SPACEX NON-GEOSTATIONARY SATELLITE SYSTEM

ATTACHMENT A
TECHNICAL INFORMATION TO SUPPLEMENT SCHEDULE S

A.1 SCOPE AND PURPOSE

This attachment contains the information required under Part 25 of the Commission’s

rules that cannot be fully captured by the associated Schedule S.

A.2 OVERALL DESCRIPTION

Apart from the additional frequencies, the Original Application’s general description of

the overall system facilities, operations and services for the SpaceX non-geostationary orbit

(“NGSO”) satellite system (the “SpaceX System”) remains unchanged. For the Commission’s

convenience, SpaceX has included in the accompanying Schedule S the information filed as part

of the Original Application with revisions associated with adding the supplemental frequency

bands sought in this application. The accompanying Schedule S therefore reflects the system as

it will operate over all frequencies, including the supplemental spectrum sought in this

application. However, unless otherwise specified, the material contained below in this technical

narrative is applicable only to the portion of the SpaceX System relevant to the supplemental

spectrum. The portion already being considered in the November processing round remains

unchanged from the Original Application.

The frequency ranges used by the SpaceX System are summarized in Table A.2-1 below,

with the supplemental frequency bands sought in this amendment highlighted in bold. Figure

A.2-1 depicts the spectrum used by the system for gateway and user beams and for telemetry,

tracking, and control (“TT&C”) operations, with the supplemental frequency bands sought in this

amendment highlighted in green, along with an indication of the U.S. frequency allocations and

1
designations that exist in these bands. The detailed channelized frequency plan is provided in the

associated Schedule S.

Type of Link and Transmission Frequency Ranges

Direction

User Downlink 10.7 – 12.7 GHz

Satellite-to-User Terminal

Gateway Downlink 17.8 – 18.6 GHz

Satellite to Gateway 18.8 – 19.3 GHz
19.7 – 20.2 GHz

User Uplink 12.75 – 13.25 GHz1

User Terminal to Satellite 14.0 – 14.5 GHz

Gateway Uplink 27.5 – 29.1 GHz

Gateway to Satellite 29.3 – 29.5 GHz
29.5 – 30.0 GHz

TT&C Downlink 12.15 – 12.25 GHz

18.55 – 18.60 GHz

TT&C Uplink 13.85 – 14.00 GHz

Table A.2-1: Frequency Bands Used by the SpaceX System

1
At this time, SpaceX seeks authority to use this band in the United States only with individually-licensed earth
stations. No such limitations would apply outside the U.S. In the future, SpaceX may seek authority to operate
blanket-licensed user terminals in the U.S. as well.

2
3
SpaceX recognizes that not all of the supplemental frequencies it proposes to use are designated

in the United States for use by NGSO FSS systems on a primary basis. As discussed below,

SpaceX believes its system can operate without causing harmful interference to or requiring

protection from any other service duly licensed in these bands with higher priority.2

A.3 PREDICTED SPACE STATION ANTENNA GAIN CONTOURS

All satellites in the SpaceX System have been designed with the same transmit and

receive antenna beams. The antenna gain contours for the transmit and receive beams for a

representative space station are embedded in the associated Schedule S, as required by Section

25.114(c)(4)(vi)(B). The contours for all transmit and receive beams are essentially the same for

satellites operating in all planes and altitudes. Below we describe the methodology for their

presentation in the associated Schedule S.

A.3.1 Ku-Band User Beams

The SpaceX system will use the 12.75-13.25 GHz band for uplink transmissions from

user terminals.3 These terminals communicate only with satellites at an elevation angle of at

least 40 degrees. Consequently, as shown in Figure A.3.1-1 below, each satellite operating at an

altitude of 1,150 km will provide service only up to 40.46 degrees away from boresight (nadir),

covering an area of about 3.5 million square kilometers (1,060 km radius).4

2
Where appropriate, SpaceX has requested a waiver for non-conforming use of spectrum.
3
In the U.S., such user terminals would be limited to individually-licensed earth stations, such as those used by
enterprise customers. In the future, SpaceX may seek authority to operate blanked-licensed user terminals in
the U.S. as well.
4
While the 40 degree minimum elevation angle remains the same from the earth station point of view, the
maximum angle from boresight at which service can be provided from the satellite changes slightly depending
upon altitude. Thus, satellites operating at 1,110 km, 1,130 km, 1,275 km, and 1,325 km altitude can provide
service up to 40.72, 40.59, 39.67, and 39.36 degrees away from boresight, respectively.

4
 Figure A.3.1-1: Steerable Service Range of Ku-band Beams (1,150 km)

Generally, beams from antennas using phased arrays widen incrementally as they are

steered away from boresight.5 However, this widening occurs only in the plane formed by

boresight and the center of the beam (“elevation”), and not in the plane normal to that plane

formed by boresight and the center of the beam (“azimuth”). As a result, the shape of a phased

array beam at boresight is circular but becomes increasingly elliptical when steered away from

boresight.

This beam widening behavior with phased array antennas creates several effects that must

be offset in order to achieve efficient use of spectrum through frequency re-use. As the beam

widens, the size of the spot on the ground increases due to the increased distance to the Earth’s

surface, and the curvature of the Earth enhances this effect. For receiving antennas, this results

in reception of radiofrequency energy from a wider area, which increases both the susceptibility

to interference from other systems and the potential for self-interference from user terminal

uplink transmissions.

5
For this purpose, we use “boresight” to refer to the direction normal to the phased array plane.

5
 The SpaceX System offsets these beamwidth variations by switching antenna elements in

the phased array on and off at certain steering angles. By ensuring that radio energy is received

from the desired direction, this switching helps to mitigate interference with other systems.

Specifically, as shown in Figure A.3.1-2 below, additional elements are turned on when the angle

reaches 23 degrees, and then again when it reaches 32 degrees. (Note this applies for both

transmit and receive antennas on each satellite.)

Figure A.3.1-2: Beamwidth Variation at Various Steering Angles

The following figures illustrate this dynamic by plotting antenna gain contours (for both uplink

and downlink beams) at key steering angles, in each case at a roll off of -2 dB, -4 dB, -6 dB, -8

dB, -10 dB, -15 dB, and -20 dB.

Figure A.3.1-3 shows the antenna gain contour with the beam pointed to nadir (boresight,

or zero steering angle).

6
 Figure A.3.1-5: Beam Contour at 23 Degrees Elevation
After Additional Elements Turned ON

Similarly, Figures A.3.1-6 and A.3.1-7 below show the same beam when it has been steered to

32 degrees, first without the additional elements turned on and then with them turned on to

reduce beamwidth.

Figure A.3.1-6: Beam Contour at 32 Degrees Elevation

Before Additional Elements Turned ON

8
 Figure A.3.1-7: Beam Contour at 32 Degrees Elevation
After Additional Elements Turned ON

Finally, Figure A.3.1.8 below shows the antenna gain contour when the beam is steered to its

maximum angle of 40.46 degrees, where it has the greatest beamwidth.

