REQUEST FOR SPECIAL TEMPORARY AUTHORITY

TO CONDUCT EXPERIMENTAL OPERATIONS

Space Exploration Holdings, LLC (“SpaceX”) requests special temporary authority (“STA”) for
180 days beginning December 10, 2023 to test its non-geostationary orbit (“NGSO”) second generation
(“Gen2”) satellites 1 with direct-to-cellular communications payloads to connect unmodified cellular
phones directly to SpaceX Gen2 satellites, subject to the conditions set forth in the Gen2 Order granting
SpaceX authority to launch and operate 7,500 satellites. This experimental authority is necessary as the
Commission continues to process SpaceX’s application to enable supplemental coverage from space
(“SCS”) for consumers on a permanent basis. 2 Experimental authority would permit SpaceX to test its
direct-to-cellular-enabled satellites beginning in December 2023 until such time as the Commission grants
SpaceX’s modification application.

This experimental STA will permit SpaceX to connect its direct-to-cellular antennas to cellular
test devices using the 1910-1915 MHz and 1990-1995 MHz bands (the “PCS G Block”) in cooperation
with T-Mobile USA, Inc. and its subsidiaries (collectively, “T-Mobile”), who are the sole licensee of the
PCS G Block in the United States. 3 The two parties executed a spectrum manager lease pursuant to which
T-Mobile granted SpaceX the right to use the PCS G Block as described in SpaceX’s underlying
application and the instant request for experimental authority. SpaceX will use the PCS G Block spectrum
licensed to T-Mobile for these experiments with T-Mobile’s consent.

SpaceX’s experiment will include several phases, including during the launch and early orbit phase
(“LEOP”) and while at operational altitude. During the critical LEOP period, which will begin within
hours of launch at an altitude between 290 km and 350 km—depending on the particulars of the specific
launch—and may continue for several weeks or months, SpaceX will test the functionality of each direct-
to-cellular payload and its network capabilities to ensure that they are operating as intended. Based on
the outcome of these tests, SpaceX may thereafter begin the orbit-raising process to an intermediate
parking orbit to conduct additional tests. Finally, SpaceX may raise its satellites to their operational
altitude for ongoing operational tests. For each of these tests, SpaceX’s satellites will communicate with
cellular test devices controlled by T-Mobile and/or SpaceX personnel and not by commercial T-Mobile
subscribers. SpaceX will rely on its existing, authorized frequencies for its Gen2 system for the backhaul
and TT&C component of these satellites.

Over the 180-day experimental STA period, SpaceX expects to operate approximately 840
satellites with direct-to-cellular payloads. At any given time, approximately 60 of these 840 payloads

1
See Space Exploration Holdings, LLC, FCC 22-91 (rel. Dec. 1, 2022) (“Gen2 Order”).
2
See Application for Modification of Authorization for the SpaceX Gen2 NGSO Satellite System to Add a Direct-to-
Cellular System, ICFS File No. SAT-MOD-20230207-00021 (filed Feb. 7, 2023).
3
SpaceX has requested that the Commission waive the requirements of Section 25.115 in its application seeking authority
to operate its direct-to-cellular satellite network. See Application for Modification of Authorization for the SpaceX Gen2
NGSO Satellite System to Add a Direct-to-Cellular System, ICFS File No. SAT-MOD-20230207-00021, Narrative at i,
1-2, 7-8, Technical Narrative at 1-2, 4, 13-14, Waiver Requests at 4-5, 9-10 (Feb. 7, 2023). And T-Mobile has urged the
Commission to refrain from requiring licensing of subscriber units in connection with supplemental coverage from space
in general. See Comments of T-Mobile USA, Inc., GN Docket No. 23-65 and IB Docket No. 22-271, at 8-10 (filed May
12, 2023); Reply Comments of T-Mobile USA, Inc., GN Docket No. 23-65 and IB Docket No. 22-271, at 9-10 (filed June
12, 2023). Accordingly, SpaceX submits this application in an abundance of caution only so that T-Mobile’s already
certified and licensed subscriber devices may communicate with the SpaceX constellation while the STA remains in effect.
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will be serving handsets in the United States under this experimental authorization. To ensure adequate
testing and compatibility with a wide range of devices, SpaceX and T-Mobile seek authority to use 2,000
test devices. Communications will conform with the technical specifications set forth in Exhibit A. All
tests will occur within 13 specific terrestrial test locations identified in Exhibit B with a radius of 100 km
around each site, except as necessary to account for international borders.

In addition to these 13 sites, SpaceX also requests experimental authority to conduct tests in
coordination with the National Science Foundation (“NSF”), including the National Radio Astronomy
Observatory (“NRAO”). Planned testing will be conducted within the National Radio Quiet Zone
(“NRQZ”) in West Virginia, where the Green Bank Telescope (“GBT”) is located, and at the Very Large
Array (“VLA”) in New Mexico or Very Long Baseline Array (“VLBA”) sites, as listed in footnote US131
of the U.S. Table of Frequency Allocations. 4 These tests will be coordinated with the NSF prior to any
transmissions to ensure that radio astronomy observations are protected from the possibility of harmful
interference. SpaceX will work through NSF with any other radio astronomy facilities within the United
States which may be impacted.

