OneWeb Comments on V

COMMENT submitted by WorldVu Satellites Limited

OneWeb Comments on V-band Application

2017-09-25

This document pretains to SAT-LOA-20170301-00027 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2017030100027_1281598

                                    Before the
                     FEDERAL COMMUNICATIONS COMMISSION
                               Washington, DC 20554


In the Matter of                            )
                                            )
Space Exploration Holdings, LLC             )         Call Sign: S2992
                                            )
Application for Approval for Orbital        )         File No. SAT-LOA-20170301-00027
Deployment and Operating Authority          )
for the Space Exploration Holdings          )
NGSO Satellite System                       )


                   COMMENTS OF WORLDVU SATELLITES LIMITED

       WorldVu Satellites Limited, d/b/a OneWeb (“OneWeb”), pursuant to Section 25.154(a)

of the rules of the Federal Communications Commission (the “FCC” or “Commission”) and the

Commission’s recent public notice,1 hereby comments on the application of Space Exploration

Holdings, LLC (“Space Exploration Holdings”) for operating authority for a non-geostationary

orbit (“NGSO”), low-Earth orbit (“LEO”) and very-low-Earth orbit (“VLEO”) satellite system in

the Fixed Satellite Service (“FSS”) using V-band frequencies.2




1
 See 47 C.F.R. § 25.154(a); Satellite Policy Branch Information: Space Station Applications
Accepted for Filing, Report No. SAT-01262 (rel. Aug. 25, 2017). See also Satellite Branch
Information: Boeing Application Accepted for Filing; Cut-Off Established for Additional NGSO-
Like Satellite Applications or Petitions for Operations in the 37.5-40.0 GHz, 40.0-42.0 GHz,
47.2-50.2 GHz and 50.4-51.4 GHz Bands, Public Notice, 31 FCC Rcd 11957 (Int’l Bur. 2016).
2
 Space Exploration Holdings, LLC, Application For Approval for Orbital Deployment and
Operating Authority for the SpaceX NGSO Satellite System, IBFS File No. SAT-LOA-
20170301-00027 (Call Sign S2992) (filed March 1, 2017) (“Space Exploration Holdings
Application”).


                                                -1-


I.       SPACE EXPLORATION HOLDINGS’ REQUEST FOR A WAIVER OF THE
         COMMISSION’S MILESTONE REQUIREMENT IS NOT IN THE PUBLIC
         INTEREST AND SHOULD BE DENIED

         Space Exploration Holdings seeks a waiver from the Commission to reduce its milestone

obligation.3 This request to meet only 14% of its proposed constellation within six years is the

second application in which Space Exploration Holdings has sought a waiver of the

Commission’s milestone regime.4 Failure to rigorously enforce the Commission’s milestone

regime increases the risk of spectrum and “space real estate” warehousing. Speculative spectrum

and orbital filings create tremendous uncertainty for other applicants who must design their

constellations to accommodate these unknown and uncertain orbital deployments and spectrum

allocations.5 Accordingly, Space Exploration Holdings’ request is not in the public interest and

should be denied.

         Space Exploration Holdings’ proposal is inconsistent with the current milestone rule6 and

even with the Commission’s proposal to relax the milestone rule applicable to NGSO FSS

constellations.7 The proposed new rule would require deployment of only 50% of the



3
    Space Exploration Holdings Application, Waiver Requests, at 15-16 (“Waiver Requests”).
4
 Space Exploration Holdings has asked to launch 11,943 LEO and VLEO satellites total, and
only launch 1,600 satellites in the first six years.
5
  See In re Space Exploration Holdings, LLC, Application for Approval for Orbital Deployment
and Operating Authority for the Space Exploration Holdings NGSO Satellite System, Comments
of WorldVu Satellites Limited, at 2-7 (filed June 26, 2017) (“OneWeb Comments”). As OneWeb
noted in its Comments on Space Exploration Holdings’ Ku- and Ka-band Application, the
truncated milestone requirement Space Exploration Holdings seeks would allow it to warehouse
spectrum indefinitely and would create uncertain operating conditions for other applicants.
6
    47 C.F.R. § 25.164(b).
7
 In re Update to Parts 2 and 25 Concerning Non-Geostationary, Fixed-Satellite Service Systems
and Related Matters, Report & Order and Further Notice of Proposed Rulemaking, IB Docket


                                                -2-


constellation within six years of the application grant and full deployment within nine years.8

The Commission proposed to adopt this milestone regime in order to provide operators with

flexibility while “discourag[ing] applicants from seeking authorizations for oversized, unrealistic

constellations.”9 The Commission explicitly noted that “allow[ing] applicants to set their own

milestone objectives” – as Space Exploration Holdings proposes to do – “would not achieve [the

