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 more than 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 the SpaceX NGSO system “will improve the experience for users of the SpaceX service,

including in often-underserved polar regions” and “enable[] a better user experience by improving

speeds and latency,” including for those in areas previously underserved or even totally unserved

by other broadband solutions. 2 In May 2019, SpaceX began launching satellites to populate its

constellation, and has launched more than 1,700 satellites in orbit.

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 Since securing that authorization, SpaceX

has developed the next generation of its user terminal. Like its predecessor, these new units

employ advanced phased-array beam-forming and digital processing technologies to make very

efficient use of Ku-band spectrum resources by supporting highly directive antenna beams that

point and track the system’s low-Earth orbit satellites. However, they do so with a slightly smaller

antenna than previously used. SpaceX Services has applied for authority to operate these user

1
See Space Exploration Holdings, LLC, 33 FCC Rcd. 3391 (2018) (“SpaceX Authorization”). The Commission
recently granted a request to modify SpaceX’s license. See Space Exploration Holdings, LLC, FCC 21-48 (rel.
Apr. 27, 2021) (“SpaceX Modification”). These authorizations anticipate that Ku-band spectrum would be used
for communications with subscribers.
2
SpaceX Modification ¶ 12.
3
See Radio Station Authorization, Call Sign E190066 (issued Mar. 13, 2020). SpaceX Services has filed for
modification to increase this authorization to five million user terminals, which remains pending. See Application
for Modification, IBFS File No. SES-MOD-20200731-00807 (July 31, 2020).

1
terminals from fixed positions throughout the United States, Puerto Rico, and the U.S. Virgin

Islands. 4

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

next-generation 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 Stations in Motion (“ESIMs”)). 5 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 earth stations

operating in these frequency bands. 6 However, the 12.2-12.7 GHz band is not specifically

available for use by ESIMs communicating with NGSO systems, 7 so below SpaceX Services

requests a waiver to authorize use of that band on an unprotected basis.

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

sharing issues relevant to their operation. We then demonstrate that grant of this application,

including the requested waiver, would serve the public interest. Lastly, we provide technical

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

4
See Application for Blanket Licensed Fixed Earth Stations, IBFS File No. SES-LIC-INTR2021-02141 (erratum
filed June 21, 2021).
5
See 47 C.F.R. § 25.103 (defining VMES, ESV, ESAA, and ESIM).
6
See id. § 25.115(f)(2).
7
See id. § 25.202(a)(10)(ii).

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narrative application. 8 To support its ambitious timetable for offering ever more diverse and

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 Services’ ESIMs will communicate with those SpaceX satellites that are visible on

the horizon above a minimum elevation angle of 25 degrees. The proposed phased array user

terminal will track SpaceX’s NGSO satellites passing within its field of view. As the terminal

steers the transmitting beam, it automatically changes the power to maintain a constant level at the

receiving antenna of its target satellite to the extent possible, compensating for variations in

antenna gain and path loss associated with the steering angle. These ESIMs will be electrically

identical with SpaceX Services’ next-generation fixed user terminals from a radiofrequency

perspective, though they will have some additional features appropriate for a mobile operating

environment (e.g., sensors to improve performance in motion and mountings that provide secure

installation on trucks/RVs, boats, and aircraft).

At the phased array’s equivalent of an “antenna flange,” the highest transmit power is 2.44

W 9 while the highest EIRP for all carriers is 38.2 dBW. The antenna gain is highest at boresight

(33.2 dBi and 34.6 dBi for the receive and transmit antennas, respectively) and lowest at maximum

slant (31.3 dBi and 32.0 dBi for the receive and transmit antennas, respectively). 10

8
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.
9
There is no difference in transmit power between ESIMs at the center or edge of the spot or between clear sky or
heavy rain conditions.
10
For purposes of Form 312 accompanying this application, SpaceX Services has supplied the highest transmit
power and EIRP figures to present worst-case conditions.

