More than two and a half years after SpaceX began the process of obtaining regulatory approval for its next-generation Starlink constellation, the US Federal Communications Commission (FCC) has finally granted the company a license – but only after drastically reducing its range.
In May 2020, SpaceX filed its first FCC license application for Starlink Gen2, an upgraded constellation of 30,000 satellites. In the second half of 2021, SpaceX modified its Starlink Gen2 app to take full advantage of the company’s more powerful Starship rocket and further enhance the constellation’s potential usefulness. It wasn’t until December 2021 that the FCC finally I accept SpaceX’s Gen2 application for filing, kicking off the final review process.
On Nov. 29, 2022, the FCC completed that review and granted SpaceX permission to launch just 7,500 of the ~30,000 Starlink Gen2 satellites it had requested over 30 months prior. The FCC has offered no explanation for how it arrived at its arbitrary 75% reduction, or why the resulting number is slightly lower than another Starlink Gen1 constellation of 7,518 satellites that SpaceX had already been licensed to deploy in late 2018. Adding insult to injury, the FCC repeatedly acknowledges that “the total number of satellites that SpaceX is allowed to deploy is not increased by our action today, and in fact is slightly reduced.
This purported reduction is due to the fact that shortly before this decision, SpaceX declared to the FCC in good faith that it would voluntarily avoid launching the dedicated V-band Starlink constellation for which it had already been licensed in order to “reduce dramatically the total number of satellites eventually in orbit. Instead, once Starlink Gen2 is approved, it would seek permission to add V-band payloads to a subset of the planned 29,988 Gen2 satellites, achieving a result similar without the need for 7,518 other satellites.
In response, the FCC reduced the total number of Starlink Gen2 satellites allowed to less greater than the number of satellites approved by the FCC’s Starlink V-band authorization of November 2018; limited these satellites to intermediate orbits, excluding Gen2 launches into higher or lower orbits entirely; and didn’t even structure its compromise in a way that would at least allow SpaceX to fully complete three Starlink Gen2 “shells”. Worse, the partial FCC grant barely mentioned SpaceX’s detailed plans to use new E-band antennas on Starlink Gen2 satellites and next-generation ground stations, simply stating that it “will defer action.” on the request until “further review and coordination with federal users.” .”
Throughout the partial grant, the FCC articulates its decision to significantly reduce SpaceX’s Starlink Gen2 constellation in terms of needing more time “to assess complex and novel issues before [the Commission]raising the question of what exactly the Commission was doing instead in the 30 months since SpaceX’s first Gen2 application and the 15 months since its Gen2 modification. By comparison, SpaceX received a full license for its constellation of 7,518 V-band satellites less than five months after applying. SpaceX’s 4,408-satellite Starlink Gen1 constellation — the first megaconstellation ever reviewed by the modern FCC — was cleared 16 months after its first application and eight months after an amended application was submitted.
Adding to the strangeness of the unusual and inconsistent decision-making in this FCC ruling, the Commission openly acknowledges that the idea to grant SpaceX permission to launch a fraction of its Starlink Gen2 constellation came from Project Kuiper from Amazon. [PDF], a major potential competitor to Starlink. The FCC says it agrees with Amazon’s argument, stating that “the public interest would be served by taking this approach to allow tracking of developments involving this large-scale deployment and to enable additional account of issues unique to other SpaceX in-orbit requests”.
The V-band Starlink constellation already approved by the FCC consisted of 7,518 satellites in very low Earth orbit (~340 km). In the first Starlink constellation of 4,425 satellites authorized by the FCC, the Commission authorized SpaceX to operate 2,814 satellites in orbits between 1,100 and 1,300 kilometers. Increasingly aware of the consequences of space debris, which would last hundreds of years at more than 1,000 kilometers, SpaceX then applied for permission in 2019 and 2020 to launch these 2,814 satellites about 550 kilometers, where the failed satellites would return. in just five years. For unknown reasons, the FCC didn’t fully approve the change until two years later, in April 2021.