Figure A.3.1-8: Beam Contour at 40.46 Degrees Elevation

The intended coverage area for each beam is a cell inside the -3 dB contour, as illustrated in

figure A.3.1-9 below. At a given frequency, only a single beam (with left hand circular

9
polarization (“LHCP”) on the uplink) would cover a single cell on the ground.

Figure A.3.1-9: Intended Beam Coverage Area

For receiving beams, the antenna gain drops slightly as the beam slants away from nadir. As a

result, the maximum G/T (9.8 dB/K) occurs at nadir, while the minimum G/T (8.7 dB/K) occurs

at maximum slant.6 In addition, as required under the Commission’s rules, SpaceX earth stations

will transmit in the 13.15-13.2125 GHz sub-band at EIRP of no more than 3.2 dBW towards the

radio horizon.7

A.3.2 Ka-Band Gateway Beams

As with the Ku-band beams discussed above, all Ka-band gateway downlink spot beams

on SpaceX satellites are independently steerable over the full field of view of the Earth. As with

user terminals, gateways communicate only with satellites at an elevation angle of at least 40

degrees. Consequently, as discussed above, each satellite can be supported by gateways located

6
Section 25.114(c)(4)(v) requires both the minimum and maximum saturation flux density (“SFD”) values for
each space station receive antenna that is connected to transponders. The concept of SFD only applies to “bent
pipe” satellite systems, and thus is not relevant to the SpaceX System. However, because the Schedule S
software requires a numerical entry for SFD (which must be different for maximum and minimum), SpaceX has
entered values of “0” and “-0.1.”
7
See 47 C.F.R. § 2.106, n. NG53.

10
only up to a certain limit away from boresight (nadir), which varies slightly by operating altitude.

Each satellite transmits two beams at the same frequency (with right hand and left hand circular

polarization (“RHCP and LHCP”)). Up to four satellites can beam transmissions to the gateway

location, for a maximum of eight co-frequency beams.

As with Ku-band user beams, the shape of the Ka-band gateway beam becomes elliptical

as it is steered away from the boresight as a consequence of the phased array technology

employed. It widens in the elevation plane, but not the azimuth plane. However, unlike the Ku-

band user beams, SpaceX does not adjust the elements of the Ka-band phased array gateway

antenna in order to limit beamwidth variation. While each Ku-band user beam is designed to

cover a number of users within a cell, each Ka-band beam is used to communicate with a single

gateway at a time, and is optimized to be as close to beam-center-to-beam-center as possible with

that link, using a beam as narrow as practical.

Figure A.3.2-1 shows the antenna gain contour (for both uplink and downlink gateway

beams) with the beam pointed to nadir (boresight, or zero steering angle).

Figure A.3.2-1: Beam Contour at Nadir

11
Figures A.3.2-2 through A.3.2-5 likewise show plots for the same gateway beam when it is

steered to 10, 20, 30, and 40.46 degrees away from nadir. As these figures show, the beam

becomes increasingly elliptical as the angle increases.

Figure A.3.2-2: Beam Contour at 10 Degrees Elevation

Figure A.3.2-3: Beam Contour at 20 Degrees Elevation

12
 Figure A.3.2-4: Beam Contour at 30 Degrees Elevation

Figure A.3.2-5: Beam Contour at 40.46 Degrees Elevation

As the transmitting beam is steered, the power (in both polarizations) is adjusted 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. As illustrated in Figure A.3.2-6 below, the

highest EIRP density (10.14 dBW/1MHz) in the 19.7-20.2 GHz band occurs at maximum slant.

13
purposes of this analysis, we discuss them separately below.

Ku-Band Geographic Coverage

As discussed above, SpaceX intends to begin providing commercial broadband service in

the U.S. and internationally after launching 800 satellites of the Initial Deployment. With those

satellites, SpaceX could provide service in the areas between approximately 60º North Latitude

and 15º North Latitude and between 15º South Latitude and 60º South Latitude. This would be

sufficient to cover the contiguous United States (“CONUS”), Hawaii, Puerto Rico, and the U.S.

Virgin Islands, but would not cover the region near the equator or areas at more extreme latitudes

(including portions of Alaska). Once the Initial Deployment has been completed, the system will

provide continuous FSS service from approximately 60º North Latitude to 60º South Latitude.

This is sufficient to cover CONUS, Hawaii, Puerto Rico, and the U.S. Virgin Islands, as well as

the southernmost areas required by the rule. However, the system will not yet provide

continuous coverage to the northernmost areas required by the rule (including portions of

Alaska) until service from one of the more inclined orbital constellations is launched.

Once fully deployed, the SpaceX System will pass over virtually all parts of the Earth’s

surface and therefore, in principle, have the ability to provide ubiquitous global service. Because

of the combination of orbital planes used in the SpaceX System, including the use of near-polar

orbits, every point on the Earth’s surface will see, at all times, a SpaceX satellite at an elevation

no less than 40 degrees, with increasing minimum elevation angles at lower latitude. This will

satisfy the Commission’s geographic coverage requirements.

Ka-Band Geographic Coverage

The gateway earth stations of the SpaceX System provide the necessary

communications links back from the SpaceX satellites to the global Internet. SpaceX intends to

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install sufficient gateway sites in the U.S. and around the world to ensure the SpaceX satellites

have a visible gateway earth station with which they can communicate from all parts of their

orbits. The actual number of gateways will scale with user demand and system deployment.

For example, SpaceX estimates that it will deploy approximately 200 gateways in the United

States to support the Initial Deployment. At Final Deployment, the SpaceX Ka-band gateway

links will be sufficient to serve SpaceX satellites at all latitudes, which meets the requirements

of Section 25.145(c)(1) and (2) as far as these rules can be applied to such types of links.

A.5 TT&C CHARACTERISTICS

A complete description of the SpaceX TT&C subsystem, including the maximum

transmit EIRP density, maximum and minimum G/T for receiving beams, and diagrams of the

antenna gain contours, is provided with the Original Application and its associated Schedule S,

and those materials are incorporated herein by reference.9

A.6 CESSATION OF EMISSIONS

Each active satellite transmission chain (channel amplifiers and associated solid state

power amplifier) can be individually turned on and off by ground telecommand, thereby

causing cessation of emissions from the satellite, as required by Section 25.207 of the

Commission's rules.

A.7 INTERFERENCE ANALYSES

As shown in Figure A.2-1 above, the frequency ranges SpaceX proposes to use in Ku-

band and Ka-band are shared with other services in the U.S. table of frequency allocations. The

SpaceX system design has been engineered to achieve a high degree of flexibility in order to

9
See, e.g., Original Application, Sections A3.3, A.5, and Schedule S.

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protect other authorized satellite and terrestrial systems under reasonable coordination

arrangements and facilitate spectrum sharing. For example, the system has the following

attributes:

 Operation at high elevation angles. The SpaceX System constellation is designed to

provide service at minimum operational elevation angles of 40 degrees for all gateway

and user earth stations.

