APPLICATION FOR BLANKET-LICENSED

EARTH STATIONS IN MOTION

I. OVERVIEW
The Commission has authorized Space Exploration Holdings, LLC (“SpaceX”) ”) to

launch and operate a constellation of over 4,400 non-geostationary orbit (“NGSO”) satellites (call

sign S2983/S3018) using Ku- and Ka-band spectrum.1 In doing so, the Commission recognized

that granting the SpaceX Authorization would “enable SpaceX to bring high-speed, reliable, and

affordable broadband service to consumers in the United States and around the world, including

areas underserved or currently unserved by existing networks.”2 To date, SpaceX has launched

over 1,100 satellites and continues to deploy its system.

The Commission has also granted a sister company, SpaceX Services, Inc. (“SpaceX

Services”), a blanket license for operation of up to one million end-user customer earth stations

that communicate with SpaceX’s NGSO constellation.3 These user terminals employ advanced

phased-array beam-forming and digital processing technologies to make highly efficient use of

Ku-band spectrum resources by supporting highly directive, antenna beams that point and track

the system’s low-Earth orbit satellites.

In this application, SpaceX Services seeks a blanket license authorizing operation of such

end-user earth stations for deployment as Vehicle-Mounted Earth Stations (“VMESs”), Earth

Stations on Vessels (“ESVs”), and Earth Stations Aboard Aircraft (“ESAAs”) (collectively, Earth

 
1
See Space Exploration Holdings, LLC, 33 FCC Rcd. 3391 (2018) (“SpaceX Authorization”); Space Exploration
Holdings, LLC, 34 FCC Rcd. 2526 (IB 2019).
2
SpaceX Authorization ¶ 1.
3
See Radio Station Authorization, IBFS File No. SES-LIC-20190211-00151 (granted Mar. 13, 2020) (call sign
E190066).

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Stations in Motion (“ESIMs”)).4 SpaceX Services seeks authority to deploy and operate these

earth stations (1) as VMES throughout the United States and its territories, (2) as ESVs in the

territorial waters of the United States and throughout international waters worldwide, and (3) as

ESAAs on U.S.-registered aircraft operating worldwide and non-U.S.-registered aircraft operating

in U.S. airspace. Consistent with SpaceX’s space station authorization, these ESIMs will transmit

in the 14.0-14.5 GHz band and receive in the 10.7-12.7 GHz band. The Commission’s rules

specifically contemplate blanket licensing for ESIMs operating in these frequency bands.5

Below, we discuss the service to be provided by these ESIMs as well as certain spectrum

sharing issues relevant to the operation of these earth stations. We then demonstrate that grant of

this application would serve the public interest. Lastly, we provide technical information to

supplement the information provided in Schedule B to Form 312 filed with this narrative

application.6 To support its ambitious timetable for launching and expanding innovative satellite

broadband services, SpaceX Services requests that the Commission grant the requested blanket

license as expeditiously as possible.

II. THE ESIMS WILL EXPAND SPACEX’S INNOVATIVE BROADBAND SATELLITE SERVICE TO
USERS IN MOVING VEHICLES, VESSELS, AND AIRCRAFT

SpaceX Service’s ESIMS are electrically identical to its previously authorized consumer

user terminals but have mountings that allow them to be installed on vehicles, vessels and aircraft,

which are suitable for those environments. SpaceX Service’s ESIMs will communicate only with

those SpaceX satellites that are visible on the horizon above a minimum elevation angle of 25

 
4
See 47 C.F.R. 25.103 (defining VMES, ESV, ESAA, and ESIM).
5
See 47 C.F.R. § 25.115(f)(2).
6
To the extent relevant, SpaceX Services hereby incorporates the technical information submitted with SpaceX’s
space station applications. See IBFS File Nos. SAT-LOA-20161115-00118, SAT-LOA-20170726-00110, SAT-
MOD-20181108-00083, and SAT-MOD-20200417-00037.

2
 
 The EIRP masks for these ESIMs, for co-polarized and cross-polarized signals, are set forth

in Exhibit A hereto, and are identical to those for the previously authorized consumer user

terminals. In addition, SpaceX Services has submitted with this application a radiation hazard

analysis to demonstrate that these earth stations are compliant with and will not result in exposure

levels exceeding the applicable radiation hazard limits established by the Commission.

