Ku-band operations don't show how the proposed MSS system might affect GSO operations in the Ka band.
Reiterating arguments made in previous filings (see 2601090021 and 2601050028), Liberty Latin America said the commission must make clear that SpaceX can't interfere with Liberty's terrestrial use of AWS-3, H-block and AWS-4 spectrum within Puerto Rico and the U.S. Virgin Islands. Otherwise, service to customers in those territories could be jeopardized, it said.
Blue Origin warned that SpaceX's authorization could be seen as a type of priority or special status over other applicants in the same band, since the company seeks authority outside a processing round. It called for any SpaceX approval to make it clear that the company has obligations to share spectrum coequally with future entrants and earlier-round systems.