 Highly directional earth station beams. The earth stations used to communicate with the

SpaceX System will operate with aperture sizes that enable narrow, highly-directional

beams with strong sidelobe suppression. Combined with the fact that these beams will be

steered to track NGSO satellites at elevation angles of at least 40 degrees, the system will

provide significant off-axis isolation to other GSO and NGSO satellites. This will ensure

that interference to other satellite systems could only occur in cases where there is an in-

line event for satellites from each system.

 Ability to select from multiple visible satellites for service. With over 4,400 satellites, the

SpaceX System will provide multiple NGSO satellites in the field of view of any given

earth station. Where appropriate, the system will have the intelligence to select the

specific satellite that would avoid a potential in-line interference event with GSO and

other NGSO operations.

Applying these and other sharing mechanisms, SpaceX is confident that it can successfully

coordinate its system with other authorized satellite and terrestrial networks. Below we discuss

the SpaceX System’s compliance with international operating parameters designed to prevent

harmful interference to other systems operating in Ku-band and Ka-band spectrum.

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A.7.1 Interference Protection for GSO Satellite Networks
The SpaceX System has been designed to provide all necessary interference protection to

GSO satellite networks in both the Ku-band and Ka-band as required under Article 22 of the ITU

Radio Regulations. In addition, in the Ku-band, the SpaceX System will fully comply with the

similar requirements in Sections 25.146 and 25.208 of the Commission’s rules. In the following

sections, we will demonstrate compliance with the Equivalent Power Flux-Density (“EPFD”)

limits set forth in Article 22 of the ITU Radio Regulations and in Section 25.146 (for the Ku-

band).

Specifically, No. 22.5C and 22.5I of the Radio Regulations define EPFD limits for the

downlink transmissions from an NGSO satellite system in certain Ku- and Ka-band downlink

frequency ranges that must be followed in order to avoid causing unacceptable interference to

GSO satellite networks.10 Similarly, No. 22.5D of the Radio Regulations defines corresponding

EPFD limits applicable to the uplinks from an NGSO satellite system in certain Ku- and Ka-band

uplink frequency ranges.11 Although the Commission’s rules do not include the ITU Ka-band

EPFDdown limits, the ITU Ku-band EPFDup limits are reflected in Sections 25.146 and 25.208(k).

SpaceX will meet all EPFD limits that apply within the supplemental frequency ranges

requested herein, and all other obligations of the ITU Radio Regulations and the Commission’s

Part 25 rules in this regard within the frequency ranges where such limits apply. Below, we

provide an explanation of the techniques SpaceX will use to comply with the EPFD limits

separately for Ku-band and Ka-band operations. Note that these techniques are used to protect

GSO satellite networks from interference from the SpaceX System but also have the effect of

10
These limits are referred to in the Commission’s rules as “EPFDdown” limits, and in the ITU Radio Regulations
as “EPFD↓”.
11
These limits are referred to in the Commission’s rules as “EPFDup” limits, and in the Radio Regulations as
“EPFD↑”.

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protecting the SpaceX System from GSO interference, as they are based on the principle of

avoiding inline and near-inline events. In addition, SpaceX has begun to provide initial briefings

on the operational parameters of its system to GSO satellite operators whose systems use the

same Ku- and Ka-band frequency ranges as the SpaceX System, and is confident that

compatibility with all GSO satellite networks in these bands can be achieved.

Finally, Resolution 76 of the ITU Radio Regulations include limits on aggregate

EPFDdown produced by all co-frequency satellites of all NGSO FSS systems operating in certain

Ku- and Ka-bands, including the 19.7-20.2 GHz band.12 SpaceX is prepared to work with other

NGSO FSS operators in order to ensure compliance with the applicable limits.

A.7.1.1 EPFD Compliance in Ku-Band

Annex 1 provides a detailed analysis of the EPFD levels produced by the SpaceX System

in the 12.75-13.25 GHz uplink band, and how they comply with the single-entry EPFD

validation limits referenced in Section 25.146(a)(1) and (2). Annex 1 also addresses other

related aspects of Section 25.146. Below we explain the principles by which the SpaceX system

protects GSO satellite networks from interference in Ku-band.

In order for an NGSO satellite system to comply with the EPFD limits for the protection

of GSO satellite networks, it must ensure that there is sufficient angular separation between the

transmissions from the NGSO satellites (in the downlink bands) and user earth stations (in the

uplink bands) relative to the potential victim GSO earth stations (in the downlink bands) and

satellites (in the uplink bands), respectively. A key factor to achieving this goal is the number of

SpaceX satellites in the NGSO constellation relative to the service areas being covered. The

SpaceX constellation has sufficient satellites to ensure that there are always multiple SpaceX

12
See ITU Rad. Regs., Res. 76.

19
satellites visible from any point in the service area at a high elevation angle – always greater than

40 degrees. In concert with the ability to turn specific antenna elements off and manage traffic

across multiple satellites utilizing inter-satellite links, SpaceX can serve a user by selecting a

satellite that offers sufficient angular separation from the GSO arc to avoid the line of sight

between GSO earth stations and their corresponding GSO satellites without interrupting service.

At higher latitudes, this is less of an issue as there is an inherent interference isolation due

to the angular separation from the GSO arc for all SpaceX satellites. In these situations, GSO

earth stations would only potentially receive low-power signals from the far-out sidelobes of the

SpaceX satellites that are in the main beam of the GSO earth station, and maximum power

signals only from the SpaceX satellites that appear in the far-out sidelobes of the GSO earth

station. Similarly, because the transmitting SpaceX earth stations point well away from the GSO

arc when communicating with SpaceX satellites at higher latitudes, receiving GSO satellites

benefit from uplink isolation as well. Using its advanced phased array antennas, the SpaceX

System further minimizes any potential interference through precision beamforming and by

using sidelobe nulling to suppress unwanted signals from both satellites and user terminals in the

direction of the GSO arc.

As the SpaceX satellites approach lower latitudes, they move closer to the line of sight

between GSO earth stations and their corresponding GSO satellites. Accordingly, in addition to

the sidelobe nulling discussed above, the SpaceX System will implement GSO arc avoidance to

protect against interference into GSO systems. Specifically, SpaceX will turn off the transmit

beam on the user terminal whenever the angle between the boresight of a GSO earth station

(assumed to be collocated with the SpaceX user) and the direction of the SpaceX satellite

transmit beam is 22 degrees or less. Because of the number and configuration of satellites in the

20
SpaceX System, there will be ample alternate satellites in view to provide uninterrupted service

to a user from satellites operating outside of the exclusion zone around the GSO arc.