SpaceX Services will ensure installation of ESIM terminals on vehicles and vessels by

qualified installers who have an understanding of the antenna's radiation environment and the

measures best suited to maximize protection of the general public and persons operating the

vehicle and equipment. An ESIM terminal exhibiting radiation exposure levels exceeding 1.0

mW/cm in accessible areas, such as at the exterior surface of the radome, will have a label attached

to the surface of the terminal warning about the radiation hazard and will include thereon a diagram

showing the regions around the terminal where the radiation levels could exceed the maximum

radiation exposure limit specified in 47 C.F.R. § 1.1310 Table 1.9

III. SPECTRUM SHARING

The Commission has allocated the Ku-band that SpaceX Services proposes to use for

uplink communications (14.0-14.5 GHz) from these blanket-licensed earth stations on a primary

basis only to FSS. Nonetheless, SpaceX recognizes that its earth station operations will be subject

to certain sharing rules.10 With respect to the requirements in Section 25.228(j), SpaceX Services

will coordinate the operations of its ESIMs in the 14.0-14.2 GHz band within 125 km of NASA

TDRSS facilities at three specified locations (for ESVs and VMESs) or within radio line of sight

 
9
See 47 C.F.R. § 25.228(d).
10
See, e.g., 47 C.F.R. §§ 25.115(f)(2); 25.208(o); 101.1409; 2.106 footnote 5.487A; and 2.106 footnote 342. In
addition, pursuant to Section 25.115(i), SpaceX Services hereby certifies that it is planning to use a contention
protocol (TDMA/FDMA), and such protocol usage will be reasonable.

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(for ESAAs); until such coordination has been completed, these ESIMs will not exceed an EIRP

spectral density towards the horizon of 12.5 dBW/MHz and will not exceed an EIRP towards the

horizon of 16.3 dBW when operating within that 125 km zone (for ESVs and VMESs) or within

radio line of sight (for ESAAs).11 In addition, SpaceX Services will not operate in the 14.47-14.5

GHz band in the vicinity of radio astronomy observatories at sixteen locations, without first

completing coordination.12 SpaceX Services will use Global Positioning Satellite-related or other

similar position location technology to ensure compliance with this commitment.13

Prior to operations of its ESAAs on U.S.-registered aircraft within a foreign nation's

airspace, SpaceX Services will ascertain whether the relevant administration has operations that

could be affected by ESAA terminals and determine whether that administration has adopted

specific requirements concerning ESAA operations. When the ESAA-equipped aircraft enters

foreign airspace, the ESAA terminal will operate under the Commission's rules, or those of the

foreign administration, whichever is more constraining.14 To the extent that all relevant

administrations have identified geographic areas from which ESAA operations would not affect

their radio operations, SpaceX Services will operate within those identified areas without further

action. To the extent that the foreign administration has not adopted requirements

regarding ESAA operations, SpaceX Services will coordinate its operations with any potentially

affected operations.

SpaceX ESAA transmissions in the 14.0-14.5 GHz band from international airspace within

line-of-sight of the territory of a foreign administration where fixed service networks have primary

 
11
See 47 C.F.R. § 25.228(j)(1) and (2). See also SpaceX Authorization ¶ 37 (requiring SpaceX to take note of
NASA TDRSS facilities at three locations).
12
See 47 C.F.R. § 25.228(j)(3).
13
See id. § 25.228(j)(5).
14
See 47 C.F.R. § 25.228(f)(3).

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allocation in this band will limit their maximum power flux-density (“PFD”) produced at the

surface of the Earth by emissions from a single aircraft to not exceed the values provided in Section

25.228(i) of the Commission’s rules unless the foreign Administration has imposed other

conditions for protecting its fixed service stations.

Certain portions of the 10.7-12.7 GHz downlink band are shared with other commercial

and government services. Notably, these earth stations would not transmit in those bands and thus

could not cause any interference to other operators using those bands. SpaceX has engineered its

NGSO system design to achieve a high degree of flexibility to facilitate spectrum sharing with

other authorized satellite and terrestrial systems. SpaceX Services understands that its operations

in the 10.7-11.7 GHz band would be authorized on an unprotected basis with respect to current

and future systems operating in the fixed service.15 In addition, because the 12.2-12.7 GHz band

is not specifically available for use by ESIMs communicating with NGSO systems,16 SpaceX

Services requests a waiver to authorize use of that band on a non-harmful interference, unprotected

basis. This should not be controversial. Grant of this waiver will serve the public interest as

operations under will not impact terrestrial uses of this band. SpaceX’s NGSO system is highly

advanced, flexible, and capable of immediately ceasing operations in the unlikely event it is

notified that harmful interference has occurred.

SpaceX is aware of its obligations under its Authorization to protect terrestrial and space

systems in these shared bands, and hereby certifies that it will comply with the applicable

equivalent power flux-density (“EPFD”) limits set forth in Article 22 and Resolution 76 of the ITU

Radio Regulations and the applicable PFD limits set forth in the Commission’s rules and Article

 
15
See id. § 25.115(f)(2).
16
See id. § 25.202(a)(10)(ii).

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21 of the ITU Radio Regulations.17 The Commission has found that compliance with these EPFD

and PFD limits is sufficient to protect GSO systems and terrestrial systems, respectively, against

harmful interference.18

As required under the Commission’s rules, each ESIM will be self-monitoring and, should

a condition occur that would cause the ESIM to exceed any emission limits included in the

conditions of its license, the ESIM will automatically cease transmissions within 100 milliseconds

and not resume transmissions until the condition that caused the ESIM to exceed those limits is

corrected.19 In addition, each ESIM will be monitored and controlled by a network control and

monitoring center (“NCMC”) or equivalent facility located in the United States.20 Each ESIM will

be designed to comply with a “disable transmission” command from the NCMC within 100

milliseconds of receiving the command. In addition, the NCMC will monitor the operation of each