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 III. SPECTRUM SHARING ISSUES

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 the fixed-satellite service (“FSS”). Nonetheless, SpaceX Services recognizes that its

earth station operations will be subject to certain sharing conditions. 13 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 (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). 14 In addition,

SpaceX Services will not operate these earth stations in the 14.47-14.5 GHz band in the vicinity

of radio astronomy observatories at sixteen locations, without first completing coordination.15

SpaceX Services will use Global Positioning Satellite-related or other similar position location

technology to ensure compliance with this commitment. 16

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

13
See, e.g., 47 C.F.R. §§ 25.115(f)(2), 25.208(o), 101.1409, 2.106 nn.5.487A & US342. 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.
14
See 47 C.F.R. § 25.228(j)(1), (2). See also SpaceX Authorization ¶ 37 (requiring SpaceX to take note of NASA
TDRSS facilities at three locations).
15
See 47 C.F.R. § 25.228(j)(3).
16
See id. § 25.228(j)(5).

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

foreign administration, whichever is more constraining. 17 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 Services 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 allocation in this band, will be limited to a 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, the proposed SpaceX Services ESIMs would not transmit in

those bands and thus could not cause any interference to other operators using those bands.

Moreover, 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. In addition,

its system is capable of immediately ceasing operations in the unlikely event it is notified that

harmful interference has occurred. 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

17
See id. § 25.228(g)(3).

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systems operating in the fixed service. 18 In addition, as mentioned above, SpaceX Services seeks

a waiver for its ESIMs to receive on an unprotected basis in the 12.2-12.7 GHz band.

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

systems in these shared bands, and has certified 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. 19 SpaceX has also demonstrated that it will comply with the applicable PFD limits

in the Ku-band set forth in the Commission’s rules and Article 21 of the ITU Radio Regulations.20

The Commission has found that compliance with these EPFD and PFD limits is sufficient to

protect GSO systems and terrestrial systems, respectively, against unacceptable interference. 21

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. 22 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. 23 Each ESIM will

18
See id. § 25.115(f)(2).
19
See Application for Modification of Authorization for the SpaceX NGSO Satellite System, IBFS File No. SAT-
MOD-20200417-00037, Technical Attachment at 15 (Apr. 17, 2020) (“Modification Application”); 47 C.F.R. §
25.115(f)(1) (incorporating certification requirement in 47 C.F.R. § 25.146(a)(2)).
20
See Modification Application, Technical Attachment at 10-12.
21
See, e.g., Updates to Parts 2 and 25 Concerning Non-Geostationary, Fixed-Satellite Service Systems and Related
Matters, 32 FCC Rcd. 7809, ¶ 32 (2017) (“NGSO Update Order”) (“Any NGSO FSS system operating in
compliance with these [EPFD] limits is considered as having fulfilled its obligation under Article 22 of the ITU
Radio Regulations not to cause unacceptable interference to any GSO network.”); 47 C.F.R. § 25.289 (same);
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).
22
See 47 C.F.R. § 25.228(b).
23
See id. § 25.228(e)(2), (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).

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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. 24

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 via phone at (360) 780-3103 or email at satellite-

[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. GRANTING A WAIVER TO ALLOW THESE ESIMS TO USE THE 12 GHZ BAND WOULD
PROVIDE REQUIRED OPERATIONAL FLEXIBILITY WITHOUT AFFECTING OTHER
AUTHORIZED USERS OF THE BAND

As discussed above, although the Commission’s rules provide for blanket licensing of

NGSO earth stations operating in the 12.2-12.7 GHz band (the “12 GHz band”), this spectrum is

not specifically listed among the bands available for ESIM operations. The Commission did not

affirmatively prohibit ESIM operations in this band—though it did so with respect to other

spectrum. 25 Rather, the omission of this band from the list of available ESIM spectrum is largely

a result of the way the rules were promulgated. The Commission adopted rules for GSO ESIMs

24
See id. § 25.228(c), (e)(1).
25
See id. § 25.115(f)(2) (prohibiting ESIM operations in the 28.35-28.4 GHz band).

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first and then proposed an analogous approach for NGSO ESIMs. With respect to the spectrum

available for ESIM use, the NGSO ESIMs NPRM makes clear that the Commission initiated the

proceeding to enable “ESIMs to communicate with NGSO FSS systems in the Ku- and Ka-bands

where the Commission’s rules allow ESIM communications with GSO FSS space stations.”26