Examples of tests under this STA could include:

1. Measuring compliance with relevant Part 25 masks;

2. Measuring in-band interference from adjacent handsets;
3. Confirming PFD levels at varying geographic locations within specified locations at a
variety of satellite transmit power levels and scan angles;
4. Measuring controlled handset received signal strength and data rates in geographically
diverse settings (e.g., under foliage, near structures, in valleys);
5. Measuring satellite receive signal strength, Doppler impairment measurements, and time
synchronization measurements from controlled handsets at a variety of handset data rates
and satellite scan angles; and
6. Testing topology software to improve coverage while meeting applicable limits;

SpaceX will operate in the PCS G Block on a non-protected, non-interference basis pursuant to
the commercial agreement between SpaceX and T-Mobile. The SpaceX direct-to-cellular system will
operate in the United States pursuant to a cooperative agreement with T-Mobile without impacting
primary terrestrial mobile operations and will protect adjacent band and cross-border operations from
harmful interference. In all cases, SpaceX dynamically plans its beams using its topology software so
that it will not exceed applicable field strength limits at any downlink power level near international
borders, except where those exceedances have been authorized pursuant to an approval from the
regulatory authority of the appropriate border country. The contours of individual SpaceX direct-to-cell
beams will depend on their elevation angle. SpaceX will place these beams to ensure that, in aggregate,
they do not exceed the applicable cross-border limit. To that end, SpaceX’s topology software typically
will place the center of lower-elevation angle beams farther from applicable border areas than beams at
higher elevation angles.

SpaceX will observe the applicable limits, including the in-band field strength limit in Section
24.236 and the out-of-band field strength limits in Section 25.202(f) along with the cessation of emissions

4
See 47 C.F.R. § 2.106 n.US131.

2
rule in Section 25.207 and frequency tolerance in Section 25.202(e). All uplink operations from certified
cellular test handsets will conform to Part 24 standards and limits. SpaceX certifies that its direct-to-
cellular system will operate without causing harmful interference to or requiring protection from any other
service duly licensed in these bands or adjacent bands. In the extremely unlikely event that harmful
interference should occur due to transmissions to or from its spacecraft, SpaceX will take all reasonable
steps to eliminate the interference. Should an issue arise, SpaceX can be reached at satellite-operators-
[email protected], which links to the pagers of appropriate technical personnel 24/7.

While operating under this experimental license to communicate with SpaceX space stations, the
cellular test devices on the ground will operate in the PCS G Block on a non-protected, non-interference
basis. All test devices are certified to operate under Part 24 of the Commission’s rules. In the extremely
unlikely event that harmful interference should occur due to transmissions to or from these T-Mobile
devices to SpaceX space stations, T-Mobile and SpaceX will take all reasonable steps to eliminate the
interference. Should an issue arise, SpaceX can be reached at [email protected],
which links to the pagers of appropriate technical personnel 24/7, and will coordinate with T-Mobile as
necessary.

The Commission has good cause to approve this request because it is in the public interest.
Granting this experimental license will enable SpaceX to begin testing its transformative direct-to-cell
technology, which will bring connectivity in areas where terrestrial mobile networks are absent or have
been impacted by natural disasters. The experimental authorization would also allow SpaceX to confirm
the operational status of its direct-to-cell satellites and their ability to communicate with cell phones
immediately upon insertion, rather than waiting weeks while the satellites complete obit raising to ensure
proper functioning. And because SpaceX will take the steps described above to protect systems in
adjacent bands and across national borders, these tests will enable SpaceX to more quickly realize the
consumer benefits of its direct-to-cell technology without causing harmful interference to other licensed
operators. Accordingly, SpaceX requests that the Commission expeditiously grant the experimental STA
for direct-to-cellular satellite communications for 180 days to support those operations beginning in
December 2023 while the Commission continues to consider its direct-to-cell application. SpaceX
understands that Commission grant of the experimental authorization does not prejudice the
Commission’s further consideration of its direct-to-cell application.

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 EXHIBIT B TEST LOCATIONS
T-Mobile Test Locations (latitude, longitude)

Mountain View, CA

• 37.41539, -122.07180
• 37.39100, -121.48750

Kansas City, KS

• 38.91540, -94.65727
• 39.92200, -96.35200

Redmond, WA

• 47.67530, -122.12833
• 47.35394, -121.45111
• 48.05000, -120.10000

San Diego, CA

• 33.46000, -117.15000
• 33.56000, -115.88000

Reston, VA

• 38.95030, -77.37785
• 38.49230, -79.68790

Dallas, TX

• 33.10832, -96.82122

Bethel, OK

• 34.35930, -94.81236

Columbus, OH

• 39.95891, -82.99997
• 39.65233, -82.02935

Virginia Beach, VA

• 36.84400, -75.98169
• 36.62074, -76.54898
B-1
Los Angeles, CA

• 34.04462, -118.25893
• 34.31502, -118.10536

Houston, TX

• 29.75328, -95.36233
• 28.71184, -98.78858

San Diego, CA

• 33.46000, -117.15000
• 33.56000, -115.88000

B-2