A.7.1.2 EPFD Compliance in Ka-Band

Annex 2 provides a detailed analysis of the EPFD levels produced by the SpaceX

System in 19.7-20.2 GHz downlink band, and how they comply with the single-entry EPFD

validation limits in Article 22 of the ITU Radio Regulations. Below we explain the principles

by which the SpaceX system protects GSO satellite networks from interference in Ka-band.13

As explained above in relation to Ku-band, in order for an NGSO satellite system to

comply with the Ka-band EPFD limits for the protection of GSO satellite networks (for both

uplink and downlink), it must ensure that there is sufficient angular separation between the

NGSO and GSO system assets. SpaceX uses a straightforward GSO arc avoidance strategy,

combined with sophisticated sidelobe nulling, to protect GSO satellite networks from

interference in the Ka-band. This approach depends upon careful choice of the SpaceX

gateway sites and placing modest constraints on the positions of SpaceX satellites with which

each gateway site is allowed to communicate. Because of the characteristics of the system,

including suppression of potentially interfering satellite and earth station transmissions through

the application of sidelobe nulling, the necessary GSO arc avoidance angle is 22 degrees. This

angle is used as the basis of the EPFD compliance analysis provided in Annex 2.

A.7.1.3 Ka-Band Frequency Range Where No EPFD Limits Exist

Neither the Commission’s rules nor the ITU Radio Regulations include EPFD limits for

the 29.3-29.5 GHz downlink frequency band. According to ITU procedures applicable to this

13
SpaceX recognizes that its use of the 19.7-20.2 GHz and 29.3-29.5 GHz bands will be on a non-conforming
basis with respect to GSO FSS systems, and has requested a related waiver. Accordingly, it will neither cause
harmful interference to, nor be protected against harmful interference from, authorized GSO FSS operations in
these bands.

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frequency range, coordination between NGSO and GSO networks is on a first-come, first-served

basis, depending on the ITU date priority of the relevant ITU filings.14 SpaceX has provided

initial briefings to various GSO satellite operators that use this frequency range, and is confident

that compatibility with all GSO satellite networks in this band can be achieved using the GSO

arc avoidance strategies discussed above.

A.7.2 Interference with Respect to Other NGSO Satellite Systems

Currently, there are no other NGSO satellite systems licensed by the Commission, or

granted access to the U.S. market, that operate within the frequency ranges subject to this

application, although applications for such authorizations are currently pending.15 The ITU has

procedures for coordination amongst NGSO systems operating in all of the Ku-band and Ka-

band frequency ranges at issue here.16 In addition, the Commission has adopted an avoidance

of in-line interference events regime for the 12.75-13.25 GHz band,17 and has proposed to

extend that regime to the 19.7-20.2 GHz and 29.3-29.5 GHz bands as well,18 such that spectrum

sharing between NGSO satellite systems should be achievable using whatever means can be

coordinated between the operators to avoid such in-line interference events, or by resorting to

band splitting in the absence of any such coordination agreement.

14
See ITU Radio Regs. No. 9.11A.
15
As set out in the public notice that initiated this series of processing rounds, one or more NGSO system
application has previously been filed for each frequency band sought herein. See Public Notice, 32 FCC Rcd.
4180, 4183 n.3 (IB 2017). Although not licensed by the Commission, there is a U.S. government NGSO
satellite system with which coordination is required under footnote US334 of the domestic table of allocations.
This is addressed in Section A.9 below.
16
See ITU Rad. Regs. No. 9.12.
17
See Establishment of Policies and Service Rules for the Non-Geostationary Satellite Orbit, Fixed Satellite
Service in the Ku-band, 17 FCC Rcd 7841, ¶ 27 (2002).
18
See Update to Parts 2 and 25 Concerning Non-Geostationary, Fixed-Satellite Service Systems and Related
Matters, 31 FCC Rcd. 13651, ¶ 23 (2016).

22
 SpaceX has engineered its system with the technical flexibility that will facilitate the

necessary coordination with other NGSO satellite systems, and is committed to achieving

mutually satisfactory agreements.

A.7.3 Coordination With Respect to Terrestrial Networks in the 12.75-13.25 GHz Band

The 12.75-13.25 GHz uplink spectrum used by the SpaceX System is shared with

terrestrial Fixed Service (“FS”) in the U.S. on a co-primary basis.19 By rule, only individually-

licensed earth stations may operate with NGSO FSS systems in this band.20 In addition, in order

to protect Broadcast Auxiliary Service (“BAS”) and Cable Television Relay Service (“CARS”)

operations in the 13.15-13.2125 GHz portion of the band, the Commission limited deployment of

NGSO earth stations near major television markets and imposed a strict EIRP limit for uplink

transmissions at low elevation angles.21 Such limitations were designed to “ensure NGSO FSS

operations could share spectrum with incumbent [FS] services without causing harmful

interference or unduly constraining future growth of incumbent services, while allowing

flexibility in implementing NGSO FSS systems.”22

SpaceX will not claim protection from licensed GSO FSS networks when operating on a

primary basis, and will ensure compatibility with licensed FS users consistent with the

19
Specifically, in the band 13.15-13.25 GHz, the following provisions apply: (a) the sub-band 13.15-13.2 GHz is
reserved for television pickup (“TVPU”) and cable television relay service (“CARS”) pickup stations inside a
50 km radius of the 100 television markets delineated in 47 C.F.R. § 76.51; and outside these areas, TVPU
stations, CARS stations, and NGSO FSS gateway earth stations shall operate on a co-primary basis; (b) the sub-
band 13.2-13.2125 GHz is reserved to TVPU stations on a primary basis and for CARS pickup stations on a
secondary basis inside a 50 km radius of the 100 television markets delineated in 47 C.F.R. § 76.51; and outside
these areas, TVPU stations and NGSO FSS gateway earth stations shall operate on a co-primary basis and
CARS stations shall operate on a secondary basis. 47 C.F.R. § 2.106 n. NG53(a)-(b).
20
See 47 C.F.R. § 25.202(a) n.6.
21
See Amendment of Parts 2 and 25 of the Commission’s Rules to Permit Operation of NGSO FSS Systems Co-
Frequency with GSO and Terrestrial Systems in the Ku-band Frequency Range, 18 FCC Rcd. 2324, ¶¶ 11-14
(2003) (“Ku-band Sharing Order”); 47 C.F.R. § 2.106 n. NG53(d).
22
Ku-band Sharing Order ¶ 5.

23
limitations imposed on operations in this band under the Commission’s rules.

A.8 COORDINATION WITH U.S. GOVERNMENT OPERATIONS

Under the U.S. Table of Frequency Allocations, federal usage of the 19.7-20.2 GHz

band is allocated solely for FSS downlink operations. Footnote G117 limits these operations to

military systems, while footnote US334 limits federal operations to specific areas of the orbital

arc and of the country.23 Footnote US334 also requires SpaceX to coordinate its NGSO system

with U.S. government satellite networks, both GSO and NGSO, in the 19.7-20.2 GHz band.

SpaceX has provided various U.S. government agencies initial information on the operational

parameters of its system, and is committed to successful coordination with all government

satellite networks operating in these bands to protect critical national security and government

systems. SpaceX will inform the Commission when coordination has been completed.

