In an October 15, 2019 letter to the US Federal Communications Commission (FCC) , Kepler Communications is petitioning the FCC to reconsider its order and authorization request from SpaceX to lower the altitude of 1,584 of its satellites to 550 km.
Kepler says in its letter that the FCC “did not adequately address the concerns of commenters regarding the new orbital debris risk posed by the First SpaceX Modification.”
The 21 page letter, available below, also addresses other concerns they have. Both OneWeb and SES have also chimed in with similar concerns.
One issue in particular has everyone in an uproar. SpaceX has recently submitted 20 International Telecommunication Union (ITU) fillings that, if enacted on, would see them seem deploy an additional 30,000 new satellites in Low Earth Orbit (LEO) below 600 km. And, yes you read that correctly.
Kepler says of this latest development, “the collision risks of such a constellation would be obviously untenable and such filings in no way support SpaceX’s claim of striving for good faith coordination. As OneWeb highlighted in its Petition, the fail-fast fail-often philosophy employed by SpaceX will, at the going rate, destroy the viability of Low Earth Orbit. Kepler urges the Commission to consider these facts in this assessment of yet another SpaceX modification.”
SpaceX for it’s part provided an email statement that says “as demand escalates for fast, reliable internet around the world, especially for those where connectivity is non-existent, too expensive or unreliable, SpaceX is taking steps to responsibly scale Starlink’s total network capacity and data density to meet the growth in users’ anticipated needs.”
One of the problems all Non-Geostationary Satellite Orbit (NGSO) regulators are facing is speed of which new constellation operators are moving at. Along with that increase in tempo, some operators, including SpaceX, are changing their plans as they iterate satellite designs.
In its letter to the FCC, SES states that “SpaceX has continued to alter its system design, rendering ITU evaluations of prior configurations moot and requiring the ITU review to begin anew each time. Because SpaceX keeps moving the goalposts, SES and other GSO operators have no assurance that there will be a definitive ITU finding any time in the near future on the SpaceX system as it is actually being operated.”
Kepler isn’t holding back on its distaste with how SpaceX is proceeding in attempting to build out and secure its LEO communications network. Their conclusion in-part states, “SpaceX has continued to inundate the regulatory pipeline with its frequent and underdeveloped requests for major modifications. SpaceX’s citation of the Commission’s practice of treating propulsion-equipped systems as having a large-object collision risk of zero has allowed it to evade the essential work of proving the safety of its system.”
The use of NGSO for constellations of satellites is in its early days. There’s going to be a lot of agitation and jostling for position. Regulators clearly have their hands full.
Kepler Communications October 15, 2019 letter.Kepler_Consolidated
SES Americom and O3b Limited October 15, 2019 letter.SES_and_O3b_Petition
WorldVu Satellites Limited (OneWeb) October 17, 2019 letter.SpaceX_STA_Requests