ESIM in its network, and transmit a “disable transmission” command to any ESIM that operates

in such a way as to exceed any emission limits included in the conditions of its license. The NCMC

will not allow the ESIM(s) under its control to resume transmissions until the condition that caused

the ESIM(s) to exceed the authorized emission limits is corrected.21

 
17
See SpaceX Authorization ¶¶ 40(b), (d), and (e); 47 C.F.R. § 25.115(f)(1) (incorporating certification requirement
in 47 C.F.R. § 25.146(a)(2)).
18
See, e.g., 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, 16 FCC Rcd. 4096, ¶ 77
(2000) (concluding that implementation of EPFD limits “will adequately protect GSO FSS networks”); 47 C.F.R.
§ 25.289 (NGSO satellite systems that comply with EPFD limits will be deemed not to cause unacceptable
interference to any GSO network); 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, 16
FCC Rcd. 4096, ¶ 42 (2000) (observing PFD limits should protect terrestrial systems in the band).
19
See 47 C.F.R. § 25.228(b).
20
See id. §§ 25.228(e)(2) and (f). In addition, to the extent SpaceX Services uses the NCMC to communicate with
ESVs on vessels of foreign registry, it will maintain detailed information on each such vessel's country of registry
and a point of contact for the relevant administration responsible for licensing those ESVs. Id. § 25.228(e)(3).
21
See id. §§ 25.228(c) and (e)(1).

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 SpaceX is confident that the highly advanced and flexible capabilities of its NGSO system,

including the ESIMs proposed by SpaceX Services herein, will be able to comply with the

limitations discussed above. Nonetheless, in the extremely unlikely event that harmful

interference should occur due to transmissions to or from its ESIMs, SpaceX Services can be

reached at its Starlink network operations center (NOC) via phone: +1 (360) 780 – 3103 or email:

[email protected], which links to the pagers of appropriate technical

personnel with authority and ability to cease all transmissions from these ESIMs on a 24/7 basis.

IV. GRANT OF THIS APPLICATION WOULD SERVE THE PUBLIC INTEREST AND PROVIDE
SERVICE TO VEHICLES, VESSELS, AND AIRCRAFT OPERATING IN AREAS OTHERWISE
UNSERVED OR UNDERSERVED BY HIGH-THROUGHPUT, LOW-LATENCY BROADBAND

Granting this application would serve the public interest by authorizing a new class of

ground-based components for SpaceX’s satellite system that will expand the range of broadband

capabilities available to moving vehicles throughout the United States and to moving vessels and

aircraft worldwide. The urgency to provide broadband service to unserved and underserved areas

has never been clearer. U.S. and worldwide demand for broadband services and Internet

connectivity continues to increase with escalating requirements for speed, capacity, and reliability

and ongoing adaptations for usage. The volume of traffic flowing over the world’s networks has

exploded, with one report estimating that by 2022 annual global Internet protocol traffic will reach

an annual run rate of 4.8 zettabytes – meaning that approximately 4,800 billion gigabytes of data

would be exchanged worldwide that year.22

Moreover, consumers are interacting with broadband platforms in an increasing variety of

ways. No longer are users willing to forego connectivity while on the move, whether driving a

 
22
See Cisco Visual Networking Index (VNI) Complete Forecast Update, 2017-2022, at 5 (Dec. 2018),
https://www.cisco.com/c/dam/m/en us/network-intelligence/service-provider/digital-
transformation/knowledge-network-webinars/pdfs/1213-business-services-ckn.pdf.

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truck across the country, moving a freighter from Europe to a U.S. port, or while on a domestic or

international flight. To help meet this demand, SpaceX has deployed an innovative, cost-effective

and spectrum-efficient satellite system capable of delivering robust broadband service to

customers around the world, particularly in unserved and underserved areas. SpaceX has already

secured U.S. authority for the space station components of its NGSO system. This application

takes the next step by seeking authority for ESIMs that will enable the extension of that network

from homes and offices to vehicles, vessels, and aircraft. Operation under the requested blanket

license will promote competition in the market for in-motion broadband services, to the benefit of

drivers, ship operators, and air travelers in the United States and abroad. These services will enhance

the security of mobile platforms and allow operators and passengers to access services that enable

increased productivity. Accordingly, an expeditious grant of this application would serve the public

interest.

Respectfully submitted,

SPACEX SERVICES, INC.

By: _/s/ David Goldman________

Counsel to SpaceX

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 Exhibit A – EIRP Mask