There is no federal allocation in the 12.75-13.25 GHz band. Footnote US251 notes that

this band is also allocated to the Space Research Service on a primary basis for reception only

at Goldstone, CA. In addition, the National Science Foundation uses this band for the radio

astronomy research of various spectral-lines, including the research of the formaldehyde line

and quasars.24 SpaceX will coordinate with the relevant facilities to achieve mutually

acceptable agreements regarding the protection of these important sites and their contributions

to the space and Earth sciences.

A.9 ITU FILINGS FOR SPACEX

The SpaceX System will operate under network filings made on its behalf with the ITU

by the administrations of the U.S. (under the satellite network name USASAT NGSO-3) and

23
See 47 C.F.R. § 2.106 nn. G117, US334.
24
See NTIA Office of Spectrum Management, Federal Spectrum Use Summary, 30 MHz – 3000 GHz, at 61
(2010), available at https://www.ntia.doc.gov/files/ntia/Spectrum Use Summary Master-06212010.pdf.

24
Norway (under the satellite network name STEAM). Taken together, these U.S. and Norway

network filings encompass all the frequencies SpaceX proposes to use in this application.

A.10 ORBITAL DEBRIS MITIGATION

SpaceX’s launch and space experience provides the knowledge base for implementing an

aggressive and effective space-debris mitigation plan. The company’s current and planned

space-based activities underscore its unparalleled commitment to safe space. SpaceX has had

extensive experience in safe-flight design and operation through many missions of both the

Falcon 9 launch vehicle and the Dragon spacecraft carrying out missions to the International

Space Station (“ISS”). The company is highly experienced with cutting-edge debris mitigation

practices and has deep ties with the domestic and international institutions tasked with ensuring

the continued safety of space operations. SpaceX has a long-standing collaborative working

relationship with the Joint Space Operations Center (“JSpOC”), a multinational focal point for

management of space traffic, debris, and other space coordination functions associated with the

U.S. Department of Defense. It also has existing relationships with both NASA and the Air

Force Center for Space Situational Awareness in the support of its space-based activities, and

will continue to utilize these experiences and relationships as resources while developing the

SpaceX System and spacecraft.

SpaceX will largely be using recommendations set forth in both NASA Technical

Standard 8719.14A and AIR FORCE INSTRUCTION 91-217, typically choosing the more

restrictive of the two and, where deemed applicable, choosing a more restrictive value than either

reference due to the scope of the project. SpaceX intends to incorporate the material objectives

set forth in this application into the technical specifications established for design and operation

of the SpaceX System. SpaceX will internally review orbit debris mitigation as part of the

preliminary design review and critical design review for the spacecraft, and incorporate these

25
objectives, as appropriate, into its operational plans. Because this mitigation statement is

necessarily forward looking, the process of designing, building, and testing may result in minor

changes to the parameters discussed herein. In addition, SpaceX will continue to stay current

with the Space Situational Awareness community and technology and, if appropriate, SpaceX

will modify this mitigation statement to continue its leadership in this area.

Spacecraft Hardware Design

SpaceX has assessed and limited the amount of debris released in a planned manner

during normal operations, and does not intend to release debris during the planned course of

operations of the satellite constellation.

SpaceX is also aware of the possibility that its system could become a source of debris in

the unlikely case of a collision with small debris or meteoroids that could either create jetsam or

cause loss of control of the spacecraft and prevent post-mission disposal. SpaceX is undertaking

steps to address this possibility by incorporating redundancy, shielding, separation of

components, and other physical characteristics into the satellites’ design. Tanks are designed to

suffer impact penetration without explosive consequences, while batteries are shielded and have

isolation features to prevent cascading failure from impacted battery cells to other battery cells.

SpaceX will continue to review these aspects of on-orbit operations throughout the

spacecraft manufacturing process and will make such adjustments and improvements as

appropriate to assure that its spacecraft will not become a source of debris during operations or

become derelict in space due to a collision.

Minimizing Accidental Explosions

SpaceX is designing its spacecraft in a manner that limits the probability of accidental

explosion. The key areas reviewed for this purpose will include rupture of propellant tanks and

26
batteries. The basic propulsion design (including a dual wall shielding effect from the bus

walls), propulsion subsystem component construction, preflight verification through both proof

testing and analysis, and quality standards will be designed to ensure a very low risk of tank

failure. A burst disk ensures that sudden failure of propulsion containment cannot overpressure

and fragment the spacecraft. During the mission, batteries and various critical areas of the

propulsion subsystem will be instrumented with fault detection, isolation, and recovery (similar

or in many cases identical to flight-proven methods utilized onboard the SpaceX Dragon capsule

for its missions to ISS) to continually monitor and preclude conditions that could result in the

remote possibility of energetic discharge and subsequent generation of debris. Through this

process, SpaceX will assess and limit the possibility of accidental explosions during mission

operations and assure that all stored energy at the end of the satellite’s operation will be

removed.

Safe Flight Profiles

SpaceX takes seriously the responsibility of deploying large numbers of satellites into

space, and intends to exceed best practices to ensure the safety of space. Through detailed and

conscientious mission planning, SpaceX has carefully assessed and limited the probability of its

system becoming a source of debris by collisions with large debris or other operational space

stations. It will maintain the accuracy of its orbital parameters at a level that will allow

operations with sufficient spacing to minimize the risk of conjunction with adjacent satellites in

the constellation and other constellations. SpaceX has and will continue to work closely with

JSpOC to ensure the service provided for conjunction assessment to SpaceX and all operators is

robust, reliable, and secure. Significant coordination must be performed with other satellite

operators in nearby orbits to safely ascend and descend through constellations and to ensure any

27
altitude perturbations do not result in unnecessarily close approaches. The propulsion system

onboard can respond quickly and at high cadence, allowing SpaceX to coordinate in advance and

respond to conjunction risks, whether with debris or other active spacecraft. SpaceX is willing to

engage with any operators of nearby constellations to ensure safe and coordinated space

operations.

SpaceX has determined that no other system is currently licensed by the Commission for,

is currently operating in, or has submitted a request for coordination to the ITU with respect to

the same nominal orbital planes sought by SpaceX. SpaceX determined this after review of the

list of licensed systems and systems that are under consideration by the Commission for the

orbital planes it has requested. In addition, in order to address non-U.S. licensed systems,

SpaceX has reviewed the list of NGSO satellite networks for which a request for coordination

has been published by the ITU.

Post-Mission Disposal

Each satellite in the SpaceX System is designed for a useful lifetime of five to seven

years. SpaceX intends to dispose of satellites through atmospheric re-entry at end of life. As

suggested by the Commission,25 SpaceX intends to comply with Section 4.6 and 4.7 of NASA

Technical Standard 8719.14A with respect to this re-entry process. In particular, SpaceX

anticipates that its satellites will reenter the Earth’s atmosphere within approximately one year

after completion of their mission – much sooner than the international standard of 25 years.