The “other orbits [requested by SpaceX]which the FCC says create unique issues that require “additional consideration” of Starlink Gen2 for 19,400 satellites between 340 and 360 kilometers and 468 satellites between 604 and 614 kilometers. Starlink satellites are expected to be about four times heavier and have a much larger surface area, but the fact remains that the FCC has already granted SpaceX permission to launch nearly 3,000 small satellites into orbits well above 604 kilometers and more than 7,500 satellites into orbits below 360 kilometers. It is therefore difficult not to conclude that the Commission’s assertions that a partial denial of a license was justified by “concerns about orbital debris and space safety” and “problems peculiar to … other orbits” are at better inconsistent.
Perhaps the oddest inclusion in the partial grant is the FCC’s decision to subject SpaceX to an arbitrary metric devised by another for-profit third-party company LeoLabs. In a March 2022 letter, LeoLabs reportedly proposed that “SpaceX’s permission to continue to deploy satellites” be tied directly to an arbitrary metric measuring “the number of years each failed satellite remains in orbit, added together for all failed satellites”. The FCC apparently loved the suggestion and made it an explicit condition of its already harsh Starlink Gen2 authorization, even adopting the arbitrary “100 object year” limit proposed by LeoLabs.
In other words, once the sum of the time it takes for all failed Starlink Gen2 satellites to naturally deorbit reaches 100 years, the FCC will force SpaceX to “cease deployment of satellites” while it “[reviews] sources of satellite failure” and “determine[s] whether there are adequate and reliable mitigation measures in the future. The FCC acknowledges that the arbitrary 100-year limit means that the failure of just 20 Starlink satellites in operational orbits would force the company to abort launches. The Commission does not explain how it will decide when SpaceX can restart Starlink launches after a launch shutdown. SpaceX must simultaneously follow the FCC’s deployment schedule, which could see the company’s license revoked if it doesn’t deploy 3,750 Starlink Gen2 satellites by November 2028 and all 7,500 satellites by November 2031.
Based on unofficial observations by astrophysicist Jonathan McDowell, SpaceX currently has more than 30 failed Starlink Gen1 satellites at or near their operational altitudes of over 500 kilometers, which means SpaceX would almost certainly be forced to shut down launch Gen1 satellites if this new arbitrary rule were applied to other constellations. The same goes for competitor OneWeb, which had a single satellite fail at around 1,200 kilometers in 2021. At that altitude, it will likely take hundreds of “object years” to deorbit naturally, easily exceeding the limit. 100-year-old draconian technology from LeoLabs.
In theory, the FCC makes it clear that it consider change those restrictions and allow SpaceX to launch more of its proposed Starlink Gen2 constellation in the future. But the Commission has also repeatedly demonstrated to SpaceX that it will fortunately take years to modify existing licenses or approve new ones – not a particularly reassuring basis for investments as large and precarious as megaconstellations.
Ultimately, barring shady behind-the-scenes handshake deals, the FCC’s partial grant leaves SpaceX’s Starlink Gen2 constellation in an undesirable position. For the company to continue operating under the current license, it may be forced to redesign its satellites and ground stations to avoid E-band, or bet on continuing to build and deploy satellites and ground stations with E-band antennas with no guarantee that it will ever be able to use this hardware. There is also no guarantee that the FCC will allow SpaceX to launch any of the ~22,500 satellites left on the table by the partial grant, which will radically change the financial calculus that determines whether the constellation is economically viable and at how extensive the associated infrastructure needs to be. be.
Also, if SpaceX takes the bet and launches all 7,500 approved Gen2 satellites only for the FCC to not approve expansions, Starlink Gen2 would be stuck with zero polar coverage, greatly reducing the constellation’s overall usefulness. Starlink Gen2 probably represents an investment of at least $30-60 billion (assuming an unprecedented $1-2 million to build and launch each 50-150 Gbps satellite). With its partial license denial and the addition of several new and arbitrary conditions, the FCC effectively forces SpaceX to take an even riskier gamble with the billions of dollars of any new infrastructure it will need to build, launch, operate and use. its Starlink Gen2 constellation.
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