Unfortunately, because GSO systems (other than Direct Broadcast Satellite (“DBS”)) are not

allowed to operate in the 12 GHz band, that band had not been contemplated for use by GSO

ESIMs—and thus, it was omitted from the list considered for NGSO ESIMs. After several

commenters in the proceeding argued for extension of the rules to include the 12 GHz band, the

Commission concluded only that the record was not sufficient at that point to include the band, not

that ESIM operation would cause any technical impediment to other authorized uses in the band. 27

Accordingly, SpaceX Services seeks a waiver to allow its ESIMs to use the 12 GHz band

on a non-protected basis, notwithstanding the fact that this spectrum is not listed as available for

NGSO ESIM operations in Section 25.202(a)(10)(ii). The Commission may waive its rules for

good cause shown. 28 “Waiver is appropriate if special circumstances warrant a deviation from the

general rule and such deviation would better serve the public interest than would strict adherence

to the general rule,” including “more effective implementation of overall policy.” 29 In considering

requests for non-conforming spectrum uses, the Commission has indicated that it would generally

grant such waivers “when there is little potential for interference into any service authorized under

26
Facilitating the Communications of Earth Stations in Motion with Non-Geostationary Orbit Space Stations, 33
FCC Rcd. 11416, ¶ 8 (2018) (“NGSO ESIMs NPRM”).
27
Amendment to Parts 2 and 25 of the Commission’s Rules to Facilitate the Use of Earth Stations in Motion
Communicating with Geostationary Orbit Space Stations in Frequency Bands Allocated to the Fixed Satellite
Service, 35 FCC Rcd. 5137, ¶¶ 45-46 (2020).
28
47 C.F.R. § 1.3. See also WAIT Radio v. FCC, 418 F.2d 1153 (D.C. Cir. 1969); NE. Cellular Tel. Co. v. FCC,
897 F.2d 1164 (D.C. Cir. 1990).
29
GE American Communications, Inc., 16 FCC Rcd. 11038, ¶ 9 (IB 2001) (quoting WAIT Radio, 418 F.2d at 1159).

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the Table of Frequency Allocations and when the non-conforming operator accepts any

interference from authorized services.” 30 As shown below, there is good cause for the Commission

to grant a waiver to allow SpaceX Systems ESIMs to receive signals in the 12 GHz bands.

The proposed ESIMs will only receive in the 12 GHz band, and because SpaceX will

operate its satellites in compliance with the EPFD and PFD limits that the Commission has found

sufficient to protect GSO and terrestrial systems, they present no risk of interference to other

authorized spectrum users. On the other hand, granting SpaceX Services access to this band is

necessary to provide robust broadband service to American consumers. The 12 GHz band

represents 500 MHz of the potential spectrum authorized for downlinks from SpaceX satellites to

customer user terminals. SpaceX must share all the downlink spectrum for which it is authorized

with other NGSO operators, must operate on a secondary basis with respect to fixed systems in

half this spectrum (10.7-11.7 GHz), and must avoid 250 MHz at the bottom of the band (10.7-

10.95 GHz) in order to protect radio astronomy operations in the adjacent band. Accordingly, the

12 GHz band constitutes a large portion of the spectrum available for communications with user

terminals and gives SpaceX needed flexibility to accommodate sharing with other spectrum users

in these bands while still providing robust broadband service to underserved and unserved

American consumers.

SpaceX recognizes that its non-conforming use of the 12 GHz band would be authorized

on a non-protected basis. That means that its ESIMs would have to accept interference from both

DBS (which it was already required to do) and MVDDS (without the protection of coordination

30
Fugro-Chance, Inc., 10 FCC Rcd. 2860, ¶ 2 (IB 1995) (authorizing non-conforming MSS in the C-band); See
also Motorola Satellite Communications, Inc., 11 FCC Rcd. 13952, ¶ 11 (IB 1996) (authorizing service to fixed
terminals in bands allocated to the mobile-satellite service).