After the mission is complete, the spacecraft (regardless of operational altitude) will be moved

to a 1,075 km circular orbit in its operational inclination, then gradually lower perigee until the

propellant is exhausted, achieving a perigee of at most 300 km. After all propellant is

25
Mitigation of Orbital Debris, 19 FCC Rcd. 11567, ¶ 88 (2004).

28
53.8 Degree Inclination DAS Input

53.8 Degree Inclination DAS Output

32
70 Degree Inclination DAS Input

70 Degree Inclination DAS Output

33
74 Degree Inclination DAS Input

74 Degree Inclination DAS Output

34
81 Degree Inclination DAS Input

81 Degree Inclination DAS Output

35
 Re-entry timelines are also provided for several disposal perigees in proximity of the

target. The 300 km target does not account for a fuel margin stack-up reserved for other uses.

In the vast majority of cases, any remaining margin would allow satellites to push their perigee

even lower than 300 km. Nonetheless, satellites would hold some fuel in reserve for

conjunction avoidance during the active de-orbit phase.26 Re-entry estimates for the year 2029

are set forth in the tables below.

53 Degree Inclination
Disposal Perigee Time to Re‐entry
200 km 22 days
250 km 100 days
> 300 km < 344 days
350 km 2.0 years
400 km 2.9 years

53.8 Degree Inclination 70 Degree Inclination

Disposal Perigee Time to Re‐entry Disposal Perigee Time to Re‐entry
200 km 22 days 200 km 24 days
250 km 98 days 250 km 118 days
> 300 km < 342 days > 300 km < 1.0 year
350 km 2.0 years 350 km 2.1 years
400 km 2.9 years 400 km 2.9 years

74 Degree Inclination 81 Degree Inclination

Disposal Perigee Time to Re‐entry Disposal Perigee Time to Re‐entry
200 km 26 days 200 km 28 days
250 km 112 days 250 km 110 days
> 300 km < 1.0 year > 300 km < 1.0 year
350 km 2.1 years 350 km 2.1 years
400 km 2.9 years 400 km 2.9 years

26
SpaceX will reserve approximately 245 m/s of delta-V – a measure of the impulse required for a given
maneuver or, here, the capability to perform those maneuvers if necessary – to deliver the described de-orbit
functionality. A spacecraft’s ability to perform a given maneuver is determined not just by the mass or volume
of propellant available, but also factors specific to the propellant tank and propellant lines (such as propellant
leakage), the exact efficiency of the propulsion system, and even the mass of the spacecraft itself, all of which
the delta-V measurement takes into account. These additional factors also remain subject to additional testing
and design improvements meaning that, while SpaceX’s reserved delta-V value will remain constant, mass of
available propellant reserves may vary as the spacecraft design is finalized.

36
Atmospheric Demise

The spacecraft’s small mass and predominantly aluminum construction make

atmospheric demise a likely scenario upon re-entry. To verify this, SpaceX also utilized

NASA’s DAS. The satellite was broken down into approximately 100 major components, each

defined with its own shape, material, mass and dimensions. Components were modeled in a

nested fashion; a child component would not be exposed to the environment until its parent

burned up. This enabled conservative re-entry survivability analysis of common problematic

components, such as spherical fuel tanks contained within an enclosed spacecraft bus. DAS

models the release of all root components 79 km above the surface; the demise altitudes of all

modeled components at all inclinations is shown in the following figures:

37
 Several objects were identified as components of interest. This reflected objects that

had a distinct mass, quantity, or shape factor that made them of particular concern during re-

entry analysis. Those components and their corresponding demise altitudes are provided in the

tables below:

38
 53 Degree Inclination
Component Demise (km)
First Bus Panel 76.6
Reaction Wheels 74.4
Batteries 70.9
Propellant Tank 70.9
Last Bus Panel 70.3

53.8 Degree Inclination 70 Degree Inclination

Component Demise (km) Component Demise (km)
First Bus Panel 76.6 First Bus Panel 76.4
Reaction Wheels 74.4 Reaction Wheels 74.2
Batteries 71.0 Batteries 71.3
Propellant Tank 70.9 Propellant Tank 70.8
Last Bus Panel 70.3 Last Bus Panel 70.3

74 Degree Inclination 81 Degree Inclination

Component Demise (km) Component Demise (km)
First Bus Panel 76.4 First Bus Panel 76.7
Reaction Wheels 74.2 Reaction Wheels 74.6
Batteries 71.6 Batteries 72.1
Propellant Tank 71.0 Propellant Tank 71.7
Last Bus Panel 70.7 Last Bus Panel 71.3

Although a major effort was made to avoid the use of components resistant to disintegration,

some scenarios were unavoidable. DAS analysis indicates that four components may have a

chance of reaching the Earth’s surface; these components are listed in the tables below. Of the

four, only two contribute substantially to the total Debris Casualty Area (“DCA”) calculation.27

27
The debris casualty area is a function of the dimensions of an average person and of the specific debris
fragment. The model does not consider more complicated aspects, such as sheltering within structures. The
total casualty area is the sum of the casualty areas of all surviving debris fragments that reach the ground with
kinetic energy greater than 15 joules.

39
 53 Degree Inclination
Component Qty. Material Mass (kg) Total DCA (m^2) Energy (J)
Thruster Internals 1 Iron 1.66 0.47 2733
Comms. Component 5 Silicon Carbide 1.50 2.79 961
Rotor Bearing 5 Stainless Steel 0.07 2.45 8
Strut Fitting 12 Titanium 0.03 4.92 6

53.8 Degree Inclination

Component Qty. Material Mass (kg) Total DCA (m^2) Energy (J)
Thruster Internals 1 Iron 1.66 0.47 2733
Comms. Component 5 Silicon Carbide 1.50 2.79 961
Rotor Bearing 5 Stainless Steel 0.07 2.45 8
Strut Fitting 12 Titanium 0.03 4.92 6

70 Degree Inclination
Component Qty. Material Mass (kg) Total DCA (m^2) Energy (J)
Thruster Internals 1 Iron 1.66 0.47 2733
Comms. Component 5 Silicon Carbide 1.50 2.79 961
Rotor Bearing 5 Stainless Steel 0.07 2.45 8
Strut Fitting 12 Titanium 0.03 4.92 6

74 Degree Inclination
Component Qty. Material Mass (kg) Total DCA (m^2) Energy (J)
Comms. Component 5 Silicon Carbide 1.50 2.79 961
Rotor Bearing 5 Stainless Steel 0.07 2.45 8
Strut Fitting 12 Titanium 0.03 4.92 6

81 Degree Inclination
Component Qty. Material Mass (kg) Total DCA (m^2) Energy (J)
Comms. Component 5 Silicon Carbide 1.50 2.79 961
Rotor Bearing 5 Stainless Steel 0.07 2.45 8
Strut Fitting 12 Titanium 0.03 4.92 6

The DCA model does not consider components characterized by a ground impact energy

of less than 15 joules. The two components in the simulation that fall into this category are

rotor bearings and strut fittings. The former may survive re-entry due to being nested in a

larger sub-assembly, while the latter may survive because they are made of titanium. These

components are 70 and 30 grams respectively, causing their impact at terminal velocity to

remain benign.

