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    SpaceX Gen2 300 KM R

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    michael.kan
    SpaceX requests approval from the FCC to operate its second-generation Starlink satellites at lower altitudes between 340-360 km. Operating at these lower shells would improve space sustainability by allowing satellites to deorbit faster, reduce collision risk, and provide higher quality broadband service with lower latency. SpaceX argues that including these lower shells in its first tranche of 7,500 approved satellites would advance sustainability goals and maximize benefits for consumers.

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    SpaceX Gen2 300 KM R

    Uploaded by

    michael.kan
    12K views2 pages
    SpaceX requests approval from the FCC to operate its second-generation Starlink satellites at lower altitudes between 340-360 km. Operating at these lower shells would improve space sustainability by allowing satellites to deorbit faster, reduce collision risk, and provide higher quality broadband service with lower latency. SpaceX argues that including these lower shells in its first tranche of 7,500 approved satellites would advance sustainability goals and maximize benefits for consumers.

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    SpaceX letter to FCC

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    SpaceX Gen2 300 km R

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    SpaceX requests approval from the FCC to operate its second-generation Starlink satellites at lower altitudes between 340-360 km. Operating at these lower shells would improve space sustainability by allowing satellites to deorbit faster, reduce collision risk, and provide higher quality broadband service with lower latency. SpaceX argues that including these lower shells in its first tranche of 7,500 approved satellites would advance sustainability goals and maximize benefits for consumers.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    12K views2 pages

    SpaceX Gen2 300 KM R

    Uploaded by

    michael.kan
    SpaceX requests approval from the FCC to operate its second-generation Starlink satellites at lower altitudes between 340-360 km. Operating at these lower shells would improve space sustainability by allowing satellites to deorbit faster, reduce collision risk, and provide higher quality broadband service with lower latency. SpaceX argues that including these lower shells in its first tranche of 7,500 approved satellites would advance sustainability goals and maximize benefits for consumers.

    Copyright:

    © All Rights Reserved
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    Download as pdf or txt
    of 2

    February 20, 2024

    BY ELECTRONIC FILING
    Marlene H. Dortch
    Secretary
    Federal Communications Commission
    45 L Street, N.E.
    Washington, DC 20554

    Re: ICFS File Nos. SAT-LOA-20200526-00055 and SAT-AMD-20210818-00105

    Dear Ms. Dortch:

    SpaceX designed its second-generation satellite system to be the most capable and
    sustainable constellation in space, providing high-speed, low-latency broadband to consumers
    wherever they are and using orbital resources responsibly. SpaceX is proud to report that its
    second-generation satellites have performed even better than expected, including during the launch
    and early orbit phase of their operations where atmospheric drag on the satellites is at a maximum.
    Based on the early successes of its second-generation satellites, SpaceX requests authority to
    leverage the shells included in its application in the 340 km-360 km range 1 as an option within its
    first tranche of 7,500 satellites.

    Expanding the range of options in SpaceX’s Gen2 license to include the lower shells for
    which SpaceX applied would improve space sustainability and enhance quality of service for
    consumers, enterprises, and first responders. As the Commission recognized in the Gen2 Order,
    satellite “failures at lower altitudes present lower risk than at higher altitudes, where remaining
    orbital lifetimes are longer.” 2 In fact, SpaceX demonstrated in this proceeding that the collision
    probability of second-generation satellites in lower shells will be as much as an order of magnitude
    lower than its satellites operated at higher orbits, which themselves operate well below the
    established threshold. 3 Further, just as the Commission found when authorizing SpaceX to
    conduct LEOP operations, operations at lower altitudes allow SpaceX to “deorbit any non-
    functional satellites in a matter of . . . weeks,” 4 not only in the post-deployment period, but also
    during the entire orbital lifetime of these satellites.

    Moreover, operating at these lower altitudes will enable SpaceX to provide higher-quality,
    lower-latency satellite service for consumers, keeping pace with growing demand for real-time

    1
    SpaceX’s amended application for its second-generation system requested to operate at altitudes of 340 km (53-
    degree inclination), 345 km (46-degree inclination), 350 km (38-degree inclination), and 360 km (96.9-degree
    inclination). See Amendment, ICFS File No. SAT-AMD-20210818-00105, Technical Attachment at 3 (Aug. 18,
    2021).
    2
    Space Exploration Holdings, LLC, 37 FCC Rcd. 14882, ¶ 85 (2022) (“Gen2 Order”).
    3
    See Letter from David Goldman to Marlene H. Dortch, ICFS File Nos. SAT-LOA-20200526-00055, SAT-AMD-
    20210818-00105, at Exhibit B (Oct. 4, 2022).
    4
    Gen2 Order ¶ 91.

    1155 F St NW, Suite 475, Washington, DC 20004 | phone 202.649.2700 | fax 202.649.2701 | spacex.com
    Marlene H. Dortch
    February 20, 2024
    Page 2 of 2

    applications to support remote work, distance education, telehealth, and emergency response.
    Lower-latency service is particularly important for consumers in rural and remote areas that lack
    terrestrial broadband options and for terrestrial broadband networks that rely on satellite backhaul.

    SpaceX urges expeditious approval to include its 300 km shells as a part of its first tranche
    of 7,500 satellites to advance space sustainability and maximize the benefits of its constellation
    for consumers everywhere.

    Sincerely,
    /s/ David Goldman
    David Goldman
    Vice President, Satellite Policy

    SPACE EXPLORATION TECHNOLOGIES CORP.


    1155 F Street, NW
    Suite 475
    Washington, DC 20004
    Tel: 202-649-2641
    Email: [email protected]

    1155 F St NW, Suite 475, Washington, DC 20004 | phone 202.649.2700 | fax 202.649.2701 | spacex.com

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