Commission’s] dual milestone goals.”10

           OneWeb agrees the Commission should reject these kind of proposed milestones to

ensure that applicants are serious about deploying their proposed constellations in their entirety

and are incentivized to release spectrum and orbital resources as early as possible if they

determine they cannot use them. Under its proposal, Space Exploration Holdings would not be

adequately incentivized to deploy more than a small portion of its constellation in a timely

manner. Space Exploration Holdings should be required to comply with any milestone

requirement that is implemented as a result of the ongoing NGSO rulemaking proceeding.11

While the Commission has already proposed to offer significant regulatory relief to Space

Exploration Holdings and other applicants with respect to milestone requirements, Space

Exploration Holdings’ further proposed milestone plan and waiver request would “create




No. 16-408, FCC-CIRC1709-04, ¶¶ 62-67 (rel. Sept. 7, 2017) (“Draft R&O and Further
NPRM”).
8
    Id. at ¶¶ 66-67.
9
    Id. at ¶ 66.
10
     Id.
11
  The Draft R&O makes clear that any rules adopted pursuant to the NGSO rulemaking will be
applied to pending applications. See Draft R&O and Further NPRM at ¶ 71.



                                                -3-


unnecessary coordination burdens and uncertainty for other operators.”12 The waiver request is

not in the public interest and should be denied.

II.       SPACE EXPLORATION HOLDINGS’ ORBITAL DEBRIS SHOWING IS
          MISSING CRITICAL INFORMATION

          Space Exploration Holdings’ application fails to adequately demonstrate that its LEO and

VLEO constellations will be operated safely in close proximity to other NGSO constellations.

Space Exploration Holdings has proposed to deploy nearly 12,000 satellites, including 4,425 that

will be in close proximity in-orbit to other NGSO constellations, such as Boeing’s proposed V-

band constellation, Telesat’s Ka-band constellation, and OneWeb’s Ku- and Ka-band

constellations.13 As discussed in OneWeb’s Comments on Space Exploration Holdings’ Ku- and

Ka-band Application, the proposed LEO constellation poses a substantial risk of collision with

other NGSO satellites having similar orbital altitudes, especially given Space Exploration

Holdings’ refusal to agree to a reasonable buffer zone between operators.14 Space Exploration

Holdings states that it “has determined that no other system is currently licensed by the


12
     Id. at n.139.
13
   See Space Exploration Holdings Application at 7 (Space Exploration Holdings plans to launch
4,425 satellites that will operate at altitudes between 1,110 km to 1,325 km – overlapping with
OneWeb’s earlier-chosen orbital altitude centered on 1,200 km). See also Telesat Canada,
Petition for Declaratory Ruling to Grant Access to the U.S. Market for Telesat’s NGSO
Constellation, IBFS File No. SAT-PDR-20161115-00108, Appendix A (Technical Annex) at 1
(filed Nov. 15, 2016) (proposing to operate at altitudes between 1,000 km and 1,248 km); The
Boeing Company, Application for Authority to Launch and Operate a Non-Geostationary Low
Earth Orbit Satellite System in the Fixed Satellite Service, IBFS File No. SAT-AMD-20170301-
00030, at 6-7 (filed Mar. 1, 2017) (proposing to operate at altitudes between 970 km and 1,082
km).
14
  See OneWeb Comments at 8-12; In re Application of Space Exploration Holdings, LLC for
Approval for Orbital Deployment and Operating Authority for the SpaceX NGSO Satellite
System, Consolidated Opposition to Petitions and Response to Comments of Space Exploration
Holdings, LLC, at 9-10 (filed July 7, 2017).



                                                   -4-


Commission for, is currently operating in, or has submitted a request for coordination to the ITU

with respect to” its exact nominal orbital planes.15 While OneWeb appreciates that Space

Exploration Holdings (like every other NGSO operator) relies on the global public filing

mechanism of the ITU to understand the locations of prior-filed constellations, its choice of

surrounding orbits presents unnecessary risks to orbital safety. The selected orbit locations of

Space Exploration Holdings ignore the large number of satellites from multiple operators that are

in such close proximity that they will overlap due to orbital perturbations and/or failed satellites.

Furthermore, any fragments from the potential intra-constellation collisions of such a closely knit

constellation will affect the other constellations near which Space Exploration Holdings has

chosen to orbit. The Commission should require that Space Exploration Holdings adequately

demonstrate its ability to avoid becoming a source of orbital debris or collisions to other NGSO

systems, and that it maintain an adequate safety buffer zone of at least 125 km – and, preferably,

200 km – from other large constellations.