10
rules applicable to fixed earth stations). 31 However, the Commission has recognized that allowing

satellite operators to make opportunistic use of spectrum on an unprotected basis provides

operational flexibility and more intensive use of spectrum without compromising service to

customers. For example, although earth stations would have to operate on an unprotected basis in

the 10.7-11.2 GHz band used by SpaceX, the Commission found such use would serve the public

interest because “[i]n the event of harmful interference, operators could switch to alternative

spectrum not shared with the fixed service, such as the adjacent 11.7-12.2 GHz band. In addition,

any operations that require certainty of protection may be individually coordinated and licensed.”32

Accordingly, granting a waiver would serve the public interest by enhancing SpaceX

Service’s ability to make productive use of valuable spectrum resources to provide high-speed,

low-latency service to customers on moving platforms, including those in otherwise underserved

or unserved areas of the United States. Moreover, it would do so without any offsetting

interference or customer service concerns.

V. 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

Over the last two years, SpaceX has deployed over 1,700 satellites, sufficient to support

introduction of its high-capacity, low-latency broadband services in portions of the United States.

This system is now on the brink of delivering this service across the entire United States—

including to the most remote corners and Polar Regions of the country that too often get left behind.

31
SpaceX recognizes that the Commission has initiated a rulemaking to explore whether to “continu[e] with the
current framework” for NGSO/MVDDS sharing or “increase[e] terrestrial use of the shared band.” Expanding
Flexible Use of the 12.2-12.7 GHz Band, 36 FCC Rcd. 606, ¶ 19 (2021). However, the Commission has expressly
restricted that proceeding—at the very outset—to only those changes it could make “without causing harmful
interference to incumbent licensees,” such as SpaceX. Id. ¶ 2. In any event, the unprotected operation of SpaceX
Services ESIMs in this band would not preclude Commission action consistent with this premise in this
rulemaking.
32
NGSO Update Order ¶ 25.

11
The demand for more broadband is surging and the need for connections has never been more

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

ground-based component 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. 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 continues to grow,

with one report estimating more traffic in 2022 alone than in the 32 years combined since the

Internet started, and more than six out of ten people in the world being online. 33 Another report

estimates that annual global Internet protocol traffic will grow from 1.5 zettabytes in 2017 to 4.8

zettabytes in 2022. 34 Similarly, the average Internet user will generate 84.6 gigabytes of Internet

traffic per month by 2022, compared to 28.8 gigabytes in 2017. 35

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

ways. Users now require connectivity while on the move, whether driving an RV across the

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

flight. In many cases, these users lack any true high-throughput, low-latency options. To close

this gap, SpaceX has deployed an innovative, cost-effective, and spectrum-efficient satellite

system capable of delivering robust broadband service to customers around the world. 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

33
See Cisco Predicts More IP Traffic in the Next Five Years Than in the History of the Internet, CISCO (Nov. 27,
2018), https://newsroom.cisco.com/press-release-content?type=webcontent&articleId=1955935.
34
See VNI Complete Forecast Highlights, CISCO, 1 (2018), https://www.cisco.com/c/dam/m/en us/solutions/
service-provider/vni-forecast-highlights/pdf/Global 2022 Forecast Highlights.pdf.
35
Id. at 5.

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that network from homes and offices to moving vehicles, vessels, and aircraft. Operation under

the requested blanket license will provide the first option for some and promote competition for

others 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________

David Goldman
William M. Wiltshire Director of Satellite Policy
Paul Caritj
HARRIS, WILTSHIRE & GRANNIS LLP SPACE EXPLORATION TECHNOLOGIES CORP.
1919 M Street, N.W. 1155 F Street, NW
Suite 800 Suite 475
Washington, DC 20036 Washington, DC 20004
202-730-1300 tel 202-649-2700 tel
202-730-1301 fax 202-649-2701 fax

Counsel to SpaceX

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EXHIBIT A – EIRP MASK