40
 Two other components with a chance of re-entry survivability are iron thruster internals

and a set of silicon carbide communications components. While the majority of the thruster is

expected to burn up in the atmosphere, the nested nature of the assembly leaves a chance of

survivability for internal components. Fortunately, the DCA of these components is relatively

small at 0.47 m2. At higher inclinations, DAS indicates the thruster internals are no longer a

risk, which is reflected by the disappearance of that row from the tables of 74 and 81 degrees of

inclination. The high survivability of the silicon carbide communications components stems

from the material properties, primarily its very high melting point of 2,730 °C.

The four components discussed above are the main contributors to the satellite’s total

DCA, set forth in Table A.10-1 below.

Table A.10-1. Summary of Human Casualty Risk Assessment

Yet even with these components, the total spacecraft Risk of Human Casualty is no more than

1:18,200, satisfying the requirement of 1:10,000 established by NASA.

41
 ENGINEERING CERTIFICATION

I hereby certify that I am the technically qualified person responsible for preparation of

the engineering information contained in this application, that I am familiar with Part 25 of the

Commission’s rules, that I have either prepared or reviewed the engineering information

submitted in this application, and that it is complete and accurate to the best of my knowledge

and belief.

/s/ Mihai Albulet

Mihai Albulet, PhD
Principal RF Engineer
SPACE EXPLORATION TECHNOLOGIES CORP.

July 26, 2017

Date
 ANNEX l

Demonstration of EPFD Compliance for Ku-Band Operations

This annex provides a detailed explanation of the equivalent power flux-density

(“EPFD”) levels produced by the SpaceX System in the 12.75-13.25 GHz band, and how

they comply with the single-entry EPFD validation limits defined in Section 25.146(a)(l)

and (2). This comprehensive technical showing demonstrates that the SpaceX system will

not exceed the validation EPFD limits in this band as specified in Section 25.208(k) for the

Earth-to-space direction (EPFDup).1

In order for a non-geostationary orbit (“NGSO”) satellite system to comply with the

EPFD limits for the protection of geostationary orbit (“GSO”) satellite networks, it must

ensure that there is sufficient angular separation between the transmissions to and from the

NGSO satellites relative to the potential victim GSO earth stations and satellites.

Accordingly, SpaceX will turn off the user downlink beam on the satellite and uplink beam

on the user terminal whenever the angle between the boresight of a GSO earth station

(assumed to be collocated with the SpaceX user) and the direction of the SpaceX satellite

transmit beam is 22 degrees or less. Because of the number and configuration of satellites in

the SpaceX System, there will always be a satellite available to provide service to a user from

outside the exclusion zone around the GSO arc with a minimum elevation angle of 40

degrees, and the use of inter-satellite links will ensure continuity of service throughout any

interference mitigation activities.

1
The EPFD limits for the transmissions to an NGSO satellite system defined in the Commission’s rules reflect
the limits set forth in No. 22.5D of the ITU Radio Regulations.

Annex 1-1
 In addition, SpaceX will use its advanced phased array antennas to further minimize

any potential interference through precision beamforming and by using sidelobe nulling to

suppress unwanted signals from both satellites and user terminals in the direction of the GSO

arc. The sidelobe nulling will reduce the sidelobe level by an additional 10 dB in a ±2 degree

zone around the GSO arc. SpaceX will also carefully coordinate its broadband transmissions

in the band to limit overall energy of the system and remain within EPFD restrictions. The

combination of these strategies ensures that EPFD levels produced by the SpaceX System

comply with the prescribed limits as demonstrated below.

EPFDup Compliance

This section demonstrates SpaceX’s compliance with the single-entry EPFD limits

with respect to Ku-band uplinks. For this purpose, SpaceX has used the latest version of the

computer program developed by Transfinite Systems (“Transfinite”) for determining

compliance with the EPFD validation limits. With its application, SpaceX is submitting

the input files that will allow the Commission to confirm that the SpaceX System

complies with the single-entry validation EPFD limits in the Earth-to-space direction in

the 12.75-13.25 GHz band.

The first set of files contains the Ku-band earth station maximum off-axis EIRP

masks for the user earth stations anticipated for use in the SpaceX System. These masks

have been generated in accordance with the specification stipulated in Recommendation

S.1503-2. The EIRP masks define the off-axis EIRP density of the Ku-band

transmitting user earth stations as a function of off-axis angle. They were derived using

a composite antenna pattern taking into account, for each angle off-boresight, the

Annex 1-2
highest off-axis gain in all directions around that boresight. The masks then assume the

off-axis gain is rotationally symmetric around the boresight of the antenna, and

therefore represent a worst-case situation. According to Recommendation S.1503-2,

they may be constant or variable as a function of the earth station latitude, but the

simulations assume the same EIRP mask at all latitudes. A single EIRP mask is created

that represents the highest on-axis and off-axis EIRP density levels (per 40 kHz) for any of

the Ku-band transmitting user terminal earth stations, which does not depend upon earth

station latitude, but is inclusive of all conditions of modulation and traffic patterns.

As discussed above, SpaceX will use advanced beam forming antenna technology to

suppress sidelobe energy in the direction of the GSO arc. The nulling zone moves around as

needed when the user earth station antenna is steered. This achieves an additional 10 dB

sidelobe rejection for an area approximately ±2 degrees around the GSO arc. Unfortunately,

the software program used for this EPFD analysis does not capture this sidelobe nulling by

earth stations used in the SpaceX System. However, as the earth station EIRP mask is only

used to calculate the earth station emissions toward the GSO arc, SpaceX has been able to

model EIRP beyond the 22 degree GSO arc avoidance angle based on the sidelobe level in

the nulling zone.

In addition, SpaceX is submitting a file that contains the orbital parameters and

other data concerning the SpaceX System necessary to run the EPFD validation

software. The data contained in this file is as follows:

1. The orbital parameters of the SpaceX constellation, consistent with the

associated Schedule S submission.

Annex 1-3
 2. The parameter entitled “nbr_sat_td” in Recommendation S.1503-2 (in Appendix
4 of the ITU Radio Regulations this is referred to as A.4.b.7.a). This is defined
as the “[m]aximum number of co-frequency tracked non-geostationary satellites
receiving simultaneously.” The SpaceX System is designed such that only one
satellite provides service to a given location. Accordingly, this parameter is set
to 1 for purposes of the EPFD validation analysis.

3. The parameter entitled “density” in Recommendation S.1503-2 (in Appendix 4

of the ITU Radio Regulations this is referred to as A.4.b.7.b). This is defined
as the “[a]verage number of associated earth stations transmitting with
overlapping frequencies per km2 in a cell.” The value of this parameter is
related directly to the size of the aggregate beam coverage area from each
SpaceX satellite, which is a hexagonal cell with a diameter of 45 km, and the
maximum number of times an uplink frequency can be spatially re-used within
this area. It is conservatively assumed that any uplink frequency will be re-used
every other cell. Therefore, the average density will be
1/((45)2*3*√(3)/4)=0.000380 earth stations per square kilometer.