         Space Exploration Holdings claims to have chosen orbital locations for its satellites in a

manner meant to “maximize the spacing between satellites and thereby preclude the risk of

conjunction.”16 However, the application does not quantify the intra-constellation conjunction

distances, in nominal and potential failure modes, for either the LEO or VLEO constellations, or

discuss how accurately Space Exploration Holdings will be able to maintain its satellites’ orbits,

especially in the high-drag VLEO environment. Space Exploration Holdings asserts that its

VLEO satellites operate in a “self-cleaning” environment where atmospheric drag quickly


15
  Space Exploration Holdings Application, Attachment A: Technical Information to Supplement
Schedule S, at 36 (“Technical Attachment”).
16
     See Technical Attachment at 36.



                                                 -5-


destroys any debris.17 However, this ignores that its VLEO constellation will consist of over

7,500 satellites and that VLEO satellite trajectories may be difficult to predict accurately, with

the VLEO constellation likely requiring frequent station-keeping maneuvers. Given the sheer

number of objects Space Exploration Holdings proposes to deploy, the risk of intra-constellation

collision could be substantial, and the over 7,500 satellites at very low earth orbit could create a

debris field which could be virtually impenetrable for passing space missions until the debris de-

orbits.

          The risk of collision between deorbiting LEO satellites and satellites in the VLEO

constellation also appears to be larger than necessary. Space Exploration Holdings intends to

target an eccentric disposal orbit for its LEO satellites with a perigee just below its operational

VLEO altitude, leaving its LEO satellites in orbits that cross with the VLEO constellation while

they decay toward re-entry.18 During this phase, Space Exploration Holdings intends to

passivate the LEO satellites and leave them in an orientation that maximizes their cross-sectional

areas.19 While this orientation reduces orbital lifetime, it also increases the collisional cross-

sectional area at a time when the satellites can no longer actively execute collision avoidance

maneuvers. This is particularly disturbing since, in this high-drag environment, positional

accuracy predictions of both the passivated LEO satellites and the frequently maneuvering

VLEO satellites will be compromised. In light of these circumstances, the Commission should

request Space Exploration Holdings to consider budgeting the minimum fuel to accelerate this


17
     See id.
18
  Compare Technical Attachment at 39 (LEO satellites to achieve a perigee of 300 km) with
Space Exploration Holdings Application at 8 (VLEO satellites to occupy orbital planes between
335.9 km and 345.6 km).
19
     Technical Attachment at 39.


                                                  -6-


phase of its LEO satellites’ re-entry to ensure that collisions between VLEO and LEO satellites

will be avoided.

        Of further concern is that the International Space Station (“ISS”) has very limited

maneuvering capability and its altitude occasionally drops into and through the proposed VLEO

orbit, as demonstrated below:20




Risks to the ISS resulting from collisions or fragmentation in the VLEO constellation may be

short-lived, but will also be sudden and unpredictable. This is not to say a constellation of the

size of Space Exploration Holdings’ VLEO constellation should not be authorized purely on the

grounds of its potential for space debris or intra-constellation collisions. However, there should

be a heightened reliability showing required both for the spacecraft and for its potential for

conjunction with other spacecraft (including intra-constellation conjunctions) and with humans

in or near its orbit and de-orbit paths.

        Space Exploration Holdings provides limited details on the reliability of its 7,500 VLEO

satellites, stating only that its propellant “tanks are designed to suffer impact penetration without




20
  James Oberg, “Space station sinks to new low – but it’s OK,” NBCNEWS.COM, March 15,
2007, available at http://www.nbcnews.com/id/17630218/ns/technology_and_science-
space/t/space-station-sinks-new-low-its-ok/#.WclYgYWcF-g.



                                                 -7-


explosive consequences,” and a “burst disk ensures that sudden failure of propulsion

containment cannot overpressure and fragment the spacecraft.”21 While these statements seem to

support a claim that Space Exploration Holdings’ propellant tanks will not explode under any

hypervelocity impact conditions, they lack the required amount of detail. The Commission

should request clarification on this point and should require Space Exploration Holdings to

submit additional information on its satellite conjunction calculations to ensure a safe operating

environment.

          Finally, there is also a substantial risk of human casualty associated with re-entry of

Space Exploration Holdings’ satellites. Space Exploration Holdings identified a subset of

components that pose a risk of human casualty, including five silicon carbide optical components

of 1.5 kg each that will survive atmospheric re-entry with an impact energy of 961 Joules (far

above the casualty threshold of 15 Joules).22 This equates to as much as 11,943 pieces of debris

that may fall to Earth with enough kinetic energy to cause a human casualty.23 While the

resulting casualty risk per satellite falls below NASA’s per-satellite threshold of 1:10,000,24

Space Exploration Holdings’ numbers suggest that the aggregate risk system poses a 1 in 3

chance of a casualty risk as the silicon carbide optical components fall to earth. The

Commission should require Space Exploration Holdings to address the aggregate casualty risk




21
     See Technical Attachment at 37.
22
     Id. at 58.
23
  7,518 VLEO + 4,425 LEO satellites = 11,943 satellites * 5 pieces of re-entry debris per
satellite, divided by a 5 year life.
24
     See Technical Attachment at 59.


