Federal Communications Commission
Washington, D.C. 20554
November 7, 2023
VIA ELECTRONIC MAIL
Mr. William M. Wiltshire
Harris, Wiltshire & Grannis LLP
1919 M Street, NW
Suite 800
Washington, D.C. 20036
wwiltshire@hwglaw.com
Re: ICFS File No. SAT-MOD-20230207-00021; GN Docket No. 23-135; Call Sign: S3069
Dear Mr. Wiltshire:
On February 7, 2023, Space Exploration Holdings, LLC (SpaceX) submitted the above-referenced
application for modification of its authorization to construct, deploy, and operate up to 7,500 of its
second-generation Starlink non-geostationary orbit (NGSO) satellites. 1 To assist the Space Bureau’s
review of the application, including review of the non-conforming use of specific frequency bands, please
provide the information requested below. 2
1. Please provide an interference analysis, including link budgets, for operations in the 1990-1995
MHz (space-to-Earth) and 1910-1915 MHz (Earth-to-space) bands, calculating the difference in
interference in clear sky and rain fade or cloud cover conditions. This analysis should take into
account the worst case scenario of all satellites transmitting at the same time, including different
power levels required for rain fade and cloud cover as well as clear sky conditions over a
particular area of coverage, and analyze the resultant level of interference produced and the
possibility of loss of service by other authorized satellite and terrestrial operators in that area. For
satellite-to-satellite analysis, provide monte-carlo simulation results that produce time-based
statistics for the level of interference expected to be seen by other satellite operators operating in
the reverse-band mode of operations. These need not be co-frequency or co-coverage.
2. Please provide a map with projected beam coverage for the United States and power levels
(maximum and typical) within the geographic areas for which T-Mobile is licensed to operate on
the 1990-1995 MHz and 1910-1915 MHz bands including areas (e.g., borders) that may require
SpaceX to reduce power.
3. Please provide additional information regarding SpaceX’s capability to cease emissions on
command under section 25.207 of the Commission’s rules. 3 If SpaceX is required to cease
operations due to harmful interference when the satellites are serving populated areas that already
have full terrestrial coverage, how will this be accomplished with multiple satellites or multiple
1
Space Exploration Holdings, LLC, Application for Approval for Orbital Deployment and Operating Authority for
the SpaceX Gen2 NGSO System, ICFS File No. SAT-MOD-20230207-00021 (filed Feb. 7, 2023).
2
47 CFR § 25.111(a).
3
47 CFR § 25.207.
coverage areas simultaneously? How would the cessation of service in those areas potentially
affect service to adjacent unserved or underserved areas? How will SpaceX prevent operation of
a handset that is outside the service area of its partner terrestrial operator?
4. SpaceX has submitted two United States International Telecommunication Union (ITU) filings
and two German ITU filings covering planned direct-to-cell operations. SpaceX’s German filings
cover the 1910-1915 MHz (Earth-to-space) band (MARS-ULS) and 1990-1995 MHz (space-to-
Earth) band (MARS-VLS), and both filed under 4.4 of the ITU Radio Regulations (ITU R.R.). 4
SpaceX’s United States ITU filings cover the 1427.0-1518.0 MHz (space-to-Earth) and 614.0-
694.0 MHz (Earth-to-space) bands (USASAT-NGSO-MULS); and the 1910-1915 MHz, 1610-
1617.775 MHz, and 148.0-150.05 MHz (Earth-to-space) and 1990-1995 MHz, 2483.5-2500
MHz, and 137.0-138.0 MHz (space-to-Earth) bands (USASAT-NGSO-MVLS). USASAT-
NGSO-MULS requests operations under ITU R.R. 4.4, but USASAT-NGSO-MVLS does not.
Please clarify why SpaceX’s USASAT-NGSO-MVLS ITU filing is not submitted under ITU
R.R. 4.4 for the frequencies specified in its application. Please also explain why there is a
significant difference in the power levels between the German and the US ITU filings.
Please submit the requested information by November 17, 2023.
Sincerely,
Kathyrn J. Medley
Acting Chief, Satellite Licensing Division
Space Bureau
4
See ITU R.R. 4.4.