4. The parameter entitled “avg_dist” in Recommendation S.1503-2 (in Appendix 4

of the ITU Radio Regulations this is referred to as A.4.b.7.c). This is defined as
the “[a]verage distance between co-frequency cells in kilometres.” The value of
this parameter is directly related to the “density” value described above, and is in
fact the square root of the inverse of the density value. This gives a value of
51.3 km as the average distance between co-frequency transmitting earth
stations.

5. The parameter entitled “elev_min” in Recommendation S.1503-2 (in Appendix 4

of the ITU Radio Regulations this is referred to as A.14.b.4). This is defined as
the “[m]inimum elevation angle at which any associated earth station can
transmit to a non-geostationary satellite.” For the SpaceX Ku-band user
terminals, this parameter is set to 40°.

6. The parameter entitled “x_zone” in Recommendation S.1503-2 (in Appendix 4

of the ITU Radio Regulations this is referred to as A.4.b.7.d.2). This is defined
as the “[w]idth of the exclusion zone in degrees,” and is meant to reflect the
minimum GSO avoidance angle measured at the surface of the Earth. For the
SpaceX Ku-band user terminals, this parameter is set to 22°.

The Ku-band EPFDup results from Transfinite’s EPFD validation computer program

using the input data discussed above are shown below. The labeling of the diagram

provides the relevant details for the analysis generated by the software. The resulting

Annex 1-4
EPFD level is shown by the red curve and the EPFD mask is shown by the orange line.

Other Rules Related to EPFD:

SpaceX will comply at the appropriate time with the requirements of Section

25.146(b) of the Commission’s rules for additional submissions prior to the initiation of

service to the public.

SpaceX confirms, consistent with Section 25.146(e), that it is not claiming

interference protection from GSO FSS networks operating in accordance with the

Commission’s Part 25 rules and the ITU Radio Regulations.

Annex 1-5
 ANNEX 2

Demonstration of EPFD Compliance for Ka-Band Operations

This annex provides a detailed explanation of the equivalent power flux-density

(“EPFD”) levels produced by the SpaceX System in the 19.7-20.2 GHz and how they comply

with applicable single-entry EPFD validation limits. This comprehensive technical showing

demonstrates that the SpaceX System will not exceed the single-entry validation EPFD limits

in this band as specified in No. 22.5C of the ITU Radio Regulations1 for the space-to-Earth

direction (EPFDdown). As discussed in Annex 1, SpaceX employs several strategies to reduce

EPFD levels of its system. These include a GSO arc avoidance area of ±22 degrees, as well as

sophisticated beam forming and sidelobe nulling by the phased array antennas used by the

system that achieve an additional 10 dB sidelobe rejection in the area closest to the GSO arc.

EPFDdown Compliance

This section demonstrates SpaceX’s compliance with the single-entry EPFD limits

with respect to its Ka-band downlinks. As discussed in Annex 1, SpaceX has used the

latest version of the Transfinite software to determine compliance with the single-entry

EPFD validation limits. With its application, SpaceX is submitting input files that will

allow the Commission to confirm that the SpaceX System complies with these limits in

the space-to-Earth direction in the 19.7-20.2 GHz band.

The first set of computer files contains the sets of Ka-band power flux-density

(“PFD”) masks for each space station in the SpaceX System. These masks define the
1
There are no EPFD limits for Ka-band in the Commission’s Part 25 rules.

Annex 2-1
maximum satellite downlink PFD in the Ka-band over the surface of the Earth that is

visible to the satellite and capture contributions from transmissions using both

polarizations (RHCP and LHCP) used for Ka-band gateway links. The PFD masks are

expressed as a function of the azimuth (“Az”) and elevation (“El”) angles as viewed from

the satellite towards the Earth relative to nadir.2

The PFD masks submitted with this application have been generated in accordance

with the specification stipulated in Recommendation S.1503-2, using the following

methodology and assumptions related to the actual design and real-world operation of the

SpaceX System:

1. We start with the two dimensional (as a function of Az/El) EIRP density mask
for a single SpaceX Ka-band satellite gateway transmit beam at the maximum
operational transmit EIRP level (for all conditions of modulation and traffic
patterns). This will vary for each of the beams on the satellite because of their
slightly different pointing directions.

2. The different spatial frequency re-use patterns used within each SpaceX satellite
are then taken into account to derive a set of different aggregate EIRP density
masks, one for each combination of co-frequency beams that is used. These
satellite-aggregate EIRP masks will be different for each re-use pattern because
of the relative pointing directions of the different beams.

3. As discussed above, gateway beams are turned off when the separation angle to the
GSO arc is 22 degrees or less. In addition, the satellites radiate lower sidelobes
toward the GSO arc, within a ±2 degree zone around the GSO arc. These measures
are reflected in the EIRP masks.

4. The different EIRP masks are then converted to PFD masks (also as a function
of Az/El) by taking account of the spreading loss from the satellite to the surface
of the Earth. The resulting PFD masks for each set of satellites are therefore a
function of Az/El and sub-satellite latitude.

2
Azimuth is in the East-West direction and elevation is in the North-South direction, as seen at the sub-
satellite point.

Annex 2-2
 SpaceX is also submitting the input data file needed to run the EPFD analysis to

validate the EPFDdown levels. This file contains the orbital parameters and other data

concerning the SpaceX System necessary to run the EPFD validation software. The data

contained in this file is as follows:

1. The orbital parameters of the SpaceX System, consistent with the associated
Schedule S.

2. The parameter entitled “nbr_op_sat” in Recommendation S.1503-2 (in Appendix

4 of the ITU Radio Regulations this is referred to as A.4.b.6.a). This is defined
as the “[m]aximum number of non-geostationary satellites transmitting with
overlapping frequencies to a given location within the latitude range.” In this
band, SpaceX will ensure that no more than one satellite is supported by a given
gateway location at one time. Accordingly, this parameter is set to 1 for
purposes of the EPFD validation analysis.

3. The parameter entitled “elev_min” in Recommendation S.1503-2 (in Appendix 4

of the ITU Radio Regulations this is referred to as A.14.b.4). This is defined as
the “[m]inimum elevation angle at which any associated earth station can
transmit to a non-geostationary satellite.” This parameter is set to a value of 40°
for both uplink and downlink gateway transmissions.

The Ka-band EPFDdown results from the EPFD validation computer program using the

input data described above are shown below. Each plot corresponds to one of the GSO

reference earth station antenna sizes from the EPFD limits. The labeling of each

diagram provides the relevant details for each analysis generated by the software. The

resulting EPFD level is shown by the red curve and the EPFD mask that applies is

shown by the orange line.

Annex 2-3
Annex 2-4
Other Rules Related to EPFD:

SpaceX confirms that it is not claiming interference protection from GSO FSS

networks operating in accordance with the Commission’s Part 25 rules and the ITU

Radio Regulations.

Annex 2-5