                                                   -8-


posed by its very large LEO and VLEO constellations and adopt adequate measures to mitigate

that risk.

III.      SPACE EXPLORATION HOLDINGS’ REQUEST FOR A WAIVER OF THE
          DOMESTIC COVERAGE REQUIREMENT IS NOT IN THE PUBLIC
          INTEREST AND SHOULD BE DENIED

          Space Exploration Holdings’ request for a waiver of the domestic coverage requirements

contained in Section 25.143(b)(2)(ii) of the Commission’s rules, 47 C.F.R. § 25.143(b)(2)(ii), for

its initial deployment is not in the public interest. As OneWeb noted in its Comments on Space

Exploration Holdings’ Ku- and Ka-band Application, the domestic coverage requirement is a

critical mechanism for ensuring NGSO FSS systems effectively utilize limited spectrum

resources by providing service to all Americans, especially those in remote or underserved

areas.25 Failing to provide coverage to rural and remote areas at the expense of densely

populated, wealthier areas significantly undercuts the Commission’s efforts to close the digital

divide.26 OneWeb acknowledges the domestic coverage requirement is the subject of a Further

Notice of Proposed Rulemaking in the ongoing NGSO rulemaking proceeding,27 and requests

that any action on the Space Exploration Holdings application be conditioned on compliance

with any requirements imposed as a result of that proceeding.




25
     See OneWeb Comments at 16-24.
26
     See id.
27
     See Draft R&O and Further NPRM at ¶¶ 73-76.


                                                -9-


IV.    CONCLUSION

       For the foregoing reasons, the Commission should deny Space Exploration Holdings’

requests for waivers of the domestic coverage requirement and the current milestone rule. The

Commission should also require Space Exploration Holdings to supplement its plans to manage

satellite altitudes and trajectories, prevent in-orbit collisions, and minimize orbital debris prior to

any disposition of its application by the Commission.

                                                Respectfully submitted,

                                                WORLDVU SATELLITES LIMITED
                                                 /s/ Mariah Shuman
                                                __________________________
                                                Mariah Shuman
                                                Senior Director, Regulatory Affairs
                                                WorldVu Satellites Limited
                                                1400 Key Boulevard, Suite A1
                                                Arlington, VA 22209

                                                Brian D. Weimer
                                                Douglas A. Svor
                                                Ashley Yeager
                                                Sheppard Mullin Richter & Hampton LLP
                                                2099 Pennsylvania Ave. NW, Suite 100
                                                Washington, D.C. 20006
                                                (202) 747-1930
                                                Counsel to WorldVu Satellites Limited
September 25, 2017




                                                 -10-


  CERTIFICATION OF PERSON RESPONSIBLE FOR PREPARING ENGINEERING
                           INFORMATION



I hereby certify that I am the technically qualified person responsible for preparation of the

engineering information contained in these Comments, that I am familiar with Part 25 of the

Commission’s rules, that I have either prepared or reviewed the engineering information

submitted in these Comments, and that it is complete and accurate to the best of my knowledge

and belief.



Dated: September 25, 2017



                                          /s/____Marc Dupuis_________________

                                         Marc Dupuis
                                         Senior Director, Spectrum Affairs
                                         WorldVu Satellites Limited
                                         1400 Key Boulevard, Suite A1
                                         Arlington, VA 22209


                                CERTIFICATE OF SERVICE

I, Ashley Yeager, hereby certify that on this 25th day of September 2017, a copy of the foregoing
Comments is being sent via first class, U.S. Mail, postage paid, to the following:

Tim Hughes
Senior Vice President and General Counsel
Patricia Cooper
Vice President of Satellite Government Affairs
SPACE EXPLORATION TECHNOLOGIES CORP.
1030 15th Street, N.W.
Suite 220E
Washington, DC 20005


William M. Wiltshire
Paul Caritj
HARRIS,WILTSHIRE & GRANNIS LLP
1919 M Street, N.W.
Suite 800
Washington, DC 20036
Counsel to Space Exploration Holdings, LLC



                                                 /s/ Ashley Yeager_______________________
                                                 Ashley Yeager



Document Created: 2017-09-25 23:37:26
Document Modified: 2017-09-25 23:37:26

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