SpaceX IB Front Offi

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by Harris, Wiltshire & Grannis LLP.

SpaceX IB Front Office Ex Parte

2019-03-21

This document pretains to SAT-MOD-20181108-00083 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2018110800083_1638586

March 21, 2019 BY ELECTRONIC FILING Marlene H. Dortch Secretary Federal Communications Commission 445 Twelfth Street, S.W. Washington, DC 20554 Re: Space Exploration Holdings, LLC, IBFS File No. SAT-MOD-20181108-00083 Dear Ms. Dortch: This is to inform you that, on March 19, 2019, Patricia Cooper, David Goldman, and undersigned counsel representating Space Exploration Holdings, LLC (“SpaceX”) met with Tom Sullivan, Troy Tanner, and Jennifer Gilsenan of the Commission’s International Bureau to discuss the above referenced application to modify SpaceX’s existing authorization to deploy and operate a non-geostationary orbit (“NGSO”) satellite system. During the meeting, SpaceX discussed its response to the Bureau’s request for further technical information with respect to that application, 1 noting the initial version of its satellite design will meet or exceed all Commission requirements for orbital debris mitigation and collision avoidance. Moreover, SpaceX has unlocked a totally demisable spacecraft design for its subsequent iteration of satellites, which will then reduce casualty risk to zero. Even including the initial iteration, SpaceX has improved the safety of its constellation by more than 90% since its initital application, which was already compliant with all Commission debris mitigation and collision avoidance rules. SpaceX also discussed the safety value in permitting communications with its spacecraft after deployment through orbit raise, authority that the Commission envisioned for all geostationary orbit (“GSO”) satellites but has not yet implemented for NGSO satellites.2 Specifically, allowing NGSO operators to transmit on their authorized frequencies (including those used for telemetry, tracking, and command (“TT&C”)) during orbit-raising maneuvers would ensure that only fully healthy satellites are raised from injection to their operational orbit by permitting persistent tracking and allowing testing of the TT&C and communications payloads during this period. 1 See Letter from William M. Wiltshire to Jose P. Albuquerque, IBFS File No. SAT-MOD-20181108-00083 (Mar. 13, 2019). 2 See 47 C.F.R. § 25.282 (authorizing GSO satellites to use authorized TT&C frequencies during orbit raising maneuvers). The Commission has recognized this issue and recently proposed to expand the provisions of Section 25.282 to include NGSO systems. See Mitigation of Orbital Debris in the New Space Age, FCC 18-159, ¶ 70 (rel. Nov. 19, 2018). HARRIS, WILTSHIRE & GRANNIS LLP | 1919 M STREET | EIGHTH FLOOR | WASHINGTON DC 20036 | T 202 730 1300 | F 202 730 1301

HARRIS, WILTSHIRE & GRANNIS LLP Marlene H. Dortch March 21, 2019 Page 2 of 2 Sincerely, William M. Wiltshire Counsel to SpaceX cc: Tom Sullivan Troy Tanner Jennifer Gilsenan


Document Created: 2019-03-21 15:13:18
Document Modified: 2019-03-21 15:13:18
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC